For the purposes of the current legislation regarding data protection (including, by way of example, but not limited to, the General Data Protection Regulation, or GDPR, (Regulation (EU) 2016/679)), the Data Controller for your personal data is:
Politubes S.r.l.
Via Fermi 9/11
20875 Burago Molgora (MB)
Tel +39 039 9054999
Fax +39 039 9054990
Data will be processed at the Politubes facility at:
Politubes S.r.l.
Via Fermi 9/11
20875 Burago Molgora (MB)
Tel +39 039 9054999
Fax +39 039 9054990

Our guiding principles

We protect personal data in a serious, lawful, correct and transparent way with regards to the interests of the data subjects. Your data will be processed with the greatest care and attention, and in full respect of the applicable laws on processing data. Security measures, both organisational as well as technical, have been adopted in order to safeguard your personal data during processing. Our partners, who assist us, shall, in turn, respect these provisions.

Your personal data will be processed

A. without your express consent (article 24(a), (b), (c) of the Privacy Code and article 6(b), (e) of the GDPR), for the following purposes:

  • to conclude any existing contracts with our company;
  • to fulfil any pre-contractual, contractual or tax obligations deriving from any existing relationship with you;
  • to fulfil the obligations required by European and/or national law and regulations or to fulfil the obligations required by a qualified Authority (regarding, for example, anti-money laundering controls);
  • to exercise all the Data Controller’s rights such as, for example, the right to defend itself in court;

B. only with your specific and express consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following marketing purposes:

  • to send you, by e-mail, post and/or SMS and/or telephone contact, newsletters, commercial communications and/or advertising materials on the products or services offered by the Data Controller and to carry out surveys to determine satisfaction levels for the quality of the services provided;
  • to send you, via e-mail, post and/or SMS and or telephone contact, commercial communications and/or promotions originating from third parties (such as, for example, business partners, associate companies and other subsidiary companies).
The parties with whom we share your personal data

Where appropriate, and in compliance with current local law and requirements, we may send your personal data, in various ways and for various reasons, to the following categories of parties:

  • Every company within our Group;
  • Tax Authorities, authorised auditing firms and any other type of authorised body, when we believe, in good faith, that the law or any other regulation compels us to share this data (such as, for example, requests from the tax authorities or requests relating to a possible dispute); external service providers who operate on our behalf (including external consultants, business partners and professionals such as lawyers, auditors and accountants, IT consultants and parties providing technical support who perform checks on and who develop our IT systems);
  • External providers of IT services and outsourced documentation archiving services, where there is a suitable agreement on how to process data (or similar protections);
  • Platforms and suppliers of marketing technologies;
  • Personnel responsible for processing data (all employees, partners, administrators, directors and collaborators to whom services requested by our company are entrusted).

We send your data to other recipients only when necessary to fulfil a contract that has been agreed with you, or when legitimate interests arise, whether ours or the recipients, to divulge your data or when you have given your consent to such a transmission.

Sending data to parties outside of the European Union

We also transfer your personal data to parties outside of the European Union, to so-called third countries. In this case, we guarantee, before any data is shared, either that the recipient has an appropriate level of data protection (such as, for example, on the basis of a decision of suitability by the European Commission for that country in question, or on the basis of a standard contractual agreement between the European Union and the recipient) or that you have provided your consent to your data being shared.
We will be happy to provide you with a report of all the third-country recipients and a copy of the specific clauses agreed to guarantee an appropriate level of data protection. To make such a request, you are invited to use the contact details found at the end of this Advisory Note on Data Protection.

How we protect your personal data

Data will be processed both with and without the aid of electronic tools but, in any case, processing will be done through the adoption of the security measures provided for by current legislation.
We are committed to taking all appropriate and reasonable measures to protect the personal data that we store against improper use, loss and unauthorised access.
To this end, we have implemented a series of specific technical and organisational measures including measures to deal with any suspected data breach.
If you have reason to suspect that your data has been subject to improper use or loss or unauthorised access, we invite you to contact us immediately.

Your rights

In the event of a complaint, below is a list of your rights. To exercise your rights, you are invited to use the contact information provided within this advisory note on data protection.

Right to have information about your data

Upon request, we will provide you with all the information we have regarding your data.

Right to have data corrected and completed

We will correct any inaccurate information about you following your notification regarding the said inaccuracy. We will complete any incomplete data that you report provided that this data is necessary for the purposes of the processing.

Right to have your data deleted

We will delete information held by us following such a request from you.
However, some data will be deleted only after a specific period of time. For example, if we are required, by law, to store certain data or if we need the data to fulfil our contractual obligations towards you.

Right to have data blocked from processing

In certain situations provided for by law, we will block your data from being processed should you wish it. Blocked data will be subject to future processing but only to a very limited degree.

Right to revoke any consent previously given

You make revoke, at any time, any consent previously given to process your data in the future. The legality of processing your data remains unaltered up to the moment that you revoke your consent.

Right to oppose having your data processed

You may oppose, at any time, having your data processed in the future. If our processing of your data is done on the basis of one of the justifications provided for by law under article 6 (1)(e) or (1)(f) of Regulation EU 2016/679. In the event that you oppose having your data processed, we will interrupt processing provided that there are no compelling or legitimate reasons for your data to be further processed. Processing your data for marketing purposes never constitutes a compelling or legitimate reason.

Right to data portability

Upon request, we can put some data at your disposal in a structured, widely-used format which can be read by an electronic device.

Right to appeal to a supervisory authority

You may lodge a complaint regarding the processing of your personal data with a Data Protection Authority.
To do this, you are invited to contact the Data Protection Authority responsible for the region in which you reside or you may contact the Italian Data Protection Authority (Garante per la protezione dei dati personali) under whose jurisdiction our company operates (see below).

Italian Data Protection Authority (Garante per la protezione dei dati personali)

Website: http://www.garanteprivacy.it

Your point of contact for any queries regarding data protection

For any query regarding data protection or to exercise your rights, you are invited to use the following reference to contact us directly:

Changes to this Advisory Note on processing data

This advisory note on processing data reflects the current status of how data is processed.
In the event that changes are made to how data is processed, this advisory note on processing data will be amended accordingly.

25 May 2018

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