This is an information about personal data treatment and protection in accordance with section 13 of Italian Legislative Decree 196/2003, also referred to as “Code”, which guarantees the protection of personal data and imposes obligations to the people who treat them.
In accordance with section 13 of Italian Legislative Decree 196/2003 Trafilerie di Valgreghentino SpA, based in Valgreghentino, Lecco, Italy, in the person of its legal representative, means to inform that the supplied personal data will be treated in accordance with its duty of secrecy and with the above-mentioned regulation.
These are the PURPOSES for which personal data are collected and processed:
- the fulfilment of fiscal and bookkeeping obligations;
- customer handling;
- the management of business activities: contracts, orders, consignments, invoices and delivery notes;
- solvency and creditworthiness control
- direct selling
- advertisement and promotional purposes
The data will be kept for the whole duration of the business relation and afterwards, as long as it is required by law and in order to fulfil management and commercial purposes.
This is HOW personal data are treated:
- by using telecommunications, paper or electronic means;
- only by authorized personnel, which is constantly identified and properly trained in the constraints of the above mentioned Legislative Decree;
- by adopting security measures in order to:
- safeguard the privacy of the person;
- prevent the access of external or unauthorized personnel to the data;
The treatment of the personal data will always be based upon the principles of correctness and transparency, whether it is carried out by using electronic means or without.
The personal data will never be spread anyhow to any unidentified person; they will only be communicated to selected addressees:
- authorized staff of our company, which is appointed to treat the personal data (in particular: shipping, logistics, sales and accountancy department staff);
- people who can have access to the data by law;
- external staff with auxiliary duties (carriers, depositaries, salesmen working for us);
- consultants working for our company( legal, fiscal and trade consultancy offices or societies), but only insofar as is necessary for the accomplishments of their tasks and after we have instructed them with a written form to secrecy and security when dealing with the data.
According to paragraph 4 of section 130 of the Privacy Code our company may use your email address in order to send you offers, promotional announcements or advertisement. You always have the right to oppose to the treatment of your data, free of charge simply by filling in this form.
The data provision is:
- a) obligatory, by the laws which regulate the contractual relations and the management of their business activities, such as bookkeeping, fiscal implementations, etc
- b) optional, until the contractual relation is settled and when concerning marketing or promotional announcements, statistic analysis, quality controls;
The partial or total refusal to authorize the treatment of personal data will cause difficulties or even the impossibility of managing a business relation, of correctly fulfilling the relative obligations, of pursuing the above mentioned aims and the unsuccessful acquisition of a right.
According to paragraph 1, section 4 of Legislative Decree 196/2003 sensitive personal data ( such as referring to health, religious or philosophical beliefs, political opinions, trade union membership, etc) will not be treated.
The treatment only concerns the common data we are given when managing contractual/ commercial relations with other companies or the data of public registries or in any case data accessible to everybody ( such as the company's address, VAT etc).
The data controller is Trafilerie di Valgreghentino SpA, in the person of Mr Luigi Sabadini.
Information on Mr Sabadini can be found at the company 's registered office.
According to section 7 of Legislative Decree 196/2003 a data subject shall have the right to obtain the updating, rectification or, where interested therein, integration of the data, the erasure, anonymization 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.
Moreover they have the right to oppose to the treatment of their data or to choose not to receive communications. info@traval.it
Section 4 (Definitions)
d) ‘sensitive data’ shall mean personal data allowing the disclosure of racial or ethnic origin,,religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade-unionist character, as well as personal data disclosing health and sex life;
Section 7 (Right to Access Personal Data and Other Rights)
- 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.
- A data subject shall have the right to be informed:
- a) of the source of the personal data;
- b) of the purposes and methods of the processing;
- c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
- d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
- e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
- A data subject shall have the right to obtain:
- a) updating, rectification or, where interested therein, integration of the data;
- b) erasure, anonymization 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.
- 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.
Section 13 (Information to Data Subjects)
- The data subject as well as any entity from whom or which personal data are collected shall be preliminarily informed, either orally or in writing, as to:
- a) the purposes and modalities of the processing for which the data are intended;
- b) the obligatory or voluntary nature of providing the requested data;
- c) the consequences if (s)he fails to reply;
- d) the entities or categories of entity to whom or which the data may be communicated, or who/which may get to know the data in their capacity as data processors or persons in charge of the processing, and the scope of dissemination of said data;
- e) the rights as per Section 7;
- f) the identification data concerning the data controller and, where designated, the data controller’s representative in the State’s territory pursuant to Section 5 and the data processor. If several data processors have been designated by the data controller, at least one among them shall be referred to and either the site on the communications network or the mechanisms for easily accessing the updated list of data processors shall be specified. If a data processor has been designated to provide responses to data subjects in case the rights as per Section 7 are exercised, such data processor shall be referred to.
- The information as per paragraph 1 shall also contain the items referred to in specific provisions of this Code and may fail to include certain items if the latter are already known to the entity providing the data or their knowledge may concretely impair supervisory or control activities carried out by public bodies for purposes related to defence or State security, or else for the prevention, suppression or detection of offences.
- The Garante may issue a provision to set out simplified information arrangements as regards, in particular, telephone services providing assistance and information to the public.
- Whenever the personal data are not collected from the data subject, the information as per paragraph 1, also including the categories of processed data, shall be provided to the data subject at the time of recording such data or, if their communication is envisaged, no later than when the data are first communicated.
- Paragraph 4 shall not apply
- a) if the data are processed in compliance with an obligation imposed by a law, regulations or Community legislation;
- b) if the data are processed either for carrying out the investigations by defence counsel as per Act no. 397 of 07.12.2000 or to establish or defend a legal claim, provided that the data are processed exclusively for said purposes and for no longer than is necessary therefor;
- c) if the provision of information to the data subject involves an effort that is declared by the Garante to be manifestly disproportionate compared with the right to be protected, in which case the Garante shall lay down suitable measures, if any, or if it proves impossible in the opinion of the Garante.
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+39 0341 604504 - Fax +39 0341 605428 - E-mail info@traval.it - P.IVA 00210700134 - R.E.A. Lecco 113707