Information for Customers, Suppliers and Partners

INFORMATION FOR CUSTOMERS, SUPPLIERS AND PARTNERS

DAP SIDES EUROLOGISTICA Srl, Owner of the processing of personal data of customers/suppliers/partners, informs, pursuant to and for the purposes of the legislation on the protection of personal data, of the following:

1. Nature of the processed data

The personal data of the customers/suppliers/partners of DAP SIDES EUROLOGISTICA Srl, or the data concerning the Directors, Legal representatives and representatives of the Customers/suppliers/partner companies and anyone acting in the name and on behalf of the same provided to DAP SIDES EUROLOGISTICA Srl, or otherwise acquired by the same, may be processed in compliance with the obligations of correctness, lawfulness, transparency and protection of confidentiality and integrity according to the principles and provisions of the aforementioned legislation on the protection of personal data (Code of Privacy and European Regulation 679 of 27 April 2016 – so-called GDPR). In particular, the data strictly pertinent to the obligations, tasks and purposes indicated below, which cannot be fulfilled or implemented through the processing of anonymous data or data of a different nature, will be processed.
The processing of personal data could also concern data categories (judicial proceedings) which will be treated in accordance with the provisions of the current legislation on Privacy.

2. Purpose of the processing of personal data

The personal data of customers/suppliers/partners or contact persons and/or legal representatives of companies Customers/suppliers/partners are collected, recorded, stored, communicated and archived for activities strictly related to the management of the relevant contractual relationship in order to treat and to fulfil all the obligations established by law, regulations, European legislation, provisions of the Supervisory Authorities of the sector as well as to fulfil the obligations deriving from the execution of contracts and the management of internal administrative, accounting, tax and organizational activities.

In particular, the main purposes of the processing are listed below:

1. care of all the formalities aimed at stipulating contracts with customers/suppliers/partners;
2. management of communication to and from customers/suppliers/partners for the correct execution of the relative contractual relationship;
3. regular keeping of accounting records and VAT register pursuant to law (for example, payment of invoices);
4. fulfilment of any type of obligation required by law, regulations and European legislation, especially in accounting, tax, contractual and health and safety at work and health protection, as well as any publication obligations provided for by Italian Legislative Decree 33/2013 (Consolidated Transparency Text), as updated by Italian Legislative Decree 97/2016, and by Law no. 190/2012 (Anti-corruption Law);
5. customer satisfaction surveys and market research (as a whole and in anonymous form) to improve the quality and range of services offered;

The legal basis of the processing for the purposes referred to in points a) and b) is the execution of the existing contract or pre-contractual measures of which the interested party is a party, pursuant to Article 6, c. 1 letter b). For the purposes referred to in points c) and d) the legal basis is given by the need to meet legal obligations to which the Data Controller is obliged, pursuant to Article 6, c. 1 letter c). For the purpose referred to in e) the legal basis of the processing is the legitimate interest of the owner.

3. Nature of the provision of data

The provision of data by Customers/suppliers/partners, for the purposes indicated above, is strictly instrumental to the execution of contractual relationships, and to the management of the relative contractual relationship. For this reason, any refusal or incorrect communication of one of the requested information will have the following consequences:

• the impossibility of establishing, executing and managing the contractual relationship; in particular the impossibility of fulfilling the obligations provided by the law for the purposes of keeping the company accounts, the obligations to pay the fees for supplies of goods, services and/or works (for example, payment of invoices) and, more generally, to the regular administrative, accounting and fiscal management of the company;
• the impossibility of fulfilling specific obligations and/or tasks required by law, regulations, European legislation, tax and accounting regulations, health and safety at work, public order and safety. In particular, the impossibility of complying with the provisions of the law with reference to the obligations deriving from the contractual relationship and, finally, the impossibility of fulfilling the obligations envisaged by the legislation on “anti-corruption and transparency”;
• the impossibility of asserting and/or defending a right in a court of law, as well as the impossibility of observing company procedures for the purchase of goods, services and/or works or to comply with the regulations in force on public procurement and contracts public works, services and supplies.

4. Procedure for the processing of personal data

The personal data subject to processing will be processed only by the personnel authorised to process data that operates in conformity and within the limits established by law and under the direct responsibility of the Company’s Legal Officer.
Personal data may be processed either on paper (and therefore kept in special protected archives and accessible only to authorised personnel) or with automated tools (therefore protected computer equipment accessible only to authorised personnel) in full compliance with the security measures provided for by law in force regarding the protection of personal data.
Specific security measures are observed in order to prevent the loss of the data, illicit or incorrect use and unauthorised access. In particular, the protection and confidentiality of personal data is guaranteed by the adoption, by the company, of “adequate security measures” prescribed by current legislation and indicated in the company regulations/procedures regarding Privacy.

5. Subjects to whom personal data may be communicated

The personal data processed relating to the aforementioned purposes will not be disseminated, however it may be communicated to Public Subjects and/or Economic Public Bodies and/or Bodies or Private Subjects whose activity is connected, instrumental or supportive to that of our Company or those relating to the offer(s) of the services referenced to you and for the fulfilment of the purposes for which the data was collected, as well as the obligations provided for by legal regulations, by European legislation, by provisions of the sector Supervisory Authorities as well as for the performance of institutional functions and/or for purposes of significant public interest. Additional suppliers that provide services related to the business activity and which are necessary or functional to the management of the relationship (for example IT service providers, web platform providers, etc.);

The third parties to whom the data is communicated may be appointed as Data Processors.

A complete list of the Managers and third-party companies to which your data is communicated is available at our Head Office. A copy can be requested by writing to: privacy@dapsides.it

6. Transfer of data outside the EU

Your data will not be transferred outside of the European Union area.

In the event of any Data transfer to Third Countries (outside the EU), including countries that may not guarantee the same level of protection required by the applicable Privacy Policy, the Data Controller hereby informs you that the processing will take place in any case according to one of the methods allowed by the Regulation, such as for example your consent, the adoption of Standard Clauses approved by the European Commission.

7. Time of conservation

All personal data, acquired in accordance with the aforementioned purposes, will be kept for the time strictly necessary for the fulfilment of legal obligations or resulting from the interruption of the contractual relationship between the parties, except for the case whereby the conservation for a longer duration is prescribed by a legal or necessary obligation to ascertain, exercise or defend a right of the Company in judicial proceedings.

8. Rights of the relevant party

The subjects to whom the data refer can at any time exercise, with respect to the Owner, their rights under the articles 15-22 of EU Regulation 679/2016

In particular the subjects to whom the data refers have the right at any time to obtain confirmation of the existence of the data and to know its content and origin, verify its accuracy or request its integration or updating, rectification, cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes for which the data was collected or subsequently processed;

The interested party may also request proof that the aforementioned operations have been brought to the attention, including with regard to their content, of those to whom the data has been communicated or disseminated, except in the case where such fulfilment is revealed impossible or involves the use of means manifestly disproportionate to the protected right.

Finally, the interested party, customer and/or supplier, has the right to object, in whole or in part, for legitimate reasons to the processing of personal data concerning him, even if pertinent to the purpose of the collection.

9. Complaints

The person concerned has the right to lodge a complaint with a supervisory authority, particularly in the Member State in which they habitually reside, work or in the place where the alleged violation occurred, which in Italy corresponds to the Data Protection Authority for the Protection of personal data, the references of which can be found on www.garanteprivacy.it.

10. Identification details of the Data Controller and Data Processors

The Data Controller is: DAP SIDES EUROLOGISTICA Srl, Via Sesia 18/20 20017 RHO (MI)
The data controller may be contacted for the exercise of rights at the following email address: privacy@dapsides.it