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Privacy Policy

Informative aspect in accordance with legislative decree of 30th June 2003, n.196 and with article 13 and 14 of UE regulation 2016/679 “Processing of personal data code” 


Dear customer/supplier, 

INDUSTRIA ZINGARDI SRL, with its registered office in VIA MAZZINI, 161 – NOVI LIGURE (AL), in the capacity of Holder of processing your personal data, in accordance with art. 13 of lgs. D. 30.06.03 n.196 (as a result, “privacy code”) and of UE Reg. 2016/679 (in succession UE Reg.), informs you that your data will treated with the modality and purpose as follow: 

1. Object of processing 


The Holder treaties the personal data, identifying (for examples, name, surname, business/corporate name, address, telephone, e-mail, fax, account and payment)- later, “personal data” or even “data”) reported by you during the contracts conclusion for the services of Holder. 

2. Processing purpose 


Your personal data are treated: 

  1. A) without your express consent (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) UE Reg.), for the following Purpose Service: 

  2. − conclude the ongoing contracts for the Holder services related to commercial, accounting and administrative management with you; 

  3. − comply with pre-contractual, contractual and fiscal obligations resulting from relations with you; 

  4. − comply with obligations provided for by Law, in Regulation, by Community legislation or for an order of Authority (for example in the field of anti-money laundering); 

  5. − exercise Holder rights, for examples the defense right in court; 


The personal data provided will be used within the limits and for the pursuit of purpose related to accounting, commercial and administrative ongoing relations and detection of degree of satisfaction to the service/product provided. In particular the processing aims at related deliverables and consequent upon nature of contract performance and of all commercial, accountant and administrative activity. The data conferral and its treatment are obligatory in respect to purpose related to deliverables of commercial, accounting and administrative nature. The conferral is also to be considered obligatory for the completion of commercial, accounting and administrative obligations. Any refusal to provide data for such purpose can determine the impossibility to accede to commercial, accounting and administrative relations same as legal obligations. 

  1. B) Only after your specific and discrete consent, (art. 23 and 130 Privacy Code and art. 7 UE Reg.), for the following Marketing purpose: 

  2. − send it by e-mail, post and/or text message and/or telephone contact, newsletter, commercial communication and/or advertising material about products or services offered by Holder; 


So, the data conferral is facultative to send communications or advertising material that our society can carry out even through your e-mail address or fax number. You can refuse the data treatment in any moment by sending an e-mail or a fax to the address/number below. 

Any refusal to provide the data for marketing purpose will not undermine the full ongoing performance of accounting and tax relations. 


3. Processing modality and duration 


The processing of your personal data is carried out through the transactions specified in the art. 4 Privacy Code and in the art.4 n.2 UE Reg. and exactly: collection, registration, organization, conservation, consultation, elaboration, modification, selection, extraction, comparison, utilization, interconnection, block, communication, cancellation and data distribution. Your personal data shall be subject to both paper and electronic treatment and/or automated. 

They will be the subject of treatment to principles of fairness, lawfulness, transparency and protection of your rights and confidentiality. Your personal data will be treated for the duration of contractual relation and even subsequently for the completion of all legal deliverables. 

4. Data Access 

Your data will be accessible for the purposes referred to in art. 2.A) and 2.B) to: 

- Employees and collaborators of the controller, in their internal office capacity of processing or as system administrators. 

- Administrative staff 

- Production staff 

- Tax Consultants 

- Third companies or other subjects (indicatively credit institutions, professional practices, consultants, insurance companies for insurance services, Etc.) and to every kind of bodies designated to monitoring and control with regard to the correct fulfilment of the above-mentioned purposes, performing outsourcing activities on behalf of the controller, in their external office capacity of processing. 

- Possible external entities, with which we have concluded precise agreements concerning measures to be taken to guarantee data security. Information data will be in any chance processed for fulfilment of the above-mentioned purposes only. 


5. Data Communication 

Without the necessity of expressed consensus (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett.b) and c) Reg. UE, the controller will be able to communicate his data for the purposes referred to in art. 2.A) to Supervisory Body, legal authorities, Insurance companies for insurance services provision, as well as to those entities to which communication would be legally binding for accomplishment of the above-mentioned purposes. These entities are to process data in their roles of independent controller of the process. 

Your information data will not be disseminated. 

6. Place of Data and Transfer Processing 

Your Data are located at corporate headquarters’. Any transfer due to such circumstances which are obligatory by law or for accomplishment of the above-mentioned purposes will be performed in full protection of Your interests. 

7. Nature of data transfer and consequences in case of refusal in response 

Data transfer for the purposes referred to in point 2.A) is mandatory. 

In case of their absence we will not be able to guarantee any of the services referred to in point 2.A). 

Data transfer for the purposes referred to in art. 2.B) is optional. You can therefore decide not to transfer any data or to subsequently deny the faculty of data processing already provided. In this case you will be not 

able to receive any newsletter, business communication or advertising material concerning any services provided by the controller. You will nonetheless continue to be entitled to the services referred to in art. 2.A) 

8. Data Subjects’ Rights 

In your subject capacity, you own the rights referred to in art. 7 Privacy Code and art. 15 Reg. UE, more precisely the rights to: 

-obtain confirmation of the existence of your data even if not yet registered, and their communication in an intelligible form; 

-obtain indication concerning: a) Data source; b) purposes and modalities of data processing; c) logic applied in case of processing performed by electronic means; d) details of ownership, officers and representatives designated in accordance to Article. 5, paragraph 2 Privacy Code and art. 3, paragraph 1, GDPR; e) entities and categories of entities to which personal data can be communicated or entities which can become aware of such data in their representation capacity designated in the territory of the State, or as officers or appointees; 

- obtain: a) update, rectification, and/or integration of data in case of interest; b) deletion, transformation in anonymous form or blockage in case of infringement of the law, which includes also those data the storage of which is not needed in relation to the purposes data have been collected for or subsequently processed; c) attestation indicating that processes referred to in letters a) and b) have been made available to those to whom data have been communicated or disseminated, even as far as the content is concerned, except if such accomplishment proves impossible or entails a use of means manifestly disproportionate with the protected right; 

- oppose, in whole or in part: a) on compelling legitimate grounds, the processing of relating data, albeit relevant to the purpose of collection; b) the processing of data to the purpose of sending advertising communication or direct selling or for market survey or business communication, by means of automated calling system without human intervention by e-mail and/or traditional marketing by phone calling and/or paper-based mail. It is noted that the right to oppose of the person concerned, referred to in the preceding point b) for direct marketing purposes by means of automated modalities is extended to the traditional ones and the judgement of the subject to exercise the right to oppose even in part may nevertheless be recognised. Consequently, the person concerned can decide to receive only communication through traditional modalities, namely only automated communication or neither of the two types. 

All the persons have also the right referred to in artt. 16-21 Reg. UE, if applicable (Right to have his/her personal data rectified, forgotten, right of restriction in processing, right to data portability, right to oppose), as well as the right to complain with the Authority. 

9. Data Storage periods 

The controller will process data for a period necessary to fulfil the above-mentioned purposes, yet in any case no longer than 10 years from the termination of cooperation for the Purposes of Service and no longer than 2 years from collection of data for marketing purposes. 

10. Procedure for the exercise of the rights 

All the persons will be able to exercise their rights by sending a registered letter to INDUSTRIA ZINGARDI SRL; an e-mail to the following addresses: or 

11. Controllers and Processors 

The data controller to whom you will be able to address to assert the right referred to in the above-written art. 8 is INDUSTRIA ZINGARDI SRL; the Processor is the acting Legal Representative. 




                                                                              Claudio Fuchs 


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