INFORMATION FOR CUSTOMERS AND SUPPLIERS
(natural persons, contact persons within legal entities or partnerships)

Pursuant to Articles 13 and 14 of EU Regulation no. 2016/679 (hereinafter, “GDPR”) and in compliance with the provisions of Legislative Decree no. 196 of 30 June 2003 (hereinafter, “Privacy Code”), we inform you that your data will be processed in the manner and for the purposes set out below.

1. Data controller

The data controller is Koenig Metalli GT S.r.l., represented by its legal representative, who is responsible for the relationship established with you or with the company with which you maintain an ongoing relationship, and who by virtue of this has received communication of your data during contractual or pre-contractual negotiations. (Hereinafter also referred to as “the Company” or “the Controller”)

2. Object of the processing

Pursuant to Article 4.1 of the GDPR, “personal data” is “any information relating to an identified or identifiable natural person (‘data subject’)”. Therefore, for the purposes of this Policy, “Data” means the personal and contact details of natural persons processed by the Company for the stipulation and performance of the contractual relationship, including that of the Customer/Supplier (natural person), the legal representative of the Customer/Supplier (legal entity) (who signs the contract on behalf of the latter), as well as the employees and/or consultants engaged by the Customer/Supplier in the activities referred to in the contract. Personal data relating to natural persons involved in the performance of the contract and related to the contractual relationship itself may also be processed. In the latter case, the source of the data is the Customer/Supplier.

That being said, we process only your personal, identifying, and non-sensitive data (in particular, your name, surname, company name, tax code, VAT number, email address, postal address, and telephone number) as communicated during the relationship referred to in subsection 1.

3. Purpose of the processing

Your personal data are processed:

A) Even without your express consent, to fulfill pre-contractual, contractual, and tax obligations arising from existing relationships with you or the company in which you work.

B) Solo a seguito di specifico e distinto consenso da parte Sua, assolutamente facoltativo, i Suoi dati personali potranno essere utilizzati per conseguire una efficace gestione dei rapporti commerciali, anche attraverso operazioni di trattamento indipendenti rispetto all’adempimento delle specifiche e contingenti obbligazioni contrattuali. Per poter avere con Lei una più ampia possibilità di contatto e conservare nei nostri archivi il Suo nominativo anche una volta esaurite le attività di esecuzione di un singolo contratto, Le chiediamo di volerci fornire il Suo consenso al trattamento dei dati personali: Le garantiamo che sarà nostra cura non abusarne. Ad eccezione delle ipotesi considerate nella presente informativa, non trasferiremo a nessuno la possibilità di utilizzare le informazioni di contatto che vorrà fornirci.

4. Mandatory or optional nature of providing data

You are completely free to decide whether or not to allow us to process your personal data. However, failure to provide such data may make it impossible to achieve the purposes indicated in letter B) of the previous point. Furthermore, failure to provide any data that is not related to legal or contractual obligations will be assessed on a case-by-case basis by the undersigned and will determine subsequent decisions based on the importance of the requested data for managing the business relationship.

5. Processing methods — Data retention period

Your personal data will be processed in a manner that guarantees its logical and physical security and confidentiality, and may be carried out using manual, computerized, and electronic tools capable of storing, transmitting, and sharing the data.

We will process your personal data for the time necessary to fulfill the purposes set out above and in any case for no longer than 10 years from the termination of the relationship for the purposes referred to in point 2 letter A), or, if of shorter duration, from obtaining your consent for the purposes referred to in point 2 letter B).

6. Access to data

Your data may be made accessible to:

— employees and collaborators of the Data Controller, in their capacity as persons in charge and/or internal data processors;

— owner, employees, and collaborators of Studio Dott. Rag. Giorgio Adeodato Norcia – Piazza S. Giovanni Decollato, 2a – 05100 Terni (TR), who will act as Data Controller for aspects related to commercial consultancy for our Company;

— members, employees, and collaborators of Datacen S.r.l. – Via Luigi Corradi 3 – 05100 Terni (TR), the company designated as Data Controller for the assistance and maintenance of our company IT system;

— members, employees and collaborators of Polo Informatico S.r.l. – Via Curio Fornaci 12 – 05100 Terni (TR), the company designated as Data Controller for certain aspects relating to the assistance and maintenance of our company management system.

7. Communication of data

Without your specific consent, your data may be communicated for the purposes referred to in point 2 letter A) to:

• to consultants appointed by the Data Controller who need to process Personal Data in order to carry out their duties, in execution of the contract concluded, in accordance with the consent given by you or in fulfillment of a specific interest of the Data Controller;
• to third parties who perform outsourced activities on behalf of the Data Controller, providing specific services as Data Processors pursuant to Art. 28 GDPR. For updated information on the names and contact details of the Data Processors, you may contact the Company at the following email address: info@koenigmetallgt.it;
• to judicial or supervisory authorities, administrations, public bodies and organizations (national and foreign), in compliance with legal provisions and upon formal legitimate request by such entities.

With your consent, your data may be shared with our partners exclusively for the purpose of effectively managing ongoing business relationships with the Company.

Your Personal Data is currently stored on servers located at the Company’s headquarters. Your data will not be disclosed to third parties other than those indicated above, nor will it be disseminated.

8. Rights of the interested party

You have the rights set forth in Articles 15 et seq. of the GDPR, specifically the rights to:

• obtain: confirmation of the existence or otherwise of personal data concerning you, as well as information on: a) the categories and origin of the personal data processed; b) the purposes of the processing and the period for which the data will be stored, or the criteria used to determine that period; c) whether automated processing is carried out to evaluate your personal aspects (e.g., lifestyle or consumption preferences, interests, behavior, work performance), and receive comprehensive information on the logical basis of the processing and its consequences for you;
• obtain: a) updating, rectification, erasure, or restriction of processing pursuant to art. 18 of the GDPR; c) certification that the aforementioned operations have been notified, including their content, to those to whom the data was communicated or disseminated, except where such disclosure proves impossible or involves a manifestly disproportionate effort compared with the right being protected;
• object, in whole or in part: a) on legitimate grounds, to the processing of your personal data, even if there is a legitimate interest of the data controller; b) at any time, to the processing of your personal data for direct marketing purposes.
• You also have the right, within the limits of Article 20 of the GDPR, to the portability of your data, meaning the right to have it transmitted to another data controller;

Your rights are, however, subject to the limitations set forth in Article 2-undecies of the Privacy Code (e.g., for crime prevention, justice, and defense of the State). However, you still have the right to contact the Italian Data Protection Authority and seek judicial remedy.

9. How to exercise your rights

You may exercise your rights at any time by sending:

— a registered letter with return receipt to the Company’s contact address, as specified below;

— an email to the address info@koenigmetallgt.it.

10. Contact details of the Data Controller

Il Titolare del trattamento è Koenig Metall GT S.r.l.,Via L. Casale, 6 – 05100 Terni.

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