PRIVACY NOTICE PURSUANT TO ART. 13 OF THE PRIVACY ACT AND ART. 13 OF THE PRIVACY REGULATION
Protecting the security and privacy of your personal data is important to Bruni Glass S.p.A.. The company conforms its activities to currently applicable regulations on privacy and data protection. We hope that the information appearing below will assist you in understanding what type of data Bruni Glass S.p.A. tends to gather, how they are used and safeguarded, and to whom they are disclosed.
Pursuant to Art. 13 of Legislative Decree 196/2003 (“Privacy Act”) and Art. 13 of EU Reg. 679/2016 (“Privacy Regulation”), we would like to inform you that your personal data shall be processed lawfully, fairly and in a transparent manner, protecting your privacy and your rights, all with a view to complying with the applicable regulations on security of personal data.
Moreover, we would like to notify you of the following:
a. Source of Personal Data
Personal data in our possession are those submitted by you upon registering and/or upon your sending an enquiry on our products via an online form available in our online product catalogue, at the following links: information request or wishlist and/or when you signed up for the following service we offer: Sign up, and enter the Bruni's world at BruniGlass.com.
All your personal data shall be processed in a manner that complies with the Privacy Act, the Privacy Regulation, and the commitment to privacy that has long been a hallmark of our company.
b. Legal Basis for, and Purpose of, Data Processing
The purposes for which your data will be processed by us are:
b1. Managing Requests
By processing the personal data you supply, we will be able to respond to your enquiries regarding:
- the characteristics, nature, or price of products in which you have expressed an interest, or those of related products in any instance where the product you seek is temporarily or permanently unavailable or out of stock, or with respect to any programme or event produced by Bruni Glass S.p.A.;
The legal basis for such processing is the execution of pre-contractual procedures undertaken at your request.
b2. Marketing, Direct Sales, and Mailing of Advertising Materials
Upon receiving your consent, and processing the data supplied by you, we may send you information on our commercial activities, including our products, or send you promotional information, offers related to our products, as well as invite you to industry trade shows, or to company events we would like for you to attend, all of which would be sent – be it manually or electronically – via email or regular post.
Even where you have provided your consent, you always have the right to withdraw it thereafter by sending a request to Bruni Glass S.p.A. in the manner described in point (h) herein, both with respect to sending automated advertising materials, as well as for direct advertising using traditional methods.
You may also easily object to further mailings by exercising your “opt-out” rights, using the methods appearing in each type of communication with which the advertising materials in question are sent.
Once consent has been withdrawn, you will receive notice of receipt on your withdrawal from Bruni Glass SpA.
Please note that, even following the exercise of such right of withdrawal, it is possible that due to technical/operational issues (e.g. the generation of contact lists competed just before Bruni Glass SpA’s receipt of the withdrawal), you may continue to receive further advertising materials. Should you continue to receive advertising materials following the exercise of the aforementioned right, please alert Bruni Glass to the issue, using the contact information listed in point h below.
The legal basis for such processing is your consent to processing your personal data, which you expressed upon submitting an online contact form present on the web page appearing at the following link: Subscribe and enter Bruni's World.
c. Method of Processing
Personal data shall be processed using manual or electronic methods suitable to ensure – with respect to the purposes for which they were disclosed and collected – the security of the same, as well as to avoid unauthorised access by third parties, in compliance with national and European law. Processing is performed by the Data Controller, External Data Processors and persons in charge of the processing appointed on a case-by-case basis.
d. Nature of Your Submission
Submission of data for the purposes listed in point (b1), supra, is mandatory as the items requested are necessary in order to respond to your enquiry. Should you refuse to submit such data, you will not be able to receive information on the products in our catalogue in which you have expressed interest.
Submission of data for the purposes listed in point (b2), supra, is optional, but it a necessary requirement for being able to receive advertising materials from Bruni Glass S.p.A. Should you fail to provide consent thereto, you will still be able to browse BruniGlass.com and submit enquiries of your own accord to Bruni Glass S.p.A.; on the other hand, you will not be able to receive the aforementioned advertising information.
Please do not send any sensitive data (i.e. information from data including but not limited to ethnic origin or race, religious creed, political opinions, party or union affiliation, or membership in any religious organisation or association, or from which any philosophical, political, or labour-union sentiments, or health status might be inferred or derived) while using any interactive service herein. If any sensitive data is in fact submitted, it will be deleted immediately.
e. Processing Entities and Data Disclosure
Your personal data may be disclosed to Bruni Glass S.p.A.’s employees and/or contractors who are tasked by Bruni Glass S.p.A. itself with carrying out operations in the pursuit of the processing purposes listed in (b.1) and (b.2), supra.
Furthermore, IT and website-management contractors, outsourcers, professionals, and independent contractors, as well as marketing email / text-messaging service providers, may likewise have access to the data (where you have consented to the same).
These entities, formally appointed by Bruni Glass S.p.A. as Data Processors, Persons in charge of the processing and/or System Administrators, shall process your personal data in compliance with, and exclusively for the purposes listed in the present notice, and under the supervision and control of Bruni Glass S.p.A. itself.
The complete and updated list of entities to whom your personal data has been disclosed may be requested of the Data Controller, who can be reached at the email address listed in point h, infra.
In order to manage your enquiries, your personal data may also be transferred to Independent Data Controllers with a registered office in their country of origin, and specifically:
- Bruni Glass France Sas, 1214 Chemin du Gheit 06390 Contes, France.
- Bruni Glass Vidremar, S.L. Domicilio social: Avenida de Brasil n°17, planta 12, 28020 Madrid - Sede Comercial y administrativa: Av. Diputación n° 17, 46892 Montaverner, Valencia (España).
- H Erben Limited, Lady Lane IP7 6AS Hadleigh Suffolk, Great Britain.
f. Data Dissemination
The Data Controller shall not disseminate or broadcast your data.
g. Transfer of personal data overseas
Your personal data may be transferred abroad to countries that are not members of the EEA (European Union, Iceland, Liechtenstein and Norway) and specifically to Berlin Packaging LLC, with registered office in 525 West Monroe St. Chicago, IL 60661, based on a Data Controller / Data Processor data-transfer agreement, which includes boilerplate approved for such purposes by the European Commission, executed between Bruni Glass S.p.A. (Data Controller / Exporter) and Berlin Packaging LLC (Data Processor / Importer) a copy of which may be requested of the Data Controller, who may be reached via the contact information appearing in point h., infra, with an attendant guarantee of processing of personal data in compliance with European standards. Pursuant to that contract, Berlin Packaging LLC has thus been appointed a Data Processor pursuant to Art. 29 of the Privacy Act and – beginning 25/05/2018 – Art. 28 of the Privacy Regulation, and therefore, these are exportable data based on instructions provided by Data Controller Bruni Glass S.p.A..
h. Rights of the Data Subject
Please note, finally, that you have the option at any time to exercise your statutory rights as listed below:
- Access the data submitted;
- Secure the correction of any supplied data, or the erasure, or anonymisation of the same, or to block any personal data processed in violation of the law, or beyond the scope of permissible processing for your personal data;
- Object to the processing of personal data;
- Withdraw your consent to the same;
- Obtain portability of your personal data;
- Determine whether your personal data exists in the system, be notified of its content and its provenance, verify the accuracy of the same and thereupon ask that it be supplemented or updated, be notified of the purposes and methods of processing, the logic applied (where electronic supports are used), the identifiers on the Data Controller, Data Processors, persons entrusted with the processing, and DPO if appointed;
- File a complaint with the authorities (Data Protection Authority);
- Object to any automated decision-making process used on natural persons, including profiling;
- Be notified promptly of any breach of your personal data;
Requests should be sent to:
- via email: email@example.com
- via fax: +39.02.484.3651
- or via post: Viale C. Colombo 12/14 - 20090 Trezzano s/N (MI) Italy
i. Data Retention Period
Data submitted by your for the purpose listed in (b1), supra, shall be retained for the time necessary to carry out your enquiry, and thereafter for the time necessary to perform under the contract (if a contract has been executed) following your enquiry. Only where you have further provided consent to us for the purpose listed in (b2), supra, by sending an enquiry to our company, we will store you data for a period of four (4) years, which is the time estimated for the Data Controller to carry out such purposes.
Data submitted by you for the purpose listed in point (b2), supra, shall be in turn retained for a period of four (4) years, which is the time estimated for the Data Controller to carry out such purposes. If you withdraw your consent and/or if for any reason retaining your data is no longer justified based on the assessments conducted (assessments based on necessity, proportionality, adequacy and relevance of the processing) the Data Controller will promptly erase or anonimyse your personal data.
J. Data Controller
The Data Controller is Bruni Glass S.p.A., by and through its pro-tempore legal representative, with registered office in MILAN, Viale Colombo, 12/14 - 20090 Trezzano S/N (MI), e-mail: firstname.lastname@example.org.