Business information privacy policy

Information on the Processing of Personal Data for Commercial Information Purposes

The full ANCIC Privacy Notice is available at the following link: Informativa Privacy A.N.C.I.C. - Home

DATA CONTROLLER: ModeFinance S.r.l. – Building H – AREA Science Park, Padriciano 99 – 34149, Trieste (TS) – ITALIA, P. IVA 01168840328.

DATA PROTECION OFFICER (DPO): The DPO may be contacted at the email address dpo@teamsystem.com or at the registered office of the parent company TeamSystem S.p.A., Via Sandro Pertini 88 – 61121 Pesaro (Italy).

This Privacy Notice is provided by ModeFinance S.r.l., as Data Controller, pursuant to privacy legislation (Article 14 of Regulation (EU) 679/2016 – “GDPR”), in accordance with the Code of Conduct for the Processing of Personal Data for Commercial Information purposes, adopted by the Italian Data Protection Authority with Provision No. 181 of 29 April 2021 and subsequent Resolution No. 127 of 12 June 2019 (hereinafter also the “Code of Conduct”).

1. SOURCES OF PERSONAL DATA

Pursuant to Article 14 of Regulation (EU) No. 679/2016 (“GDPR”), ModeFinance S.r.l., as Data Controller (“Controller”), informs data subjects that, under a specific licence and prefectural authorisation (pursuant to Article 134 of the Consolidated Public Security Act – T.U.L.P.S.), it collects and processes personal data relating to the registered subject and to other persons possibly connected to that subject from a legal and/or economic perspective. Such data are obtained from public registers, lists, archives or public records (held, for example, by Chambers of Commerce or the Italian Revenue Agency) or from sources that are generally accessible to the public (such as professional registers, press reports and publicly accessible websites) (the “Data”).These Data may also be obtained through other commercial information providers.

2. CATEGORIES OF DATA PROCESSED

For commercial information purposes (as defined in Article 2(c) of the Code of Conduct), ModeFinance S.r.l. may acquire both information relating to organisational, production, industrial, commercial, economic, financial, asset-related, judicial, administrative and accounting aspects of the activities carried out by economic operators (such as sole traders, family businesses, small entrepreneurs, professionals, key company officers, etc.) and data relating to natural persons who do not carry out a business or professional activity, where such persons are legally and/or economically connected to the registered subject. ommercial information may also include data relating to, by way of example, company registry extracts, financial statements, protests, insolvency proceedings, liens and encumbrances, land registry and cadastral data, as well as any judicial data reported in public or generally accessible sources. In the cases expressly provided for by the Code of Conduct, ModeFinance S.r.l. may process data relating to criminal convictions and offences (Article 10 GDPR) originating from public sources or, in certain circumstances, from generally accessible sources, as defined in the Code of Conduct.

3. PURPOSE OF PROCESSING

The Data are processed by ModeFinance S.r.l. in order to provide its clients (commissioning parties) with processed commercial information through statistical processes or automated models, including analyses and assessments carried out by ModeFinance S.r.l.’s financial experts and/or based on predefined classifications. The purpose is to formulate an assessment of the soundness, solvency and reliability of a legal or natural person (registered subject), which may be expressed in predictive or probabilistic terms or in the form of alphanumeric indicators, codes or symbols. Such assessments are used to evaluate the economic, financial and commercial capacity of a natural or legal person, to carry out checks in the context of existing or prospective commercial relationships, and to safeguard the related rights.

4. LEGAL BASIS FOR PROCESSING

The processing of Data for the above-mentioned commercial information purposes, including the formulation of assessments regarding the soundness, solvency and reliability of the registered subject, is based on the pursuit of the legitimate interests of ModeFinance S.r.l., as a provider of commercial information services and commissioning clients requesting such services. These legitimate interests include conducting due diligence on the economic, financial and asset position of data subjects, for protective purposes, prior to and during the establishment and management of commercial relationships (including pre-contractual relationships), the supply of goods and services, the determination of payment terms, compliance with applicable legal obligations (including anti-money laundering legislation), fraud prevention, and the protection of related rights, including in judicial proceedings.

5. METHODS OF PROCESSING AND DATA SECURITY

ModeFinance S.r.l. collects personal data from public or generally accessible sources in compliance with the forms and limits established by applicable legislation governing the accessibility, usability and publicity of such records. Data collection is carried out using IT tools and, following appropriate checks (including automated checks) aimed at ensuring accuracy, completeness and consistency, the Data are stored in our databases and periodically updated. These databases are organised and managed through IT procedures necessary to communicate documents containing data extracted from public sources to our clients (including electronically), as well as to analyse, compare and process such data for the preparation of economic or commercial information reports and dossiers. Personal data are safeguarded by appropriate technical, organisational, physical and procedural security measures, including pseudonymisation and, where applicable, encryption, in order to prevent direct intelligibility or identification of data subjects. Data may be accessed only by duly authorised personnel and by persons entrusted with data collection, analysis, processing, communication, report drafting, and technical maintenance of IT systems. In any case, processing is carried out in accordance with the principles of lawfulness, fairness and relevance pursuant to Article 5(1)(a), (b), (c), (d) and (f) GDPR, and in compliance with Article 32 GDPR.

6. DATA DISCLOSURE AND TRANSFERS TO THIRD COUNTRIES

Personal data collected from public sources and processed for commercial information services are disclosed by ModeFinance S.r.l., including electronically, to its clients in accordance with public security legislation (T.U.L.P.S.) and subsequent amendments. Data may also be shared with authorised individuals pursuant to Article 29 GDPR (e.g. employees, system administrators); service providers acting as data processors pursuant to Article 28 GDPR (e.g. IT, technical, administrative service providers and consultants); clients established in Italy or abroad, acting as independent data controllers; public authorities or entities where disclosure is required by law or by order of an authority. Where disclosure to clients involves transfers of Data outside the European Economic Area, ModeFinance S.r.l. shall ensure compliance with Chapter V GDPR, in particular through:

• transfers to countries deemed adequate by the European Commission;

• the execution of Standard Contractual Clauses.

In carrying out such transfers, the Controller shall also take into account relevant national and EU case law and the recommendations of the European Data Protection Board.

7. DATA RETENTION

Data shall be retained only for the period necessary to fulfil the purposes for which they were collected, in compliance with the principle of data minimisation under Article 5(1)(c) GDPR and within the time limits established by the Code of Conduct.In particular, personal data obtained from public or publicly accessible sources shall be retained for as long as they remain accessible and/or published in the relevant sources, in accordance with applicable legislation.

The requirements set out in Article 8 of the Code of Conduct shall be complied with, pursuant to which:

(a) information relating to bankruptcy or insolvency proceedings shall be processed for a period not exceeding 10 years from the date on which the bankruptcy or insolvency proceedings are opened. Upon expiry of this period, such information may be further processed by the Data Controller only where additional information relating to a subsequent bankruptcy is available or where a new bankruptcy or insolvency procedure has been initiated in respect of the registered subject or another connected subject; in such cases, processing may continue for a maximum period of 10 years from the respective opening dates;

(b) information relating to adverse events and land registry records (including mortgages and enforcement actions) shall be retained for a period not exceeding 10 years from the date of registration or recording thereof, unless such records are cancelled prior to the expiry of that period, in which case a record of the cancellation shall be retained for a period of 2 years.

Further information is available from the Data Controller.

8. DATA SUBJECTS’ RIGHTS

The data subject may exercise, at any time, the rights granted under applicable legislation, including: (i) the right of access, in order to ascertain whether and which personal data are being processed by ModeFinance S.r.l.; (ii) the right to rectification and updating of inaccurate or incomplete data;(iii) the right to erasure of personal data in the cases provided for under Article 17 GDPR; (iv) the right to restriction of processing where the conditions set out in Article 18 GDPR are met; (v) the right to obtain notification from ModeFinance S.r.l. of any rectification, erasure or restriction of processing carried out in relation to recipients to whom the data have been disclosed; and (vi) the right to lodge a complaint with the competent Data Protection Authority. The data subject may exercise the right to object to the processing of commercial information by ModeFinance S.r.l. where, pursuant to Article 21(1) GDPR, he or she demonstrates that his or her interests, rights and freedoms override the legitimate interests of the Data Controller. The right to data portability (Article 20 GDPR) shall not apply, except where the processing by ModeFinance S.r.l. of data collected directly from the data subject is carried out by automated means and is necessary for the performance of a contract between ModeFinance S.r.l. and the data subject. The exercise of data subject rights is subject to the condition that the relevant request does not concern the rectification or supplementation of personal data of an evaluative nature processed by ModeFinance S.r.l., including assessments, opinions or other subjective appraisals, or indications of conduct to be adopted or decisions that ModeFinance S.r.l. intends to take.

Through the portal www.informativaprivacyancic.it and the dedicated section therein, each data subject may submit an initial request to ModeFinance S.r.l. in order to obtain confirmation as to whether personal data relating to him or her are held in ModeFinance S.r.l.’s archives or databases. Where applicable, the data subject may then contact ModeFinance S.r.l. directly, using the contact details provided below, in order to exercise the other rights referred to above.

Without prejudice to the option of using the portal www.informativaprivacyancic.it, the data subject may submit a request by writing to dpo@teamsystem.com, or to ModeFinance S.r.l. Building H, AREA Science Park, Padriciano 99 – 34149 Trieste (TS), Italy, or to the registered office of the parent company TeamSystem S.p.A., Via Sandro Pertini 88 – 61121 Pesaro, Italy.

The data subject may also lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) by following the instructions available at the following link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.

Last update: 29/01/2026