PRIVACY POLICY – DATA PROCESSING FOR MARKETING PURPOSES

(Pursuant to Article 13 of Regulation (EU) 2016/679 – “GDPR”)

1. Data controller

The data controller is Nanosystems S.r.l., with registered office in Via del Commercio, 76/A (Ascoli Piceno), VAT number 01085650446, hereinafter referred to as “Nanosystems” or “Company”.

2. Type of data processed

In the context of the online questionnaire completed on a voluntary basis when requesting a software demo, the following data is collected:

• identification and contact details (e.g., first name, last name, email address, company, role);
• information contained in the answers provided in the questionnaire (e.g., number of devices managed, preferences, scope of use of the product).

3. Purpose of processing and legal basis

The personal data collected will be processed for the following purposes:

a) Management and analysis of questionnaire responses, to assess interest in the product and improve the services offered.

Legal basis: implementation of pre-contractual measures at the request of the data subject (Art. 6, para. 1, letter b) GDPR).

b) Sending promotional communications and direct marketing regarding Nanosytems products, services, and initiatives via email, telephone, or other contact channels indicated in the questionnaire.
Legal basis: consent of the data subject (Art. 6, para. 1, letter a) GDPR).

By submitting the questionnaire, the user gives their consent to be contacted for the purposes referred to in letter b).

Consent is optional and may be revoked at any time without prejudice to the lawfulness of the processing carried out previously.

4. Methods of processing

The processing will be carried out using IT and telematic tools, in compliance with the principles of lawfulness, fairness, transparency, and data minimization.

Appropriate technical and organizational measures will be taken to ensure the security and confidentiality of the information (Article 32 of the GDPR).

No automated decision-making or large-scale profiling is carried out on the basis of the answers provided.

5. Data retention period

• The data collected for the analysis of the questionnaire will be retained for a maximum period of 12 months from collection.
• Data processed for marketing purposes will be retained until consent is withdrawn or, in the absence of withdrawal, for a period not exceeding 24 months.

6. Recipients and categories of subjects authorized to process data

Personal data may be processed by:

• internal personnel expressly authorized and trained by the data controller;
• third parties providing services instrumental to the processing (e.g., hosting services, CRM, mailing platforms), appointed as data processors pursuant to Article 28 of the GDPR. 

The updated list of data processors is available on request at the email address privacy@nanosystems.it.

• consultants or business partners of the Company, limited to marketing purposes and in compliance with current legislation.

The data will not be disclosed or communicated to unauthorized parties.

7. Transfer of data to third countries

Some service providers used by the Data Controller or its Data Processors may have their headquarters or infrastructure located outside the European Economic Area (EEA).
In such cases, personal data will only be transferred to countries for which there is an adequacy decision by the European Commission (Article 45 of the GDPR), or after the adoption of Standard Contractual Clauses approved by the Commission (Article 46 of the GDPR) or other appropriate safeguards.

8. Rights of the data subject

The data subject may exercise the rights provided for in Articles 15-22 GDPR at any time, including:

• obtaining confirmation of the existence of data concerning them and accessing its content (right of access);
• requesting its rectification or erasure (“right to be forgotten”);
• request the restriction of processing or object to the processing of data;
• withdraw consent at any time;
• lodge a complaint with the Data Protection Authority.

To exercise these rights, the data subject may send a request to: privacy@nanosystems.it

9. Provision of data

Completing the questionnaire is optional and failure to do so will not affect your ability to use the software demo in any way. 

10. Updating of the policy

This policy may be updated periodically.