CLIENTS AND SUPPLIERS PRIVACY POLICY

Policy in accordance with and pursuant to Art. 13 EU Reg 2016/679 (European Regulation regarding the protection of personal data).

You are hereby informed that EU Reg. 2016/679 (European Regulation regarding the protection of personal data) foresees the protection of persons and other subjects of the law with respect to the processing of personal data. As per articles 13 and 14, therefore, you are hereby considered informed of the following information:

1. Joint Proprietorship and Contact Info

1.1 The following companies, HOLDING SANTI SRL, located at 3/A Via Trento, 31020 Castello di Godego (TV), TRAPUNTATURA BELPUNTO SRL, 2 Via Asiago, 31030 Castello di Godego (TV), ITTTAI SRL, 2 Via Asiago, 31030 Castello di Godego (TV), SAGIWA SRL, 1 Via Asiago, 31030 Castello di Godego (TV), and RENIER S.S., 2 Via Asiago, 31030 Castello di Godego (TV), operate jointly as joint proprietors of the processing policy (hereinafter referred to as “joint proprietors”). 1.2. The email address and contact info of the internal reference person to contact for matters relating to the processing of personal data is the following: privacy@belpunto.it, Privacy Office, 2 Via Asiago, 31030 Castello di Godego (TV), telephone number +39.0423.46.98.71 ext. 233.

2. Purpose and Legal Foundation

2.1 The processing of your personal data, given to us by you, is for the sole purpose of fulfilling the reciprocal contractual obligations arising out of the contract. The legal foundation of the processing thus resides in the execution of the contract (Art. 6, b) GDPR).
2.2. Specifically, your personal data shall be processed in order to manage our business relationship, to communicate our mutual needs and for any other type of communication regarding works in progress.
2.3. Moreover, some data may be processed in order to exercise or defend a right, even that of a third party, in judicial proceedings, in administrative offices or in arbitration and reconciliation proceedings, where foreseen by the law, by European Union law, by regulations or by collective contracts, where the data have been processed exclusively for that final purpose and for the minimum time necessary for the said pursuit. Personal data processing carried out for the purpose of protecting one’s legal rights must refer to ongoing disputes or preliminary proceeding situations. The legal foundation for the processing is Art. 6, f) GDPR (legitimate interests of the owner).

3. Source from which personal data come

3.1 The personal data that are processed, based on the actual business relationship, are the first name, last name, the business name, trade/brand name, email address, delivery address, telephone number, mobile phone number (where necessary), tax number (VAT), payment method, payment deadline, ID number, bank data, shipping company, website, sector, ongoing project and contact data of the internal reference (sales office, administration office, shipping office, etc.).
3.2. The personal data are collected directly from you as clients or suppliers at the moment of first contact or at the conclusion of the first order.

4. Processing measures

4.1. Regarding the destination of your data, they are subject to digital and paper processing. The processing operations are carried out in such a way as to guarantee the logical and physical security and the privacy of your personal data.

5. Compulsory data provision

5.1. Provision of data for the purposes described above in Articles 2.1, 2.2 and 2.3 are compulsory for contractual execution.

6. Nature of personal data

6.1. Your generic personal data are considered subject to processing.

7. Recipients of Data

7.1 Your data may be communicated to:
• all those whose right to access such data is recognized by regulatory measures;
• our collaborators or employees, within the limits of relevant areas and tasks;
• those in charge of IT security for our IT system and all those in charge of maintenance thereof.
• all those physical and/or legal persons, public and/or private when communication is deemed necessary or pertinent to the carrying out of the contractual relationship.
7.2 Some recipients of the data are selected as responsible for data processing. You may request a list of such persons at any moment by making a simple request.

8. Transfer of data abroad

8.1 Personal data shall not be transferred out of the EU, nor shall it be transferred to international organizations.

9. Period and method of personal data retainment

9.1 The joint proprietors, in accordance with civil and tax laws, declare a maximum term of 10 years for the retainment of generic data and their relevant documentation or in the case of a different period, even longer than that previously stated, based on the laws in force or the time period necessary in order to safeguard a legal right in proceedings of the joint proprietors or third persons, until end of the term for appeal and later, until reaching the statute of limitation for enforcement proceedings.

10. The rights of involved persons

According to European regulation, you have the right to request:
• access to your personal data (therefore to know what personal data is in our possession);
• the rectification of imprecise data or the addition of that which is incomplete (in the case that some data has undergone modifications);
• the deletion of personal data (upon verification of one of the conditions indicated in Art. 17, para. 1 of the GDPR, while respecting the exceptions foreseen by para 3 in the same article);
• the limitation of the processing of personal data, referring to one of the hypotheses indicated in Art. 18, para. 1 of the GDPR;
• the opposition to processing;
• to receive your personal data in a structured and legible (on an automated device) format, even for the purposes of communicating such data to another policy owner (right to porting);
• to revoke consent in any moment, within the limits of the hypotheses in which the processing is based on the consent to one or more specific purposes and regards common personal data (for example the date and place or birth or place of residence), or specific data categories (for example data relevant to race, political opinions, religious beliefs, health status or sexual orientation). Processing based on consent and carried out prior to the revocation of the said however, preserves its lawfulness until the moment of revocation;
• the above-listed rights, when the data refer to deceased persons, those who have a personal interest therein, or who act on behalf of the deceased person as their legal representative, or for family reasons requiring protection, unless the interested person has not expressly denied the same through a written declaration presented to the joint proprietors of the policy or which has been communicated to the latter. • to make a claim to the regulating authority (Authority Guarantor for the protection of personal data www.garanteprivacy.it).

MODIFICATIONS REGISTER
01/02/2020: first upload of Website online
25/07/2022: last modification