PRIVACY POLICY PURSUANT TO ART. 13 REGULATION ON THE PROTECTION OF PERSONAL DATA

Last updated on 16.12.2021

Protecting the security and privacy of your personal data is important to Berlin Packaging Italy S.p.A., which acts in accordance with the laws currently in force regarding the protection and security of personal data. We trust that the information below will help you understand what kind of data Berlin Packaging Italy S.p.A. collects, how it is used and safeguarded, and with whom it is shared.

Pursuant to Art. 13 of the Regulation EU 679/2016 (“Privacy Regulation”), we therefore wish to inform you that the processing of your personal data will be based on the principles of correctness, lawfulness and transparency, protecting your confidentiality and your rights and in compliance with the current legislation on security and protection of personal data.

In particular we inform you as follows:

a.     Data Controller

The Data Controller is Berlin Packaging Italy S.p.A., in the person of its legal representative pro tempore, with registered office in MILAN, Via C.Colombo, 12/14 – 20090 Trezzano S/N (MI); email: privacy.it@berlinpackaging.com

b.     Source of personal data

The personal data in our possession are those you provide when you submit an information request and/or when you subscribe to our newsletter service via the checkboxes provided on the berlinpackaging.eu website.

All personal data will be processed in compliance with the Privacy Code, the Privacy Regulations and the confidentiality obligations that have always guided our company’s activities.

c.     Legal basis and purposes of processing

The purposes for which your data will be processed by us are as follows:

c.1.     Managing requests

By processing the data you provide, we will be able to respond to your requests for information sent to us from www.berlinpackaging.eu
The legal basis for such processing is the execution of pre-contractual measures taken at your request.

c.2.     Marketing, direct sales and sending commercial communications

Subject to your consent, we may use the data you provide to send you information about our business activities, including our products, or to send you promotional material, offers relating to our products, and invitations to trade fairs or company events in which we would like you to participate, including by automated means, via email or post. Even after having given consent, you can withdraw it at any time, by request to Berlin Packaging Italy S.p.A. using the methods indicated in the following point i. both as regards the forwarding of promotional material via automated methods and also via traditional methods.
You may also object to further mailings simply by exercising your so-called opt-out right, using the procedures contained in each type of commercial communication method used and referred ti herein.Once you have withdrawn your consent, you will receive confirmation from Berlin Packaging Italy S.p.A. that they have received the same.
Berlin Packaging Italy S.p.A. However, we would like to inform you that, even after exercising this right of revocation, it is possible that, for technical and operational reasons, (e.g. contact lists already compiled and completed shortly before Berlin Packaging Italy S.p.A. received the revocation), you may continue to receive some further commercial communications. Should you continue to receive commercial communications after exercising the aforementioned right, please report the problem to Berlin Packaging Italy S.p.A., using the contacts indicated in point i. below.
The legal basis for such processing is your consent to the processing of your data, as expressed by you when filling in the contact form at the time of your request for information and/or at the time of your request to subscribe to our newsletter service via the checkboxes provided on the pages of the berlinpackaging.eu website.

d.     Processing methods

The data will be processed manually or electronically in such a way as to guarantee their security in relation to the purposes for which they were communicated and collected, and to prevent unauthorised access by third parties and, in any case, in compliance with the provisions of national and European legislation. Processing is carried out by the Data Controller, the External Managers and those processing agents, delegated for this purpose.

e.     Nature of conferral

The conferral of data in relation to the purposes set out in point c.1. is compulsory as it is a necessary requirement in order to be able to respond to your requests and your failure to do so will result in you not being able to receive the information you have requested and in which you have expressed an interest.

The provision of data in relation to the purposes set out in point c.2. is optional, but it is a necessary requirement in order to be able to receive commercial communications from the Berlin Packaging Group. If consent is not given, you will not be able to navigate the https://www.berlinpackaging.eu Site. Spontaneous requests for information to the Berlin Packaging Group, will not be affected in any way, except that it will not be possible to receive the aforementioned commercial communications. When using the interactive services, please do not provide any sensitive data, i.e. data from which, among other things, such as racial or ethnic origin, religious beliefs, political opinions, membership of parties, trade unions, associations and organisations of a religious, philosophical, political or trade-unionist nature, or your state of health, may be inferred. Any sensitive data provided will be deleted immediately.

f.     Data subjects and Communication of data

Your personal data may come to the knowledge of employees and/or agents of Berlin Packaging Group companies charged with carrying out these  same activities necessary to achieve the purposes of processing as per paragraphs c.1 and c.2 above, for Berlin Packaging Italy S.p.A.

Suppliers of computer and logistical services functional to the operation of the site, suppliers of outsourced services, professionals and consultants, companies in charge of sending promotional emails and text messages or commercial communications (if you have consented) may also have knowledge of your data.

These subjects, formally nominated by Berlin Packaging Italy S.p.A. as agents, Processing Managers and/or System Administrators, will treat your data in respect of and exclusively for the purposes indicated in this policy document and under the control and supervision of Berlin Packaging Italy S.p.A. itself. A complete and up-to-date list of the subjects to whom your data has been disclosed may be requested from the Data Controller, whom you may contact by writing to the email address indicated in point i.

Your personal data may also be shared with companies in the Berlin Packaging Group for the business purposes mentioned in point c.2. If you have given consent.

g.     Dissemination of data

The Data Controller will not disseminate your personal data.

h.     Transfer of data abroad

Your personal data may be transferred abroad to countries that are not members of the EEA (European Union, Iceland, Liechtenstein and Norway) and, in particular, to Berlin Packaging LLC, a Delaware-based, limited liability company, with its registered office at 525 West Monroe St., Delaware, Chicago, IL 60661, on the basis of a data transfer agreement from Data Controller to Data Processor, including standard contractual clauses approved by the European Commission, entered into by Berlin Packaging Italy S.p.A. (Owner-exporter) and Berlin Packaging LLC (Manager-importer) with the consequent guarantee of data processing in accordance with European standards. Berlin Packaging LLC may process personal data coming from the European Union only on the basis of instructions provided by the Owner, Berlin Packaging Italy S.p.A. and on the basis of agreements stipulated with Companies in the Group.

i.      Rights of the data subject

Finally, we would like to inform you that you may exercise, at any time, the rights recognised to you by law, which are set out below:

  • access to data provided;
  • obtain the rectification, erasure, transformation into anonymous form or the blocking of data provided by you and processed in breach of the law, or restriction of the processing of your data;
  • oppose the processing of your data;
  • withdraw your consent;
  • obtain data portability;
  • obtain confirmation of the existence or otherwise of such data, know its content and origin, verify its accuracy or request its integration or updating, know the purposes and methods of processing, the logic applied where processing is effected with the aid of electronic tools, the identity of the owner, managers, agents and the DPO, if one is designated;
  • lodge a complaint with the supervisory authority (Italian Data Protection Authority);
  • object to automated decision-making concerning natural persons, including profiling;
  • obtain, with no undue delay, notification of a breach of your personal data.

Requests should be sent:

j.      Data retention period

The data provided by you in relation to purpose c.1 above will be kept for the time necessary to process your request for information and, subsequently, for the time necessary to fulfil the contract, if it is concluded, following your request for information. Only in the event that you, by making an enquiry to our company, have also given your consent in relation to purpose c.2 above, will your data be stored for a maximum period of two years from the last contact and in exception of any request for early deletion.

The data provided by you in relation to purpose c.2 above will in turn be kept for a maximum period of two years, which is considered adequate time by the Data Controller for the fulfilment of the purposes referred to in the above point. In the event that you withdraw your consent and/or if, for any reason, the storage of your personal data is no longer justified on the basis of evaluations carried out, taking into account the principles of necessity, proportionality, adequacy and relevance of the processing, the Controller will erase or anonymise your data without delay.