Informative


 

INFORMATIVE CIRCULAR

 

In the wake of the enactment of Decree Law 196/03 (hereinafter called the “law”), disciplining personal data protection – and for reasons of internal organisation and filing - Brawo S.p.A. as Custodian of the data handling has decided to update its informative sheets according to article 13 of the law.

Nature of the data

 

In pursuance of our relations, sensitive data will not be handled and the consensus requested does not therefore concern this data; instead it concerns data falling within the generic category of personal data. We remind you that, by personal data, we mean any information which could concern you directly or indirectly, including – as mere examples – personal details and information concerning the contractual relationship. The data prevalently acquired directly from all interested persons may be integrated by data collected from third parties, largely taken from public registers, or from acts or deeds in the public domain.

 

Handling Purpose

 

Personal data is handled in the ambit of our business for the following purposes:

 

  1. to satisfy contractual obligations with regard to you by implementing an act or several acts or a group of operations necessary to satisfy the abovementioned obligations;

  2. to satisfy other obligations established by national or community civil and fiscal measures connected with the execution of the supply contract;

 

c) to set-up engagements preliminary to the stipulation of the contract;

 

d) to execute administrative-accounting fulfilments and ones for dispute management.

 

The conferment of the personal data necessary for the purposes cited in points a), b), c), and d) is obligatory; your eventual refusal to confer the same will lead to the impossibility of arranging for the execution of the obligations deriving from the contract and the law. We advise that the handling of this data, including the communication to the subjects indicated in the following paragraph “Categories of subjects to whom the data may be communicated” is not subordinate to your consensus according to article 24, paragraph 1 of the law.

 

Moreover, your data will be handled for the following further purposes, which even though not strictly connected to the execution of the contractual fulfilments are useful for improving the quality of the service offered to the Customers and to permit swifter knowledge of the initiatives which our Company intends to promote with regard to you:

 

  1. to communicate and diffuse commercial references; the diffusion will be implemented via e-mail, or on paper, advertising sheets and materials, as well as by insertion in our internet site. The personal data which can be diffused such as references will be company name, the complete address of your headquarters and the kind of product/service you offer;

  2. for sending advertising material;

  3. conducting market research;

  4. sending commercial communications;

  5. communicating it to other customers or suppliers.

 

The purposes cited in points e), f), g), h) and i) may be pursued directly by our Company, or by availing ourselves of Companies supplying us with goods and/or services. The conferment of personal data for the aforementioned purposes is not obligatory, and the handling concerned, including any eventual communication to Companies supplying us with goods and/or services is subordinate to obtaining your consensus according to art. 24, paragraph 1 of the law. If you do not wish to confer the data we shall be deprived of the possibility of knowing your organisational structure to the best and of satisfying your demands, even in terms of quality in an optimum way.

 

Handling methods

 

Personal data is handled via manual, IT., and data communication instruments, with logic strictly correlated to the purposes indicated above and anyway so as to guarantee the security of the data itself, via the adoption of suitable and preventive security measures foreseen by the law. The data will be recorded in one or more data banks and/or conserved in paper archives and/or on magnetic supports. All the handling operations indicated in art. 4 paragraph 1, letter a), of the law will be performed. In particular, automated handling permits the subdivision of the data by customer typology, by regions, provinces, by goods class and by material code. Your personal data is collected and recorded exclusively for pursuing the purposes indicated in the purposes described and will be conserved in a form which permits your identification only for the time necessary to implement it; after this period it will be destroyed or rendered anonymous. Your data will be handled legally and correctly and it will be periodically updated. For this purpose, we kindly ask you to communicate to us, any eventual changes in the same so that we may up-date our data bases.

 

Categories of subjects to whom the data may be communicated

 

In pursuing the purposes indicated, Brawo may communicate your personal data to the following subjects:

 

- public administrations within the limits established by the laws and regulations;

 

  • business organisations;

  • legal studios and accountants;

  • insurance companies, credit recovery, leasing and factoring companies;

  • banks;

  • studios and companies offering commercial, company and business advice;

  • suppliers or potential suppliers;

  • customers or potential customers;

  • Brawo group companies;

  • transport companies.

 

Your data may be known by nominated employees of our Company “assigned” according to art. 30 of the law depending on the respective competence profile, with the purpose of performing the handling necessary for the attainment of the purposes described above on behalf of Brawo. Your data may also be known by personnel temporarily hired by Brawo or who continuously perform work on behalf of Brawo who need to handle your data for the performance of all the operations necessary in managing the contractual relations between Brawo and your Company. Finally, your data may be known by employees assigned by external Managers to whom all or a part of the handling of your personal data has been delegated to. The personnel cited will always be assigned via a dedicated assignment letter on the basis of the tasks assigned. The detailed list of the subjects to whom the data may be communicated to is available by sending a request to the Delegated Custodian, via fax to number 0364 599073 or, alternatively to the following e-mail address: privacy@brawo.it.

 

Rights of the interested party

 

Finally, we advise you that art. 7 of the law in question, permits you to exercise specific rights. In particular, it permits you to obtain the following from our Company:

 

  1. confirmation or denial of the existence of personal data concerning you, even if still not yet recorded, and communication of the same in an intelligible form;

  2. indication of the origin of the personal data;

  3. indication of the handling purposes and methods;

  4. indication of the logic applied in the case of handling with the aid of electronic instruments;

  5. indication of the identification details of the custodian and of the manager;

  6. indication of the subjects or categories of subjects to whom the personal data may be communicated to or who may come to know by being assigned to the handling;

  7. the updating, changing and integration of the data, where there is interest;

  8. the cancellation, transformation into an anonymous form, or the blocking of data handled in violation of the law, including that which does not need to be conserved in relation to the purposes for which the data was collected or successively handled;

  9. certification that the operations mentioned in points g) and h) have been brought to the knowledge – even concerning their content – to anyone to whom the data was communicated or diffused to, excepting the case in which such fulfilment proves impossible or leads to the use of means manifestly disproportionate with respect to the protected right.

 

You also have the right to fully or partially oppose the handling of the personal data which concerns you:

 

- for legitimate reasons, as long as this data is pertinent to the purpose of collection;

 

- for the purposes of sending advertising material or for conducting Market research or commercial communications.

 

 

 

We finally advise you that in order to exercise the aforementioned rights or to receive any further information, you may directly contact us by phone at +39 0364591556, asking for the privacy office, by fax at +39 0364599073 or by e-mail at privacy@brawo.it.

 

Unless otherwise specified in written, this document will be considered as accepted within the above-mentioned law.

 

  

 

BRAWO SPA