PRIVACY NOTICE UNDER ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 “GDPR”

The Regulation (EU) 2016/679 (hereinafter “Regulation“) establishes rules on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

In compliance with the principle of transparency provided for by Article 5 of the Regulation, La Termoplastic FBM S.r.l., in its quality as Data Controller, hereby provides you with the information required by Articles 13 and 14 thereof.

Purpose of the Processing

The processing of your personal data shall be based on the principles of fairness, lawfulness and transparency so as to protect your privacy and your rights and in compliance with the corporate privacy policy. The Company shall also process your data in compliance with the principle of “data minimization”, i.e. by acquiring and processing data limited to what is necessary in relation to the following purposes:

a) Management and fulfilment of pre-contractual obligations;
b) Management and fulfilment of contractual obligations;
c) Data entry into company databases for the monitoring of the contractual performance;
d) Management of tax and accounting obligations;
e) Compliance with the obligations established by law, regulations and EU legislation;
f) Direct marketing activities through the use of the e-mail coordinates provided by you for sending promotional and advertising material related to products similar to those covered by the contract;
g) Direct marketing activities carried out by the marketing or commercial department through the use of traditional methods of contact (such as operator calls), and automated methods (such as email, Vox).

Moreover, we hereby inform you that:

  • as to the purpose of letters a), b) and c) above, processing shall be anyway lawful even without your consent as it is necessary for the performance of the contract you have entered into (under Art. 6.1 letter b) of the Regulation);
  • as to the purpose of letters d) and e) above, processing shall be anyway lawful even without your consent as it is necessary for the compliance with a legal obligation (under Art. 6.1 letter c) of the Regulation);
  • as to the purpose of letter f) above, processing is lawful and authorized under Art. 130, paragraph 4, of Italian Legislative Decree no. 196/2003. However, you may object to this processing as from the beginning or later with any subsequent communications, including by means of an informal request to be sent to the Data Controller;
  • as to the purpose of letter g) above, processing shall be lawful only if you have given your consent (under Art. 6.1 letter a) of the Regulation)

The provision of your personal data is mandatory for the purposes referred to under letters a), b), c), d), and e) above, and your refusal to provide them shall result in the total impossibility to enter into and perform the contract.

The provision of your personal data for the marketing purposes referred to under letters f) and g) above, however, is optional and your refusal does not prevent the contractual relationship to be correctly entered into and subsequently performed.

Methods of processing

Your personal data shall be processed by using paper supports and IT tools in compliance with the provisions on personal data protection and, in particular, through the appropriate technical and organizational measures pursuant to Art. 32.1 of the Regulation and with each and every precautionary measure that guarantees their integrity, confidentiality and availability.

Source from which the personal data originate

DATA COLLECTED FROM THE DATA SUBJECT DATA COLLECTED FROM THIRD PARTIES
All data are collected directly from the Data Subject TYPE OF DATA SOURCE
Leads on potential customers Social Network (LinkedIn, Facebook, etc.)

Categories of recipients

Your personal data may be communicated, strictly related to the aforementioned purposes, to the following recipients or categories of recipients:

a) entities which data are to be disclosed to under the current legislation on tax and accounting issues;
b) credit institutions;
c) companies operating in the logistics sector;
d) professionals, for the purpose of analysing and resolving any legal problems related to your contractual position (e.g. lawyers);
e) professionals (both natural and legal persons) entrusted by the Data Controller for the performance of some outsourced activities (e.g. accountants and consultants).

Moreover, we hereby inform you that:

  • the disclosure of your data to the categories of recipients referred to in letter a) above represents a legal obligation which the Data Controller must comply with;
  • the disclosure of your data to the categories of recipients referred to in letters b), c), d) and e) above is necessary for the performance of the contract you have entered into

As to the categories of recipients referred to in letters b), c), d) and e) above, the Data Controller shall only and exclusively co-operate with entities providing adequate guarantees regarding data protection, and shall appoint them as Data Processors pursuant to Article 28 of the Regulations. The list of Data Processors is available at the Company’s premises and may be viewed upon request to the Data Controller.

Furthermore, your data shall be processed only and exclusively for the aforementioned purposes by Company employees and/or co-operators specifically authorized and instructed by the Data Controller pursuant to Article 29 of the Regulation.

Your personal data shall not be disclosed, except where required by a rule of law, regulation or community legislation.

Storage period

CATEGORIES OF DATA STORAGE PERIOD REGULATORY REFERENCES
  • Identification data
  • Contact details
  • Invoices
10 years as from the contract termination
  • Art. 43 of It. Presidential Decree no. 600/73;
  • Art. 2946 of It. Civil Code on the ordinary prescription

Data Subject’s rights

You may, at any time, exercise your rights towards the Data Controller, as provided for under Articles 15 to 22 of the Regulation.

In particular, you may obtain, at any time:

  • the access to your personal data;
  • the rectification of any inaccurate personal data concerning you;
  • the erasure of your persona data;
  • the restriction of processing of your personal data.

Moreover, you shall have the right to:

  • object to the processing of your persona data if processed for the purposes of a legitimate interest of the Data Controller, should you consider this in violation of your fundamental rights and freedoms;
  • withdraw at any time your consent in relation to the purposes which it is necessary for;
  • data portability, i.e. the right to receive the personal data concerning you in a structured, commonly used and machine-readable format

Identity and contact details of the Data Controller

The Data Controller is La Termoplastic FBM S.r.l., phone +39 0331299100, fax +39 0331764270, e-mail: privacy@fbm.eu

Contact detail of the Data Processor Officer

La Termoplastic FBM S.r.l. is not subject to the obligation of appointing a Data Processor Officer under Art. 37 of the Regulation. 

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