SHD ITALIA S.r.l., with registered office in Corso Italia 11, 28010 Fontaneto d’Agogna (Novara) – hereinafter “Holder” – as data controller, informs you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, “Privacy Code“) and art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR“) that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment

The Holder processes personal data, such as name, surname, company name, address, telephone number, e-mail address, bank and payment details) – hereinafter, “personal data” or even “data” – which you have communicated on the conclusion of contracts for the services of the owner or following marketing operations.

2. Purpose of the treatment

Your personal data are processed:

A. without your express consent (Article 24 letter a,b, Privacy Code and article 6 letter b, GDPR), for the following Service Purposes::

  • conclude contracts for the services of the Owner;
  • fulfill the pre-contractual, contractual and tax obligations deriving from relations with you;
  • fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
  • exercise the rights of the holder, for example the right to defense in court;

B. ONLY upon your specific and distinct consent (Article 23 and 130 of the Privacy Code and Article 7 of the GDPR), for the following Marketing Purposes::

  • send you via e-mail, mail and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material on products or services offered by the Holder and detection of the degree of satisfaction on the quality of services..

Please note that if you are already a customer, we may send you commercial communications relating to services and products of the Holder similar to those you have already used, subject to your disagreement (Article 130 paragraph 4 of the Privacy Code).

3. Method of treatment

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.

The Holder will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the purposes of service and no later than 10 years from the collection of data for the Marketing Purposes.


4. Access to data

Your data may be accessible for the purposes referred to in art. 2.Aand 2.B:

  • to employees and collaborators of the Holder in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
  • to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge or responsible for providing the contractual service (planning, planning, management, logistics, etc.);
  • to third-party companies or other subjects (as an indication, credit institutes, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourcing activities on behalf of the Holder, in their capacity as external managers of treatment.

5. Data communication

Without the need for express consent (pursuant to Article 24 letter a,b,dof the Privacy Code and Article 6 letter band cof the GDPR), the Holder may communicate your data for the purposes referred to in art. 2.Ato Supervisory Bodies (such as IVASS), judicial authorities, banking institutions and insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be diffused.

6. Data transfer

Personal data are stored on servers located at the headquarters of the owner. In any case, it is understood that the Holder, if necessary, will have the right to move the servers inside or outside the European Union. In this case, the Holder hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of providing data and consequences of refusing to answer

The provision of data for the purposes referred to in art. 2.Ais mandatory. In their absence, we cannot guarantee the services of the art. 2.A.

The provision of data for the purposes referred to in art. 2.Bis optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A.

8. Rights of the interested party

As an interested party, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights to:

  1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
  2. get the indication:
    a) of the origin of personal data;
    b) of the purposes and methods of the processing;
    c) of the logic applied in case of treatment carried out with the aid of electronic instruments;
    d) of the identification details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR;
    e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;
  3. obtain:
    a) updating, rectification or, when interested, integration of data;
    b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
    c) the attestation that the operations referred to in letters and have been brought to the attention, alsowith regard to their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
  4. oppose, in whole or in part:
    a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of the collection;
    b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, by e-mail or through traditional marketing methods, telephone and / or mail paper;

It should be noted that the right of opposition of the interested party, set out in point b above, for direct marketing purposes through automated methods extends to the traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition even if only partly. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, it also has the rights referred to in art. 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. Modality to exercise rights

You can exercise your rights at any time by sending:

  • a registered letter to SHD ITALIA S.r.l. – Corso Italia 11, 28010 Fontaneto d’Agogna (Novara);
  • an e-mail to

10. Holder, manager and agents

The Holder is SHD ITALIA S.r.l. with legal and operative office at the plant in Corso Italia 11, 28010 – Fontaneto d’Agogna (Novara).

The updated list of data processors and data processors is kept at the registered office of the Holder.