Extract from the USCO S.p.A.

Personal Data Retention Policy

1. Introduction and Purpose

This extract provides general guidance on the personal data retention procedures of USCO S.p.A. (the “Company”), in compliance with:

  • Regulation (EU) 2016/679 (GDPR) regarding the protection of natural persons and data processing.

  • Current national and European Privacy Legislation.

2. Definitions

  • Personal Data: Any information regarding an identified or identifiable natural person (“data subject”).

  • Processing: Any operation performed on personal data (collection, recording, storage, erasure, etc.), with or without automated means.

  • Controller: The entity that determines the purposes and means of the processing (USCO S.p.A.).

  • Data Processor: A person or body that processes personal data on behalf of the controller.

3. Principles Relating to Data Retention

3.1 General Principles

USCO processes data following these core pillars:

  1. Lawfulness, Propriety, and Transparency: Processed fairly and clearly.

  2. Purpose Limitation: Collected for specific, explicit, and legitimate purposes.

  3. Data Minimization: Adequate, relevant, and limited to what is necessary.

  4. Storage Limitation: Kept in a form that allows identification for no longer than necessary.

Note: Data may be kept longer than standard deadlines if required by legal obligations (civil, fiscal, or employment laws) or for the exercise or defense of legal rights.

3.2 Retention Periods by Category

The duration of retention depends on the purpose of processing. Below are the specific factors for the main categories:

Data Subject Category Factors Determining Duration Legal Retention Constraints*
Personnel (Employees/Associates) Duration of employment/collaboration Yes (P)
Candidates Period of interest for the profile Max 2 years
Customers Term of contractual relationship Yes (P)
Third Parties Term of contractual relationship Yes (P)
Visitors 6 months from registration No
Trade Agents / Sales Reps Term of contractual relationship Yes (P)
Administrative Positions Office term (Board, Auditors, etc.) Yes (P)

* Legal Constraints (P): Refers to obligations such as tax, social security, or employment legislation, which usually require a retention period of 10 years from the end of the relationship.

4. Right to Erasure

The data subject has the right to obtain the erasure of their data (“Right to be Forgotten”) when:

  • The data are no longer necessary for the original purposes.

  • Consent is withdrawn (and no other legal ground exists).

  • The subject opposes the processing (and there are no overriding legitimate grounds).

  • The data were processed unlawfully.

  • Erasure is required to comply with a legal obligation.

Exceptions to Erasure

The right to erasure does not apply if processing is necessary for:

  • Exercising freedom of expression and information.

  • Compliance with a legal obligation or public interest tasks.

  • Archiving in the public interest, scientific/historical research, or statistics.

  • The establishment, exercise, or defense of legal claims.

5. Contacts

For more information regarding data retention or to exercise your right to erasure, please contact: