Privacy Policy

ANEST IWATA STRATEGIC CENTER SRL with registered office at Cardano al Campo (VA), Via degli Aceri 1-5, as Data Controller pursuant to Legislative Decree No. 196/2003 and subsequent amendments – Personal Data Protection Code (“Privacy Code”) – and to EU 679/2016 General Regulation on Data Protection applicable from 25 May 2018 – General Data Protection Regulation (“GDPR”) (hereinafter Privacy Code and GDPR are collectively referred to as “Applicable Law”) recognizes the importance of protecting personal data and considers their protection one of the main objectives of its activity.
In accordance with the Applicable Law, we provide you with the necessary information regarding the processing of the personal data you supply. This information is provided in accordance with art. 13 of the Applicable Law and Anest Iwata Strategic Center srl invites you to read it carefully as it contains important information on the protection of personal data and on the security measures adopted to guarantee their confidentiality in full compliance with the Applicable Law.
Anest Iwata Strategic Center srl informs that the processing of personal data will be based on the principles of lawfulness, correctness, transparency, limitation of purposes and storage, minimization of data, accuracy, integrity and confidentiality. Personal data will therefore be processed in accordance with the legal provisions of the Applicable Law and the confidentiality obligations provided for therein.

1. DATA PROTECTION MANAGER
Pursuant to the Applicable Law, the Data Protection Manager is Anest Iwata Strategic Center srl with registered office at Cardano al Campo (VA), Via degli Aceri 1-5.

2. PERSONAL DATA SUBJECT TO PROCESSING
Personal Data shall mean any information relating to an identified or identifiable natural person in particular by reference to a name, an identification number, location data, an online identification number or one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity.
Particular Data shall mean personal data revealing racial or ethnic origin, religious or philosophical beliefs, or trade union membership, as well as personal data disclosing genetic and biometric data and data likely to reveal health status and sexual activity and orientation.
Judicial data shall mean personal data likely to reveal criminal convictions and offences or related security measures.
Personal Data Processing shall mean 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 the collection, recording, organization, structuring, storage, adaptation or modification, extraction, review, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, erasure or destruction.

3. DATA PROCESSING PLACE
Data processing takes place at the aforementioned headquarters of the controller, at the operational offices and at identified third parties.

4. TYPES OF DATA PROCESSED
The processing relates to personal and identification data provided voluntarily by the interested party (but not limited to name, surname, address, VAT number, tax code, landline or mobile phone number, e-mail address, bank account details, etc.).

5. PURPOSE, LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING
Personal data voluntarily provided will be processed by the data controller for the following purposes:

A. Administrative and accounting. For the purposes of the application of the provisions regarding the protection of personal data, the processing performed for administrative-accounting purposes are those related to the performance of organizational, administrative, financial and accounting activities, regardless of the nature of the data processed. In particular, these objectives pursue internal organizational activities, those functional to the fulfillment of contractual and pre-contractual obligations, the management of the employment relationship in all its phases, the keeping of accounting and the application of the rules on tax matters, trade union, social security, health, hygiene and safety at work.
B. Information and promotions.
The use of e-mail information provided by the customer in the context of the sale of a product or service for the direct sale of their products or services, is allowed for the purpose of sending information and newsletters. The interested party, at the time of collection and at the time of sending each communication, is informed of the possibility of opposing the processing at any time, easily and free of charge (art. 130 paragraph 4 of Legislative Decree No. 196/03). To unsubscribe from the mailing list it will be sufficient to write at any time an e-mail to the e-mail address privacy@anest-iwata-st.com with the subject “unsubscribe from mailing list”.
C. Security, pursuant to Legislative Decree No. 81/2008, with particular reference to the identification data freely given by the visitors to our offices (name, surname, institution or company), the processing has the exclusive purpose of ensuring compliance with the corporate security procedures formally applied, even in accordance with current regulations.

6. METHOD OF PROCESSING – DATA RETENTION
The processing will be carried out in an automated and manual manner, with methods and instruments ensuring the maximum security and confidentiality, by authorized persons appointed and in charge of processing in accordance with the Applicable Law. The data will be stored for a period not exceeding the purposes for which they were collected and subsequently processed, and in any case consistent with the contractual or commercial relationship.

7. SCOPE OF COMMUNICATION AND DISSEMINATION OF DATA
The processed data will not be disseminated, except with the explicit authorization of the interested party released subject to prior information. The data may be transferred to companies contractually linked to the Data Controller and, where necessary, also to individuals inside and outside the European Union, in accordance with and within the limits of articles 42, 43 and 44 of Legislative Decree No. 196/2003. The data may be disclosed to third parties belonging to the following categories:
- persons who provide services for the management of the information system used by the Data Controller and the telecommunication networks, and who deal with technical maintenance (including e-mail and the newsletter service);
- persons and organizations that cooperate with the Data Controller to carry out training courses, by way of example teachers and professional training associations;
- freelancers, firms or companies in the context of assistance and consultancy;
- persons who carry out checks, audits and certification of the activities carried out by the Data Controller;
- competent authorities for the fulfillment of legal obligations and/or provisions of public bodies, upon their request.
The identification data processed under the corporate security procedures are not subject to disclosure, with the exception of explicit and specific requests potentially made by the competent judicial and investigative Authorities.

The subjects belonging to the aforesaid categories perform the function of Data Processor, or operate in complete autonomy as separate Data Controllers. The list of processors is constantly updated and available on request from the Data Controller.
Any further communication or disclosure will take place only with the explicit consent of the interested party.

Furthermore, during the ordinary processing activities, they will be able to access personal and identifying data and therefore the subjects expressly designated by the writer (authorized processors as per their profiles) will be aware of it.

8. NATURE OF PROVISION AND REFUSAL
With regard to the data that we necessarily need to process in order to fulfill the obligations arising from existing contracts, and the obligations provided for by laws, regulations, Community legislation, or provisions issued by the Authorities legitimated by the law and by supervision and control authorities, failure to provide such data will make it impossible to establish or continue the relationship, as such data are essential for this purpose. The provision of data to allow the controller to send commercial communications is optional; the interested party can refuse the processing at any time by exercising the rights provided for by the Applicable Law in the forms and methods indicated herein.

The controller also states that any non-communication, or incorrect communication, of any mandatory information, has the following consequences:
- impossibility of the controller to guarantee the adequacy of the processing itself to the contractual agreements for which it is performed;
- possible mismatch between the results of the processing and the obligations imposed by the fiscal, administrative and civil law to which it is addressed.
The Data Controller’s consent to the processing of the aforementioned data by Anest Iwata Strategic Center srl is not necessary to execute a contract between the parties or to take steps at the request of the data subject prior to entering into a contract; pursuant to art. 6 paragraph b) these data will be processed without the need for consent, in case of common data functional to these obligations.

9. RIGHT OF ACCESS TO PERSONAL DATA AND OTHER RIGHTS
Finally, we inform you that at any time you can exercise your rights towards the data controller under the Applicable Law (Chapter III, articles from 15 to 22), in order to obtain confirmation of the existence or otherwise of the data, to know its content and origin, to verify its accuracy, to ask for integration, updating, or correction.
Upon the occurrence of the conditions set forth in the Applicable Law, you have the right to request cancellation, processing restriction, portability, and to object, for legitimate reasons, to their processing.
More specifically: right to access (art.15), right to rectification (art.16), right to erasure/ right to be forgotten (art.17), right to the restriction of processing (art.18), right to data portability (art. 20), right to object (art. 21).
Pursuant to art. 13 paragraph 2 letter d) you are informed of the right to lodge a complaint with the supervisory authority for the protection of personal data if you find a violation of your rights.

10. CHANGES TO THIS PRIVACY STATEMENT
This information may change. It is therefore advisable to regularly check this information on our corporate site www.anest-iwata-coating.com and to refer to the latest version.

Cardano al Campo 01/10/2019