Privacy Policy

Dear User,

La Termoplastic – F.B.M., acting as data controller (hereinafter “F.B.M.” or “Data Controller”), deems privacy and Personal Data protection as one of the main objectives of its activity. This document has been prepared pursuant to Art. 13 of the EU Regulation 2016/679 (hereinafter “Regulation”) in order to allow you to know our privacy policy; before communicating any personal data to the Data Controller we therefore invite you to carefully read this Privacy Policy as it contains important information on the protection of your personal data.

This Privacy Policy:

  • is intended for the site (hereinafer “Site”);
  • is an integral part of the Site and the services we offer;
  • is provided to the users interacting with the web services of the Site, pursuant to Art. 13 of the Regulation.


Your personal data shall be processed based on principles of fairness, lawfulness, transparency, purpose and storage limitation, data minimization, accuracy, integrity and confidentiality, as well as the principle of accountability pursuant to Art. 5 of the Regulation. Your personal data shall therefore be processed in accordance with the legislative provisions of the Regulation and the confidentiality obligations provided for therein.

The term processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;



  1. Data Controller
  2. Personal data subject to processing
  3. Navigation data
  4. Data voluntarily provided by the user
  5. Third-party data voluntarily provided by the user
  6. Purpose of the processing
  7. Legal basis and mandatory or optional nature of the processing
  8. Recipients of Personal Data
  9. Transfer of Personal Data
  10. Retention period
  11. Data Subjects’ rights
  12. Changes

1. Data Controller

The Data Controller is LA TERMOPLASTIC F.B.M. S.R.L. Società Unipersonale- REA n. 96748 – C.C.I.A.A. Varese – R.I. Varese C.F. – P.IVA 00302610126 – Capitale Sociale euro 300.000,00 INT. VERS. Soggetta a direzione e coordinamento da parte di F.B.M. HOLDING S.R.L
2.Personal data subject to processing

F.B.M. shall process the personal data collected following your browsing the Site, including identifiers such as a name, an identification number, an online identifier or one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of the Data Subject, which may make the Data Subject identified or identifiable (hereinafter “Personal Data”). The Personal Data processed through the Site are the following:

a. Navigation data

The computer systems and software procedures used to operate the Site usually acquire some Personal Data whose transfer is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified Data Subjects but, by their very nature, they could allow users to be identified through processing and association with data held by third parties. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Site, the URI (Uniform Resource Identifier) ​​addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained, the numeric code indicating the status of the response given by the server (success, error, etc.), and other parameters relating to the user’s operating system and IT environment. These data are used only to obtain anonymous statistical information on the use of the Site, to check its correct functioning, to allow the correct provision of the services according to the systems used, for security reasons and assessment of responsibility in the event of any computer crimes against the Site or third parties. These data are usually cancelled after sixty days.

b.Data voluntarily provided by the user

The Site offers users the possibility to voluntarily provide personal information, for example when registering for a contact form, requesting services, information or offers, sending an optional, explicit and voluntary electronic mail to the addresses indicated on the Site, etc. This Privacy Policy is also intended for the processing of Personal Data voluntarily provided through the Site.

c.Third-party data voluntarily provided by the user

Third-party personal data provided by you while using some of the services of the Site may also be subject to processing. That being the case, you shall act as an independent data controller, thus accepting all legal obligations and responsibilities. You shall therefore indemnify and hold FBM harmless from and against any dispute, claim, damage compensation related to the processing, etc. that should be filed against the Data Controller by any third parties whose Personal Data have been processed due to your use of the Site functions in breach of the applicable Personal Data Protection laws.

In any case, should you provide or otherwise process any third-party Personal Data while using the Site, you guarantee as from now, and take full responsibility in this regard, that this particular processing is lawful pursuant to Art. 6 of the Regulation.

3.Purpose of the processing

Your Personal Data shall be processed, with your consent where necessary, for the following purposes, where applicable:

  1. to allow the provision of the requested services (e.g.: request for contact, “Demos” or offers, subscription to the Newsletter, enquiry or enrolment in training courses, request to send documentation or permission to download it from the Site, abuse reporting), as well as the browsing of the Site;
  2. to reply to specific requests addressed to the Data Controller;
  3. to fulfil any obligations required by applicable laws, regulations or EU legislation, or to comply with any requests from the authorities;
  4. to analyse CVs, assess the consistency of candidates’ profile with respect to any required job positions offered by the Data Controller, manage personnel selection procedures and contact candidates who submitted their application through the section of the Site “Career”;
  5. to fulfil statistical purposes, without it being possible to trace the user’s identity;
  6. to carry out direct marketing via e-mail for products and services similar to those requested by you (including demos, material or documentation that can be downloaded from the Site), unless you expressly refuse to receive such communications, such refusal to be expressed when requesting services or thereafter.

4.Legal basis and mandatory or optional nature of the processing

The legal basis for Personal Data processing for the purposes referred to in section 3.a. and 3.b. is Art. 6.1 letter b) of the Regulation (“[…] processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”), as the processing is necessary for the provision of the services or for the reply to the Data Subject’s requests. The provision of Personal Data for these purposes is optional but failure to provide such data would make it impossible to provide the requested services or to reply to your requests.

The processing of your Personal Data referred to in section 3.c. is lawful pursuant to Art. 6.1 letter c) of the Regulation (“[…] processing is necessary for compliance with a legal obligation to which the controller is subject”).

The processing of your Personal Data for the purposes described in section 3.d. is lawful pursuant to Art. 6.1 letter b) of the Regulation (“[…]processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”). Providing your data is optional, but failure to do so would make it impossible for the Data Controller to evaluate your profile or schedule job interviews.

Please note that the processing of your Personal Data referred to in section 3.e. is not performed on personal data and therefore can be freely performed by the Data Controller.

The processing of your Personal Data for the purposes described in section 3.f. is lawful under the applicable legislation on personal data protection and does not require your consent (Art. 130 paragraph 4 of Italian Legislative Decree no. 196/2003). You may object to the processing of your Personal Data for this purpose, both when requesting the products and services available on the Site and during following communications from the Data Controller.

5.Recipients of Personal Data

Your Personal Data may be shared, for the purposes referred to in section 3 above, with:

  1. entities acting as data processors, such as: i) individuals, companies or professional offices that provide assistance and advice to the Data Controller in administrative and legal matters, relating to the provision of services; ii) entities which it is necessary to interact with for the provision of services (e.g. hosting providers, including Aruba S.p.A., which operates as data processor); iii) entities entrusted with technical maintenance activities (including maintenance of network equipment and electronic communication networks);
  2. entities, bodies or authorities to which it is obligatory to communicate your Personal Data by virtue of legal provisions or authorities’ orders, or in the case of reports to investigate complaints and identify the source of messages received from users;
  3. persons authorized by the Data Controller to process Personal Data as necessary to carry out activities strictly related to the provision of services, provided that they are committed to comply with confidentiality provisions or have adequate confidentiality legal obligations (e.g. employees).

6.Transfer of Personal Data

The Data Controller does not intend to transfer your Personal Data outside the European Economic Area.

7.Retention period

The Personal Data processed for the purposes referred to in section 3.a. and 3.b. shall be keptfor the time strictly necessary to achieve those purposes. In any case, since data are processed for the provision of services, the Data Controller shall process the Personal Data up to the time allowed by the Italian legislation for the protection of its interests (Art. 2946 of Italian Civil Code, as subsequently amended).

The Personal Data processed for the purposes referred to in section 3.c. shall be kept up to the time required by the specific obligation or applicable rule.

As regards the processing referred to in section 3.d., CVs shall be kept for 24 months as from their submission and can be used for contacts and possible future job interviews. At the end of this period, you shall receive a request to update your Personal Data: failing to receive a reply from you, your Personal Data shall be deleted after 15 days from our request; should we receive a reply from you, your Personal Data shall be kept for further 12 months and subsequently cancelled.

The Personal Data processed for the purposes referred to in section 3.f. shall be processed until you object to such processing.

8.Data Subjects’ rights

Pursuant to Articles 15 and following of the Regulation, you are entitled to obtain from the Data Controller, at any time, access to your Personal Data or their rectification or erasure, to object to their processing under Art. 21 of the Regulation, to obtain the restriction of processing of your personal data in the cases provided for by Art. 18 of the Regulation, as well as to receive the personal data concerning you in a structured, commonly used and machine-readable format in the cases provided for by Art. 20 of the Regulation.

In any case, if you think that the processing of your Personal Data is not compliant with the legislation in force, you are always entitled to lodge a complaint with the competent Supervisory Authority (Personal Data Protection Supervisory Authority) pursuant to Art. 77 of the Regulation.


The Data Controller may totally or partially modify or simply update this Site Privacy Policy, also due to changes in the laws and regulations governing this matter and protecting your rights. Such changes and updates to the Privacy Policy shall be notified to users on the home page of the Site. We therefore invite you to regularly visit this section to become aware of the most recent and updated version of this Privacy Policy so that you may always be updated on the information we collect and on the use we make of it.

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