Privacy Policy_Eng

PRIVACY POLICY- INFORMATION FOR CUSTOMERS ON THE PROCESSING OF PERSONAL DATA

(according to Articles 13 and 14 of the EU General Regulation on the protection of personal data no. 679/2016 “GDPR”)

TO OUR CUSTOMERS

Introduction

This information is provided in compliance with the provisions and obligations established by Regulation (EU) no. 2016/679 of 27 April 2016 (hereinafter “GDPR”), in force since 25 May 2018, for the protection of individuals with regard to the processing of personal data, as well as the free circulation of such data which repeals Directive 95/46 /CE.

Who is the Data Controller of personal data?

The owner of the processing of personal data is the company Pack Co. S.r.l., in the person of its legal representative, with registered office in Milan Via Angelo Brunetti, 8, C.F. and VAT number 03492710961 tel. 0233431526, fax 0233431814 e-mail: info@pack-co.it PEC: pack-co@legalmail.it.

Pack Co. S.r.l. informs, pursuant to art. 13 and 14 of the GDPR, which will proceed to the processing of personal data referring to natural persons for the purposes and in the manner indicated in this statement.

The Data Controller may make use of the collaboration of specifically identified managers or agents.

What is meant by “Personal data” subject to processing pursuant to the GDPR?

According to art. 4 n. 1, GDPR “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”) with particular reference to an identifier such as the name, an identification number, location data, an online identifier or an or more characteristic elements of his physical, physiological, psychic, economic, cultural or social identity.

Pursuant to art. 9 GDPR, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify are considered “particular data” a natural person, data relating to the health or gender sexual life.

For such data considered “sensitive”, the GDPR allows its processing in the presence of the explicit consent of the interested party or the need to fulfill the obligations and exercise the specific rights of the data controller or the interested party.

What is meant by “processing of personal data” pursuant to the GDPR?

Pursuant to art. 4, no. 2, GDPR, “processing of personal data” means any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization , structuring, storage, adaptation or modification, extraction, collection, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

Who are the “Interested people” in this information?

In order to protect personal data, this information is addressed to the natural persons of the company (legal representatives, staff, collaborators, etc.) of the customers of Pack Co. S.r.l., identified or identifiable, who on behalf of the Customers are legal entities.

What is the scope and purpose of this information?

This information applies to personal data processed in relation to the activities and services performed by Pack Co. S.r.l. for its customers.

The purpose of this privacy statement is to provide maximum transparency regarding the information that Pack Co S.r.l. collects and how such personal information is used, in order to protect the confidentiality of the natural persons referring to the Clients of Pack Co. S.r.l.

What is the scope and purpose of this information?

This information applies to personal data processed in relation to the activities and services performed by Pack Co. S.r.l. for its customers.

According to the rules of the GDPR, the treatments carried out by Pack Co. S.r.l. they will be based on principles of correctness, lawfulness and transparency and protection of confidentiality.

What categories and what types of personal data are processed?

Pack Co. S.r.l. carries out the processing of common data, that is personal and contact data (such as, for example, the name, surname, e-mail address, telephone number) of the natural persons who are company contacts and / or who work on of its Clients legal entities.

No sensitive personal data is collected as required by the GDPR, nor judicial data.

What is the source of the personal data?

The personal data processed may be collected directly from the interested party and / or obtained from third parties on the occasion of:

visits or phone calls;
requests for information, including via email;
requests for quotation;
requests for registration to training courses organized by Pack Co. S.r.l. and / or filling in the relative form;
purchase orders and related management;
contracts with the customer and their execution.

For what purposes Pack Co. S.r.l. does the processing of personal data and what is the legal basis of the processing?

The personal data of the natural persons referring to Pack Co. S.r.l. will be processed for the following purposes:

Purpose Legal basis of the processing

the management and execution of pre-contractual measures (for example, the preparation and sending of estimates) (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of a contract or execution of pre-contractual measures

order management, stipulation and execution of contracts between Pack Co. S.r.l. and its Customers, the provision of requested services and the fulfillment of mutually assumed contractual obligations (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of a contract or execution of pre-contractual measures

communications with customers for the execution of pre-contractual measures, of the contract and for the management of the post-contractual phase (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of a contract or execution of pre-contractual measures

the management of accounting, collections and payments (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of a contract

the prevention and management of possible disputes arising from the contract and / or from the pre and post contractual phase (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of a contract

the fulfillment of the obligations provided for by the civil, fiscal, administrative and fraud prevention laws (Article 6, paragraph 1, letter c), GDPR)

Fulfillment of a legal obligation

the inclusion of the personal data of the contact persons of the Pack Co. S.r.l. Customers in IT and / or paper company databases; (Article 6, paragraph 1, letter b), GDPR)

Fulfillment of pre-contractual measures or a contract

(Article 6, paragraph 1, letter c), GDPR)

Fulfillment of a legal obligation

direct marketing activities for sending promotional information and newsletters on the services offered or related to their activities with electronic tools (in particular via email) and with manual tools (telephone with operator or paper mail), including promotion of seminars, scientific conferences, post-graduate courses for researchers and professionals, meetings, conferences and training seminars and refresher meetings for corporate staff of Customers (Article 6, paragraph 1, letter f), GDPR)

Consent of the interested party

the detection of the degree of satisfaction of the interested party, as a representative of the Customer legal person, through customer satisfaction surveys on the quality of the services rendered by Pack Co. Srl, including statistical analysis with electronic tools (in particular via email) and with manual and non-automated (telephone with operator or paper mail) (Article 6, paragraph 1, letter f), GDPR)

Consent of the interested party

The processing of personal data for direct marketing purposes with electronic tools (in particular via email), manual and non-automated (telephone with operator or paper mail) will take place with the specific consent of the interested party.

Furthermore, without prejudice to the right to object to the processing that the interested party may exercise at any time, Pack Co. S.r.l. may send, by e-mail and paper mail, promotional information relating to services similar to those covered by the contracts concluded with the Customer.

The processing of personal data for the purpose of detecting the degree of satisfaction of the interested party, as a representative of the legal person Customer, through customer satisfaction surveys on the quality of the services rendered by Pack Co. Srl, including statistical analysis, will be carried out prior specific consent of the interested party. The interested party’s right to object to the processing of personal data for this purpose remains unaffected.

Pack Co. S.r.l. informs that personal data will be processed in compliance with the principles of relevance and non-excess

Is the provision of personal data by the interested parties mandatory?

The provision of personal data by the interested parties is necessary and functional for the execution of pre-contractual measures, for the conclusion of the contract between the parties and for its execution, as well as for post-contractual management.

In these cases, therefore, failure to provide data could compromise or make it impossible for Pack Co. S.r.l. to provide the service.

The processing of personal data necessary for contractual obligations, as well as for the management of the pre-contractual and post-contractual phase and / or for the fulfillment of legal obligations does not require the consent of the interested party, as required by the GDPR.

Therefore, the processing of personal data carried out for the aforementioned purposes is lawful regardless of the consent of the interested party.

The provision of personal data for direct marketing purposes, such as sending promotional information and newsletters on the services offered or relating to the activity of Pack Co. S.r.l. with electronic tools (in particular via email) and with manual and non-automated tools (telephone with operator or paper mail), it is free and optional. The processing of personal data provided for direct marketing purposes will take place following the consent of the interested party.

The consent to the processing of personal data for marketing purposes can be revoked at any time.

The provision of personal data for the detection of the degree of satisfaction of the interested party, as a representative of the legal person Customer, through customer satisfaction surveys on the quality of the services rendered by Pack Co. Srl, including statistical analysis with electronic tools (in particular via email) and with manual and non-automated tools (telephone with operator or paper mail) is also free and optional. The processing of personal data provided for customer satisfaction purposes will take place following the consent of the interested party.

The consent to the processing of personal data for customer satisfaction purposes may be revoked at any time.

How does Pack Co. S.r.l. does the processing of personal data?

Personal data will be processed with non-automated tools, with the aid of electronic tools and with computerized methods or with automated tools, for the time strictly necessary to achieve the purposes for which they were collected, by specifically appointed subjects and / or authorized in compliance with the provisions of the GDPR, according to the principles of correctness, lawfulness, transparency, in order to preserve the confidentiality and rights of the interested party.

The Owner Pack Co S.r.l. will not carry out treatments on the personal data of the interested parties that consist of automated decision-making processes.

Who carries out the processing of personal data? Are personal data objects of communication and dissemination to third parties?

The personal data collected may be disclosed and processed by employees and / or collaborators of Pack Co S.r.l. who need to have knowledge of it in carrying out their work activities. These subjects will operate as authorized or data processors.

The data will be processed and stored at the Data Controller’s registered office in Viale Angelo Brunetti 8 – 20156 Milan (MI) and at the operational headquarters in via Tiepolo, 34 – 59100 Prato (PO).

Personal data may be disclosed to authorized external parties or who may act as data processors, to the extent that the disclosure is necessary for the fulfillment of contractual obligations and / or by virtue of legal and / or regulatory requirements.

Following indication above, personal data may be disclosed by Pack Co. S.r.l. to the subjects indicated below:

to Banks or institutions that carry out banking activities, for the management of receipts and payments;

to companies, consultants or professionals, law firms, arbitrators, insurance companies, experts, natural and / or legal persons, if the communication is necessary or functional for the correct fulfillment of the contractual obligations undertaken, as well as the obligations deriving from the law;

to companies and freelance consultants who take care of the IT services of Pack Co. S.r.l., the management and maintenance of electronic communication equipment and the related consequent obligations on behalf of the Owner Pack Co. S.r.l.

to companies and consultants for administrative, accounting and tax purposes;

to subjects (judicial and police authorities or other public administrations including Public Authorities) who have access to personal data by virtue of regulatory or administrative provisions.

Pack Co. S.r.l. provides specific information about the managers and recipients at the request of the interested party.

Personal data will not be disseminated.

Are personal data transferred to third countries or to international organizations?

Pack Co. S.r.l. does not transfer personal data to third countries or to international organizations. However, the Owner reserves the right to use cloud services. In this case, the service providers will be selected from those who provide adequate guarantees, as required by art. 46 GDPR.

How long are the personal data kept?

Personal data will be kept for the time necessary to guarantee the correct provision of the services requested and the achievement of the purposes for which the data are processed in compliance with current regulations and legal obligations.

In particular, in relation to the management of the contractual relationship, personal data will be kept for the time necessary to achieve the related purpose.

In cases of termination of the contractual relationship for any reason, personal data will be kept for a period of ten years from their receipt.

In relation to the processing of personal data for direct marketing purposes and / or for customer satisfaction surveys on the quality of the services rendered by Pack Co. Srl, in case of manifestation of the optional consents requested, the data collected will be kept for the necessary time. for the management of the aforementioned purposes, according to criteria based on compliance with current regulations and correctness and balancing between the legitimate interest of the owner and the rights and freedoms of the interested party.

Therefore, in the case of sending newsletters on the services offered or relating to the activity of Pack Co. S.r.l. with electronic tools, in particular via e-mail, the processing of the personal data of the interested party is considered valid until the request for cancellation of the message itself which will be transmitted through the appropriate link (“unsubscribe”) present in each e- mail.

In the absence of specific rules that provide for different storage times, Pack Co. S.r.l. will take care to use the data for the aforementioned direct marketing and customer satisfaction purposes for a time appropriate to the interest expressed by the person to whom the data refers with respect to the initiatives of the owner.

In any case, Pack Co. S.r.l. will proceed, on a periodic basis, to appropriately verify the effective persistence of the interest of the person to whom the data refers to have the processing carried out for marketing purposes and / or for customer satisfaction purposes as specified above.

Upon expiry of the retention periods, personal data will be permanently and irreversibly deleted or made anonymous.

What rights can the interested parties exercise?

Pack Co. S.r.l. informs the interested parties about the rights that can be exercised by them, as provided for by art. 15 and following of the GDPR.

In particular, the interested parties have the right:

1) at any time, to know whether or not personal data are being processed and, if so, to request and obtain access to their personal data and information relating to the purpose of the processing, to the categories of data processed, to the recipients of the same, to the retention period; in addition, the interested parties have the right to have information on the origin of the data and to have a copy of it (Article 15 of the GDPR);

2) at any time, to request the rectification and / or integration of personal data (Article 16 of the GDPR) and / or the cancellation of the same (Article 17 of the GDPR) and / or the limitation of processing (Article 18 of the GDPR) );

3) of data portability (Article 20 of the GDPR);

4) to oppose the processing (Article 21 GDPR);

The exercise of the aforementioned rights may take place by sending a written request to the Data Controller which may be addressed:

by e-mail to the address: info@pack-co.it

by ordinary mail to the address of the Data Controller’s registered office: Pack Co S.r.l., via Angelo Brunetti 8, 20156 Milan.

The request will be answered as soon as possible and, in any case, within the terms set out in the GDPR.

Interested parties also have the right to lodge a complaint with the competent supervisory authority (for Italy: Guarantor for the protection of personal data) if they believe that the processing of their personal data is contrary to the legislation in force.

How are changes to the information managed?

In compliance with the provisions of the law, the Owner Pack Co. S.r.l. reserves the right to modify and / or update the Information, at any time, also taking into account any and subsequent additions and / or amendments to the national and / or European Union regulations on the protection of personal data or by effect of any further purposes of data processing.

The new versions of the information will replace the previous ones and will be valid, effective and applied from the date of publication on the company website or from the date of communication to the interested parties asking them to provide consent, where it is necessary.

Milan, 30 May 2021