In accordance with art. 13 of Regulation (EU) 2016/679
(General Regulation for the Protection of Data)
FD Fiduciaria Digitale S.r.l. and Visabit S.r.l are strongly innovative companies working together to offer their services through state-of-the-art technologies and significant computerisation. FD Fiduciaria Digitale S.r.l. and Visabit S.r.l walk have embarked on a game-changing path in trust mandate management with the service called “Fiduciaria Digitale” and have developed this service including a vast range of other functions with high added value to support clients in many aspects of their lives and their technological and multimedia experience. For activation and subsequent management of the trust mandate, FD Fiduciaria Digitale S.r.l. operates as the Trust company authorised by the Ministry of Economic Development and Visabit S.r.l takes care of the technological framework supporting the “Fiduciaria Digitale” service.
In order to begin using the “Fiduciaria Digitale” service, FD Fiduciaria Digitale S.r.l. clients must first register on this website by supplying various items of information (mainly personal identification and contact details) that are strictly necessary to complete the registration phase and begin communication with the above-mentioned companies. Please note that registration to the “Fiduciaria Digitale” website is open only to adults who are resident in Italy.
- Once registration on the website has been successfully concluded, once the client has consented to providing the requested personal data and has passed the preliminary checks, the client can proceed to the identification phase required by the regulations in force for the prevention of the use of the financial system for the purpose of money laundering. During this second phase we will collect further personal and contact details regarding the client and we will automatically verify the client’s geographical position through the device. The identity card (or passport), the health insurance card bearing the tax code or Carta Regionale dei Servizi (CRS, Regional Services Card) are also scanned.
- Once the identification phase is successfully completed, the client accesses the third phase in the process of joining the “Fiduciaria Digitale” service. This phase includes the suitable verification required by regulations for the prevention of use of the financial system for the purpose of money laundering. This phase can be activated and managed only if the client consents to the processing of his or her personal data through the video call system. In other words, the state-of-the-art service that allows client and Trust company to carry out and document proper verification and to manage it remotely.
- Having passed the phases described above, the client is effectively authorised to use the “Fiduciaria Digitale” service and can then access the advanced electronic signature service offered by FD Fiduciaria Digitale S.r.l. and supported by Visabit S.r.l. and begin signing mandates and other services offered by FD Fiduciaria Digitale S.r.l.
As already stated in the premise, the “Fiduciaria Digitale” service uses FD Fiduciaria Digitale S.r.l.’s products, but also grants the client exclusive access to a vast range of services that will be directly or indirectly provided by Visabit S.r.l. and eventually defined on the basis of one or more contracts that from time to time will be offered to the client to sign.
Therefore, with reference to the processing of personal data concerning the client’s contracts that require activation by the FD Fiduciaria Digitale S.r.l. “Fiduciaria Digitale” service, and all the other services that will then be provided by Visabit S.r.l., the two companies have prepared this notice in accordance with Regulation (EU) 2016/679 (hereinafter “Regulation”). The processing of personal data inherent in the processing of the advanced personal signature and the trust mandates is further described in the specific notices that will subsequently be submitted to the client.
At the end of this notice the client will be asked to express formal consent for the processing of all personal data, data regarding health and further specific categories of personal data that will be required by FD Fiduciaria Digitale S.r.l. and Visabit S.r.l. Granting consent to the processes described in this document as described in their entirety is indispensable to begin the registration process.
FD Fiduciaria Digitale S.r.l. and Visabit S.r.l. will process Your personal data only for the processes that concern them specifically and as independent Data Controllers in accordance with art. 4 clause no. 7 of the Regulation and in compliance with the Regulation, the implementation measures and, in particular, with the principles of correctness, lawfulness and transparency and the protection of confidentiality.
Purposes of Processing
The personal data you provide upon activation of the “Fiduciaria Digitale” service as described in all its phases above or in any subsequent activation of said service will be processed by FD Fiduciaria Digitale S.r.l. for:
- purposes strictly connected to the activation and subsequent execution of duties deriving from the contractual relationship or to carry out pre-contract activities (for example, acquisition of preliminary information at the conclusion of a contract with you, execution of tasks as per contract concluded with you, carrying out your specific requests);
- purposes connected to fulfilment of obligations deriving from laws or regulations, EU policy, as well as provisions from authorities empowered by law and monitoring and auditing authorities (e.g., regulations against money laundering and financing of terrorism, etc.)
Visabit S.r.l. can have access to the above personal data as the provider of highly technological services that are expressly identified and authorised by FD Fiduciaria Digitale S.r.l. as Data Processor, in accordance with art.28 of the Regulation.
Your personal and other specific category of data or in any case related to you that you will provide to Visabit S.r.l. or that they may otherwise collect in the provision of a different service will also be processed by Visabit S.r.l. for the purposes listed below:
- provision of services expressly requested by you through signing one or more specific contracts
- provision of services inseparably linked to the provision of services expressly requested by the client as per item above.
Types of data processed
The processing involves personal data and specific categories of data; of these, images taken during the video call, whereby the drawing of information concerning the state of health of the client cannot be ruled out, are also considered personal data.
Recipients or categories of recipients
In compliance with fiduciary secrecy and applicable regulations, the achievement of the purposes in question can also occur by means of transmission and communication of personal data to third parties, meaning third parties authorised for the processing of said data to implement specific services that are strictly functional for the execution of the contractual relationship such as:
- parent, subsidiary or associated companies in accordance with art. 2359 of the Italian Civil Code, companies subject to common audit, as well as consortiums, company networks and groups and temporary associations of companies with their members for administrative accounting purposes;
- subjects that carry out activities that are instrumental or connected to the technical and administrative management activities of the relationship with you;
- members of auditing bodies;
- subjects that carry out banking, financial, insurance and investment services;
- subjects that manage national and international audit systems for fraud against Trust companies, banks, financial intermediaries and financial subjects;
- administrative and judiciary authorities;
- auditing companies and other subjects that carry out consulting.
A detailed list of these companies is available at the offices of the Data Controllers, each for the processes of their respective competence.
Your personal data is not subject to distribution, meaning that knowledge of your personal data will not be circulated to indeterminate subjects.
The personal data subject to processing gathered during activation of the “Fiduciaria Digitale” service will be stored in accordance with accounting records storage obligations and with the prudential storage requirements of contractual, tax and administrative documentation specifically required by the trust relationship and all services relating to it.
The personal data subject to processing that Visabit S.r.l. will collect or of which it will otherwise be aware during provision of the value-added services will be stored according for the time required by accounting records storage obligations and the storage requirements specified in contractual, tax and administrative documentation as per further specific contracts that are agreed between the parties.
From time to time, depending on the services that the Data Controllers are able to provide, they reserve the right as of now of identifying a legitimate interest to proceed with further processing in accordance with art. 6, letter f of the Regulation.
Some types of data such as images of documents, some forms of collected information, the recording of video calls will also be stored, in compliance with the provisions concerning digital storage, at qualified suppliers.
You have the right to access your personal data from each of the Data Controllers – autonomously and independently – and ask for the amendment or deletion of the same or request limits in their processing, or oppose their processing, as well as limit their portability. In addition, you have the right to make a complaint with a Supervisory Authority.
These rights, defined in detail in art. 15 and following of the Regulation, can be exercised in writing to the Data Controllers for their respective activities as explained above, by writing to:
- FD Fiduciaria Digitale S.r.l., Via Alfredo Piatti, 17 – 24125 Bergamo (BG), Italy;
- Visabit S.r.l., Via Alfredo Piatti 15/17 – 24125 Bergamo (BG), Italy.
Consequence of refusal to provide the data
Providing personal and other categories of data defined as mandatory in the registration from and the collection of data during use of the “Fiduciaria Digitale” service are strictly necessary to use the “Fiduciaria Digitale” service, depending on the type of data, the strict necessity may be tied to legal obligations or other normative or regulatory acts, or to specific requests by FD Fiduciaria Digitale S.r.l. and Visabit S.r.l. for the services provided. Failure to consent prevents the use of any service.
Methods of processing
FD Fiduciaria Digitale S.r.l. and Visabit S.r.l inform you that they will process the personal data through manual processing, telematic and computer tools, strictly for the purposes defined and, in any case, in a manner as to guarantee the security and confidentiality of said data.
Having read this notice, I declare that I have been informed and that I grant consent for my personal and other specific categories of data to be processed for the respective competence but in a manner inseparably linked between them and connected to the provision of the services that I requested or will request in the future, as long as the methods guarantee their security and confidentiality by:
FD Fiduciaria Digitale S.r.l. for:
- purposes strictly related to the activation and subsequent execution of the obligations deriving from the contractual relationship or the achievement of the pre-contract activities (for example, acquisition of preliminary information to the conclusion of the contract with you, execution of the operations on the basis of the obligations deriving from the contract concluded with you, execution of your specific requests.;
- purposes connected to the obligations deriving from laws and regulations, from EU policy, as well as the provisions issued by legal authorities and monitoring and audit authorities (for example, regulations to combat money laundering and the financing of terrorism, etc.).
Visabit S.r.l. for:
- provision of services expressly requested by you through subscription to one or more specific contracts;
- provision of services inseparably related to the provision of services expressly requested by the client as per the above item).