Customers Privacy Policy

//Customers Privacy Policy
Customers Privacy Policy 2019-02-05T10:38:50+00:00

INFORMATION NOTICE REGARDING THE PROCESSING OF CUSTOMER’S PERSONAL DATA IN COMPLIANCE WITH ART. 13 OF THE 2016/679 EU REGULATION (“GDPR”)

Data Controller

The Cavagna Group companies that may process the Data (as defined hereinafter) in quality of Data Controllers are:

  • Cavagna Group S.p.A., with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS). Fiscal Code: 01390980173 and Vat No. 00622330983;
  • Pergola S.r.l., with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS). Fiscal Code: 01302030224 and Vat No. 01908970989;
  • Enne.Pi. S.r.l., with registered office in Via Risorgimento 1, 25080, Calvagese della Riviera (BS). Fiscal Code: 01127410171 and Vat No. 02100760988;
  • Cori Engineering S.p.A.,with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS). Fiscal Code: 01 6067001 75 and Vat No. 00641840988;
  • Kosan International S.r.l., with registered office in Via Gavardina 46/A, 25081, Bedizzole (BS). Fiscal Code: 03576660173 and Vat No. 02152100984;
  • Cavagna Group Engineering S.r.l., with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS). Fiscal Code: 03158130983 and Vat No. 031581 30983;
  • Cavi-matic S.r.l.,with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS). Fiscal Code: 01914030174 and Vat No. 00664470986;
  • Mesura Metering S.r.l., with registered office in Via Statale 11/13, 25011, Ponte San Marco di Calcinato (BS), Fiscal Code and Vat No.03996920983;
  • Bigas International Autogas Systems S.r.l., with registered office in Via Di Le Prata 62/66, 50041, Calenzano (FI) – Italy. Fiscal Code and VAT number 05061900485;
  • Greengear Global S.r.l., with registered office in at Viale Duca degli Abruzzi, 163, 25129, Brescia – Italy. Fiscal Code: 01687780906.

Where the expression “Data Controller” is used in this Information Note, such expression will refer to any of the above-listed companies whose details are indicated in the purchase order received by the supplier. Consequently, it may occur that more than one of the companies of the Cavagna Group processes Data as autonomous Data Controllers.

Contacts (for all the companies of the group):

E-mail: privacy@cavagnagroup.com

Tel.: +39 030 9663 111

Definition of “Data” and “Source of Data”

By “Data” we mean the data regarding natural persons that are processed by the Data Controller in order to execute a contractual relationship with its customers/buyers, intended as legal persons (“Customers”). By way of example, the Data may include that of the legal representative who undersigns the contract on behalf of the Customer, as well as Data belonging to Customer’s employees and consultants who are involved in the above-described activities. In this latter case, the Data source is the Customer.

Purposes of the processing

Legal basis for the processing

Data retention period

Purposes related to the establishment and the subsequent execution of a contractual relationship between the Customer and the Data Controller.

As per the legal representative’s Data: performance of the contract.

As per the Customer’s employees/consultants involved in the activities described in the contract: legitimate interest.

Contract period and, after its termination, 10 years.

In case of judicial dispute, the Data will be retained for the entire duration of the dispute until the time limit for lodging an appeal expires.

Training of Customer’s personnel.

Legitimate interest.

Contract period and, after its termination, 10 years.

In case of judicial dispute, the Data will be retained for the entire duration of the dispute until the time limit for lodging an appeal expires.

Performance of administrative-accounting obligations such as accounts and treasury management, as well as invoicing (for example the verification and registration of invoices), in compliance with the current legislations.

The necessity to fulfil a legal obligation to which the Data Controller is subject.

Contract period and, after its termination, 10 years.

In case of judicial dispute, the Data will be retained for the entire duration of the dispute until the time limit for lodging an appeal expires.

Out-of-court debt collection.

Legitimate interest.

Contract period and, after its termination, 10 years.

In case of judicial dispute, the Data will be retained for the entire duration of the dispute until the time limit for lodging an appeal expires.

If necessary, the Data will be processed in order to verify, exercise and/or defend the Data Controller’s right in court.

Legitimate interest.

Contract period and, after its termination, 10 years.

In case of judicial dispute, the Data will be retained for the entire duration of the dispute until the time limit for lodging an appeal expires.

Management of business trips or invitation to events.

Performance of a contract.

12 months from the booking date.

When the above-mentioned data retention periods expire, the Data will be destroyed or anonymized, in compliance with the technical procedures of erasure and backup.

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Provision of personal data

The provision of the signatory’s Data is compulsory in order to conclude and/or execute the contract- the refusal to provide the Data does not allow to establish a contractual relationship and/or fulfil the corresponding obligations.

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Provision of personal data

The provision of the signatory’s Data is compulsory in order to conclude and/or execute the contract- the refusal to provide the Data does not allow to establish a contractual relationship and/or fulfil the corresponding obligations.

Recipients of personal data

The Data may be communicated to external subjects operating as data controllers, by way of example: authorities and control/supervisory bodies and, in general, public or private parties legitimized to request to access the Data.

On behalf of the Data Controller, the Data may be processed by external subjects appointed as data processors, who carry out specific activities on behalf of the Data Controller. By way of example, these companies may deal with accounting, fiscal and insurance obligations, transport and postal shipping, payments and proceeds management. Other Cavagna Group’s companies, travel agencies, customs assistance, etc.

The list of the recipients of the Data is constantly updated and can be easily and freely consulted by sending a written notice to the Data Controller at the following e-mail address: privacy@cavagnagroup.com

Personnel authorized to process personal data

The employees of the deputed corporate functions may process the data in order to pursue the abovementioned scopes.

These employees have been expressly authorized to perform such processing and they have received adequate operative instructions.

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Data transfer to extra EU countries

The Data may be transferred to extra EU Countries and, in particular, to:

1) Extra-EU countries whose data protection level has been considered adequate by the European Commission in compliance with art. 45 of GDPR”

or

2) Extra-EU countries different from those indicated at point 1) upon signing the Standard Contractual Clauses approved by the Europena Commission in compliance with art. 46, 2 letters c) and d)”

A copy of the Data may be obtained by contacting the Legal Department via e-mail at the following address: privacy@cavagnagroup.com, in accordance with the modalities described at the section “Rights of the Data Subject”.

Rights of the data subject – complaint with the supervisory authority

By contacting Cavagna Group’s Legal Department via e-mail at the following address: privacy@cavagnagroup.com, the data subjects have the right to access the Data processed by the Data Controller; furthermore they have the right to rectification and or integration of incomplete data, to erasure and also to restriction of processing in cases envisaged by art. 18 of GDPR. The data subjects can also exercise the right to oppose the processing on ground relating to his or her particular situation.

If the processing is based on consent or on a contract and is carried out by automated means, the data subjects have the right to receive the personal data concerning them, which they provided to a controller, in a structured, commonly used and machine-readable format. The data subjects shall also have the right to transmit the data to another controller without hindrance, if this is technically feasible.

The data subjects have the right to lodge a complaint with the competent supervisory authority in the Member State of their habitual residence place of work or place of the alleged infringement.