Privacy Policy

 

PRIVACY POLICY PURSUANT TO ART. 13 OF THE EUROPEAN PERSONAL DATA PROTECTION REGULATION 2016/679

Protecting the security and privacy of your personal data is important to Berlin Packaging Italy S.p.A., that acts in accordance with laws currently in force concerning protection and security of personal data. We hope the information that follows will help you to understand what type of data Berlin Packaging Italy S.p.A. generally collects, how it’s used and maintained and with who it’s shared.

Pursuant to art. 13 of Regulation (EU) 2016/679 ( “Privacy Regulation”), we wish to inform you that your personal data’s processing will be in compliance with the lawfulness, fairness and transparency principles,  and will ensure your privacy and your rights and will be in accordance with current legislation on security and protection of personal data.

In particular, we inform you of the following:

a. Source of Personal Data
Personal data we hold is the one you gave at the time of registration and/or at the time you sent us a request for information on our products, by filling in the form shown in the products’ online catalogue, following the links: information request or wishlist and/or when you signed up for the following service we offer: Sign up, and Newsletter Subscription at BruniGlass.com.
All personal data will be processed in accordance with the Privacy Code, with  the Privacy Regulation and with those confidentiality requirements which have always inspired our company’s activities.

b. Legal basis and Purpose of processing
The purposes for which we will process  your personal data are the following:

b1. Requests handling
By processing the data you gave , we will be able to answer your enquiries concerning:
- details, nature or price of products for which you have shown your interest, or of similar products, if the ones you are interested in aren’t temporarily or definitively available, or concerning any initiatives by Berlin Packaging Italy S.p.A.; the legal basis of this processing is the implementation of pre contractual measures that you requested.

b2. Marketing, direct sale, and business communications
After obtaining your consent, by processing the data you gave, we will send you information concerning our retail business, including our products, or promotional materials, offers on our products, as well as invitations to trade fairs or corporate events to which we would be glad you attended, all - also with automated means - via e-mail or post service.  Even if you give your consent, you will be able to withdraw it at any time, by sending a request to Berlin Packaging Italy S.p.A. with the means listed in the following point h., as regards the forwarding of promotional material via both automated means and traditional means.
You will be able to easily stop further mailing also by enforcing the ‘ Right to opt-out’ via the means featured in every communication concerning the above said business communications.
After withdrawing your consent, you will receive the acknowledgement of receipt of such withdrawal from Berlin Packaging Italy S.p.A..
Berlin Packaging Italy S.p.A. however informs you that after practicing the right to opt-out, it may happen that, for technical and operative reasons (e.g. the contact list was completed just before Berlin Packaging Italy S.p.A. received the withdrawal), you will continue receiving further business communications. If you continue receiving such communications after practicing the above said right, we kindly ask you to notice the issue to Berlin Packaging Italy S.p.A., using the references listed in the following point h.
The legal bases of the above said processing is the consent to processing your data that you granted when you filled in the contact form in the website’s section given at the following link: Newsletter Subscription.

c. Processing methods
Data processing will take place via manual or computerised means that are eligible to ensure its security, as well as to avoid unauthorised access by third parties and, either way, according to the national and  european legislation. Data processing is carried out by the Owner, by the External responsible Subjects and by the Delegated Data Processors.

d. Nature of provision
Data provisioning for the purposesin point b1. is compulsory as it  is a necessary requirement in order to acknowledge your requests and in the event of missing data provision, your possible refusal will  enable you to receive information on our products you showed your interest in.
Data provisioning for the purposes in point b2., is optional, but  is a necessary requirement in order to receive business communications from Berlin Packaging Italy S.p.A. In the event of lack of consent your ability to browse BruniGlass.com and to ask information to Berlin Packaging Italy S.p.A., won’t be affected in any way, still you won't have the above said business communications.
We advise you to not provide, while using the interactive services, sensitive data, which is data that gives out, apart from the rest, racial and ethnic origin, religious beliefs, political opinions, membership to parties,to  trade unions and to philosophical, religious, political or union organisations, as well as health conditions. Potential sensitive data provided will be immediately deleted.

e.  Parties involved in data  processing and data  communication.
Employees and/or collaborators of Bruni Glass SpA appointed by Berlin Packaging Italy S.p.A. to carry out the same activities necessary to do processing activities, as listed in the above paragraphs b.1) and b.2), could gain knowledge of your personal data.
As well as suppliers of IT and logistics services, functional to the sites efficiency, outsourced services’ suppliers, professionals and advisors, companies appointed to send promotional emails and text messages or business communications (where you have consented), could gain knowledge.
Such parties, formally named by Berlin Packaging Italy S.p.A. as ‘Appointees’, data Processors, and/or System Administrators, will process your data according to and only for the purposes listed in this policy and under the control and supervision of Berlin Packaging Italy S.p.A. The full and updated list of the parties to whom your data has been given, can be requested to the Owner, by writing at the email in point h).
Your personal data could also be shared with Companies of the Berlin Packaging Italy S.p.A. Group, for the business  purposes of point b 2.

f. Data Dissemination
The Data Processor will not carry out dissemination activities involving your personal data.

g. Transfer of data abroad

Your personal data could be transferred abroad to Countries that are not Members of the EEA (European Union, Iceland, Liechtenstein and Norway) and, in particular to the Berlin packaging LLC company, a limited liability company of Delaware, based in 525 West Monroe St. Chicago, IL 60661, based upon a data transfer agreement from the Data Controller to the Data Processor, including standard clauses approved by the European Commission, concluded by Berlin Packaging Italy S.p.A. (Data Controller-exporter) and Berlin Packaging LLC ( Data Processor-importer), resulting in a warranty of data processing in accordance with European standards. Berlin Packaging LLC will process personal data coming from the European Union only on the basis of instructions given by the Data Berlin Packaging Italy S.p.A. and according to the agreements stipulated with the companies of Berlin Packaging Group.

h. Rights of the data subject
Lastly, we wish to inform you, of the chance to enforce at any time the rights recognised to you by law, as listed below:

- to access to provided data;
- to obtain the amendment of provided data, its deletion, its anonymous transformation, the blocking of data processed in violation of the law or limit the processing of data that concerns you;
- to object to process your data;
- to obtain the transfer of your data;
- to obtain confirmation of the presence or not of the said data, find out its content and origin, verify its accuracy or ask for its integration or update, find out the processing’s purposes and how it’s carried out, the logic behind data processing with computerised means, and the references of the Owner, Responsibles and of the DPO, whenever appointed;
- to issue a claim to the Supervisory Authority ( Privacy Authority);
- to object to a computerised decision-making concerning people, including profiling;
- to obtain, without undue delay, communication of the violation of your personal data.

All requests must be sent to:
- via email: privacy.it@berlinpackaging.com
- via fax: +39.02.484.3651
- or via post: Viale C. Colombo 12/14 - 20090 Trezzano s/N (MI) Italy

i. Data storage period

Data you provided for the purposes in the previous point b.1), will be stored for the time necessary to complete your enquiry and, then, for the time necessary to perform the contract, whereas it’s signed, after your inquiry.
Only if, by submitting an inquiry to our company, you have also agreed to the purposes in the previous point  b.2), your data will be stored for 2 years the most since the last interaction, unless an early request for deletion occurs.
The data you provided for the purposes in b.2) will be stored for 2 years the most, estimated by the Owner to be adequate in order to fulfill the mentioned purposes. In any event you withdraw your consent and/or,  for any reason, your personal data storage isn’t any longer justified, the Owner will delete or anonymise your data without delay.

J.  Data Processor
The Data Controller is Berlin Packaging Italy S.p.A., in person of its current  legal representative, based in MILAN, Viale Colombo, 12/14 - 20090 Trezzano S/N (MI), email: privacy.it@berlinpackaging.com

 

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