Information to Customers pursuant to art. 13 of EU Regulation 2016/679 

Reference Regulations:

  • EU Regulation n. 679 of 27 April 2016 relating to the protection of individuals with regard to the processing of personal data, as well as the free movement of personal data (hereinafter "EU Regulation")
  • Legislative Decree n. 196 of 30 June 2003 (hereafter "Privacy Code"), as amended by Legislative Decree no. 101 of 10 August 2018


ICOS S.p.A. (hereinafter "the Company"), with registered office in Via Monsignor L. Maverna, 4 - 44122 Ferrara, VAT no. 01031270380, informs that personal data will be processed in compliance with the legislation dictated by the EU Regulation.

The processing of personal data relating to legal persons does not fall within the scope of the discipline of protection of personal data prepared by the EU Regulation 2016/679. For the purpose of clarity and transparency towards its Customers, the Company also makes this information available to legal entities, describing the methods and purposes of all the treatments that it carries out or has the right to carry out on the personal data of the interested parties such as defined below.

The Company acts as "Data Controller"; It is the Data Controller who processes personal data, establishing the purposes and methods of processing personal data.

Specifically, the processing of the personal data of the "interested parties" may be carried out by subjects specifically authorized by the Company to carry out processing operations.

This information concerns the "interested parties", by which is meant the natural persons to whom the personal data refer, or all those subjects who operate in the name and on behalf of the legal entity Customer of the Company and whose personal data are processed by the same .

Purpose and legal basis for the processing of personal data

The collection and processing of personal data by the Company takes place for the purposes indicated below:

  1. the execution of pre-contractual activities and the acquisition of preliminary information for the conclusion of the contract;
  2. the execution of contractual obligations (for example: administration, accounting, contract management, billing / payments services);
  3. the management of relations between the Customer and the Company (for example, the management of disputes, or of credits deriving from a contract and / or collateral acts, factoring).In relation to the aforementioned purposes, the processing is carried out to fulfill the contractual / pre-contractual obligations and the legal obligations related to the relationship established with the Company; consequently consent to the treatment is not necessary.

It should also be noted that the personal data collected could be used for marketing and commercial promotion purposes in reason and within the limits of what is allowed by art. 130 paragraph 4 of the Privacy Code, as amended by Legislative Decree 101/2018, with regard to the so-called "Soft spam"; therefore, without having to acquire the prior consent of the interested parties, the Company may use the e-mail coordinates provided in the context of a previous sale for the purpose of direct sale of further products or services, provided that these are products and services similar to those object of the previous sale. It should be noted that the interested parties may object, at any time, to the aforementioned treatment by writing to the e-mail address of the Company, as identified in point 5 of this information.

Nature of the provision of personal data

The provision of personal data is mandatory for those personal data in relation to which there is a legal or contractual obligation to provide the same; likewise, the provision of personal data necessary for pre-contractual obligations is mandatory. Any refusal to provide such "mandatory" personal data could result in non-contractual performance. Any refusal to provide personal data strictly functional to the execution of contractual relationships, but for which there is no obligation to provide, will in principle not have any consequence, if not the possible impossibility of following up on the related operations to such personal data or the impossibility of establishing new relationships.

Processing methods and storage time of personal data

The processing of personal data will be carried out in a lawful and correct manner and in any case in accordance with the applicable legislation, by means of suitable tools to guarantee the security and confidentiality of the personal data; the processing of personal data will be mainly carried out through IT tools in order to store, manage and transmit the data.

The processing of personal data will be carried out, primarily, by company personnel specifically authorized and instructed by the Company regarding the performance of processing operations.

With reference to the further subjects that could process the personal data of the interested subjects, please refer to point 4 of this information.

The storage of personal data will take place in a form that allows the identification of the interested parties for a period of time not exceeding that necessary to pursue the purposes for which the data are collected and processed.

In particular in relation to the management of the contractual relationship, personal data will be kept for the times defined by the reference legislation as well as, upon the termination of the contractual relationship, for the ten-year term for the conservation of only data of a civil nature.

In relation to the completion of a processing operation connected to the so-called "Soft spam", the personal data collected will be kept for the time strictly necessary for the management of the aforementioned purposes according to criteria based on compliance with current regulations and correctness as well as the balance between the legitimate interest of the Company and the rights and freedoms of the subjects concerned . Consequently, in the absence of specific rules that provide for different storage times, the Company will take care to use personal data for the aforementioned marketing and commercial promotion purposes for a time that is congruous with respect to the interest shown by the parties concerned in the products and services of the Company itself.

In any case, the Company will take every care to avoid the use of personal data indefinitely, proceeding periodically to adequately verify the effective persistence of the interest in having the treatment carried out for marketing and commercial promotion purposes.

Recipients of personal data

In relation to the personal data of the subjects concerned, the Company may make communications deriving from a legal obligation, regulation or community legislation. For the purposes referred to in point 1, let. a), b), c) of this information (i.e. for purposes related to the execution of the contract, pre-contractual measures and the management of relations between the Customer and the Company).

Communication, also by simply consulting or making available the personal data of the subjects concerned, can also intervene towards the following subjects:

  1. public bodies, supervisors, authorities or institutions;
  2. natural or legal persons who provide specific services, such as data processing, customer satisfaction surveys, administrative, tax and / or accounting consultants, organization of fairs and communication events;
  3. commercial intermediaries, banks and credit institutions, legal consultancy companies, financial intermediation companies, natural or legal persons responsible for credit recovery, auditing and / or certification of financial statements and quality systems, independent collaborators of the Company, agents and reporters , insurers and brokers;
  4. natural and / or legal persons who request references / data for the purpose of participating in public contracts, or in the context of the execution of supply contracts with customers by the Company.

The subjects referred to in points a), c), d) operate as independent Data Controllers.

The subjects referred to in point b) operate as Data Processors, specially appointed.

In any case, only the personal data necessary and relevant with respect to the purposes stated in this statement are transferred to the aforementioned subjects.

The list of these third parties will be constantly updated and accessible by the interested parties upon request to the Company.

If necessary for the execution of contractual relationships, personal data may be transferred to third countries not belonging to the European Union (EU) or to the European Economic Area (EEA) on the basis of the existence of adequacy decisions of the European Commission or on the basis of the adoption of model contractual clauses, duly adopted, or of specifically authorized binding corporate rules.

Personal data will not be disclosed and therefore will not be disclosed to the public or to an indefinite number of subjects.

Rights of the interested party pursuant to articles 15, 16, 17, 18, 20 and 21 of the EU Regulation

Each interested party can exercise the rights of access to personal data provided by art. 15 of the EU Regulation and the rights provided by the articles 16, 17, 18, 20 and 21 of the same Regulation regarding the rectification, cancellation, limitation of processing, portability of personal data, where applicable and opposition to the processing of personal data.

The aforementioned rights can be exercised by writing to the following address: This email address is being protected from spambots. You need JavaScript enabled to view it.

If the Company does not provide a response to the request from each interested party within the timeframe provided for by the legislation or the response to the exercise of rights is not suitable, the interested party itself may lodge a complaint with the Data Protection Authority.

Here are the contact details:

Italy's Data Pritection Authority

Website: -

E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

Who is ICOS

Value Added Distributor (VAD) offering channel partners a set of IT solutions and services designed to face successfully the most complex business challenges.

It delivers a full range of leading infrastructure and cybersecurity enterprise solutions, adding technical, marketing and training services.

ICOS S.p.A, Ferrara (Italy), Tel.: +39 0532 783411,email: - VAT N.: 01031270380 - Registerd Capital € 500.000,00 fully-paid.