The company KEMPER SRL, based in via PONTE ROSSO, snc, 25020 DELLO (BS), Fiscal Code 03417030172 and VAT number 02107240984, (hereafter, “Data Controller”), as data controller, informs you pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR”) that it bases the processing of data on the principles of correctness, lawfulness, transparency and necessity, as required by the aforementioned regulations and that your data will be processed in the manner and for the following purposes:

1. Object of the processing

The Data Controller processes personal data, identifying and non-sensitive data (specifically, name, surname, tax code, VAT number, email address, telephone number – hereafter, “personal data” or even “data” that you have communicated:

– when registering on the website of the Data Controller.

– upon registering for the newsletter service offered by the Data Controller.

– when the Data Controller responds to the request for information from users / subscribers of the site.

2. Purpose of the Processing

Your data are processed:

A) without your express consent [Article 6 letter b) and e) of the GDPR], for the following Service Purposes:
– close the contracts for the goods / services of the Data Controller.

– fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you.

– allow you to register on the website of the Data Controller.

– answer to your questions posed by means of the form to be filled out on the website of the Data Controller.

– manage and maintain the website of the Data Controller.

– allow you to subscribe to the newsletter service provided by the Data Controller and any additional Services you may have requested.

– fulfill the obligations established by the Law, by a regulation, by the Community legislation or by an order of the Authority (such as for Anti-Money Laundering)

– exercise the rights of the Data Controller, for example the right to defense in court.

B) Only in the case of prior specific and distinct consent (Article 7 GDPR), for the following Marketing Purposes:

– Sending by via e-mail, and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material about products or services offered by the Data Controller and survey of the degree of satisfaction on the quality of goods / services.

3. Processing Modalities

The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data.

Your personal data are subjected to both paper and electronic and / or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the previous purposes and in any case for no more than 10 years from the termination of the relationship for the Service Purposes and for no more than 3 years from the collection of data for the Marketing Purposes.

4. Access to Data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B) of this information:

- to employees and collaborators of the Data Controller, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;

- to third-party companies or other subjects (providers for the management and maintenance of the website, suppliers, credit institutions, professional firms) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors.

5. Communication of Data

Without the need for your express consent (Article 6 letter b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the accomplishment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disseminated.

6. Data Transfer

The management and storage of personal data will take place on servers located within the European Union of the Data Controller and / or third-party companies appointed and duly appointed as Data Processors. The data will not be transferred outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the location of the servers to Italy and / or the European Union and / or non-EU countries. In this case, the Data Controller ensures from now on that the transfer of non-EU data will take place in compliance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for by European Commission.

7. Nature of the provision of data and consequences of refusal to reply

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we will not be able to guarantee you neither the registration on the site nor the services of art. 2.A).

The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Data Controller or any business partner. In any case, you will continue to be entitled to the Services referred to in art. 2.A).

8. Rights of the data subject

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

i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered and their communication in an intelligible form;

ii. obtain the indication: a) of the origin of the personal data; b) the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) the identity of the owner, manager and the representative appointed pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents;

iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data which need not be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;

iv. 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 email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right of opposition also only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

Where applicable, it also has the rights referred to in Articles. 16-21 GDPR (Right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. How to exercise rights

You can exercise your rights at any time by sending:

- a registered letter with return receipt to KEMPER SRL, via PONTE ROSSO, snc, 25020 DELLO (BS)

- an e-mail to the address: privacy@kemper.it 

10. Data Controller, Data Processor and people appointed

The Data Controller is KEMPER SRL, based in via PONTE ROSSO, snc, 25020 DELLO (BS), Fiscal Code 03417030172 and VAT number 02107240984.

The updated list of data processors and persons in charge of processing is kept at the headquarters of the Data Controller.


The company KEMPER SRL, based in via PONTE ROSSO, snc, 25020 DELLO (BS), Fiscal Code 03417030172 and VAT number 02107240984 (hereafter, “Data Controller”), as data controller, informs you pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the purposes described:
1. Object of the processing
The Data Controller processes personal data, identifying and non-sensitive data (specifically, name, surname, tax code, VAT number, email address, telephone number - hereafter, "personal data" or even "data" that you have communicated;
- at the conclusion of contracts for the goods / services of the Data Controller.
2. Purpose of the Processing
Your data are processed:

A) without your express consent [Article 6 letter b) and e) of the GDPR], for the following Service Purposes:

- close the contracts for the goods / services of the Data Controller;
- fulfillment of pre-contractual and contractual obligations set forth by any relevant agreement; 

- fulfill the obligations established by the Law, by a regulation, by the Community legislation or by an order of the Authority (such as for Anti-Money Laundering) 
- exercise the rights of the Data Controller, for example the right to defense in court.
B) Only in the case of prior specific and distinct consent (Article 7 GDPR), for the following Marketing Purposes:
- Sending by via e-mail, and / or sms and / or telephone contacts, newsletters, commercial communications and / or advertising material about products or services offered by the Data Controller and survey of the degree of satisfaction on the quality of goods / services

3. Processing Modalities

The data processing shall be conducted pursuant to art. 4 n.2) of GDPR, through the following operations: collection, recording, mining, comparison, use, exchange, blocking, communication, cancellation and destruction of data. 
Your data will be subject to a paper and electric/automated processing. 
Your data will be retained for a period appropriate for the purpose of the processing, and in any case not longer than 10 years starting from the termination of the relationship for the purposes of service and for no more than 3 years from the collection of data for the purposes of marketing, in the case of prior consent.


4. Access to Data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B) of this information note:
- to employees and collaborators of the Data Controller or of the Group companies of which the Controller belongs, in their capacity as people appointed and / or internal managers of the processing and / or system administrators;
- to Group companies of which the Data Controller is a part (for example, for supporting activities in the production of goods / services, for logistics management activities, for storage of personal data, etc.) or for third-party companies or other subjects (for example, providers for the management and maintenance of the website, suppliers, lenders, professional offices, etc) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external processors.

5. Communication of Data

Without the need for your express consent (pursuant to Article 6 letter b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to art. 2.A) to Supervisory Bodies, Judicial Authorities and to all the other subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers. Your information will not be disclosed

6. Data Transfer

The management and storage of personal data will be carried out on servers located within the European Union. 
The servers are located at the data controller, or at third-party companies appointed appointed as data processors.
Currently the servers are located in Italy, at the company headquarters.
The data will not be transferred outside to the European Union. In any case, it is understood that the Data Controller, where necessary, will have the right to move the server location to Italy and / or the European Union and / or non-EU countries.
The Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for European Commission.

7. Nature of the provision of data and consequences of refusal to reply

The provision of data for the purposes referred to art. 2.A) is mandatory. In their absence, we can not guarantee you neither the registration to the site nor the services of the art. 2.A).
The provision of data for the purposes referred to art. 2.B) is optional.
You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. In any case, you will continue to be entitled to the Services referred to art. 2.A)

8. Rights of the data subject

In your capacity as an interested party, you have the rights referred to in art. 15 GDPR and precisely the rights of: 
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered and their communication in an intelligible form;
ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the data controller, the data processors managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, data processors or appointed;
iii. obtain: a) updating, rectification or, when interested, integration of data; b) cancellation in accordance with the law, which are not necessary or processed; c) the attestation that the operations referred to in subparagraphs a) and b) have been gathered knowledge, also with regard to their content, of which the data
have been communicated;
iv. to 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 email and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially.
Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Where applicable, it also has the rights referred to Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. How to exercise rights

You can exercise your rights at any time by sending:
- a registered letter to KEMPER SRL, via PONTE ROSSO, snc, 25020 DELLO (BS)
- an e-mail to the address: privacy@kemper.it 

10. Data Controller, Data Processor and people appointed
The Data Controller is KEMPER SRL, based in via PONTE ROSSO, snc, 25020 DELLO (BS), Fiscal Code 03417030172 and VAT number 02107240984.
The updated list of data processors and people appointed is at the Data Controller's headquarters.