1. Purposes of Data Processing
The personal data of users will be processed by KLA for the following purposes:
- compliance with contractual obligations a) (article 6(1)(b) of Regulation (EU) No 2016/679 of 27 April 2016), in particular to implement the General Terms and Conditions of the Site, which are accepted by User during the registration process. Subject to the specific and optional consent given by User to KLA for the processing of personal data for marketing purposes under paragraph 2, all personal data (name, surname, e-mail and telephone number) will only be used by KLA to investigate the identity of User (also through e-mail validation), to prevent fraud or the practice of illegal acts and to contact User for matters related to the provision of service;
- compliance with legal obligations (article 6(1)(c) of Regulation (EU) No 2016/679 of 27 April 2016) in order to comply with legal obligations under national law and European laws or regulations.
The provision of personal data for the processing of the aforementioned purposes is optional but necessary to the extent that registration and use of the Site is impossible in the event of non-provision of data. The asterisk on the registration form identifies the personal data required for purposes of the processing described in paragraph 1.
2. Additional Purposes of Data Processing: marketing (sending of promotional material, direct sales and commercial communication)
Through the free and informed consent of user, some personal data (name, surname, e-mail, address and fixed and mobile phone number) can also be processed by KLA for marketing purposes (sending promotional material and commercial communication).
Consent to the processing of data for such purposes is free and optional. If consent has been given, User may revoke it at any time by notifying KLA through the methods specified in paragraph 5 of this policy for the appropriate purposes.
KLA hereby states that User may continue to receive marketing messages for technical reasons (for example, marketing messages prepared shortly before exercise of the right to object) subsequent to e exercise of the right to oppose the sending of commercial communications. If User continues to receive marketing communications after 48 hours from exercise of the right to object, KLA requests that he/she immediately report the situation to the contacts specified in paragraph 5 of this policy.
3. Processing Methods
Personal data of users will be processed in an automated and manual manner through computer systems, applying an approach strictly related to the purposes of processing and in all cases ensuring the security and confidentiality of personal data.
4. Disclosure and Transmission of Personal Data
KLA employees appointed to manage personal data may access the personal data of Users. Such employees, appointed by KLA as “controllers”, shall process the personal data of Users solely for the purposes specified in accordance with this policy and in strict compliance with Regulation (EU) No 2016/679 of 27 of April 2016.
Third parties who may process personal data on behalf of KLA may also access the personal data of Users as subcontractors, such as, but not limited to, the IT service providers needed for operation of the Site, outsourcing service providers or providers of cloud computing services, professionals and consultants, or companies responsible for the distribution of marketing emails on behalf of KLA, with such services being currently provided by the company Digital Connection, with its registered office at Estrada Consiglieri Pedroso, Consiglieri Park Edifício E, 2º, 2730-055 Queluz.
User has the right to obtain a complete and up-to-date list of subcontractors (if any) appointed by KLA, requiring the submission of a specific request to KLA under the terms specified in paragraph 5 of this policy.
5. Rights of Data Subjects
In accordance with Regulation (EU) No 2016/679 of 27 April 2016, KLA states that users have the right to obtain information on (i) the identity of the controller, and, if applicable, the representative thereof; (ii) the purposes of processing, (iii) the recipients or categories of data recipients, (iv) the optional or mandatory nature of the response and the possible consequences of not responding and (v) the existence and conditions of the right of access and rectification, provided that they are necessary, taking into account the specific circumstances of data collection, to ensure that the data of the subject is processed fairly. KLA also informs data subjects that they have the right to: a) update, rectify or, if applicable, request the integration of data; (b) erasure, anonymisation or blocking of personal data which have been unlawfully processed, including personal data whose retention is not necessary for the purposes for which they were collected and consequently processed; (c) certification that the operations carried out pursuant to subparagraphs a) and b) have been reported, as well as related to their content, to the entities to which the data were communicated or disclosed, unless this requirement is impossible or involves a manifestly disproportionate effort compared to the right to be protected. Users have the right to object, in full or part: a) for legitimate reasons, to the processing of their personal data, even if they are relevant for purposes of collection; b) to the processing of personal data for purposes of sending promotional materials, direct sale or conducting market research or commercial communication.
6. How to Contact KLA
Users may exercise their rights by contacting KLA through the following methods: i) registered letter with acknowledgement of receipt sent to the address indicated by KLA, ii) via e-mail: firstname.lastname@example.org.