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Privacy management system

reg. ue 679/2016


Extended information

(art. 13 - 14)

mod. inf

rev. 1 del 30.11.21

pag 1 


Brindisi - Via Thaon de Revel 33     I     Tel: +39 0831525165     I     Fax: +39 0831521833

P.I. e C.F:  00060540747    I    Capitale Sociale €  994.000,00 i.v.    I   R.E.A. n° 18338

Under sorvegliance of:


  1. Identity and Data Controller and Managers contact data

The Data Controller is IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL with registered office and headquarters in Via Amm. Paolo Thaon De Revel,33-72100 Brindisi.

The designation of the managers and of the people in charge of processing is supervised by the registered office of the Data Controller.

IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL, with registered office in Via Thaon de Revel,33-72100 Brindisi (BR), VAT number 00060540747, as Data Controller, wishes to inform you that your data will be handled in accordance with the art. 13 of the UE Regulation n 2016/679 (later on, “GDPR”) for the following purposes:

  1. Data collected

IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL processes personal data, identifying data (e.g., name, surname, business name, address, telephone number, e-mail)- hereinafter “personal data” or also “data”) communicated by you specifically for the conclusion of public and private contracts more specifically, but not exhaustively,

  • To guarantee the boarding and the transfer of passengers as required by the customer by virtue of a contract, in order to guarantee the transport and tow service.
  • Specifically for the end of job agreements between the parties (Employees’ selection and hiring).
  • Specifically for the end of supplying agreements between the parties.


  1. Purpose of data processing and legitimate interests

The data are used:

  • Without the express consent (Article 6 lettering b), e) GDPR), for the following service purposes:


-when the treatment is necessary in order to perform a contract, in which the interested party takes part, or in order to perform pre-contractual measures dictated at the request of themselves (personal data related to contracts or pre-contractual activities with clients, suppliers; employees data pending hiring or pre-hiring);

-namely in order to fulfil the obligations laid down in Community rules, in national law, in regulations in force or under an Authority order;

-lastly, in order to exercise the Data Controller’s rights, e.g., the right of defence in court;


  • With the express consent, in all other circumstances not previously specified.


  1. Personal data recipients and data communication


Your data can be made accessible for the purposes found in the art. 3 to employees and partners of the Data controller including outer partners, as appointees and/or managers of the data and/or System administrator.


Personal data collected on any terms by the company are typically entrusted to:

  • Labour consultant for the fulfilment of payrolls processing in tax matters
  • Administrative tax consultant in telematic transmission of 770 models and CU
  • Medical doctor in charge of supplying mandatory medical examinations in relation to occupational medicine
  • Internal representative of the management of human resources for the distribution to employees and the computerized filing of payrolls and for the employees’ management regarding administrative fulfilments (time off, sick leave, days of leave, etc)
  • Workers’ Protection and Security Service Manager in order to provide the service

 In the event of personal data of personal data of the passengers to be transported, the data can be transmitted to the following recipients:

  • Internal appointee who deals with the data needed in order to provide the service ( Master of the vessel)

Personal data are kept on servers located in the EU: in any case it’s still allowed for the Data Controller,               whenever necessary, to also relocate the servers outside the EU borders (extra EU).                                     In that case, the Data Controller ensures from now on that the relocation of data outside the EU borders will happen in compliance with the appliable legal provisions, subject to stipulation of the standard contractual clauses established by the European Commission.

Without the necessity for express consent art. 6 lit. b) and c) GDPR), the Data Controller can communicate Your data for the purposes explicit by the art. 3 to:

  • Supervisory bodies ( e.g. IVASS),Legal authorities, insurance companies in order to provide insurance services, as well as subjects, to which the communication is mandatory according to the law for the fulfilment of the said purposes. These subjects  will process the data in their capacity as autonomous data controllers.


  1. Methods of data processing and duration of retention


Your personal data processing is carried out by means of operations stated by the art. 4 n. 2) GDPR and precisely: collection, registration, organisation, conservation, consultation, processing, use, interconnection, block, communication, erasure and destruction of the data.

Your personal data are subject to both paper and electronic processing and partially automated.

The Data Controller will process personal data for the time necessary to fulfil the aforementioned purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes.


  1. Rights of the data subject

In your capacity as the interested party, you enjoy the rights referred to in art. 15 GDPR and precisely the rights of:

  • Obtain confirmation of the existence or lack thereof of personal data regarding you, even if you are not yet registered, and to receive their communication in an intelligible manner;
  • Obtain the indication: a) on the source of the personal data; b) on the purposes and methods of the processing; c) on the logic applied in case the data have been processed with the aid of electronic means; d)  on the identification details of the data controller, of the managers and of the appointed representative according to the art. 3, paragraph 1, GDPR; e) on the entities or categories of entity to which the personal data may be communicated or which may learn about said data in their capacity as designated representatives in the State’s territory, as managers or as appointees;
  • Obtain: a) the update of the data, the rectification or, whenever it is wished, supplementation; b)the deletion, the transformation into an anonymous form or the block of the data processed in breach of law, including the data which isn’t necessary keeping for the purposes for which the data has been collected or subsequently handled; c) evidence that operations a) and b) have been communicated, including the exact content, to those to whom the data were communicated or widespread, unless this requirement proves impossible or requires manifestly disproportionate measures with respect to the protected right;
  • Object, in whole or in part: a)for legitimate reasons to 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, through the use of automated call systems without the intervention of an operator by e-mail and/or by traditional marketing methods by telephone and/or paper mail. It should be noted that the interested party’s right to object, set out in the previous point b), for direct marketing purposes through automated methods it extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right to object even only partially. Therefore, the interested party can decide to receive communications only by using traditional methods or only by automated communications or neither of the two types of communication.
  • Rectify your personal data if they are modified and do not correspond to those previously acquired or communicated (art. 16)
  • Delete the data (“right to be forgotten” art.17)

IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL, whenever one of the following cases subsists, deletes the data from all databases and archives where it is contained:

  1. The data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. The interested party revokes the consent and if there is no other legal basis for the processing;
  3. The interested party opposes the processing pursuant to article 21, paragraph 1, and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21, paragraph 2;
  4. personal data have been unlawfully processed;
  5. Personal data must be deleted to fulfil a legal obligation under Union law or the law of the Member State to which the data controller is subject;
  • Restricting the processing (article 18). The interested party has the right to obtain the limitation of processing from the Data Controller when one of the following circumstances occurs:
  1. The interested party disputes the accuracy of personal data for the period of time necessary for the data manager to verify the accuracy of said personal data;
  2. The processing is unlawful and the interested party opposes the cancellation of personal data and requests instead that its use be limited;
  3. Although the data controller no longer needs it for the purposes of the processing, the personal data are necessary for the interested party to ascertain, exercise or defend a right in court;
  4. The data subject has objected to the processing pursuant to Article 21, paragraph 1, pending verification of the possible prevalence of the legitimate grounds of the data controller over those of the data subject.
  • Exercise the right to object (art. 21-22): The interested party has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him pursuant to article 6, paragraph 1, point e) or f),including profiling on the basis of those provisions. IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL does not subject the data to decisions based solely on automated processing.

IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL notifies each data subject of any correction, limitation or deletion of data.

IMPRESA FRATELLI BARRETTA DOMENICO E GIOVANNI SRL refrains from further processing personal data unless there are compelling legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defence of a right in court.

  1. Procedures for exercising your right


You can exercise your rights at any time by sending:


  1. Nature of the collection and consequences of the refusal to respond


The provision of data for the purposes referred to in art. 3. is mandatory. In their absence, we will not be able to guarantee the Services of art. 3.A

Since 1945