Policy and request for the processing of personal data pursuant to Article 13 of the Law Decree 196/2003

In compliance with the obligations provided by the Legislative Decree 196 dated June 30, 2003 concerning the processing of personal data (the so-called Privacy Code) enforced on January 1, 2004, we hereby inform you that Industrie Associate s.r.l. with head office at the address via Giorgio La Pira 12 - 25021 Bagnolo Mella (BS) (hereinafter the "Company") will process the personal data concerning you and that were or will be communicated to us by you or others.  The processing of personal data will comply with the enforced rules and at the following conditions.

1. Purpose of the processing

The processing of personal data is exclusively intended for the following purposes:

a) for the preliminary requirements for the stipulation of sales contracts, in order to execute them and for the protection of credits arising from them;

b) to fulfil any kind of obligations required by enforced laws or regulations, in particular tax issues;

c) for operational, management and accounting purposes;

d) for the access registrations to the Company's website and to use the services offered by it;

e) for purposes of monitoring the trend of relations with customers and/or the associated risks and to improve these relationships;

f) for commercial and strategic and operational marketing purposes.

2. Processing methods

The data may include, in addition to the collection, their recording, filing, modification, communication, cancellation, distribution, etc. and will be carried out with the use of papery forms, and with the use of electronic computerised and data systems, in a manner and with instruments that guarantee the security and confidentiality of the data, in accordance with the provisions of Articles 31 and following of the Legislative Decree 196/2003, relating to “minimum security measures for the processing of personal data”.

In particular, all suited technical, computerised, organisational, logistical and procedural safety measures shall be taken as provided by the Legislative Decree 196/2003 and “Annex B” of this decree, so as to guarantee the minimum level of data protection provided by law.

In addition, the applied methods guarantee that the access to the data is permitted only to persons appointed for their treatment by our Company.

3. Providing the data

Providing the data is:

a) Mandatory to achieve the purposes related to obligations under applicable laws or other binding regulations;

b) Necessary for the correct establishment and continuation of the relationship with you.

A possible refusal to provide the above data, although legitimate, could jeopardise the regular relationship with our Company and, in particular, it could make it impossible for us to execute your orders and to provide the required services and invoicing.

4. Disclosure and diffusion of the data

The disclosure of personal data collected for the purposes at issue of point 1 may occur only when:

a) this communication is mandatory to ensure the compliance with the obligations provided by law or by other binding regulations;

b) this communication is required to ensure the correct establishment or continuation of our business relationship with you.

The personal data collected to achieve the above purposes may be disclosed, within their specific competence, to public and private entities, individuals and/or legal entities, for commercial and/or for the management of information systems and/or payment systems, including third parties performing specific tasks on behalf of our Company.

In particular, the data can be communicated to the following categories: commercial networks, banks and companies specialised in managing payments, law and consulting firms, persons in charge of auditing the financial statements of our Company, public authorities or administrations for the legal fulfilments, Italian and foreign suppliers, financing and transport companies, thirds in charge of checking the quality of the logistic-commercial flow as well as other companies that are part of our Group.

The data can also be transferred but only in an aggregate, anonymous form and for statistical purposes.

5. Data transfer abroad

Within the limits tightly necessary to execute the contractual relationship with you, your personal data may be disclosed to third parties (such as suppliers) abroad, within or outside the European Union.

6. Rights for the involved party

According to Article 7 and following of Legislative Decree 196/2003, you have the right, among others, to:

a) obtain confirmation of the existence of your personal data and their communication in an intelligible form;

b) obtain from the Data Controller or the Data Processor:

 i) information on the origin of personal data, on the purposes and methods for the processing, on the logics applied in the case of processing with electronic instruments;

 ii) information on the identity of the Data Controller and Data Processor as well the representative designated by a foreign entity for the data processing in Italy;

 iii) information on the persons or categories of persons to whom the data may be communicated or who may become aware of these as a designated representative on the territory of the State, managers or agents.

c) obtain:

 (i) The updating, rectification or integration of data concerning you;

 (ii) the cancellation, anonymisation or blocking of unlawful processed data, including data for which the preservation is unnecessary for the purposes for which the data were collected or subsequently processed;

 (iii) The declaration that the operations of which at the above points (i) and (ii) have been notified, even with regards to their content, to those to whom the data were communicated or disseminated, except for the case in which this requirement is impossible or involves the use of means that are clearly  disproportionate to the protected right.

d) oppose, in whole or in part:

 i) for legitimate reasons, to the processing of your personal data, even if pertinent to the collection purposes;

 ii) the processing of your personal data, provided for the purposes of commercial information or to receive advertising materials or direct sales or for market research or commercial communications.

The above rights may be exercised either directly or through your representative in the forms provided for in Articles 8 and 9 of Legislative Decree 196/2003

7. Holder and Responsible

We also confirm that the data controller is the Company, in the person of its legal representative, with main office in via Giorgio La Pira 12 - 25021 Bagnolo Mella (BS).

The processor of the concerning you, domiciled for this office at the Company’s main office, is the Manager of the Computer Services who can be contacted by e-mail:

8. Consent the processing

Lastly, we would like to inform you that agreeing to the processing of personal data in the way and for the purposes outlined above is optional. If you refuse to consent, our Company will not process your  personal data, but only use them in accordance with the obligations provided by Law or other legislations with the possible consequences described in the above paragraph 3.

As you know, the Legislative Decree 196/2003 provides that the processing of personal data is made with the consent of the person involved except in cases of exclusion specifically indicated by law. For this reason, please fill in the electronic form requesting the consent as a receipt of the information referred to in this letter, as well as expressing the consent to the processing of personal data.