www.topnotch.it is owned by Intelsis Srl (hereinafter also referred to as ‘Intelsis’), with registered office in Via del Cottanello, 13, Rome 00158, Italy, VAT No. 14570261009 and Rome Companies Register No. 1530908.

This POLICY NOTICE is pursuant to and for the purposes of Article 13 of European Union General Data Protection Regulation 679/2016 (‘GDPR’) and Article 122 of the Italian Privacy Code.
Pursuant to and for the purposes of the provisions of Article 13 of European Union General Data Protection Regulation 679/2016 (hereinafter the ‘GDPR’) and Article 122 of the Italian Privacy Code, we hereby inform you that your personal data will be processed by electronic and manual means, in Italy and abroad. This policy notice (the ‘Notice’), prepared according to the principle of transparency and to all requirements of the GDPR, is divided into individual sections, each of which deals with a specific topic, in order to make its reading swifter, easier and more comprehensible (hereinafter “Information “).

1. Legal basis and purposes of the data processing

Purposes	Legal basis
a) Sending of communications, replies to requests for information and newsletters of an informative and non-commercial nature;	The processing for these purposes is performed with the consent of the user / Data Subject (as per Article 6, Letter a, GDPR).

2. Categories of data processed

The personal data that will be processed are: name, surname, e-mail address, credit / debit card number, and billing information.

2.1 Data of minors

The personal data of children under the age of 14 will not be processed by the Data Controller unless prior authorization has been given by the Holder of Parental Responsibility. The Data Controller shall assume no responsibility for the processing of the data of minors.

3. Nature of the provision of the data and consequences of any refusal to provide it

The provision of the personal data in relation to the purposes referred to above in point a) is mandatory such that any refusal to provide the data will make it impossible for Intelsis to proceed with and fulfil the purchase order.
The provision of the personal data in relation to the purpose referred to above in point b is voluntary such that any refusal to provide the data shall not preclude fulfilment of the purchase order.
The processing of the data will be carried out with manual and automated systems designed to store, manage and transmit the data held in a database by Intelsis according to the aforementioned purposes, under the responsibility of the user of the website to promptly notify Intelsis of any necessary corrections, additions or updates.
The processing shall be performed strictly for the aforementioned purposes, and, in any case, in a manner as to guarantee the security and confidentiality of the data.

4. Scope of the communication and disclosure of the data

For the aforementioned purposes, the data strictly necessary for each type of processing may be communicated by Intelsis:

• To all subjects having the right of access to such data by law;
• To contractors, employees and suppliers of Intelsis, within the scope of related duties and contractual obligations, and concerning commercial relations with the interested parties;
• To other national companies of the same group;
• To post offices, shippers and couriers for the sending of documentation or materials;
• To all public or private, physical or juridical parties (legal, administrative or fiscal consultancy offices, chambers of commerce, industry chambers and employment offices, etc.) when such communication is necessary or functional to the performance of the our activity according to the methods and purposes indicated above;
• Banking institutions for the management of receipts and payments deriving from the fulfilment of contracts.

5. Identification details of the Data Controller

The Data Controller is Intelsis Srl, with registered office in Via del Cottanello, 13, Rome 00158, Italy, VAT No. 14570261009 and Rome Companies Register No. 1530908, in the person of its Legal Representative, who can be contacted via e-mail at: info@topnotch.it

6. Data retention period

The personal data collected will be processed by the Data Controller for the minimum time strictly necessary to achieve the indicated purposes of the processing, that is until the conclusion of the existing contractual relationships, except for any further retention period which may be imposed by legal obligations.

7. Rights of the Data Subject

Articles 15 et seq. of the GDPR provide for the exercise of specific rights to obtain:

• Confirmation as to whether or not your personal data is being processed, and, where that is the case, access to the personal data and information on the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the data have been or will be communicated, and the data retention period;
• Rectification of inaccurate personal data concerning the Data Subject, completion of incomplete personal data and integration of supplementary declarations;
• Erasure of the personal data as per the cases provided for by the GDPR;
• Limitation of the processing of the personal data as per the cases provided for by applicable legislation;
• Portability of the personal data, a copy of the personal data of the Data Subject provided to the Data Controller and direct transmission of the data to another data controller;
• Opposition to the processing of personal data concerning the Data Subject at any time for reasons relating to a particular circumstance, as per applicable privacy law.

Such rights may be exercised by contacting the following e-mail address with an attached copy of an identity document: privacy@topnotch.it

8. Complaints

If you believe that the processing of your data is contrary to applicable privacy legislation, you may, at any time, lodge a complaint with the competent authority (the Guarantor for the Protection of Personal Data), as per Article 77 of the GDPR.