INFORMATION ON THE PROCESSING OF PERSONAL DATA (EU REGULATION 2016/679 – GDPR) – CONTEXTUAL REQUEST FOR CONSENT
Dear Sir, Dear Madam
Pursuant to Art. 13 of EU Regulation 2016/679 (for brevity “GDPR”), PROSUCCESS FZCO, in the person of its legal representative, with headquarters001 Building A1, IFZA Business Park, DDP Dubai – United Arab Emirates, email: prosuccessfzco@gmail .com – as Data Controller (hereinafter Data Controller, Prosuccess FZCO or Company), hereby provides you with information on the processing of your personal data and the rights that you may exercise to protect them.
- PERSONAL DATA BEING PROCESSED
Your personal data, which may be processed, will be the sole datic.d. “municipalities.” Pursuant to EU Regulation 2016/679 (GDPR), the following are Municipalities, by way of example: surname and name, date of birth, residence, home, tax code, registration title; telephone contacts, e-mails; surname and name, degree of kinship, place and date of birth of dependent family members.
The common data that you voluntarily provide, and any changes in such data that you will communicate to the Data Controller in the future, will be processed in strict compliance with current regulations and only and exclusively for the purposes, and in the manner, indicated below.
- PURPOSE OF PROCESSING – COMPULSORINESS OF CONFERMENT – LEGAL BASIS
The collection and processing of yourpersonal data by PROSUCCESS FZCO will take place solely and exclusively to enable the organization, management and delivery of the contractual performance underlying this notice.
Failure to provide personal data will prevent the establishment and continuation of the contractual relationship. The confermentis, therefore, mandatory and requires your express manifestation of consent.
The data you provide will be processed for the following purposes: (a) related and instrumental to the establishment and execution of the existing contractual relationship with PROSUCCESS FZCO; (b) related and instrumental to the management of litigation, contractual fulfillments, warnings, settlements, debt collection, arbitrations, and court disputes; (c) related to credit evaluation and protection; d) related to the fulfillment of obligations arising from national and EU regulations as well as given by authorities empowered to do so by law; (e) promotional and commercial information on services distributed by PROSUCCESS FZCO.
It is specified that the person concerned may be the subject of audio/video recordings, with the aim of optimizing the effectiveness of teaching activities. Such photographic and video images, in color or in black and white, taken/taken by the professionals appointed by the Holder, in their studio or during a training course or other, may be used on promotional brochures distributed during courses organized by the Holder and/or during partner events, on the Holder’s and/or partner’s websites, on the Holder’s products, on roll-ups and/or promotional and informational material used during events and training courses of the Holder and/or partners.
The collection and processing of personal data will take place in compliance with the provisions of laws and regulations, as well as with the Community regulations and the provisions issued by public authorities empowered to do so and/or by supervisory and control bodies (first and foremost, the Supervisory Authority).
The personal data of each Interested Party will be processed within the organization of the Data Controller, i.e., by Trustees and/or External Data Processors, who will take care to act in strict compliance with Reg. EU 2016/679.
- MODE OF DATA PROCESSING AND STORAGE
The acquired data will not be subject to dissemination, except within the limits specified above (see art. 2); they will be processed with appropriate methods and procedures, including computer and telematic, only by the personnel appointed by the Owner and by qualified external subjects, involved in the aforementioned activities, contractually obliged to be compliant with the GDPR and to act under express confidentiality constraints. Your personal data will be kept for the time strictly necessary to achieve the purposes for which it was collected. Specifically, it should be noted that your personal information will be kept by the Company for a maximum period of 5 years; after that period, it will be automatically removed from our files, without your having to take any action.
The right to use images and footage under Art. 2 shall be understood to be granted according to law.
- COMMUNICATION OF DATA
For the performance of certain activities necessary for the provision of the requested services, the Data Controller is required acommunicate some of your data also to third parties, such as: companies, entities or consortia, associations or professional consulting firms in tax and legal matters or that carry out activities necessary for the execution of the contract with particular but not exclusive reference to debt collection and/or assignment companies, printing and enveloping companies, companies controlling, controlled by or related to thePROSUCCESS FZCO, banks, factoring companies or insurance companies, subjects whose right to access data is recognized by legal provisions. The data may also be communicated: to entities operating in the credit, financial or banking sector as part of securitization or credit assignment operations for purposes strictly related and instrumental to the management of the relationship with the assigned debtors/guarantors, as well as to the issuance of securities by the company; to companies operating abroad, including in countries outside the European Union, but always only and exclusively for the purposes outlined above. The list of names of the parties to whom your data are or may be disclosed is available to you at the Data Controller’s office and you may request it easily by making a special request to the Data Controller.
It may happen that your data are circulated (in electronic format), to other countries of the European Union, if only as a result of organizational choices – at the level of IT infrastructures – of the aforementioned third parties; the same, in any case, will be processed only for the purposes in question and in compliance with the GDPR.
- DATA TRANSFER ABROAD
Data collected by the data controller may be processed outside the borders of the European Union and, specifically: – UAE – United Arab Emirates. The legal basis for the aforementioned processing lies in paragraph 1 of Art. 49 of Regulation (EU) 2016/679, letter (b) and (c) as follows: “(b) the transfer is necessary for the performance of a contract concluded between the data subject and the data controller or for the performance of pre-contractual measures taken at the request of the data subject”; “(c) the transfer is necessary for the conclusion or performance of a contract concluded between the data controllerand another natural or legal person for the benefit of the data subject”.
- RIGHTS OF THE DATA SUBJECT
Pursuant to and within the limits of Chapter III of the GDPR, you may exercise the following rights at any time, pursuant to Articles 15-21Reg. EU 2016/679: (a) Access to personal data; (b) rectification of your personal data (we will, upon your request, correct your incorrect data that has also become incorrect because it is out of date); (c) revocation of consent; d) deletion of data (right to be forgotten) (e.g., in case of withdrawal of consent, if there is no other legal basis for processing); (e) limitation of processing; (f)objection to processing for legitimate reasons; (g) Data portability (upon your request, the data will be transmitted to the entity you indicate informed that makes it easy to consult and use); (h) complaint to the supervisory authority (Privacy Guarantor).
To exercise the rights set out above, and to obtain detailed information about the subjects or categories of subjects to whom the data will be communicated – or who will become aware of it as Managers or Persons in Charge – you can contact the Data Controller, at the contact details indicated in the following art. 9.
- APPLICABLE LAW
This Policy is governed by UAE law and the GDPR, where applicable, which governs the processing of personal data – including data held abroad – by anyone who is a resident of a member state of the European Union. TheGDPR ensures that the processing of personal data is carried out with respect for the fundamental rights and freedoms and dignity of the data subject, with particular reference to confidentiality, personal identity, and the right to protection of personal data.
- DISCLOSURE UPDATE
This policy may be modified over time to accommodate changes in relevant legislation or for reasons of commercial convenience. Any material changes will be posted on the Site and it is incumbent upon you to monitor the Site periodically to inform yourself as to whether theseconditions are in force or have changed.
- HOLDER
The processing of your common and sensitive personal data is entrusted to PROSUCCESS FZCO (Data Controller), in the person of its legalerapp.te p.t. – based at 001 Building A1, IFZA Business Park, DDP Dubai- United Arab Emirates, email: [email protected], whom you may contact to assert your rights as provided in the aforementioned Chapter III of the GDPR.
