INFORMATION NOTICE PURSUANT TO ARTICLE 13 OF EU REGULATION NUMBER 679 OF 27 APRIL 2016
The European Regulation number 2016/679 (hereinafter referred to as the “GDPR”) requires that the person who processes personal data informs the Data Subject (in other words, the person to whom the data refer) about key aspects related to the data processing, which must be conducted according to the principles of fairness, lawfulness and transparency, ensuring the privacy and rights of the Data Subject. Pursuant to Article 13 of the aforementioned Regulation, we hereby inform you of the following:
The processing will be carried out through collection, recording, organisation, storage, consultation, preparation, alteration, selection, retrieval, alignment, use, combination, restriction, disclosure, erasure and destruction, and it will be carried out by the controller, processors and persons authorised to carry out the processing.
The data shall be processed in a lawful, fair and transparent manner, and they shall be collected for specific, explicit and legitimate purposes; they shall not be processed in a manner that is incompatible with these purposes. The data shall be adequate, relevant and limited to what is necessary for the purposes for which they are processed. They shall be accurate, up to date and processed with the utmost confidentiality, mainly using electronic and IT tools and stored on IT devices, hard copy, and any other suitable medium, pursuant to the principles outlined in the European Regulation on personal data protection and the provisions issued by the Supervisory Authority. In any case, the data shall be processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing or loss, including accidental loss, using appropriate technical and organisational measures.
IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
The Data Controller is Arconvert S.p.A., a company with registered office at Strada del Linfano 12 PC 38062, Arco (TN), assigned Tax Identification Code (CIF) 01192310223. For the purpose of exercising the rights stipulated in the Regulation and for any query you may have regarding your personal data, you can contact the Data Controller by sending a registered letter to the aforementioned address, or a message to the following email address: email@example.com.
PURPOSES AND LEGAL BASIS OF THE PROCESSING
The data will be collected and processed for the following purposes:
To send quotes at the request of the Data Subject. The legal basis of the processing is based on the Data Controller’s legitimate interest, pursuant to Article 6(1), point f) of the GDPR.
To send informative and promotional material, and/or commercial messages related to new products or updates and news about existing products and/or promotional initiatives and events organised by Arconvert S.p.A. or in which Arconvert S.p.A. participates, including sending newsletters; to conduct market surveys. The legal basis of the processing is based on the Data Subject’s consent, pursuant to Article 6(1), point a) of the GDPR, which is specified at the bottom of this Information Notice.
To sign up to the specific event in which the Data Subject takes part and to fulfil the associated requirements (including information, advertising, promotion and documents related to the event). The legal basis of the processing is based on the Data Subject’s consent, pursuant to Article 6(1), point a) of the GDPR, which is specified at the bottom of this Information Notice.
In accordance with the purpose stated in point c), in general terms the Data Subject may be photographed and/or filmed by persons appointed for such purpose by Arconvert S.p.A. providing he/she has granted his/her express prior consent.
TYPES OF DATA SUBJECT TO PROCESSING
The data collected for the aforementioned purposes are general personal data (contact details) such as full name, email address, telephone number, name of the company that employs the data subject and the business position thereof. However, possible images and frames from video recordings and/or photo shoots that may take place during a specific event (or trade fair) in which the Data Subject takes part may also be processed.
USE OF THE IMAGES AND PURPOSES
The images in which you appear may be reproduced in catalogues, monographs, free access areas of the company’s website, presentations to customers (current and potential), suppliers (current and potential), organisations and associations, TV programmes, newsletters and social networks on which Arconvert S.p.A. has its own company profile. All the foregoing may appear on both paper and digital format in order to promote Arconvert S.p.A.’s company image. The company reserves the right to reproduce additional successive editions of the same publication. Both the display and use of the images are considered to be carried out entirely free of charge. Arconvert S.p.A. shall not disseminate images that diminish the honour, good name or integrity of the person filmed or photographed, pursuant to Article 97 of Italian Act number 633/41 and Article 10 of the Italian Civil Code. Processing your image will be based on the principles of lawfulness, fairness and transparency and the protection of your privacy.
MANDATORY OR OPTIONAL NATURE OF PROVIDING DATA
Although providing your data is optional, refusal to provide all or some of your personal data or authorise the processing thereof shall prevent Arconvert S.p.A. from achieving the aforementioned purposes.
RECIPIENTS OR CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA
The personal data held by the undersigned company shall not be disseminated. Such data may be disclosed within the company and transferred to authorised persons and data processors appointed by Arconvert S.p.A. as well as, possibly, to companies in the Fedrigoni group to which Arconvert S.p.A. belongs.
TERM FOR STORING PERSONAL DATA
The personal data you provide will be stored for 24 months counted from the date consent is granted or, if the legal basis is based on the legitimate interest, for as long as such legitimate interest exists, observing at all times the basic rights and freedoms of the Data Subjects.
Once this term expires, unless contractual relations have been established with the company to which the Data Subject belongs, the request for consent shall be renewed, if necessary.
The data may be kept for a longer period of time due to petitions received from the Public Authorities or another judicial, government or regulatory body or due to the undersigned company being involved in legal proceedings that imply processing the personal data provided by you.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
Arconvert S.p.A. does not intend to transfer your personal data to countries outside the European Union.
In any case, if this occurs, Arconvert S.p.A. guarantees that this transfer will be made:
To companies in the Fedrigoni Group that adopt the same procedures regarding personal data processing (Corporate Binding Rules approved by the competent Supervisory Authority, or standard clauses, pursuant to Article 46 of the GDPR);
To countries outside the EU that, according to the European Commission, ensure an adequate level of protection (Article 45 of the GDPR), or have previously adopted the mechanisms specified in Article 46 of the GDPR;
With the Data Subject’s prior consent when this is permitted by law (Article 49, point a) of the GDPR).
Exceptions may be made in relation to the foregoing, providing they comply with Article 49 of the GDPR.
RIGHTS OF THE DATA SUBJECT
By virtue of Articles 15 to 22 of the Regulation (EU) number 2016/679, the Data Subject is entitled to the following: a) to obtain confirmation of whether or not his/her personal data exist; b) to access the personal data and obtain information regarding the purposes of the processing, the categories of personal data, the recipients or categories of recipient to whom the personal data have been or will be disclosed, and, where possible, the envisaged period for which the personal data will be stored; c) to obtain the rectification of data that are inaccurate and to have incomplete data completed; d) to obtain the erasure of the data or the restriction of data processing; e) to obtain data portability; f) to object to data processing at any time; g) to file a claim with a Supervisory Authority, represented in Italy by the Italian Data Protection Authority.
The Data Subject has the right to revoke the consent granted to process the personal data at any time. In any case, revoking such consent shall not affect the legality of the processing that was carried out based on the consent granted prior to such revocation.
NON-EXISTENCE OF AUTOMATED DECISION-MAKING PROCESSES
The processing object of this information notice will not be subject to automated decision-making processes.
Request for consent
Having read this Information Notice,
The undersigned specifically consents to the processing of his/her personal data for marketing purposes (sending informative and promotional material and/or commercial messages related to new products or updates and news about existing products and/or promotional events organised by Arconvert S.p.A.), including sending newsletters, pursuant to Article 6 point a) of the European Regulation number 2016/679 and in accordance with the Guidelines on promotional activity and prevention of spam of the Italian Data Protection Authority of 4 July 2013.
□ I consent □ I do not consent
The undersigned specifically consents to the processing of his/her personal data in order to sign up for events and fulfil the associated requirements in the manner described above.
□ I consent □ I do not consent
The undersigned specifically consents to the publication and dissemination of his/her image in photographic and/or audio-visual form via printed media, online at www.arconvert.com and on social networks used by Arconvert S.p.A. for the promotional purposes of Arconvert S.p.A.
□ I consent □ I do not consent
We would like to inform you that, pursuant to Article 21 of the European Regulation 2016/679, if the data are processed for direct marketing purposes, the Data Subject is entitled to object to such processing, at any time, including profiling to the extent that it is related to such direct marketing.
Place…………………………………………...and date .....…………………….