Privacy information
Privacy policy
Dear Customer,
With this privacy policy, Brawo S.p.A. (hereinafter also "Brawo", "the Company", or "the Data Controller") intends to describe, in compliance with Art. 13 of EU Regulation 2016/679 "Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data" (hereinafter "EU Regulation"), the management methods adopted by the Company with regard to the processing and protection of personal data provided by its customers as "data subjects". The EU Regulation requires that anyone processing personal data is required to inform the data subject of the data processed and the relevant information regarding such processing. In any case, processing must be carried out in accordance with the principles of fairness, lawfulness, and transparency, protecting the personal privacy and inalienable rights of the data subjects.
We therefore provide you with the following information.
DATA CONTROLLER
The Data Controller is Brawo S.p.A., with registered office in Pian Camuno (BS) – 25050, Via XXV Aprile, no. 36, Tax Code: 00483130175, VAT No.: 00566320982, Tel. 0364/591556.
TYPE OF DATA PROCESSED
The data collected by the Data Controller are exclusively common personal data (for example, personal details, company affiliation, accounting data, bank details, data relating to the sales relationship, email addresses, etc.).
LEGAL BASIS AND PURPOSE OF PROCESSING
The personal data requested from you by the Data Controller are necessary for the conclusion and performance of the contract to which you are a party. Specifically, your personal data may be processed for the following purposes:
a) activities preliminary to the conclusion of the contract;
b) activities related to the execution of the contract, such as processing, operational, and management requirements—within the limits established by laws or regulations—necessary for the Company's operational and administrative activities, or legal obligations related to civil, tax, and accounting regulations, administrative management of the relationship, fulfillment of any contractual obligations, and technical support and information regarding the products and services covered by the contract;
c) tax requirements, payment for the service/product provided, and the application of laws and regulations in general;
d) information, marketing, promotional, and advertising activities relating to the products and services offered by Brawo;
e) market analysis, statistical, and financial assessments.
CONSEQUENCES OF FAILURE TO PROVIDE DATA
Failure to provide data for the purposes referred to in letters a), b), and c) will make it impossible to conclude and perform the contract between the parties.
For the purposes referred to in letters d) and e), the data subject may object to the processing at any time by exercising the right of withdrawal in the forms and ways indicated in this policy.
PROCESSING METHODS
Data processing may be carried out with or without the aid of electronic or automated means and will include all the operations envisaged in Article 4, paragraph 2, of the EU Regulation (collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of data) necessary for the processing in question, including disclosure to the parties listed in the following section "Disclosure of Data."
The data will be recorded and stored in both paper and electronic archives, in accordance with the principles of fairness, lawfulness, and transparency, and with organizational systems consistent with the purposes of the processing. Furthermore, to protect data from destruction or loss (even accidental), to guarantee its integrity and confidentiality (including against unauthorized access or disclosure), and in general to safeguard the rights of the data subject, the Data Controller has adopted technical and organizational security measures, in accordance with the provisions of the EU Regulation (with particular reference to Articles 24, 32, and 35).
DATA DISCLOSURE
The personal data you provide may be disclosed:
DATA DISSEMINATION AND TRANSFER
The personal data referred to for the purposes indicated above will not be disseminated or transferred outside the European Union.
DATA RETENTION PERIOD
The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes, except for the period required for administrative and accounting purposes, which is for a maximum of 10 years for the sole purpose of fulfilling legal obligations.
DATA STORAGE LOCATION
Personal data will be stored at the Data Controller's operational headquarters and, in any case, within the European Union.
DATA SUBJECT RIGHTS
The data subject to whom the personal data refers has the right to request and obtain, at any time, from the Data Controller, access (Article 15 of the EU Regulation), rectification (Article 16 of the EU Regulation), and erasure (right to be forgotten) (Article 17 of the EU Regulation) of their personal data. The data subject also has the right to restrict the processing of personal data (Article 18 of the EU Regulation), the right to data portability (Article 20 of the EU Regulation), and the right to object, for legitimate reasons, to their processing (Article 21 of the EU Regulation). In any case, the data subject has the right to lodge a complaint with the Data Protection Authority, as provided for by Article 77 of the EU Regulation, or to take appropriate legal action pursuant to Article 79 of the EU Regulation if you believe that the processing of your personal data has violated the provisions of the EU Regulation.
RIGHT OF WITHDRAWAL/ERASURE
For the purposes referred to in points (d) and (e), the data subject may object to the processing at any time by withdrawing the consent given in accordance with Articles 15 et seq. of the EU Regulation and Article 130 of Legislative Decree 196/2001 (on unsolicited communications). This, however, does not affect the lawfulness of the processing carried out before the withdrawal/erasure.
HOW TO EXERCISE YOUR RIGHTS
You may exercise the rights identified above at any time by sending, for the attention of the Internal Privacy Officer: an email to privacy@brawo.it or a registered letter with acknowledgement of receipt to Brawo S.p.A., Via XXV Aprile, n. 36, Pian Camuno (BS) – 25050.
Information on the Processing of Personal Data, Pursuant to Article 13 of EU Regulation 2013/679
With this information notice, Brawo S.p.A. (hereinafter also "Brawo", "the Company", or "the Data Controller") intends to describe, in compliance with Article 13 of EU Regulation 2016/679 "Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data" (hereinafter "EU Regulation"), the management methods adopted by the Company with regard to the processing and protection of personal data provided by its suppliers as "data subjects". The EU Regulation requires that those processing personal data are required to inform the data subject of the data processed and the relevant information regarding such processing. In any case, processing must be carried out in accordance with the principles of fairness, lawfulness, and transparency, protecting the personal privacy and inalienable rights of the data subjects.
We therefore provide you with the following information:
DATA CONTROLLER
The Data Controller is Brawo S.p.A., with registered office in Pian Camuno (BS) – 25050, Via XXV Aprile, no. 36, Tax Code: 00483130175, VAT No.: 00566320982, Tel. 0364/591556.
TYPE OF DATA PROCESSED
The data collected by the Data Controller are exclusively common personal data (for example, personal details, company affiliation, accounting data, bank details, data relating to the sales relationship, email addresses, etc.).
LEGAL BASIS AND PURPOSE OF PROCESSING
The personal data requested from you by the Data Controller are necessary for the conclusion and performance of the contract to which you are a party. Specifically, your personal data may be processed for the following purposes:
a) activities preliminary to the conclusion of the contract;
b) activities related to the execution of the contract, such as processing, operational, and management requirements—within the limits established by laws or regulations—necessary for the Company's operational and administrative activities, or legal obligations related to civil, tax, and accounting regulations, administrative management of the relationship, fulfillment of any contractual obligations, and technical support and information regarding the products and services covered by the contract;
c) tax requirements, payment for the service/product provided, and the application of laws and regulations in general.
CONSEQUENCES OF FAILURE TO PROVIDE DATA
Failure to provide data for the purposes referred to in letters a), b), and c) will make it impossible to conclude and perform the contract between the parties.
METHODS OF PROCESSING
Data processing may be carried out with or without the aid of electronic or automated means and will include all the operations provided for in Article 13 of the GDPR. 4, no. 2), EU Regulation (collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of data) necessary for the processing in question, including disclosure to the parties listed in the following section "Disclosure of Data." No data profiling activities are performed.
The data will be recorded and stored in both paper and electronic archives, in accordance with the principles of fairness, lawfulness, and transparency, and with organizational systems consistent with the purposes of the processing. Furthermore, to protect the data from destruction or loss (even accidental), to guarantee its integrity and confidentiality (including against unauthorized access or disclosure), and in general to safeguard the rights of the data subject, the Data Controller has adopted technical and organizational security measures, in accordance with the provisions of the EU Regulation (with particular reference to Articles 24, 32, and 35).
DATA DISCLOSURE
The personal data you provide may be disclosed:
DATA DISSEMINATION AND TRANSFER
The personal data referred to for the purposes indicated above will not be disseminated or transferred outside the European Union.
DATA RETENTION PERIOD
The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes, except for the period required for administrative and accounting purposes, which is for a maximum of 10 years for the sole purpose of fulfilling legal obligations.
DATA STORAGE LOCATION
Personal data will be stored at the Data Controller's operational headquarters and, in any case, within the European Union.
DATA SUBJECT RIGHTS
The data subject to whom the personal data refers has the right to request and obtain, at any time, from the Data Controller, access (Article 15 of the EU Regulation), rectification (Article 16 of the EU Regulation), and erasure (right to be forgotten) (Article 17 of the EU Regulation) of their personal data. The data subject also has the right to restrict the processing of personal data (Article 18 of the EU Regulation), the right to data portability (Article 20 of the EU Regulation), and the right to object, for legitimate reasons, to their processing (Article 21 of the EU Regulation). In any case, the data subject has the right to lodge a complaint with the Data Protection Authority, as provided for by Article 77 of the EU Regulation, or to take appropriate legal action pursuant to Article 79 of the EU Regulation if you believe that the processing of your personal data has violated the provisions of the EU Regulation.
RIGHT OF WITHDRAWAL/ERASURE
For the purposes referred to in points (d) and (e), the data subject may object to the processing at any time by withdrawing the consent given in accordance with Articles 15 et seq. of the EU Regulation and Article 130 of Legislative Decree 196/2001 (on unsolicited communications). This, however, does not affect the lawfulness of the processing carried out before the withdrawal/erasure.
HOW TO EXERCISE YOUR RIGHTS
You may exercise the rights identified above at any time by sending, for the attention of the Internal Privacy Officer: an email to privacy@brawo.it or a registered letter with acknowledgement of receipt to Brawo S.p.A., Via XXV Aprile, n. 36, Pian Camuno (BS) – 25050.