Information to data subjects pursuant to Sect. 13, It. Leg. Decree 196 of 30 June 2003
(Personal Data Protection Code)
The “Personal Data Protection Code” (It. Leg. Decree D.Lgs 196 of 30 June 2003) Sect. 13 imposes a duty to inform the data subject of the fundamental elements of processing (specified at par. 1, letter a/f.)
As Savio S.p.A. fully complies with the provisions of Leg. Decree 196 of 30 June 2003, this information notice is intended to provide you with appropriate information on the purposes and modalities of processing personal data, the field of any communication or dissemination of such, and the kind of data in our possession and any dissemination of such.
According to the above-mentioned act (Sect. 2 – Purposes), Savio S.p.A. guarantees that the processing of personal data will respect fundamental rights and liberties, as well as the dignity of the data subject.
Subject to the principle that Savio S.p.A. does not process and does not intend to process any of your personal data that is “sensitive” (Sect. 4 par.1 lett.d) or “judicial” (Sect. 4 par.1 lett. e) in nature, this information notice has been provided for information collected directly from the data subject (Sect. 13, par.1); collected from third parties (Sect. 13 par.4); and which we receive from public registers, lists, records or documents that are publicly available (Sect. 24, par. 1 letter c) without prejudice to the limitations and modalities laid down by laws on its accessibility.
1. Purposes of processing personal data (Sect.13 par.1, lett. a)
All the information of the data subjects is processed exclusively for requirements related to the company’s economic activity, in particular:
- 1. Compliance with legal, Community and contractual obligations (ex. bookkeeping; tax formalities; administrative management; protection of personal data; requirements arising from sales or supply agreements, etc.);
- 2. Managing certification of quality system;
- 3. Meeting pre-contractual needs (offers, processing your orders, solvency checks);
- 4. Management of customers or prospects;
- 5. Management of suppliers or prospects;
- 6. Risk control (fraud, insolvency, reliability, etc.);
- 7. Litigation management;
- 8. Management of electronic payment systems;
- 9. Warehouse and transport management.
For all those who give their consent, as well as for those described above, personal data will also be processed for the following purposes:
- 1. Operating and strategic marketing (ex. market analysis);
- 2. Technical, commercial or promotional communication, including on a systematic basis;
- 3. Sending advertising material;
- 4. Reporting degree of customer/supplier satisfaction.
2. Modalities of processing (Sect.13 par.1, lett. a)
In relation to the purposes of this information notice, personal data is processed exclusively at our premises by specially appointed persons, using both paper and computer media, by telephone and electronic means, including through automated equipment designed to store, manage and send said information, in compliance with all precautionary measures, which guarantee its security and confidentiality, as well as full compliance with the provisions of law.
3. Scope of communication and dissemination of information (Sect.13 par.1, lett. d)
With respect for the above-listed purposes and subject to communication to third parties in compliance with the provisions of law or pursuant to regulations or other Community provisions, we may disseminate the information in Italy or abroad (in compliance with Community provisions and the opinion of the guarantor of the quality of security guarantees offered in the country of destination) to the following parties:
- 1. Personnel in our plants, appropriately assigned and informed by the data controller;
- 2. Our sales network (ex. area heads, agents, subagents, etc.);
- 3. Companies, bodies, associations or natural persons who provide us DPC services and the relative maintenance;
- 4. Other affiliates or subsidiaries (where processing will have purposes related to the ones indicated in this information notice) ;
- 5. Banks and credit institutions;
- 6. Commercial information companies;
- 7. Consultants and professionals;
- 8. Professional and company consulting offices;
- 9. Auditors;
- 10. Shippers, carriers and couriers;
- 11. Telecommunications operators;
- 12. Public economic bodies;
- 13. Customers/suppliers;
- 14. Judicial offices, within the sphere of criminal investigations, or other parties whose ability to access the information is recognized by the provisions of law or secondary or Community provisions;
- 15. Other companies, bodies or natural persons who engage in activities connected or instrumental to ours, or which support it, or which are necessary or functional to the performance of the contracts or services requested.
With the exception of our personnel and those working in our sales network, these parties may process the data as “controllers” pursuant to Leg. Decree 196 of 30 June 2003, with full autonomy.
Savio S.p.A will engage in no dissemination or communication in Italy or abroad for purposes not indicated in paragraph 1 of this document, without the express free consent of the data subject.
4. Obligatory or voluntary nature of providing information (Sect.13 par.1, lett. b)
The provision of information by the data subject is obligatory only for the purposes set forth in points 1 to 9 of paragraph 1 of this information notice. Subject to the free consent of the data subject, as more clearly specified in the special request form, information provided may be processed for the purposes set forth in points 10 to 13 of paragraph 1.
With regard to point 2 of paragraph 1, Savio S.p.A. holds that the proper functioning of its quality system is indispensable for supplier compliance with contractual obligations.
5. Consequences of any refusal to respond (Sect.13 par.1, lett. c)
With regard to points 1 to 9 of paragraph 1, regarding the purposes of processing, any refusal by the data subject to provide the data requested will make it impossible to establish contractual relationships. With regard to points 10 to 13, any refusal to consent to processing the information for the purposes indicated will have no consequence on contractual relationships, but will result in a de facto prevention of informational relationships related to commercial and marketing activities and services aimed at improving product quality and customer satisfaction.
6. Duration of processing (Sect.13 par.1, lett. a)
Information will be processed for the entire duration of contractual or informational relationships established with the data subject, for the duration necessary to conserve an economic profile for statistical purposes, and thereafter, for the duration necessary to comply with our legal obligations.
7. Rights of the data subject pursuant to Section 7 (Sect.13 par.1, lett. e)
- 1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
- 2. A data subject shall have the right to obtain information on:
- a. the source of personal data;
- b. the purposes and modalities of processing;
- c. the logic applied if processing is carried out by means of electronic equipment;
- d. the identification details of the data controller and data processors;
- e. the parties or categories of parties to whom personal data may be communicated or who may become aware of such as data processors or persons in charge of the processing.
- 3. A data subject shall have the right to:
- a. updating, rectification or, where interested therein, integration of the data;
- b. erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
- c. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
- 4. A data subject shall have the right to object in whole or in part:
- a. on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
- b. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
8. Data controller’s identification data (Sect.13 par.1, lett. f)
The data controller is Savio S.p.A., with operational offices at Via Torino, 25 (trunk road s.s. 25) 10050 Chiusa S. Michele (To – Italy), tel. +39 011 964.34.64 , fax +39 011.371.94.49. The data processor is Sara Moscatelli, domiciled at said operational offices.
9. Exercise of rights (Sect.8)
To exercise the rights provided at Sect. 7 of Leg. Decree 196/2003, reported in paragraph 6, the data subject must send a written request to the attention of the Data processor or Data controller, in one of the following ways (Sect. 9 par. 1):
- – Through email to the special address firstname.lastname@example.org
- – Through fax to the following number: +39 011.371.94.49
- – Through registered letter to the following address: Savio S.p.A. / Via Torino, 25 (trunk road s.s. 25) 10050 Chiusa S. Michele (To – Italy)