Information related to Legislative Decree No. 196 June 30th 2003

In conformance to article 13 of Legislative Decree n. 196 dated June 30th 2003, we wish to inform you that PRIMA INDUSTRIE S.p.A. shall handle all personal data concerning your Company and that of the person/s acting on its behalf according to the terms and finalities hereunder described.

1. Data processing information
Details submitted to data processing shall be: personal, fiscal and account data, telephone and fax numbers, email addresses, bank details, information concerning the company’s structure and organization, data for the proper accomplishment of assignments, sale statistics, details for the fulfilment of requirements related to present and future contracts and/or foreseen by the law as wells as for statistic, commercial, marketing, promotional and credit safeguard purposes.
Finally data processing information can also be related to professional experience submitted through curriculum vitae.

2. Purposes of Data handling
Here follow general objectives of data handling:

2.1 – Main purpose
To carry out business arising from the supply of goods and/or services between the parties during the negotiation and duration of contracts referring in particular to their accomplishment and payment of agreed fees.
To fulfil requirements foreseen by the UE provisions, regulations and laws especially as far as accounting, fiscal, health and public order and safety issues are concerned.
To complete the procedures adopted in order to comply with the ISO 9001-2000 standards among which is the periodical customer satisfaction monitoring.
To avail of one’s rights and those of third parties where juridical, arbitral and administrative proceedings are concerned.

2.2 – Commercial objectives
Sending communications both for monitoring purposes and business relationships with customers. Carrying out Marketing planning and activity performances.
Promotional and marketing information even for those products/services not restricted to those for which the business was established for in the first place.

2.3 – Personnel selection objectives
Carrying out personnel research, selection and appraisal.

3. Data handling methods
The above data in any form it is collected, directly or indirectly from the concerned person, shall be handled in paper, electronic files, data processing and telecommunication systems and strictly organized in accordance to liabilities and objectives as per the above item.
Such data can be handled abroad and/or outside the UE.
In any case data shall be filed and handled with the aid of adequate technical and organizational instruments considered essential in order to avoid destruction and cancellation of documents and safeguard privacy. Such safety measures are detailed and described in the “Safety Programme Document” drawn in accordance to the law in force.
Data shall be kept only for the period of time necessary to accomplish duties and attaining the above finalities.

4. Data transmission
Personal data, collected aiming at attaining finalities as per item 2, can be distributed/diffused, according to each professional competence, to the following groups: natural or legal persons, public or private bodies, Income Tax Departments, Public order and safety bodies, banks, liquidation agencies, law and fiscal consultation offices, public and administration authorities concerning illegal acts, financial and transport agencies.
Persons entitled to collect such data are: employees and/or collaborators of the above companies to whom such tasks have been assigned as well as external consultants or collaborators who have been expressly instructed to handle such data in conformance to Legislative Decree 196/2003 in accordance to article 25 encl. B.

5. Official data handler
The official data handler is PRIMA INDUSTRIE S.p.A. in the person of its Managing Director Mr. Gianfranco Carbonato.

6. Responsible person for data handling
The responsible person for data handling whom to refer to, in case of assertion of rights as per article 7, is Mr Adriano Gallea, domiciled at PRIMA INDUSTRIE S.p.A., Via Antonelli 32, 10097 Collegno (TO).

7. Data collection and possible consequences arising from refusals
Data collection become necessary in order to set up and pursue business relationships established with you, as per the finalities given in item 2.1. Any possible refusal would not allow the complete or partial performances of contract liabilities agreed upon and in particular would imply PRIMA INDUSTRIE’s inability to place orders, to perform the requested services and its related invoicing.
However, according to article 24 of Legislative Decree n 196 dated June 30th 2003, the concerned person’s consensus is not required for his/her personal data handling should such data be available on public registers (e.g. registry office, income tax office, Chamber etc.), or should the person be appointed to fulfil liabilities foreseen by the law or by contracts.
For commercial and marketing finalities described in item 2.2 data conferment is not compulsory, nevertheless it will be our care, with your co-operation, to obtain an explicit consensus.
For personnel selections described in point 2.3 data conferment, and the handling of CV data is possible only if the person has explicitly given consensus by transmitting authorization with the CV.

8. Rights of the involved
The involved person bears all rights provided by article 7 of Legislative Decree n. 196 dated June 30th 2003. Attached is the text of the article.

Adriano Gallea

Article 7 – Legislative Decree no. 196 – June 30th 2003 (Right of access to personal data and other rights)

1. The person involved has the right to be given a confirmation of the existence or not of his/her personal data, even though not yet registered, and to be communicated in an intelligible form.

2. The person involved has the right to obtain information concerning:
a) Personal data source;
b) Data handling methods and finalities;
c) The logic applied in the case of electronic handling;
d)The owner’s ID details, those of responsible persons and of the appointed representative according to article 5, paragraph 2;
e) people or categories of people to whom the data may be distributed or who may become aware of it in their role of appointed State area representatives, managers or people assigned to specific tasks.

3. The person involved has the right to:
a) ask for updating and corrections or, when interested, all data integration;
b) cancel, transform in anonymous form or block data handling should any violation of the law occur, including data collected or handled for finalities where filing is not compulsory;
c) ask for anassertion stating that activities, including their contents, regarding items a) and b), have been forwarded to persons to whom data has been transmitted except when such task is impossible or requires a disproportion of means compared to the right to be safeguarded.

4. The person involved has the right, completely or in part, to oppose to,:
a) his/her personal data handling owing to well-founded and rightful reasons, even though relevant to finalities of data collecting;
b) to his/her personal data handling aiming at mailing advertising or direct sale material or for market research and commercial purposes.