The Data Controller is TM & PARTNERS SCF S.r.l. This notice presents the contents of document 249; the specific notice for the Contact form is derived from document 6734.
The provided text also describes functions that are not active on the new website and contains legal bases that require updating. Verification by the Data Controller and the privacy contact person is required prior to final publication.
Regulatory references
- Directive 2002/58/EC – concerning the "processing of personal data and the protection of privacy in the electronic communications sector"
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);
- Legislative Decree no. 196 of 30 June 2003 “Personal Data Protection Code”, as amended by Legislative Decree no. 101 of 10 August 2018.
Data Controller
Following consultation of this website, data relating to identified or identifiable persons may be processed. The “Data Controller” for such processing is TM & PARTNERS SCF S.r.l., based in Fano (PU); e-mail: info@tmandpartners.it.
To exercise your rights: info@tmandpartners.it or Via Carlo Gozzi 8/A, Fano (PU).
Data provided voluntarily
TM & PARTNERS SCF S.r.l. collects personal data voluntarily provided by users through the site (www.tmandpartners.it) in the following cases:
- Sending requests via the Contact form.
- Newsletter subscription, if the relevant service and consent form are activated.
Specific summary notices will be progressively displayed on the site pages dedicated to specific on-demand services.
Cookies
For the categories and cookies indicated in document 249, please consult the Cookie Policy.
Purposes and legal bases
Document 249 identifies the following purposes:
- Enabling site navigation and browsing.
- Responding to information requests and, if activated, managing the newsletter.
- Preventing abuse and fraud attempts.
Regarding defensive purposes, the document cites the data controller's legitimate interest (Art. 6, para. 1, letter f, GDPR). For navigation and forms, it indicates consent inferred from browsing or filling out the forms; this wording requires revision before final publication, as mere browsing does not equate to consent for non-technical cookies, and consent for the newsletter must be given separately.
Provision of data
Apart from what is specified regarding navigation data, the user is free to provide personal data by filling out the forms on the site. Failure to provide personal data may make it impossible to fulfill the request.
Processing methods and duration
Personal data are processed using automated tools for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are observed to prevent data loss, illicit or incorrect use, and unauthorized access. Drawing on leading international standards, TM & PARTNERS SCF S.r.l. has also adopted additional security measures to minimize risks regarding the confidentiality, availability, and integrity of the personal data collected and processed.
The document does not specify numerical retention periods for each data category. The Data Controller must confirm the periods or criteria applicable to logs, contact requests, and any newsletter.
Data recipients
The collected data may be transferred or communicated to other companies—specifically appointed as Data Processors—for activities strictly related to the aforementioned purposes and instrumental to the service's operation, such as IT system management. Apart from these cases, personal data will not be communicated or disclosed to anyone, unless contractually provided for or authorized by the data subjects. In this regard, personal data may be transmitted to third parties, but only and exclusively if: a) there is explicit consent to share the data with third parties; b) it is necessary to share information with third parties in order to provide the requested service; c) it is necessary to comply with requests from judicial or public security authorities. No data derived from the web service is disseminated. A list of the entities appointed as Data Processors is available at the company's headquarters at Via Carlo Gozzi 8/A, Fano (PU).
Download the position paper
The data controller is TM & PARTNERS SCF S.r.l., Via Carlo Gozzi 8, Fano (PU), info@tmandpartners.it. We collect the email address, the date of the request, and the version of the policy to facilitate the download and document the request, based on the measures requested by the data subject for the provision of the service (Art. 6, para. 1, letter b, GDPR). The email address is required to use this form; it is not added to marketing lists.
Requests are stored in the site’s log for 180 days following the last request; thereafter, they are removed from the active log and queued for deletion in accordance with the site’s technical processes. Authorized administrators and technical providers necessary for the site's operation may access this data, in accordance with their respective roles. No automated decision-making or profiling is performed for this service. Technical browsing logs remain governed by the Privacy Policy.
You may request access to, rectification of, erasure of, restriction of processing of, and portability of your data in the applicable cases by writing to the Data Controller; you may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali). For further information regarding data processing, please consult the Privacy Policy.
Privacy notice for the Contact form
The specific notice provided in document 6734 specifies that the data submitted via the form (name, email, phone number, subject, and message) are processed by TM & PARTNERS SCF S.r.l. to respond to the request, for the time necessary to provide a reply and subject to legal obligations. Providing data is optional; however, without the data requested in the form, it is not possible to provide a response.
Authorized personnel may access the data, and service providers engaged for necessary services may receive it on behalf of the data controller. The data is not disseminated. The notice also provides for potential processing for a newsletter regarding the company’s activities and initiatives, but only subject to express consent. The new Contact form does not include a newsletter subscription.
To exercise the rights set forth in Articles 15 et seq. of the GDPR, please write to info@tmandpartners.it or to TM & PARTNERS SCF S.r.l., Via Carlo Gozzi 8/A, Fano (PU).
Rights of data subjects
Personal data protection legislation expressly grants certain rights to the individuals to whom the data relates (the so-called "data subject"). In particular, pursuant to Articles 15 et seq. of Regulation (EU) 2016/679, every data subject has the right to obtain confirmation as to whether or not personal data concerning them exists and, if so, to obtain access to said personal data, as well as to obtain rectification, erasure, restriction of processing, and data portability, and to object to the processing.
To exercise the rights indicated above, the user may contact the Data Controller by sending a registered letter with return receipt to the indicated address or an email to info@tmandpartners.it.
Right to lodge a complaint
Data subjects who believe that the processing of their personal data via this site violates the GDPR have the right to lodge a complaint with the supervisory authority, as provided for in Art. 77 of the GDPR, or to seek judicial remedy (Art. 79 of the GDPR).
Changes to the policy
TM & PARTNERS SCF S.r.l. periodically reviews its privacy and security policies and, where appropriate, updates them to reflect regulatory or organizational changes or developments in technology. In the event of a policy change, the new version will be published on this page of the website.
Governing law and jurisdiction
The interpretation and execution of these conditions are governed by Italian law. The Court of Pesaro (PU) (Italy) shall have exclusive jurisdiction over any dispute connected in any way to these conditions. The Data Controller reserves the right to seek urgent remedies before any court, including those abroad, to protect its interests and enforce its rights.