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Personal data processing policy pursuant to articles 13-14 of EU reg. 2016/679

Data Subjects: Suppliers and Third Parties Working for Supplier Companies.

IVAS INDUSTRIA VERNICI S.P.A. in its capacity as Data Controller, pursuant to and for the purposes of EU Regulation 2016/679 (hereinafter referred to as 'GDPR'), hereby informs you that the aforementioned legislation envisages the protection of data subjects with regard to the processing of personal data and that such processing shall be based on principles of correctness, lawfulness, transparency and protection of your privacy and rights.

Your personal data will be processed in accordance with the legislative provisions of the above-mentioned legislation and the confidentiality obligations provided for therein.

Purpose and legal basis of the process: your data will be used for the following purposes relating to the fulfilment of legislative obligations:

• fulfilment of legal obligations in relation to taxation and accounting;
• handling of disputes;
• obligations envisaged by the laws in force.

Your data will also be used for the following purposes relating to the implementation of measures related to contractual or pre-contractual obligations:

• management of logistics.

Your data will also be used for the following purposes necessary for the pursuit of the legitimate interest of the controller:

• quality management;
• planning of activities also with the aid of dedicated software systems.

A los efectos del tratamiento indicado, el Titular podrá tener conocimiento de datos personales relativos a condenas penales o delitos en virtud del art. 10 del RGPD y en información sobre las medidas judiciales.

Processing methods. Your personal data may be processed in the following ways:

• assignment of processing activity to third parties;
• association or comparison with data from other public or private databases;
• computerised or telematic data collection;
• collection of data from public registers, lists, deeds or documents;
• processing through electronic databases or software systems managed or programmed directly;
• manual processing by means of hardcopy files.

Every process takes place in accordance with the procedures set out in articles 6 and 32 of the GDPR and through the implementation of the appropriate security measures envisaged.

Your data will be processed only by personnel expressly authorised by the Controller and, in particular, by the following categories of employees authorised:

• laboratory staff;
• manufacturing staff;
• company management;
• programmers and analysts;
• reception;
• maintenance managers;
• forwarding agents;
• purchasing department;
• administration department;
• maintenance operators and hardware and internal software service providers;
• marketing department;
• shipping department;

Communication: Your data may be communicated to external subjects for the correct management of the relationship and particularly to the following categories of addressees, including all the duly appointed Processors:

• banks and financing institutions;
• consultants and freelancers, also in associated form;
• within the framework of public or private organisations for which the communication of data is compulsory or necessary in fulfilment of legal obligations or is otherwise functional to the administration of the relationship;
• armed forces;
• police forces;
• insurance companies;
• subsidiaries and associates;
• forwarding agents, transporters, post offices, logistics companies.

Disclosure: Your personal data will not be disclosed in any way.

Data storage period. Please note that, in accordance with the principles of lawfulness, purpose limitation and data minimisation, pursuant to art. 5 of the GDPR, the storage period applicable to your personal data is:

• established for a period of time not exceeding the achievement of the purposes for which they are collected and processed for the implementation and fulfilment of contractual purposes;
• established for a period of time not exceeding the fourth year after the legally compulsory periods of time.

Controller: the Data Controller, in compliance with the Law, is IVAS INDUSTRIA VERNICI S.P.A. (Via Bellaria, 40 , 47030 San Mauro Pascoli (FC); email: privacy@ivas.it; telephone: +390541815811; VAT no.: 00124120403) in the person of its legal representative pro tempore.

You have the right to obtain from the controller the cancellation (right to be forgotten), limitation, updating, rectification, portability, opposition to the processing of personal data concerning you, and you can, in general, exercise all the rights envisaged by Articles. 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR.

EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 - Data subject rights

1. The data subject has the right to obtain confirmation of the existence or otherwise of personal data concerning him or her, even if not yet recorded, and their communication in intelligible form, and may also complain to the Supervisory Authority.
2. The party concerned has the right to obtain details about:
   • the origin of the personal data;
   • the purposes and methods of processing;
   • the logic applied in the case of processing carried out with the help of electronic instruments;
   • the identity of the data controller, data processors and the representative designated in accordance with article 5, paragraph 2;
   • the subjects or categories of subjects to whom the personal data may be communicated or who may learn about them as representatives designated in the territory of the State, processors or appointed persons.
3. The party concerned has the right to:
   • the update, rectification or, where pertinent, the integration of the data;
   • the cancellation, transformation into anonymous form or blockage of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
   • certification to the effect that the operations indicated under letters a) and b) have been notified, along with their contents, to the entities to whom or which the data have been communicated or disclosed, unless this requirement proves impossible or involves a manifestly disproportionate effort in relation to the right that is to be protected;
   • data portability.
4. The Party concerned has the right to object to, either entirely or partly:
   • for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of collection;
   • the processing of personal data concerning him/her for the purpose of sending advertising materials, direct selling or the performance of market research or commercial communication surveys.