Supplier Privacy Policy

We wish to inform you, pursuant to Article 13 of European Regulation (EU) 2016/679 (hereinafter GDPR), that the personal data you provide and acquired in relation to your relationship with our company will be processed in compliance with the provisions of the GDPR and Legislative Decree 196/2003 (Privacy Code) and subsequent amendments.

1. Data controller

The data controller is ELETTRA S.R.L., Tax Code and VAT No. 00629080284, in the person of its pro tempore legal representative, with registered office in Via Lisbona No. 28A/5, Padua, registered in the Padua Register of Companies, e-mail privacy@elettra.it.

2. TYPE OF DATA PROCESSED

ELETTRA S.R.L. will process your personal data. In particular, the processing will concern: common personal data, such as personal details, bank account details, telephone numbers, e-mail addresses, contact details, and your image.

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING

The collection and processing of the above personal data by ELETTRA S.R.L. has the following purposes and legal bases:

PURPOSE OF PROCESSING	CATEGORIES OF PERSONAL DATA	LEGAL BASIS FOR PROCESSING
a) to execute a contract to which the data subject is a party or to take pre-contractual measures at their request (e.g. responding to requests for contact, quotations and/or commercial information, etc.) and management of the contractual relationship	common personal data of the data subject	necessity for the performance of a contract or pre-contractual measures, for the provision of a service, or in any case the response to a request from the data subject
b) to comply with legal obligations to which ELETTRA S.R.L. is subject	common personal data of the data subject	necessity to fulfil legal obligations to which the data controller is subject
c) asserting or defending, including in court, a right of the data controller	common personal data of the data subject	legitimate interest of the data controller in protecting the company’s assets and ensuring compliance with contractual obligations

4. MANDATORY OR OPTIONAL NATURE OF THE PROCESSING

Failure to provide the data referred to in point a) may make it impossible for Elettra s.r.l. to establish and execute the contractual/pre-contractual relationship with you. The provision of data referred to in point b) and c) is necessary

5. DATA RECIPIENTS

Data processing will be carried out by ELETTRA S.R.L. internal staff, identified and authorised to process data in accordance with instructions and tasks assigned in compliance with current legislation on privacy and data security. The data may be disclosed to external parties, who will process it as data processors or independent data controllers, as applicable. Specifically, the Personal data may be processed by: banks, professionals who provide assistance or advice to the data controller. PURPOSE OF THE PROCESSING OF PERSONAL DATA CATEGORIES LEGAL BASIS FOR PROCESSING a) to execute a contract to which the data subject is a party or to take pre-contractual measures adopted at their request (e.g. respond to requests for contact, quotations and/or commercial information, etc.) and relationship management contractual Personal common data of the interested necessity for the performance of a contract or of pre-contractual measures, for the provision of a service, or in any case a response to a request by the data subject b) comply with legal obligations to which ELETTRA S.R.L. is subject Personal common data data subject necessity to comply with legal obligations to which the data controller is subject c) assert or defend, including a right of the holder in court Personal common data data subject legitimate interest of the data controller in protecting company assets and to ensure compliance with contractual obligations for administrative, accounting, tax or legal protection purposes; judicial authorities; IT service providers such as cloud services, e-mail, hardware and software maintenance services, which may also indirectly access personal data; individuals, entities or authorities to whom it is mandatory to communicate data for legal compliance. The data will not be transferred outside the European Economic Area. However, should it become necessary to transfer the data outside the EEA, this will be done in accordance with the appropriate and necessary safeguards, in accordance with applicable legislation and, in particular, Articles 44 et seq. of the GDPR. The data will be stored for the duration necessary to fulfil the purposes for which it was collected.

6. PROCESSING METHODS – STORAGE PERIOD

The personal data collected will be processed both on paper and electronically. It will be processed and stored by ELETTRA S.R.L. for the period of time strictly necessary to achieve the purposes indicated (generally no longer than 10 years from the date of the contract between the parties), except except in cases where storage for a longer period is required by current accounting, tax, civil and procedural legislation, by the competent authorities or by law; in the event of a dispute, the data will be deleted at the end of the dispute. The data subject has the right to request access to and rectification of the data, as well as to request the erasure of the data, to object to the processing of the data and to request the portability of the data.

7. RIGHTS OF THE DATA SUBJECT

You have the right to obtain confirmation of the existence or otherwise of personal data, to know its content, verify its accuracy, access the data, request its origin, correction, integration, deletion, purposes and methods of processing, updating if incomplete, incorrect or collected in violation of the law, as well as to oppose their processing on the basis of the legitimate interest of the data controller and to obtain restriction of processing; you have the right to block data processed in violation of the law and to data portability. If the processing is based on consent, you have the right to withdraw it. Requests should be addressed to the
data controller by e-mail to privacy@elettra.it or by registered letter to the
following address: ELETTRA S.R.L., Via Lisbona n. 28A/5, Padova, indicating “Privacy” in the subject line.

8. FORMS OF PROTECTION

If you believe that your personal data has not been processed in accordance with current legislation, you have the right to lodge a complaint with the Data Protection Authority, Piazza Venezia, 11 – 00187 Rome, tel. +39 06.696771, certified email address protocollo@pec.gpdp.it, or you may appeal to the judicial authorities.