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INFORMATION PURSUANT TO REGULATION (EU) 2016/679, here in after also GDPR (updated on 08/04/2019)

- CLIENT INFORMATION -

1. General information: The Writing Company (Pettenon Cosmetics SpA) hereinafter also referred to as simply "Company", hereby communicates the information on the processing of your data / company data represented by you (e.g. personal data, addresses, tax code, VAT number, data necessary for the customer's administrative management, the execution of the contract and the fulfilment of legal obligations, data relating to payments, data necessary to defend or enforce a right of the Company). The Company will request and process only the data necessary for the pursuit of the purposes set forth in this information. Some data (that contained in the chamber of commerce’ certified company registration and that on the state of solvency obtained from credit information companies used for contractual and pre-contractual purposes, which for legitimate interests such as verifying the existence and customer data as well as any prejudicial ones) may also be found in chamber of commerce and in credit information companies.
2. Purpose and legal basis:
A) for contractual and pre-contractual purposes (e.g. order management, administrative and accounting requirements, customer management ...); process based on the following legal bases: execution of the contract, fulfilment of legal obligations and execution of pre-contractual measures adopted at the request of the interested party
B)to comply with legal obligations, regulations and EU regulations; process based on the following legal basis: compliance with legal obligations;
C)to assert or defend a right of the Company and therefore for a legitimate interest of the Company itself consisting in allowing the defence and the actions for its own protection; process based on the following legal basis: pursuing legitimate interests;
D) to assess possible prejudice to the establishment or continuation of the relationship (for example a bankrupt company) and therefore for a legitimate interest consisting in preventing risk situations; process based on the following legal basis: pursuing legitimate interests;
E)to assign/sell or discount the receivables (and therefore for a legitimate interest of the Company consisting in obtaining liquidity before payment deadlines or pending payments); process based on the following legal basis: pursuing legitimate interests;
F)in order to share your data with the other AGF88 Group Companies in order to coordinate the activities of the group thus avoiding overlapping of customers and signalling any outstanding balances and risks (e.g. bankruptcy, prejudicial) in the interest of the AGF88 Group; all therefore for legitimate interests consisting in having qualified customers and avoiding commercial overlaps; process based on the following legal basis: pursuing legitimate interests.
3. Obligation or not of the conferment: the provision of the requested data is necessary for the purposes referred to in point 2 let. A, B, C and therefore any refusal to provide them in whole or in part may result in the Company being unable to execute the contract or continue the relationship. The provision of data for the purposes referred to in point 2 let. D of this information is not mandatory but failure to provide it could make it impossible to start or continue the relationship. The provision of data for the purposes referred to in point 2 let. E of this information is optional but failure to provide it could make it impossible to start or continue the relationship. The provision for the purposes referred to in point 2 let. F is optional but failure to provide it could make it impossible to follow up the contract or continue the relationship.
4. Categories of data recipients: without prejudice to further communications (of which you will be informed if the communications themselves are not already known) that may become necessary in compliance with legal and contractual obligations, the data collected and processed may be communicated by the Company (communicating the data only if necessary for the prosecution of the purposes indicated in this information and communicating only the indispensable data) for the purposes referred to in point 2 lett. A to: banks, professionals (e.g. lawyers), consultants and service companies, transporters, shippers, judicial authorities and police and supervisory bodies, public bodies, post-couriers (communicating the data necessary to send any communications); for the purposes referred to in point 2 lett. B and C the data may be communicated to professionals (e.g. lawyers), judicial authorities, police and supervisory bodies, public bodies, post-courier companies (communicating the data necessary to send any communications). For the purposes referred to in point 2 lett. And the data may be communicated to factoring companies or companies to which the credits are assigned as well as to banks. For the purposes referred to in point 2 lett. D the data will not be disclosed. For the purposes referred to in point 2 lett. F the data may be communicated to the other AGF88 Group Companies. The subjects specifically delegated by the company for processing (administrative / legal and logistic workers, commercial staff even external to the Company, marketing staff even external to the Company, members of the Board of Directors and of the board of auditors, agents, area managers, IT technicians and information systems officers, consultants also external to the Company – e.g. quality/certifications consultants, IT consultants, legal advisors, tax consultants - interns, collaborators of data processors) and data processing managers (companies that perform ancillary activities to that of the Company such as, for example, IT consulting companies, accountants and tax consultants, consultancy firms in general) always appointed by the Company and whose list is available by contacting the data controller. It should be remembered that for debt collection activities, the Company may avail itself of debt collection companies and lawyers whose name will be available from the data controller and who may act as data controllers or independent data controllers of the process The names of these subjects, if appointed as data processors, will be communicated to you in any case before entrusting the file/practice to the subjects themselves.
5. Data retention: the data may be stored and processed by the Company for the entire period necessary to achieve the purposes contained in this information. The data retention period is as follows:
-for the pre-contractual purposes up to the eventual approval or formalization of the contract except for possible further conservation foreseen by the Italian and European regulations;
- for the contractual purposes until the termination of the relationship and also following the termination for the period determined by Italian and European regulations, including in tax matters;
- for legal obligations, regulations and community regulations, for the periods imposed by these regulatory sources;
- for the purposes referred to in point 2 lett. D until the data analysis;
- for the purposes referred to in point 2 lett. E for the entire duration of the relationship and subsequently if required by legal obligations;
- for the purposes referred to in point 2 lett. F of this information the data may be stored for the entire duration of the relationship except for the exercise of the rights indicated in point 7 of this information notice;
In any case, all data may be stored for a period necessary to assert or defend a company right under Italian and European regulations.
6. Data Controller and Data Protection Officer: The data controller is: Pettenon Cosmetics S.p.A with registered offices in Via del Pala, 7d - 35018 San Martino di Lupari (PD), Tel. +39 049 99888 Fax. +39 049 9988809 e-mail gruppoprivacy@agf88holding.it. It is not currently required and necessary by law to have a data protection officer on the part of the Company who, should it become necessary, will in any case be made known through the Company's website multisite.agf88holding.it which we invite to periodically visit also for any updates to this data information.
7. Rights: we inform you that the GDPR provides the possibility for the data subject to ask the data controller (at the addresses indicated above) to access personal data and to correct the data, cancel it or limit the processing that concerns it, the data portability; the interested party may also have the opportunity to object to the processing of data and to exercise the other rights contained in Chapter 3 Section 1 of the GDPR including the one to revoke the consent, where applicable: the revocation of the consent does not prejudice the lawfulness of the process based on the consent given before the revocation.
8. Complaints: the interested party can always lodge a complaint with the Italian Privacy Guarantor whose references can be found on the website www.garanteprivacy.it
9. Profiling: the processing of data for the purposes referred to in point 2 lett. H. of this information can be considered profiling. The profiling is based on customer data related to his purchases and habits also found through questionnaires, in order to better understand his consumption habits and guide his purchases with targeted communications as well as to develop a dedicated commercial strategy. The data is extracted and processed also through software that creates a profile consisting in cataloguing of the customer in certain classes of belonging (e.g. first-class customer to whom special promotions are dedicated, second-tier customer to whom the company decides to show only some products….) based on the requested data (e.g. purchases, turnover, products sold by the competition). This process, however, does not constitute a particular risk for the interested party considering the type of basic profiling that does not require data of a particularly delicate nature or that allows the detailed reconstruction of particularly confidential aspects of private life, especially considering the business-to-business relationship. Furthermore, legal effects that concern the person concerned or that significantly affect his / her person are not produced based on profiling, as no decision is made based on automated processing. In any case, the interested party has the right to obtain human intervention, to express his opinion, to obtain an explanation of the decision reached and to challenge the decision..
10. Data of collaborators / employees: please note that if the interested party to whom this information is addressed must communicate to the Company for reasons related to the execution of the contract, the names and contact details of his collaborators, the interested party must inform the employee of the information contained in this information and of the fact that the data will be communicated to the Company that may process the data for reasons related to the performance of the contract, obtaining consent to the communication and processing where necessary.
11. Process modalities: data may be processed by the Company in paper, manual, IT and telematics mode (therefore retaining and processing data both on paper and on computer). All the data referred to in the object will be stored and processed by the Company, taking all the measures necessary for its protection, in compliance with all current regulations (and therefore also in compliance with the principles of correctness, lawfulness, transparency and protection of confidentiality and rights) and with logic strictly related to the purposes indicated in this information. Data will be completed only with the operations necessary to achieve the purposes indicated in this information. The data will be stored, as far as the Company is concerned, at the Company's offices and at the data processors appointed by the Company (as well as at third parties indicated in this information to which the data is communicated and which treat them as autonomous holders ) The data will also be organized in databases - data bases, including IT databases.

Ultimo aggiornamento: 2020-01-09 12:09:38