Privacy Customer, Supplier e Thirds

Articles 13 - 14 of EU REG. 679/2016.
PERSONAL DATA PROTECTION POLICY FOR
CUSTOMERS - SUPPLIERS - THIRD PARTIES
OF VENETA CASSETTI S.R.L.

Amended July 2018
This document is subject to amendment following the introduction of new regulations or in the case of
new processes that may be established by VENETA CASSETTI S.R.L. For updates and amendments to this
policy, please visit our website at www.venetacassetti.com and view the “Policy for Customers, Suppliers and
Third Parties”.
For all clarifications, information or to exercise the rights indicated in this policy, please contact us at
This email address is being protected from spambots. You need JavaScript enabled to view it., or write to us by recorded mail at VENETA CASSETTI S.R.L., registered offices at Via Veneto
19, 31040 Gorgo al Monticano (TV).

Index

1. General information on Privacy.
2. Definition of personal data and data processing.
3. Our data processors.
3.1 Data Controller.
3.2 Data Manager.
3.3 Data Processors.
4. Purposes of the processing and related information.
4.1 General clause on data processing.
4.2 Processing carried out for pre-contractual and contractual purposes concerning Customers.
4.3 Processing carried out for pre-contractual and contractual purposes concerning Suppliers.
4.4 Processing carried out for pre-contractual and contractual purposes concerning Customers and
Suppliers.
4.5 Processing carried out to assess CVs submitted by Third Parties.
4.6 Processing carried out to send newsletters or marketing communications for Customers, Suppliers
and Third Parties.
4.7 Processing carried out via the website concerning users (Contact Forms - Newsletters - Cookies).
4.8 Processing carried out for statistical or market analysis purposes.
5. Rights of the Customer, Supplier and Third Party.
6. Security measures.

_ _ _

1. GENERAL INFORMATION ON PRIVACY.

With this policy, the company VENETA CASSETTI S.R.L., with registered offices at Via Veneto 19, 31040
Gorgo al Monticano (TV), Tax Code no. 02483790263, - in the person of its legal representative pro tempore - as Personal
Data Controller, hereby informs you of the processing of your personal data, pursuant to EU Regulation 2016/679 which
established the regulations for the protection of natural persons with regard to the processing of their personal data.
This policy regulates the processing of personal data for the purposes described in paragraph 4 et seq. For
information on all data processing carried out via our website www.venetacassetti.com, please visit the link “Website Privacy
Policy” available on the website.
The processing of personal data is governed by the principles of correctness, legality, transparency and the
protection of the privacy and rights of Customers. VENETA CASSETTI S.R.L. undertakes to observe the aforementioned
principles and, to this end, hereby informs you that - with the exception of data processing for which your explicit consent
is required by law - by providing your personal data, you consent and agree to be bound by the terms and conditions of this
policy.
EU Regulation 679/2016 provides for increased protection for minors aged sixteen and under, whose personal
data may be processed only with the prior consent or authorisation from a parent or guardian.
In any event, VENETA CASSETTI S.R.L. wishes to provide you with certain information concerning personal
data processing, data controllers, the main processing activities carried out by the company and the rights of the data
subject.

2. DEFINITION OF PERSONAL DATA AND DATA PROCESSING.

Personal data refers to all data and information that identifies or enables the identification of a certain individual.
This includes information that may enable the direct (name, surname or tax code) or indirect (ID number or profiling
cookies, in the case of use of the website) identification of the data subject.
Personal data processing refers to any operation or set of operations which is performed on personal data or on
sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure or destruction.

3. OUR DATA PROCESSORS.
3.1 Data Controller.

The Data Controller is the natural or legal person, public authority, agency or other body that, either individually or
jointly with others, determines the methods used to process your personal data. The Data Controller is also responsible for
the security aspects of data processing. For the purposes of processing your personal data, the Data Controller is the
company VENETA CASSETTI S.R.L., in the person of its legal representative pro tempore, as identified above.
For all clarifications or to exercise your rights, please contact the Data Controller at the aforementioned addresses.

3.2 Data Manager.

Data Manager refers to a natural or legal person, public authority, agency or other body that processes personal
data on behalf of the Data Controller. The Controller has appointed the following external parties to process your personal
data:
- its accountancy film, which processes only the data necessary to comply with fiscal and accounting obligations applicable
to the Controller by law;
- the supplier of data management software, which may process your personal data during maintenance, support or system
updating procedures;
- the web agency that developed our website, which may process your personal data in the course of its site management or
email marketing activities on behalf of our company.
For further information regarding the type of data processed, the processing methods or the business name of
external Data Managers, please contact us at the addresses provided above.
The appointment of such parties and their scope of responsibility are limited to the aforementioned processing
purposes.

3.3 Data Processors

Data processors refers to the natural persons who process your personal data on behalf of the company. In this
regard, VENETA CASSETTI S.R.L. has formally appointed its employees and certain third parties as authorised data
processors. Each processor has received instruction and training relative to the types of activity carried out on behalf of our
company in order to securely process your personal data.
For more information on these Data Processors, please contact us at the aforementioned addresses.
4. PURPOSES OF THE PROCESSING AND RELATED INFORMATION.

4.1 General clause on data processing.

VENETA CASSETTI S.R.L. processes only data which is strictly necessary for the various purposes of the data
processing.
The data that you provide will not be disclosed in any way nor transferred to international organisations. Our
company undertakes not to transfer your data to Extra-EU Countries: in any case, should this occur, the transfer will be
performed with all of the necessary guarantees provided for by law (adequacy decision, binding corporate rules, contracts,
etc.). All processing activities are carried out at our company's registered offices or at the offices of the aforementioned
Data Managers.
With the exception of processing carried out for contractual and legal purposes, your personal data will not be
processed without your prior consent. In certain cases, and only if the processing is carried out to benefit the data subject in
view of his/her legitimate expectation of the same - the legal basis of the processing is the legitimate interest of our
company.
Your data will not be disclosed to third parties unless required by contractual and/or legal obligations.
The data storage period - unless in the case of revocation or objection by the data subject - shall be the service
execution period.
With the exception of cookies (please see the policy published on our website), VENETA CASSETTI S.R.L. will
not carry out any automated data processing, such as profiling, that may form the basis of decisions which have legal
implications or which may otherwise affect the natural persons involved.

4.2 Processing carried out for pre-contractual and contractual purposes

concerning Customers.

Types of data we process. Name and surname, address, tax code, VAT code, business name, address of
registered offices or operating sites, email address, telephone number, bank details, name and surname of employees of the
Customer in the case of a legal person.
Legal basis of the processing. The processing of your personal data is lawful when it is carried out: 1) to execute
pre-contractual measures adopted at the request of the data subject (your personal data may be used to provide a quote, to
contact you via telephone or email when necessary in order to arrange the offer, etc.); 2) to execute the contract (your
personal data may be used for the material execution of the contract, to contact you by email, CEM or phone when
necessary to provide the service, etc.); 3) to comply with legal obligations (your personal data may be used to prepare the
fiscal and accounting records which the company is obliged to keep by law, etc.).
Compulsory and non-compulsory data. The Customer is not obliged to provide the abovementioned data;
however, failure to provide such data will prevent VENETA CASSETTI S.R.L. from providing a quote or otherwise
performing the activities pursuant to the contract.
Data disclosure. To comply with contractual and/or legal obligations, certain aspects of the abovementioned data
may be disclosed to banking institutions (e.g. to make payments under contract), insurance companies (in the case of
complaints) and public authorities (in cases required by legal obligations, certain data may be disclosed to administrative
and/or legal bodies, etc.). To defend its rights, VENETA CASSETTI S.R.L. may also disclose such information to
solicitors. In any case, data is disclosed to data processors who have received formal training for the protection of personal
data, authorised third parties or appointed External Managers.
Data transfer to Extra-EU Countries. VENETA CASSETTI S.R.L uses independent servers located in Italy; as
such, your data will not be transferred to Extra-EU Countries. In order to provide its email service, VENETA CASSETTI
S.R.L. engages the services of companies which guarantee high levels of protection in line with European standards. In any
case, if, for the performance of certain services on your behalf, VENETA CASSETTI S.R.L. engages companies located in
Extra-EU Countries (or whose servers are located in such countries), VENETA CASSETTI S.R.L. undertakes only to use
competent and reliable suppliers with appropriate data protection guarantees.
Processing methods. Data may be processed using electronic systems (e.g. PCs, email, CEM or management
systems) and paper systems (printed documents).
Data storage period. In the case that the Customer expresses interest in a quote but does not immediately sign a
contract, the data contained in the offer will be stored for six months. If the offer is unambiguously declined, the data will
be immediately deleted. Finally, if the contract is signed, data will be stored for 10 years from the termination of the
contractual agreement in order to fulfil all legal, fiscal and accounting requirements applicable to the company by law.
Closing clause. The Customer, at the time of acknowledgement of this policy, undertakes to provide the same to
all employees who may provide their personal data to our company in virtue of the pre-contractual or aforementioned
contractual agreement.

4.3 Processing carried out for pre-contractual and contractual purposes

concerning Suppliers of good and services.

Types of data we process. Name. surname, VAT code, legal offices or operating sites, bank details, email address,
telephone numbers, name and surname of employees of the Supplier in the case of a legal person, etc.
Legal basis of the processing. The processing of your personal data is lawful when it is carried out: 1) to execute
the pre-contractual measures adopted at the request of the data subject (your personal data may be used to assess the quote
provided to us, to contact you by telephone or email, etc.); 2) to execute the contract (your personal data may be used to
make payments to your account, to contact you by email, telephone, CEM, and in any case to perform data processing
activities strictly linked to the contract); 3) to comply with legal obligations (your personal data may be processed to prepare
the fiscal and accounting records that the company is required to keep by law, etc.).
Compulsory and non-compulsory data transfer. Service Suppliers are not obliged to provide the
aforementioned data; however, failure to do so will prevent VENETA CASSETTI S.R.L. from evaluating the opportunity
of stipulating supply contracts for goods or services or proceeding with the signing of the definitive contract.
Data disclosure. To comply with contractual and/or legal obligations, certain aspects of the abovementioned data
may be disclosed to banking institutions (e.g. to make payments under contract), insurance companies (in the case of
complaints) and public authorities (in cases required by legal obligations, certain data may be disclosed to administrative
and/or legal bodies, etc.). To defend its rights, VENETA CASSETTI S.R.L. may also disclose such information to
solicitors. In any case, data is disclosed to data processors who have received formal training for the protection of personal
data, authorised third parties or appointed external Data Managers.

Data transfer to Extra-EU Countries. See paragraph 4.2.
Processing methods. Data may be processed using electronic systems (e.g. PCs, email, CEM or management
systems) and paper systems (printed documents).
Data storage period. In the case that VENETA CASSETTI S.R.L. is interested in the quote, but at the time of its
submission has no need of such a contract, data will be stored for a maximum period of 12 months; after this period, the
data will be deleted. However, in the case that the company is not interested in the quote, the data shall be deleted
immediately. Finally, if the contract is signed, data will be stored for ten years from the termination of the contractual
agreement in order to fulfil all legal, fiscal and accounting requirements applicable to the company by law.
Closing clause. The Supplier, at the time of acknowledgement of this policy, undertakes to provide the same to all
employees who may provide their personal data to our company in virtue of the pre-contractual or aforementioned
contractual agreement.

4.4 Processing carried out for pre-contractual and contractual purposes

concerning Customers and Suppliers.

Types of data we process. Name, surname, email address, telephone number, business name, registered offices
(only when necessary).
Legal basis of the processing. The processing of your personal data is lawful when it is carried out in the
legitimate interest of the Data Controller.
Compulsory and non-compulsory data transfer. Customers and Suppliers are not obliged to provide such data;
however, failure to do so will prevent the Data Controller from providing courtesy services on behalf of loyal Customers or
Suppliers. Courtesy services may include the sending of greetings cards to mark special occasions, invitations to special
events, etc. The Data Controller deems that the special relationship entered into with certain Customers or Suppliers
warrants the existence of a legitimate interest regarding the sending of communications relative to the aforementioned
courtesy services. This does not affect the rights and freedoms of the data subject.
Data disclosure. Such data will not be disclosed to third parties. In effect, the aforementioned data will be
processed exclusively by employees of VENETA CASSETTI duly appointed for this kind of data processing.
Data transfer to Extra-EU Countries. See paragraph 4.2.
Processing methods. Data processing is carried out using electronic systems (e.g. email) and paper systems
(printed documents to be sent by post).
Data storage period. The storage period depends on the wishes of the Customer or Supplier, who may oppose
this type of data processing at any moment by contacting the addresses given above.
4.5 Processing carried out to assess CVs submitted
by Third Parties (candidates).
Types of data we process. Name, surname, email address, CV, tax code, etc.
Legal basis of the processing. The processing of personal data is lawful when it is carried out in virtue of the
consent given by the candidate at the foot of their CV.
Compulsory and non-compulsory data transfer. The provision of such data is not obligatory; however, failure
to provide certain data will prevent VENETA CASSETTI from evaluating the CV submitted by the candidate.
Data disclosure. Such data will not be disclosed to third parties. In effect, the aforementioned data will be
processed exclusively by employees of the company who are duly trained to perform this kind of data processing.
Data transfer to Extra-EU Countries. See paragraph 4.2.
Processing methods. Data may be processed using electronic systems (receipt of emails from the candidate) and
paper systems (manual submission of CV or printing of the same if sent by email).
Data storage period. The storage period depends on whether or not a working relationship is established. In the
case that VENETA CASSETTI S.R.L. is not interested in a profile, the candidate’s data shall be deleted immediately.
However, in the case of profiles deemed interesting but not necessary at the time of submission, VENETA CASSETTI
S.R.L. shall store the data for a maximum period of one year. Finally, if a contract is signed with the candidate, the company
will store the data of the new employee for ten years from the termination of the working agreement for the purposes of
legal protection.

4.6 Processing carried out to send newsletters or marketing communications

for Customers, Suppliers and Third Parties.

Types of data we process. Name, surname, email address, telephone number (only if strictly necessary).
Legal basis of the processing. The processing of the data is lawful when it is carried out with the consent of the
data subject or in the legitimate interest of the Data Controller. The latter case refers particularly to certain Customers or
Suppliers who, in virtue of existing contractual agreements with the company, expect VENETA CASSETTI S.R.L. to send

communications in line with certain previously expressed preferences or interests. This does not affect the rights and
freedoms of the data subject.
Compulsory and non-compulsory data transfer. The provision of such data is not obligatory; however, failure
to do so will prevent VENETA CASSETTI S.R.L. from sending marketing communications regarding our products, offers,
promotions, event invitations and newsletters to keep you up to date with the drawer manufacturing world. Such
communications and news - of a generic and non-personalised nature - may be forwarded by email, SMS, MMS, fax or post.
Data disclosure. Data used for this type of data processing may be disclosed to employees or external Data
Managers who are duly authorised and trained to carry out this kind of processing. In certain cases, to perform services on
your behalf, data may be disclosed to third party companies engaged by VENETA CASSETTI S.R.L. to manage our email
marketing service (see below).
Data transfer to Extra-EU Countries. VENETA CASSETTI S.R.L. undertakes not to transfer data to Extra-EU
Countries. However, in cases where the Data Controller engages the services of third parties to provide advertising or
newsletter services, certain data may be transferred to Extra-EU Countries. This circumstance may occur as the
aforementioned companies - or the servers used by the same - may be based in Extra-EU Countries. However, a data
transfer of this nature should not be a cause for concern as such transfers may only take place with the existence of the
guarantees provided for by law, i.e. on the basis of an adequacy decision adopted by the European Commission, or with the
protections provided for by the new European Regulation (such as the presence of binding corporate rules) or, in the
absence of such conditions, with the consent of the data subject, or in the context of a contract between the data subject
and the Data Controller, or in the context of a contract between the Data Controller and a third party for the performance
of a service on behalf of the data subject. For any clarifications or information on the transfer of your personal data to
Extra-EU Countries, please contact us at the addresses provided.
Processing methods. Data is processed using electronic systems (email, SMS, MMS, etc.) and only occasionally
with paper systems (printing documents to be sent by post).
Data storage period. The storage period for data processed for advertising, marketing or newsletter purposes
depends on the wishes of the Customer, Supplier and Third Party, who may revoke any previously given consent at any
moment. In the case of data processing based on the legitimate interest of the Data Controller, the Customer, Supplier or
Third Party may oppose the processing of their data at any time.
Final clarifications. This paragraph governs two separate and independent data processing purposes: data
processing for the sending of newsletters; and data processing for the sending of marketing communications. In this regard,
the Data Controller undertakes to obtain separate consent and to evaluate the separate legitimate interest of the type of
processing it intends to carry out.

4.7 Processing carried out via the website concerning users
(Contact Forms – Newsletters - Cookies).

VENETA CASSETTI S.R.L. has a website (www.venetacassetti.com) through with the Data Controller collects
the data of the data subject. For more information on the types of data processing carried out via the website, please visit
the link “Website Policy” found at the bottom of the website.

4.8 Processing carried out for statistical or market analysis purposes.

In order to improve its services, VENETA CASSETTI S.R.L. analyses certain data that the Customer, Supplier or
Third Party provides following some or all of the data processing activities mentioned above. This should not be a cause of
concern for the data subject as the data used for market research purposes does not in any way enable the identification or
detectability of the natural persons and, in any case, VENETA CASSETTI has established appropriate security measures to
guarantee anonymity.

5. RIGHTS OF THE CUSTOMER, SUPPLIER AND THIRD PARTY.

The data subject (i.e. the person who provides their personal data to the Data Controller) has the following rights:
 the right to request access to their personal data, or to know which data is processed by the Data Controller;
 the right to update their personal data;
 the right to correct their personal data, or the right to amend such data if their details have changed;
 the right to add to their data, or the right to add additional data as provided by the data subject;
 the right to restrict the processing of their personal data, or the right to limit the use of such data by the Data
Controller;
 the right to oppose, on legitimate grounds, the processing of their personal data;

 the right to data portability, or the right to receive all data processed by the Data Controller in a structured
format supported by IT systems;
 the right to request the deletion of their personal data;
 the right to request the transformation into anonymous form or the blocking of personal data processed
unlawfully, including data whose storage is not required for the purposes for which the data was collected or
subsequently processed;
 the right to obtain a statement declaring that the updating, correction, integration, deletion, blocking or
transformation operations, including as regards its content, have been notified to those to whom the data has been
communicated or disclosed, except in the case that this is impossible or requires the use of means which are
disproportionate to the right;
 the right to revoke any explicit consent previously given, at any moment, without prejudice to the lawfulness of
the data processing carried out until that moment;
 the right to lodge a complaint with the Italian Data Protection Authority in the case of breaches to legislation.
For a more detailed breakdown of the rights to which you are entitled, please see articles 15, 16, 17, 18, 20 and 21 of EU
Reg. 679/2016. Requests may be made without a formal procedure to the Data Controller at the addresses indicated above.

6. SECURITY MEASURES.

The Data Controller undertakes to protect your personal data through the adoption of all necessary digital and
physical security measures. However, no security system can definitively guarantee this protection. Therefore, except in
cases of liability in which the Data Controller is at fault, VENETA CASSETTI may not be held responsible for the actions
of third parties who unlawfully access systems and workplaces without the necessary authorisations. For more information
on security measures, please contact us at the addresses indicated above.

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