Subject: Privacy Policy for customers and suppliers provided by Caprari S.p.A. under art. 13 of European Regulation no. 2016/679

This privacy policy has been prepared and issued pursuant to art. 13 of European Regulation 2016/679 (also referred to below as the European Regulation), which introduced significant regulatory changes.
This privacy policy updates and supersedes any past versions.
In light of the above, please note that:

1. when you enter into a business relationship with our company and in the course of business, we will collect and process your personal data;
2. for the sake of clarity, we are providing the following definitions set forth by the above specified European Regulation:

Personal data: any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity;
Processing: any operation or set of operations performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.
Therefore, pursuant to article 13 of European Regulation 2016/679, our Company will collect and process your personal data as follows:

• Purposes: your data will be processed in order to fulfil accounting and tax requirements, commercial and technical tasks and perform business activities relating to the existing relationship;
• Advertising purposes: your data may also be used, with your prior express consent, to send you advertising material/messages by post, e-mail, fax, text messages and similar means. When you have given your consent, you retain the right to refuse processing of your data for such purposes at any time and free of charge;
• Methods: your data shall be processed both in hard copy and using electronic/computerised/ICT systems, in full compliance with the law, according to principles of lawfulness and fairness, and in such a manner as to protect your privacy;
• Optional provision: providing your data is optional and not mandatory;
• Consequences of refusal: if you refuse to provide your data or refuse any and all processing, you may be unable to maintain a business relationship or any kind of relationship with our company. Conversely, refusing to authorise the use of data for sending advertising material/messages will not affect existing or future relationships with our Company;
• Parties or categories of parties (recipients) which the personal data may be communicated or disclosed to: your data may be communicated to third parties for the sole purpose of fulfilling law requirements or contract obligations. Your data shall not be disseminated under any circumstances whatsoever;
• Persons authorised for processing: your data shall only be processed by duly authorised persons tasked with processing and employed in the administrative and sales departments of the Company;
• Automated decision-making processes (e.g. profiling): no automated decision-making processes are managed in any way;
• Rights of the data subject: you have all the rights set out in the European Regulation, such as the right to request access to and rectification of personal data, their erasure, restriction of processing, the right to object to their processing, as well as the right to data portability. You also have the right to lodge a complaint with the Supervisory Authority;
• Transfers to third countries: any transfer of personal data to a third country outside the European Union or to an international organisation will take place on the basis of an adequacy decision by the Commission or, in the case of the transfers referred to in articles 46, 47 or 49, second paragraph, of the European Regulation, on the basis of appropriate safeguards;
• Period of data retention: the data will be kept for the period strictly necessary to meet the requests of the data subject or in accordance with the provisions of current legislation or any contractual clauses;
• Data Controller: the data controller is the company Caprari S.p.A., with registered office in Modena (MO), Italy, at Via Emilia Ovest no. 900, in the person of its legal representative pro tempore;
• Data protection officer (DPO): the data protection officer is Mr Juri Torreggiani, with office located in Reggio Emilia, Via Piccard no. 16/G, tel. +39/0522/301169, fax 39/0522/387996: any request for clarification or information may be addressed to this person.

This privacy policy may be supplemented, verbally or in writing, with additional elements and indications as to better respond to any enquiry you may submit concerning Privacy matters and to comply with changing law and regulations.
 
Modena, 24/05/2018

The Data Controller
Caprari S.p.A.