We wish to inform you that, because of our commercial relationship, we are in possession of details (personal and tax data regarding your business) gathered either verbally or from public registers, lists, deeds and documents and/or public and/or private data banks (commercial information companies) about you and that these details are considered as personal by Italian law.

With reference to these details we wish to inform you that:

— these details are dealt with according to the contract requirements and consequent performance of the legal and contractual obligations deriving from them as well as with the aim of managing our commercial relationship efficiently, safeguarding the credit and better managing our rights with regards to the individual commercial relationship.

Said details shall be dealt with in writing and/or on a magnetic, electronic or telematic medium and anyway strictly in keeping with the abovementioned aims.

— the disclosure of these details is compulsory in as much as it is required by the law and the contract and therefore any objection to supplying them or to the way in which they are dealt with shall make it impossible for us to continue with our commercial relationship;

— the disclosure of any details not required by either the contract or the law is optional but not supplying them shall cause us to decide whether a new commercial relationship might be established.

— Without prejudice to the communication and spreading of said details due to the contract and the law, these details can be communicated either in Italy or abroad to:

our network of agents and suppliers, factoring companies, banks, debt recovery companies, credit insurance companies, credit information companies, consultants, solicitors, accountants, auditors, architects, printers, transport and logistics companies.

These people shall deal with the details as “independent holders” in compliance with art.13 e 14 del Regolamento (UE) 2016/679.

For the same purpose, your details might be disclosed to the following groups of our internal people:

— Sales Director, Key Account Managers, front-office clerks and customer service employees, purchasing clerks and Manager with the purpose of acquiring/issuing and executing the order;

— Technical and Works Department clerks and Manager in order to design and install our products;

— Delivery and Stockroom staff and Manager in order to manage the delivery/transport;

— Finance Director and Accounts staff in order to fulfil the contract obligations and perform the necessary bookkeeping;

We also wish to inform you that:

— said details shall be dealt with for the whole duration of the contract and also afterwards in order to fulfil all legal requirements as well as for future commercial purposes on condition that the law does not require previous written consent, in which case we will ask for your consent.

-with regards to the details, your Company shall be entitled to exercise the rights provided for in the following articles of Decree Law No.196/2003:

Art. 7 Paragraph 1: to obtain confirmation of whether said details exist even if they have not been entered yet and be informed about them;

— Paragraph 2 (…): to be informed about a) the origin of the details; b) how they will be dealt with and for what purpose; c) what the applied logic is if the details are dealt with by electronic means; d) the details of the holder and the people responsible for dealing with them; the people or categories of people who might come to know the details as appointed representatives in the Country, as people responsible or holders.

— Paragraph 3 (…): to obtain a) the updating, correction or integration of the details, if required; b) the annulment, transformation into anonymous form or the block of the details dealt with in violation of the law, including those that don’t need to be kept with regards to the purposes for which they have been gathered or dealt with afterwards; c) the statement that the operations as per a) and b) have been relayed, also as far as their contents are concerned, to the people the details have been disclosed to, except if such statement is impossible or involves the use of means obviously disproportionate to the right safeguarded;

— Paragraph 4 (…) to oppose totally or partly a) for valid reasons, that your details are dealt with, even if they are relevant to the purpose why they have been gathered; b) that your details are dealt with the purpose of sending advertising materials, direct marketing, or for market research or a commercial report (NB: our Company, though, does not deal with the details for the purposes stated in the above 4th Paragraph of art. 7)

Art. 8 Paragraph 1: The rights mentioned in art. 7 are exercised by sending your request to the holder or person responsible, even via an intermediary, and by that person answering without any delay. Paragraph 2: When it doesn’t involve objective details, exercising the rights mentioned in art. 7 can take place with the exception of when the correction or integration of the personal details regards opinions, decisions or other subjective evaluations as well as instructions regarding what to do or decisions about to be taken by the person responsible for dealing with the details.

Art. 9 Paragraph 1: The request to the holder or person responsible can be sent by a) registered letter, fax or electronic mail too, b) if it concerns the rights mentioned in art. 7 paragraphs 1 and 2, even orally and in this case the holder or person responsible shall make note of it. Paragraph 2.

In exercising the above-mentioned rights you can give a proxy, in writing, to persons, bodies, associations or organisations. You can also ask somebody you trust for assistance. Paragraph 3. The rights mentioned in art. 7 regarding personal details of deceased people can be exercised by an interested party or by someone who acts in defence of the interested party or for family reasons that deserve to be protected. Paragraph 5.

The request mentioned in art. 7 paragraphs 1 and 2 can be renewed at an interval of not less than ninety days, with the exception of whether there are justified reasons.

— the holder of the details is ISAF M.TG S.r.L., its Registered Office being in Via B. Parodi,286 16014 CERANESI — Genoa (Italy);

— the person responsible for dealing with personal details is the C.E.O. in charge at the moment, domiciled at the CERANESI office.


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