AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L., legal office: Via Pontano n. 61, 80122, Naples (NA), registration number in the Naples Business Register code Rea NA-890484, and VAT number 07522871214 (hereinafter, also, the “Company” or “Data Controller”), acknowledges the importance of protecting personal data and proactively commits to processing them responsibly and in compliance with EU Regulation 2016/679 (GDPR) and the applicable national regulations (Legislative Decree 196/2003 or the “Privacy Code,” updated by Legislative Decree 101/2018).

For this purpose, the present Policy outlines the privacy practices applicable to the personal information we collect, use, and potentially share to establish a working relationship and, if already in place, to manage it.

In order to ensure a consistent and high level of protection for the aforementioned data, we would like to inform you, in your capacity as a Client and “Data Subject” – that is, the individual to whom the data being processed refers – of the technical and organizational measures taken by the Company and the essential elements of the operations carried out.

DATA CONTROLLER

The data controller of the personal data of Clients is AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L. For any clarifications and to exercise the rights referred to in Articles 15-22 of the GDPR, the clients of AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L. can contact the legal representative pro tempore. The aforementioned rights can be exercised by sending communications to the following addresses:

Certified email: info@martelogistics.com
Or by sending a registered letter to:
AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L., Via Pontano n. 61, 80122, Naples (NA)
An updated list of Data Processors and authorized subjects for processing is kept at the Data Controller’s registered office.

PROCESSED DATA, PURPOSES AND LEGAL BASIS OF PROCESSING

The provision of data is mandatory for all that is required by legal and contractual obligations. Therefore, any refusal to provide such data, in whole or in part, may result in the impossibility for the Company to execute the contract or to carry out the related obligations.

Personal data voluntarily provided by the clients of AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L. are those necessary for the Data Controller to provide the available services and will be processed in accordance with the principles of fairness, lawfulness, and transparency, as well as safeguarding privacy and the rights of Clients. These data are also collected and recorded for the purposes specified below and used in processing operations that are not incompatible with these purposes.

Personal identifying data, such as, for example, name and surname, business name, tax code, VAT number, address, phone/fax, email, bank and payment details, are collected and processed:

• To carry out activities related to the Client based on pre-contractual and contractual agreements;

• For administrative, fiscal, or accounting purposes related to the client-supplier relationship and to fulfill any obligations imposed on the Data Controller by laws, regulations, community norms, requests from judicial authorities, or for the exercise of the Data Controller’s rights (e.g., right of defense in court);

• With your specific consent, to send (via email, mail, SMS, or phone contact) newsletters, updates on the Data Controller’s activities, promotional material, or commercial communications regarding products or services offered by the Data Controller that may be of interest to you, and to measure satisfaction with the quality of services, including requests to participate in market analysis or research;

• With your specific consent, to send (via email, mail, SMS, or phone contact) newsletters, updates, and informational material regarding the services offered by the Company; in this case, data may be processed through both automated methods (e.g., email, SMS, or similar) and traditional methods (e.g., postal mail and calls by operator).

The legal basis for processing data under points “a” (pre-contractual and contractual agreements) and “b” (administrative, fiscal, or accounting purposes) is the performance of a contract of which the Client is a party, or, at the Client’s request, the performance of pre-contractual activities.

For the purposes outlined in points “c” and “d”, the legal basis is the consent, if freely given by the Client. These categories of data will, therefore, be processed by the Data Controller only upon express consent, which the Client may provide in writing by signing this Policy.

PROCESSING METHODS

Personal data is defined as “any information relating to an identified or identifiable natural person, that is, the data subject, directly or indirectly, with particular reference to an identifier such as the name, identification number, location data, online identifier, or to one or more factors specific to the person’s physical, physiological, genetic, mental, economic, cultural, or social identity” (Article 4 GDPR).

Processing of Clients’ personal data may include the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction of data.

Personal data of Clients will be collected through direct submission to the Data Controller, via completion of specific forms or through contractual documents, or collected by phone by the Data Controller or an authorized collaborator during pre-contractual activities.

Data will mainly be processed using electronic or telematics tools, with a minimal portion processed manually in paper format.

The collected data is stored by the Data Controller in computerized and paper archives, safeguarded to minimize risks of accidental destruction or loss, unauthorized access, or processing that does not comply with the collection purposes.

Data will be processed by the Data Controller’s collaborators, properly instructed for such purposes.

CATEGORIES OF RECIPIENTS

Subject to legal and contractual obligations, the collected and processed data may be communicated, strictly necessary for the purposes indicated, to:

• Collaborators of the Company involved in processing data to provide the services expressly requested by Clients;

• External subjects such as professionals, companies, associations, or law firms that provide the Data Controller with assistance or consultancy for administrative, fiscal, legal, or accounting purposes, with whom the Company has signed specific agreements on measures to ensure the security of entrusted data;

• Public institutions required by law, and in general, entities stipulated by current regulations on accounting and fiscal matters as recipients of mandatory communications;

• Banks for payments and collections, as well as professionals or companies for market analysis, credit recovery, or financial services;

• Insurance companies, financial intermediaries, and credit institutions;

• Legal entities, both private and public, chambers of commerce, social security, and assistance entities (e.g., INPS, INAIL, provincial labor offices, tax offices, financial administration), and other bodies responsible for verifying the correct fulfillment of the aforementioned purposes.

In any case, personal data will not be disseminated, except for the above purposes.

DATA RETENTION PERIOD

The data will be retained even after the termination of the working relationship to fulfill any obligations related to the conclusion of the relationship, according to the timelines set by law, particularly:

• For the purposes outlined in letters “a” (pre-contractual and contractual agreements) and “b” (administrative, fiscal, or accounting obligations), Clients’ personal data will be processed and stored by the Data Controller for the entire duration of the contractual relationship and, at its conclusion, for the time required by applicable accounting, fiscal, civil, and procedural laws.

• For the purposes outlined in letters “c” and “d”, Clients’ personal data will be processed and stored by the Data Controller until the Client revokes their consent or exercises their right to object to processing or request the deletion of personal data.

RIGHTS OF THE DATA SUBJECT

Data subjects have the right to obtain from AGGREGAZIONE PUBBLICO – PRIVATA SULLA LOGISTICA MARE-TERRA S.C.R.L., where applicable, access to their personal data and the correction or deletion of the same, or the limitation of processing, or to object to processing (Articles 15 et seq. of the Regulation);
Finally, if you believe the processing of your data is non-compliant with European Regulation 679/2016 (GDPR), you have the right to file a complaint with the Data Protection Authority, by:

• Sending a registered letter to the Data Protection Authority, Piazza Venezia, 11, 00187 Rome;

• Email to: protocollo@gpdp.it, or protocollo@pec.gpdp.it;

• Fax at: 06/69677.3785.

EXERCISING YOUR RIGHTS

The Data Subject, for any clarifications and to exercise the rights referred to in Articles 15-22 of the GDPR, may contact the Company at the addresses indicated in the previous section of this notice.

The exercise of rights by the Data Subject is free of charge, according to Article 12 of the GDPR. However, in case of manifestly unfounded or excessive requests, including due to their repetitive nature, the Data Controller may charge the Data Subject a reasonable administrative fee to cover the costs incurred for processing their request or deny the satisfaction of the request.