PRIVACY POLICY TO CUSTOMERS ON THE PROCESSING OF PERSONAL DATA
ART. 13 “EUROPEAN REGULATION ON THE PROTECTION OF PERSONAL DATA – GDPR” (REG. EU 2016/679)

With this document, we wish to provide you with some information on the processing of your personal
data.

Purpose of data processing
We will collect and process data to:

  1. perform the operations imposed by regulatory obligations related to the contract being signed;
  2. carry out operations connected with and instrumental to the acquisition of information preliminary
    to the conclusion of the contract;
  3. manage the relationship with the customer and for the management of accounting, orders,
    invoicing and any litigation;
  4. to archive documents as required by current regulations;
  5. do promotional and commercial activities within the limits of any consent provided and in
    compliance with current regulations.

Methods of data processing
We will respect the principles of correctness, lawfulness, and transparency. We will protect the
confidentiality and rights of the data subjects and use suitable instruments to guarantee their security.
We will treat the data referring to the data subjects with manual, computerized and telematic tools, with
logic strictly related to the indicated purposes.

Categories of processed data and legal basis
Personal identification data
To pursue the above-mentioned purposes, we will process the personal identification data (name and
surname, company role, e-mail and/or direct telephone number) (i) of the customer who is a natural
person or (ii) of the employees of the customer who is a legal person. In this case, the customer will
indicate the employees identified to carry out the activity of service delivery and management of the job
order.
For the purposes referred to in numbers 1), 2), 3) the processing is necessary to fulfil the obligations under
the contract and related pre-contractual activities.
For the purpose referred to in number 4) the processing is necessary to fulfil a legal obligation to which the
data controller is subject.
To pursue the purpose referred to in number 5) it is necessary to acquire the specific consent to the
processing.
We remind you that you can revoke the consent expressed here at any time by written communication to
the addresses below. Such revocation does not affect the lawfulness of the processing based on the
consent given before.
We invite you to communicate promptly any changes in the data to keep them up to date in our archives.

Mandatory or optional nature of providing data, consequences of a possible refusal to provide data
Providing the above data is necessary to establish, execute and manage the contractual relationship
correctly. Therefore, not providing the data makes it impossible to establish and execute the contract.
Failure to provide the data necessary for promotional activities will only result in not sending you our informative and promotional material. Still, it will not affect the execution of the contract.
Categories of subjects to whom the personal data may be communicated or who can learn about them as data processors or authorized persons; scope of dissemination of personal data
We inform you that within the limits of the obligations, tasks or purposes indicated above:

  • personal data will be processed exclusively by employees and/or collaborators of the Data
    Controller and by the Data Controller’s consultants in charge of the management of orders and the
    administrative-accounting control of the orders, of the management of the quality system and for
    the related activities, in compliance with the provisions of the law also with regard to the security
    measures to protect and safeguard the data themselves;
  • the data will not be disseminated in any way unless otherwise agreed in writing.

We may communicate and disseminate personal data to perform legal obligations.
Outside of this hypothesis, personal data may be communicated in Italy and/or abroad to:

  • professionals and consultants, consulting companies, factoring companies, credit institutions, debt
    collection companies, credit insurance companies, commercial information companies, companies
    operating in the transport sector;
  • public and private entities, also as a result of inspections or audits (e.g. Financial Administration,
    Tax Police, Judicial Authorities, Social Security, Chamber of Commerce, etc.);<\li>
  • subjects who can access the data under the provision of law.

Transfer of data outside the European Economic Area
Personal data may be transferred to countries outside the European Economic Area exclusively for
technical needs, in any case to subjects based in countries recognized as “adequate” by the European
Commission, or with the stipulation of specific Standard Contractual Conditions in the text approved by the
European Commission.

Period of data retention
The data provided will be kept in our archives for the time thus determined:

  • for the purposes referred to in numbers 1), 2), 3) and 4): 10 years from the conclusion of the
    contract, as established by art. 2220 c.c., without prejudice to any late payment of fees and/or
    litigation justifying the extension;
  • for the purposes referred to in number 5): 24 months.

Rights of the data subject
You may, at any time, exercise your rights under the European Regulation No. 2016/679. Specifically, you
have the right:

  • to access your personal data;
  • to obtain the rectification or erasure of the same or the limitation of the processing that concerns
    you;
  • to oppose the processing;
  • to the portability of the data;
  • to revoke consent, where applicable: as specified, the revocation of consent does not affect the
    lawfulness of processing based on consent given before the revocation;
  • to lodge a complaint with the supervisory authority. For Italy, the supervisory authority is the
    “Garante per la protezione dei dati personali”.

You can exercise of your rights by sending a request by e-mail to info@fortop.it

Contact details of the data controller and indication of how the data subject can access the updated list
of data processors
The Data Controller of the processing operations is the company Fortop S.r.l., with registered office in
Corso Sempione 10, Milan, VAT no. 02001910500, which you can contact at the following addresses:

  • Ordinary mail: Via Pasquale Pardi, 9 – 56121 PISA
  • Tel: 050 893 7942
  • Fax: 050 893 7943
  • E-mail: info@fortop.it

The list of data processors, system administrators and custodians of credentials is available at the Company
Management.