Data protection information according to Article 13 GDPR
We take the protection of your personal data very seriously. We process your data in accordance with the EU General Data Protection Regulation (GDPR) and the Data Protection Adaptation and Implementation Act EU.
Information on personal data processing
Your privacy is important for us. We will only use the information that you provide to us during interactions, whether on-line, on the phone, or at our offices, to improve our services and your experience with us, Eceplast may contact you, from time to time, via email or by phone with news on our products or business, based on any previous dealings with you and which we feel may be of interest to you.
Pursuant to art. 13 of Legislative Decree no. 196/2003 (the personal data protection code), as well as art. 13 of Regulation (EU) 2016/679, Eceplast s.r.l., with registered office at Via della Repubblica Italiana, 110 – 70032 Bitonto BA, (hereafter, “Eceplast” or the “Controller”), as the Controller hereby provides you with information on the processing of your personal data.
The personal data provided by you and that we may acquire at a later date, will be processed by the Company maintaining your confidentiality and in compliance with the law using manual, computerised and electronic tools, with logic strictly related to the purposes of the processing.
TABLE OF CONTENTS
- Personal data we collect and process
- Purposes of the processing
- Legal basis for the processing of personal data
- Categories of persons to whom personal data may be disclosed or become aware of them in their capacity as processors or persons in charge of the processing.
- Retention period
- Rights of the data subject
- Can my personal data be transferred abroad?
- Security measures for your personal data
- Cookies and similar technologies
- Links to third-party websites
1. PERSONAL DATA WE COLLECT AND PROCESS
The personal data that we may collect about you through our websites falls into the following categories:
Information provided voluntarily
Some parts of our websites may require that you voluntarily provide personal data, for example when filling in a web form:
- full name, company name, position and address, country;
- personal data (phone number, e-mail, fax, etc.);
- name, address, service, contact details and other information concerning a company that you represent and, where applicable, your position at the company;
- VAT number, tax i.d.;
- user preferences (e.g. website language settings);
- marketing preferences;
- service requests and orders made;
- signing up to newsletters, enrolment in promotions, use of special offers, etc.
- survey responses, reviews, evaluations and other types of feedback provided;
- content and communication sent through websites, including information published in social media, on websites or otherwise shared with Eceplast and/or other users;
- other information posted or downloaded on websites (e.g. Content entered in an online form, photos downloaded).
Automatically collected information
We may collect certain information automatically on the device that you use to access our websites. In some countries, including those in the European Economic Area, this information may be considered personal data under applicable data protection laws.
In particular, the information we automatically collect may include:
- IP address, operating system, browser type, browser version, browser configuration, ISP name and other types of information relating to the device and the connection used to identify the type of browser in order to guarantee the correct exchange of data and comfortable user experience.
- URL and IP address websites used to access or websites or which were directed to our websites, in particular the date and time;
- secondary pages that you had access to while visiting our websites, links monitored on websites, in particular the date and time;
- the full Uniform Resource Locator (URL) clickstream to, through, and from our Web site, in particular the date and time;
- purchase history, including transactions initiated and completed;
- search terms entered and services/products viewed or searched on the websites.
Collecting this information allows us to know more about visitors to our websites, to understand where they come from and what content on our websites interests them. We use this information for internal analysis and to improve the quality and relevance of our websites for our visitors.
Some of this information may be collected using cookies and similar tracking technologies, as explained in detail in the section below entitled “Cookies and similar technologies” (Section 10).
Information obtained from third-party sources
Where appropriate, we may obtain personal data about you from third-party sources (newsletters, marketing campaigns, surveys and similar). However, we collect personal data only after verifying that these parties have received your consent or are legally authorised or required to disclose it.
2. PURPOSES OF THE PROCESSING
Pursuant to articles 12 et seq. of Regulation (EU) 2016/679, Eceplast s.r.l., with registered office at Via della Repubblica Italiana, 110 – 70032 Bitonto BA, (hereafter, “Eceplast” or the “Controller”), as Controller, hereby provides you with some information on the processing of personal data, with regard to its customers and suppliers (natural persons), as well as natural persons who operate in the name of and on behalf of its customers and suppliers (legal persons), associations and entities.
Eceplast would like you to know that personal data will be processed using manual, computerised and/or electronic tools and will be based on the principles of lawfulness, fairness, transparency, purpose limitation and retention, data minimisation, accuracy, integrity and confidentiality, protecting the rights and freedoms of the data subject. Your personal data will therefore be processed with logic strictly related to the purposes listed below, in accordance with the provisions of the GDPR and Legislative Decree no. 196/2003 (Personal Data Protection Code) and, in any case, in a manner that ensures the security and confidentiality of such data.
We normally collect personal data about you only when (i) processing them is necessary for the purposes of the legitimate interests pursued by our company and does not override the interests of the data subject., (ii) we need personal data to enter into a contract with you or (iii) we have your consent to do so.
Your personal data will be processed for the following purposes:
a. compliance with obligations provided for by laws, regulations and Community legislation, or provisions issued by authorities and/or bodies entitled to do so by law;
b. compliance with obligations resulting from contracts entered into with Eceplast (e.g. bookkeeping, management and organisation of orders, arrivals, contacts, payments and reconciliation of payments);
c. purposes strictly associated with and instrumental to the management of customer relations (e.g. obtaining information prior to entering into a contract, checks and assessments on relationship results and progress, as well as on the risks connected with them, notices on new price lists);
d. other updates on our business (e.g. “service” communications concerning the publication of new catalogues, official statements, invitations to participate at trade shows, etc.);
e. to manage disputes and protect our rights, also before the court and third parties;
f. for commercial, promotional and marketing purposes, in order to explain to customers (also via e-mail, fax, telephone, sms, mms, social media, online advertising, search engine advertising and other specific web marketing activities, including through third parties) the features of our products and our business, to inform them of the incentives, promotions and commercial offers in place, also by sending promotional advertising material or related to initiatives and offers aimed at rewarding customers (including through third parties);
g. for profiling choices, needs and consumption patterns, responses to questions and requests (for example through forms filled out online), in order to send commercial communications concerning products and/or services that could be of interest to customers; or to improve and personalize our websites and our marketing activities; for the management of rewards, studies, lotteries, contests or other promotional activities and events;
h. to market our products and services that are similar to those already provided;
i. to measure the level of customer satisfaction;
j. to manage the Company’s business, its organization and evaluation of its value, as well as for the assessment of whether to make any legal or structural changes, in whole or in part (even just one branch), to the Company, mergers, demergers and other similar exceptional events that may involve the Company as a whole or even only part of it;
k. for research and studies related to target markets, segmenting our customer portfolio and developing dedicated offers, products and services (processing data through our CRM); for economic and statistical analyses on the sales of our products and/or services; for analysis of online traffic and the effectiveness of our online and offline promotional activities;
l. for audits and certification of optional financial statements;
m. for archiving historical data.
n. to ensure the security of our company and our personnel and help to maintain the quality of service (calls to our customer services can be monitored and recorded for authentication, security, quality and training purposes);
o. for other activities expressly accepted and in any case as permitted by applicable law.
The provision of your personal data for the purposes referred to in points a), b), c) and e) is mandatory. If you refuse to provide your data for these purposes Eceplast will not be able to establish and/or continue the contractual relationship with you. The provision of the data necessary to achieve the purposes referred to in point d), f) is, however, optional. If you refuse to provide this data, there are no consequences, but it would hinder the management of the relationship, preventing us, among other things, to update you on our activities and to share other official communications with you. The provision of data for other purposes is optional; your refusal would have no consequences for you, other than preventing the processing of your data for the respective purposes.
3. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
The legal basis for processing your data is provided by law for the purposes in point a) and by the contract for the purposes in points b), c), d) and h). Similarly, the communication of data to public authorities has its legal basis in law. Failure to disclose your data to the authorities could result in sanctions for the Company or make it impossible to establish an employment relationship with us.
The processing of your data for the purposes in points e), i) j), l) are instead based on our legitimate interest in the efficient management and operation of our economic activities and the protection of our rights.
Processing for the other purposes listed above is instead based on your consent, which you can withdraw at any time without prejudice to processing activities previously carried out.
4. CATEGORIES OF PERSONS TO WHOM PERSONAL DATA MAY BE DISCLOSED OR BECOME AWARE OF THEM IN THEIR CAPACITY AS PROCESSORS OR PERSONS IN CHARGE OF THE PROCESSING.
For the aforementioned purposes, your data may be communicated in Italy and transferred abroad, including to countries outside the European Union, to the following categories of recipients:
a. public authorities and supervisory and control bodies; we may share personal data when we believe that such sharing is necessary to comply with applicable laws or regulations, to exercise, establish or protect our rights recognized by law or to protect your vital interests, rights or security of our websites, other users or third parties (e.g., to protect against fraud). These include, but are not limited to cases where we are required to share personal data by law or by an executive order of courts, law enforcement agencies or other regulatory agencies.
b. other Company offices or parties related to the Company, parents, controlled undertakings, affiliates or in any case, forming part of the Eceplast company;
c. Eceplast employees and/or consultants who carry out activities involving the processing of your data for the aforementioned purposes (e.g. administrative staff and/or back office staff) and will be specifically appointed by the Controller, Processors or Persons in charge of processing. The data will not be disclosed further. Your data may also be transferred abroad, including outside the European Union and in particular to the United States. Some of these countries are considered by the European Commission as guaranteeing an adequate level of protection; in other cases, the Company will provide for the transfer of data based on the contractual clauses approved by the European Commission to protect its data. Transfer to the United States is based on the Privacy Shield principles.
d. parties who collaborate in the performance of our activities or who provide services to our Company (involved in tasks of a technical or organisational nature or in providing IT service, company agents and other collaborators carrying out sales and commercial activities on behalf of the Company, parties involved in customer support activities; external parties entrusted with payment management; firms and companies in the field of assistance and advice, including legal. Those third parties who provide our Company with data processing services or otherwise process personal data for the purposes described in this privacy notice have access only to the personal data needed to carry out their activities and only to perform these activities. Our Company takes the necessary steps to ensure that these third parties are aware of and comply with these obligations and that they process your personal data in accordance with the requirements of applicable data protection laws and adopt satisfactory technical and organizational security measures.
• Solo / Sales force / Microsoft dynamics 365 CRM
• Mail Chimp
• Survey monkey
e. parties who send, pack, transport and sort communications to the data subject;
f. parties who carry out marketing and commercial promotional activities on behalf of Eceplast and market research companies;
g. parties who carry out filing and data entry activities;
h. parties who carry out checks, audits and certification of activities carried out by Eceplast, also in the interest of its Customers and users;
i. parties who provide services for credit risk management and fraud control (such as data processing centres, banks, risk centres, debt collection companies, law firms);
j. banking institutions and credit card companies;
k. Personal data may also be known to potential buyers and/or consultants of Eceplast. During the development phase of our Company’s business, we may sell all or part of our websites or the company. Our Company may disclose your personal data to an actual or potential buyer (and its agents and consultants) in connection with a payback, merger or purchase, actual or potential, of any part of our business or websites, provided that our Company informs the buyer that he or she should use your personal data only for the purposes set out in this privacy notice.
The parties belonging to the above categories process personal data as separate Data Controllers or as Processors or persons in charge of processing if they are specifically appointed by Eceplast for this purpose.
The Processors are the Head of Sales and Marketing and the Head of Finance and Control of the Eceplast division, who you can contact to exercise your rights in accordance with the law or by email at the following address: firstname.lastname@example.org. The complete list of external processors and third parties to whom data may be communicated is available at Eceplast’s head office located at Strada Provinciale 115, km 15,050 – 71029 Troia FG.
6. RETENTION PERIOD
Data processed for the purposes referred to in points a), b), c), d), e), h), i), j), l) and m) will be kept for the entire duration of the contractual relationship with our Company, as well as after its termination for the period necessary to protect the Company’s rights and allow it to demonstrate fulfilment of its obligations.
Data processed for the purposes referred to in points f), g), k), n), and o) will be processed for a period of 24 months or in any event until you revoke your consent and/or do not object to the related processing, as well as subsequently to allow the company to demonstrate compliance with the law in the related processing activities.
7. RIGHTS OF THE DATA SUBJECT
You may at any time exercise the rights provided by law in favour of data subjects including the right to access your data, to obtain the rectification or erasure or restriction of processing of your data or to oppose its processing, as well as the right to the portability of your data.
You may also exercise the following personal data protection rights:
- To access, correct, update or request erasure of your personal data; you can do so at any time by contacting our Company at the contact address indicated in point 5 of this document. Upon receipt of your written or e-mail request and of sufficient information to enable us to identify your personal data, we will communicate the personal data in our possession. You have the right to request that your inaccurate personal data be corrected or to delete personal data which you believe that our Company no longer has lawful grounds to retain it, as required by current legislation. Requests to erase personal data are subject to the legal and ethical obligations related to the registration and retention of documents.
- In addition, you can object to the processing of personal data in certain situations, in particular when personal data are processed on the basis of legitimate interests.
- To ask our Company, in certain situations, to restrict the processing of personal data (i.e. to stop processing but keep the information) or to ensure personal data portability (i.e. transfer of personal data to yourself or to another party based on your request). Also in this case, you may exercise these rights by contacting our Company at the address indicated in point 5 of this document.
- To unsubscribe at any time from the marketing communications we send you. To exercise this right, click on the “unsubscribe” or “cancel” link in the marketing emails sent to you by our company. To unsubscribe from other forms of marketing (such as snail mail marketing or telemarketing), please contact us through one of the channels listed in point 5 of this document.
- To withdraw consent at any time. Termination of the contract does not affect the lawfulness of any data processing we have carried out prior to such withdrawal and the processing of personal data carried out on a legal basis other than the contract.
- To lodge a complaint with a national supervisory authority
The Italian Data Protection Authority can be contacted at the following address:
Piazza di Monte Citorio, 121
Tel. +39 06 69677 1
Fax +39 06 69677 785
Our company responds to all requests from individuals exercising their data protection rights in compliance with applicable data protection legislation.
8. CAN MY PERSONAL DATA BE TRANSFERRED ABROAD?
Our group companies and our suppliers and third-party access partners are present all over the world. Therefore, your data may also be transferred abroad, including outside the European Union and in particular to the United States. Some of these countries are considered by the European Commission as guaranteeing an adequate level of protection; in other cases, the Company will provide for the transfer of data based on the contractual clauses approved by the European Commission to protect its data.
For example, if you are in the EU/EEA or Switzerland, the country where the beneficiary is located may be recognised as a country not providing an adequate level of protection for personal data within the meaning of the European Directive on data protection (95/46 / EC), the General Data Protection Regulation of the EU (679 / 2016) or the Federal Data Protection Act. In these cases, Eceplast guarantees a satisfactory level of personal data protection in accordance with applicable data protection laws. This includes the guarantee that the recipient follows the Privacy Shield principles (for beneficiaries in the United States). This includes the implementation of the standard contractual clauses of the European Commission applying to the transfer of personal data between the companies of our group;
Our standard contractual clauses are available on request [we have implemented satisfactory comparable safeguards with our suppliers and third-party access partners and can provide further details on request].
9. SECURITY MEASURES FOR YOUR PERSONAL DATA
We have made commitments to protect the privacy and security of the information that is provided to us and have implemented appropriate technical, physical and organisational security measures to protect against unauthorised access, breach, disclosure or loss of your personal data that we collect and process. The measures that we apply are designed to ensure a level of security appropriate to the risks represented by the processing of personal data. You should also be aware that Internet communications, such as e-mail, are not secure unless they have been encrypted.
10. COOKIES AND SIMILAR TECHNOLOGIES
We may use these technologies to show you targeted ads based on this information, a technique offered by Advertising Networks called Behavioural Targeting (i.e. “interest-based advertising”). Advertisements may be personalised to generate ads that are more relevant to users based on their online behaviour. These behaviours may then be used to inform a network and to place an ad on a website that is part of the network. Details on how you can “disable” behavioural advertising cookies are available at: www.youronlinechoices.eu
By disabling cookies from any network, you can disable the possibility for a network to deliver advertising targeted to your interests.
This notice was created in consideration of the Provision of the Italian Data Protection Authority (Garante) dated 8 May 2014 concerning “simplified arrangement to provide information and obtain consent regarding cookies” ( the “Provision”), the provisions of Regulation (EU) 2016/679 which came into force on 25 May 2018 (the “GDPR”) and the prescriptions of the Italian Personal Data Protection Code, insofar as they apply and are enforceable after the entry into force of the GDPR.
The Data Controller is Eceplast srl a, with registered office at Via della Repubblica Italiana, 110 – 70032 Bitonto BA, (hereafter, “Eceplast” or the “Controller”), ID No. and VAT ID No. IT 02095980716.
WHAT IS A COOKIE?
Cookies are small text files placed on a device when its user visits a website. At each subsequent visit cookies are resent to the website that created them (first-party cookies) or to another website that recognises them (third-party cookies). They have different purposes like, for example, allowing smooth browsing between pages, remembering favourite websites and, in general, improving browsing experience. Cookies also help provide the user with interest-based targeted marketing content. Based on function and the data subject which created them cookies can be divided into technical cookies, analytical cookies, profiling cookies, first-party cookies and third-party cookies. Cookies cannot be used to run programs or send viruses to your device.
Web beacons (also known as ‘web bugs’) are small strings of code on web pages or in our emails that provides a way to read and set cookies. Web beacons are often used in combination with cookies to facilitate the operation of our websites and emails and to collect information about online activities.
While browsing the Websites, the User may also receive cookies from third-party websites or web servers (so-called “third-party cookies”) on their terminal. This happens because the Websites may contain features such as images, maps, sounds, specific links to web pages of other domains hosted on different servers to the requested page. In other words, those cookies are placed not by our Websites, but rather by other website operators or servers. In theory, third parties may place cookies while you visit the Websites and thus obtain information relating to the fact that you visited the Websites. Click on the link for more information about using cookies.
We use Google Analytics to collect information on how users use our Sites. We do this to verify that the Sites meet the needs of users and to understand how we can improve them.
Google Analytics records information about the people who visit the site, how long they stay on the site, how they arrived at the specific site and what they click.
The following cookies are set by Google Analytics:
Name Timeout content:
number _utma randomly generated 2 years
number _utmb randomly generated 30 minutes
number _utmc randomly generated at end of browser session
number _utmx randomly generated 2 years
number _utmxx randomly generated 2 years
number _utmz randomly generated and stores information on how the user reached our site (e.g. directly or through an organic search or a paid search) 6 months
HOW TO DISABLE COOKIES
Most browsers are initially set to automatically accept cookies. Users can change this setting to block cookies or prevent cookies from being stored on their device. There are various ways of managing cookies. Users can use their browser’s technical guidelines and/or help screen to manage or change browser settings. For different devices (for example computer, smartphone, tablet, etc.), Users must ensure that each device’s browser settings are configured according to their cookie preferences. Below are several links to the online documents of the most popular web browsers:
Internet Explorer ™: http://windows.microsoft.com/it-IT/windows-vista/Block-or-allow-cookies
Safari ™: http://www.apple.com/it/support/
Chrome ™: https://support.google.com/chrome/answer/95647?hl=it&hlrm=en
Firefox ™: http://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
Opera ™: http://help.opera.com/Windows/10.20/it/cookies.html
11. LINKS TO THIRD-PARTY WEBSITES
You can see when this privacy notice was last updated by checking the “last updated” date shown at the top of this privacy notice.
If you have any requests, questions or concerns about our use of your personal data, please contact us at:
Address: Strada Provinciale 115, km 15,050 – 71029 Troia (FG)
Phone: +39 0881 97 80 80
Compliance and cooperation with regulatory agencies
We regularly review our privacy notice. Our procedures and practices comply with EU GDPR and will remain in effect when the UK leaves the EU.