Privacy disclaimer


 This privacy policy statement is provided to inform you in advance as to the use of the data concerning you and to be able to give your free, informed and aware consent to several processing activities and communications of personal data, in accordance with Legislative Decree 196 dated 30 June 2003, containing provisions for the protection of the processing of personal data of people and of other subjects, supplemented by EU regulation 2016/679 dated 27 April 2016 (jointly “General Data Protection Regulation”). To this end, Eudaimon S.p.a. ("Eudaimon" or "Data Controller") provides you, in your capacity as user (“User”) of the welfare services provided by Eudaimon ("Welfare Services”), with the privacy policy statement required by law and asks you to give your consent to the processing and to the communications connected with the operations requested. 


1. Data Controller and Supervisor. 

The Data controller is Eudaimon with registered office and head office in Vercelli, Piazza Pajetta n.2,  Postal Code 13100. Eudaimon has appointed a person as data supervisor (e-mail internally, who has adopted all the measures deemed necessary and appropriate for adequate Data protection.

2. Purposes and methods of processing and legal basis

The personal data (“Data”), including several sensitive data, as specified and defined below, are processed by Eudaimon for purposes which are exclusively related to providing the Welfare Services, namely for purposes related to obligations imposed by laws, regulations and EU legislation (e.g. obligations imposed by the Supervisory Authorities). Several Welfare Services imply the acquisition by the Controller of health-related data (“Sensitive data”). The processing activities occur manually or with electronic tools or in any case automated tools, according to logics strictly related to the purposes for which the data are provided and, in any case, in a way that guarantees confidentiality and security. The consent which the User gives at the bottom of this privacy policy statement is the legal basis of the Data processing activity performed by Eudaimon.

3. Transfer of Data and Sensitive Data abroad - purposes

The Data and Sensitive Data can be lodged with and/or transferred to third party subjects residing in non-EU countries, whose legislation on the matter of personal data protection has been recognised as suitable by the European Commission, for exclusive purposes of gathering, processing, archiving and storage activities. It is also specified that Eudaimon S.p.a. has stipulated agreements with several of these third party subjects which contain specific contractual clauses to guarantee the transfer of personal data to third countries, approved by the European Commission and confirmed by the Personal data protection authority. The list of these third party subjects residing in non-EU countries is constantly updated and you can have knowledge of this easily and free of charge by presenting a request to the e-mail address set out in paragraph 1.

4. Categories of subjects to whom the data can be communicated

Eudaimon avails of trusted third parties to provide the Welfare Services. The list of aforementioned subjects is constantly updated and you can have knowledge of this easily and free of charge by presenting a request to the e-mail address set out in paragraph 1. The Data, including Sensitive Data, held by Eudaimon can be communicated, exclusively in relation to the processing purposes set out above:

(i) to subjects who can access them by virtue of legal provisions, regulation or EU legislation, within the limits provided for by such rules; 
(ii) to Eudaimon personnel, as long as they are qualified as supervisor or person in charge of the processing activity, or, as system administrator; 
(iii) to third parties, whom Eudaimon avails of for the purpose of providing Welfare Services and who operate as distinct data controllers or as external supervisors of the processing activity, appointed by Eudaimon; 
(iv) to banking or financial intermediaries, to implement the provisions issued and regulate the considerations referred to the Welfare Services; 
(v) to the employer, in the fulfilment of regulations pertaining to the law, tax and contributions, to credit and debit the pay check, if provided for by the Welfare Services and for statistical purposes to evaluate the Welfare Services; 

The Data processed by Eudaimon are not the subject matter of any other disclosure to third parties, without prejudice to the communications to the subjects listed above.

5. Period of data storage

The Data shall be stored until you remain User of the Welfare Services and will be definitively cancelled within 15 days from the termination of said status, with the exception of those which must be stored for a set period of time, according to the current legislation.

6. Rights of the interested party.

In relation to the processing of Data, the User, as interested party, according to the GDPR (General Data Protection Regulation) shall have the right:
(i) to ask the Data controller for access to the Data and correction or cancellation of the same or to limit the processing of data concerning him or to oppose their processing;
(ii) to data portability;
(iii) to withdraw his consent at any time, without compromising the lawfulness of the processing activity based on the consent given before the withdrawal;
(iv) to update and correct Data related to him;
(v) to request full cancellation of all the Data, exercising the right to withdraw from the service requested;
(vi) to lodge a complaint with the Personal data protection authority. Exercising one’s rights provided for by this paragraph can be done by the interested party by sending a registered letter with notice of receipt to the address of the Data Controller.

7. Consequences of failure to provide Data and failure to consent to the processing of them

The provision of Data is compulsory, in that failure to communicate them or rather the withdrawal of consent makes it impossible to access the provision of the Welfare Services.