Privacy policy Synkrony Exchange

EXXE srl recognizes the importance of protecting personal information and undertakes to process it responsibly and in accordance with the applicable regulations for the protection of personal data in all countries where It works.
EXXE srl, with registered office in Viale Giovanni Milton, 53.50129 Florence (hereinafter “Data Controller“), as data controller, informs you pursuant to EU Regulation no. 2016/679 (hereinafter, “GDPR“) that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment
The Data Controller processes personal, identification data (for example, name, surname, company name, address, telephone number, e-mail address, bank information, etc.) – hereinafter, “personal data” or even “data” communicated by you in occasion of the conclusion of contracts for the services of the Data Controller.

2. Purpose of the treatment
Your personal data are processed in order to allow the service offered by E-vote to be provided (electronic voting system)

for the following Service Purposes:

– to conclude the contracts for the services of the Data Controller;

– to fulfil the pre-contractual, contractual and tax obligations deriving from existing relationships with you;

– to answer your questions and give you continuous assistance on our products and / or services

– to fulfil the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as,  for example, in the field of anti-money laundering);

– exercise the rights of the Data Controller, for example the right to defend in court;

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

  1. To obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
  2. To 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 Data Controller, Data processor 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, Data processor or person in charge with the treatment;
  3. To 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 fulfilment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
  4. 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 e-mail 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 authorized communications or neither of the two types of communication.

Where applicable, he 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 Garante della Privacy.

If the processing is based on consent, the interested party has the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.

4. Processing methods
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.

5. Data retention
The data collected by the site during its operation are used only for the purposes referred to in point 2 and kept for the time strictly necessary to carry out our activities. We will not keep the data for a period of time longer than that necessary to fulfil the purpose for which they were collected, without prejudice to the pre-contractual contractual and legal obligations connected or deriving from them.

6. Access to data
Your data may be made accessible for the purposes referred to in art. 2:

– to employees and collaborators of the Data Controller, in their capacity as persons in charge and / or Data Processor and / or system administrators;

– to third-party companies or other subjects (by way of example, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourced activities on behalf of the Data Controller or Data Processor.

7. Communication of data
Without the need for express consent (pursuant to art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2 to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is required 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 disseminated.

8.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.

9. Nature of the provision of data and consequences of refusal to respond
The provision of data for the purposes referred to in art. 2 is mandatory. Your refusal to process will make it impossible to conclude this contract.

10. How to exercise the rights
You can exercise your rights at any time by sending:

– a registered letter with return receipt to EXXE srl, viale Giovanni Milton, 53.50129 Florence (FI);

– an e-mail to