INFORMATION IN ACCORDANCE WITH ARTICLE 13 OF THE EUROPEAN REGULATION No. 2016/679 (General Data Protection Regulation)

1. Data controller

The Data Controller is FOPE S.p.A. (P.IVA 00163880248), in the person of its legal representative pro tempore, with registered office in Vicenza, via Giuseppe Zampieri 31, www.fope.com, hereinafter referred to as ‘the Data Controller’.

The Data Controller intends to provide the data subject with full information on the purposes and methods of personal data processing.

2. Modalities of personal data processing

Personal data (e.g. personal details, telephone number, email address, etc.) are processed by computer or, in any case, with the aid of computerised or automated tools and entered in the relevant databases, which may be accessed by those responsible for processing the data, in compliance with security measures and, in any case, in such a way as to guarantee the integrity, security and confidentiality of the data. Processing may also be carried out by third parties who provide specific processing, administrative or instrumental services necessary to achieve the purposes set out below.

3. Purpose of processing

The Controller will process your personal data for the following purposes

• performance of contractual and pre-contractual activities
• fulfilment of fiscal or legal obligations
• sending newsletters for information and promotional purposes;

Personal data will also be processed exclusively for purposes strictly connected with and instrumental to the fulfilment of the obligations pertaining to the aforementioned points.

The consent you have given is the legal basis for the processing pursuant to Art. 13(1)(c) of the GDPR.

4. Nature of conferment

The provision of your data for the purposes referred to in points 1) and 2) of Article 3 does not require any formal consent as it is preliminary and essential to any contractual or pre-contractual relationship.

The provision of your data for the purposes referred to in points 3) of art. 3 is optional and requires your express consent. Failure to consent will only entail the consequences described below: the impossibility of sending newsletters for informative and promotional purposes.

In any case, if you have given your express consent to authorise the Holder to pursue the purposes set out in point 3) of Art. 3, you shall remain free at any time to revoke it by sending a communication to this effect without any formality to the e-mail address privacy@fope.com. Following receipt of this opt-out request, the Data Controller shall promptly proceed to remove and delete the data from the databases used for processing for the purpose of sending newsletters and to inform, for the same purposes of deletion, any third parties to whom the data have been communicated. The mere receipt of the request for deletion will automatically be considered as confirmation of successful deletion.

5. Recipients or category of recipients of personal data

The personal data provided by you, for the purposes described above, may be disclosed to employees and/or collaborators of the Data Controller and communicated to the following parties:

1. third-party companies possibly appointed by the Data Controller to perform the obligations assumed by the latter for the implementation of the processing envisaged by the purposes referred to in points 1) and 2) of art.3;
   all parties (including Public Authorities) who have the right to access the data by virtue of regulatory or administrative provisions;
2. third-party companies that provide essential support services for the processing and have direct or indirect access to your data;
3. third-party companies appointed by the Data Controller for the processing of the data envisaged by the purposes referred to in points 3), of art.3.
4. All collaborators or suppliers used by the Data Controller for the processing of your personal data have been appropriately and legally authorised and made responsible for the methods and purposes of the processing attributed to them and will act in compliance with and in accordance with this information.

The personal data provided by you, for the purposes described above, may be transferred to commercial partners for the data processing provided for by the purposes referred to in points 3), of art.3.

The personal data provided by you and subsequently processed in relation to the management of the service are not subject to disclosure.

For the subjects indicated in points a), c) and d), only the category of recipients is indicated, as it is subject to frequent updates and revisions. Therefore, the interested parties may request the updated list of recipients by contacting the Data Controller through the channels indicated in art. 1 of this information notice.

6. Data retention periods

Your personal data will be stored for the periods defined by the relevant legislation, which are specified below pursuant to art. 13, paragraph 2, letter a) GDPR:

• for the purposes indicated in points 1), 2) of art. 3 for the periods prescribed by the laws in force and in any case for a period of no less than 10 (ten) years
• for the purposes indicated in points 3), of art. 3 for 2 (two) years from the moment of giving consent to the processing.

7. Exercise of rights by the interested party

Pursuant to Articles 13, paragraph 2, letters b) and d), 15, 18, 19 and 21 of the GDPR, the interested party is informed that he/she has the right to:

1. Access to personal data: obtain confirmation as to whether or not data concerning you are being processed and, where that is the case, access to the following information: the purposes, the categories of data, the recipients, the retention period, the right to lodge a complaint with a supervisory authority, the right to request rectification or erasure or restriction of processing or to object to the processing itself, as well as the existence of an automated decision-making process;
2. Request for rectification or erasure of the same or restriction of processing concerning you; “limitation” means the marking of stored data with the aim of limiting their processing in the future;
3. Objection to processing: object for reasons related to your particular situation to the processing of data for the performance of a task of public interest or for the pursuit of a legitimate interest of the Data Controller;
4. Data portability: in the case of automated processing carried out on the basis of consent or in execution of a contract, to receive in a structured, commonly used and machine-readable format, the data concerning you; in particular, the data will be provided to you by the Data Controller in .xml format;
5. Revocation of consent to processing for marketing purposes, both direct and indirect, market research and profiling; the exercise of this right does not in any way affect the lawfulness of the processing carried out before the revocation;
6. Submit a complaint pursuant to art. 77 GDPR to the competent supervisory authority based on your habitual residence, place of work or place of violation of your rights; for Italy, the competent authority is the Guarantor for the protection of personal data, which can be contacted via the contact details provided on the website http://www.garanteprivacy.it.

The aforementioned rights may be exercised by sending a specific request to the Data Controller via the contact channels indicated in art. 1 of this information.

Requests relating to the exercise of your rights will be processed without undue delay and, in any case, within one month of the request; only in cases of particular complexity and the number of requests may this deadline be extended by a further 2 (two) months. The exercise of rights is not subject to any formal constraints and is free of charge. The email address for exercising your rights is privacy@fope.com.

“Data Protection Officer (DPO)

The Data Controller has designated the Data Protection Officer – the so-called Data Protection Officer or “DPO” – pursuant to art. 37, GDPR, the company Top Management Consulting Srl, in the person of the legal representative Eng. Maurizio Squaiella, with registered office in 36100 Vicenza, Via Divisione Folgore n. 7, Int. 11, tax code 03947550244, which can be contacted for any information and/or request by sending an e-mail to privacy@fope.com