Privacy Policy

Privacy policy pursuant to art. 12 et seq EU Regulation 679/2016
of Haltho ag.

Haltho ag, tax code and VAT number CH410188203, with registered office in CH-9443 Widnau Switzerland, via Unterlettenstrasse n.10, by its legal representative pro tempore, informs you that the processing of personal data (common. Such as for example name, surname, email, …) provided by you when requesting information (the pre-contractual phase) or when concluding the contract for the provision of services with Haltho ag (hereinafter, the Contract), or gathered during its performance, will be based on principles of correctness, lawfulness and transparency, protecting your privacy and your rights. We would herein inform you as follows.

1. PURPOSES OF THE PROCESSING.
The processing of personal data will be carried out for the following purposes:
1 – (pre-contractual and contractual purposes): to allow the provision of the information requested (pre-contractual phase) and/or compliance with the obligations deriving from the Contract. The contract constitutes the legal basis for the processing. After the cessation of the contract, the legal basis will be compliance with legal obligations.
2 – (promotional purposes): to carry out promotional activities, sending a newsletter, containing advertising and promotional material relating to Haltho ag The legal basis for the processing is the consent, which may be revoked at any time. Following revocation of the consent, the legal basis is the compliance with any obligations provided by the law.
3 – (legal purposes): to comply with the law.

2. MANNER OF PROCESSING.
The processing of the aforementioned data will be made by the data supervisors and persons in charge of the processing formally identified who will use instruments and supports – paper based, magnetic, computer based or telematic – suitable to guarantee the security and confidentiality. The processing may also be carried out using automated instruments that can record, manage and transmit said data online.

3. NATURE OF THE PROCESSING – The nature of provision is respectively:
– OBBLIGATORY as far as relates to the pre-contractual and contractual purposes stated at point
1); therefore the refusal to provide said data, in whole or in part, or the failure to authorise their processing and/or their communication to third parties involved in the performance of the Contract by Haltho ag may result in the impossibility on the part of Haltho ag to provide the information and to perform the Contract.
– FACULTATIVE as far as relates to the promotional purposes stated at point
2); therefore the refusal to provide said data, in whole or in part, or the failure to authorise their processing and/or their communication to third parties involved in the promotional activity by Haltho ag may result in the impossibility on the part of Haltho ag to effect the promotional activity.

4. RIGHTS OF THE DATA SUBJECT
4.1 In relation to personal data (common), you, as a data subject, may – by sending an email to : info@mastswiss.com – to Haltho ag, with registered office in CH-9443 Widnau Switzerland, via Unterlettenstrasse n.10, by its legal representative pro tempore – :
– request that Haltho ag, as data controller, grant you access to your personal data, correct or cancel the same, or that the processing be limited or you may oppose the processing (ex arts. 15, 16, 17, 18, 19, 21 EU Reg 679/2016). In particular:
* as far as regards the correction of personal data, taking into account the purposes of the processing, you are entitled to obtain an integration of any incomplete data, also providing a statement of integration ;
* as far as regards the limitation of the processing, you are entitled to obtain this in the presence of one of the following circumstances:
a) your objection that the personal data are inexact, for the period necessary in order that Haltho ag can verify the exactness of the personal data;
b) the processing is unlawful and you object to the cancellation of the personal data and request on the other hand that their use be limited;
c) although Haltho ag no longer requires the processing, the personal data are necessary to allow it to ascertain, exercise or defend a right before the courts;
* as far as regards the cancellation of the personal data without undue delay, you are entitled to obtain this the presence of one of the following circumstances :
a) the personal data are no longer necessary with respect to the purposes for which the same were gathered or otherwise processed;
b) you as a data subject revoke your consent on which the processing is based and provided there is no other legal basis for the processing;
c) the personal data have been unlawfully processed;
d) the personal data must be cancelled in order to comply with a legal obligation provided by the European Union to a Member State to which Haltho ag is subject;
– receive in a structured format, of common use and readable on an automatic device, the personal data relating to you provided to a data controller, and you will be entitled to send said data to another data controller without any impediment on the part of Haltho ag (so called “data portability” ex art. 20 EU Reg 679/2016);
– revoke consent at any time without prejudicing the lawfulness of the processing effected on the basis of the consent given prior to the revocation (ex art. 8, par. 3, EU Reg 679/2016).
4.2 Your personal data will not be divulged or transferred to third party States or international organisations.

5. DATA CONTROLLER – DATA PROCESSOR.
The data controller is Haltho ag, tax code and VAT number CH410188203, with registered office in CH-9443 Widnau Switzerland, via Unterlettenstrasse n.10, by its legal representative pro tempore, which can be contacted at the following address: info@mastswiss.com.
Data processors are:
– partner used by Haltho ag for the provision of services to Customers (eg development/maintenance of websites, applications, management information system, accounting software and sending newsletters ).

6. COMMUNICATION OF THE PROCESSING.
Save always the communications made in compliance with the legal obligations, your personal data may also be communicated within Italy to: employees / collaborators of Haltho ag; partners used by Haltho ag for the provision of services to Customers (eg development/maintenance of websites, applications, management information system, accounting software and sending newsletters ).

7. PERIOD OF DATA RETENTION.
Personal data (common) provided by you will be stored in such form as allows your identification, as a data subject:
– for a period of time not exceeding the completion of the pre-contractual and contractual phases stated at point 1 for which the same were processed, save always compliance with any legal obligations;
– until the revocation of consent for the promotional purposes stated at point 2 above, for which the same were processed, save always compliance with any legal obligations.
There is no automated system for the cancellation of the personal data at the end of their retention period given that their cancellation takes place manually once the legal obligations following from the cessation of the contract have been complied with.

8. COMPLAINTS.
If you consider that the processing violates EU Reg. 679/2016, you are entitled to make a complaint to a supervisory authority in the Member State in which you habitually reside, work, or of the place where the alleged violation occurred.