Privacy Information

Dear customer

SBS Steel Belt Systems Srl informs you that, for the establishment and execution of ongoing contractual relationships with you, it holds personal and fiscal data, related to you, directly acquired verbally or through third parties and qualified by law as personal data.

With reference to these data we inform you that:

– the data are processed according to the contractual pre and post sales requirements and to the consequent fulfilment of the legal and contractual obligations, deriving from the submission of offers and the relevant provision of services; – the provision of data is mandatory for everything previously described, therefore the possible refusal to provide the data or the refusal to their consequent treatment, would determine the impossibility of SBS Steel Belt Systems Srl to fulfil the contractual relationships themselves; – the data processing is carried out by appointed and specialized personnel, by paper, electronic and computerized means and by any other type of technology considered suitable; the processing of data will be carried out in a lawful and correct manner and in any case in compliance with the above mentioned law, by suitable means that guarantee security and confidentiality; the data will be stored at the relevant offices of SBS STEEL BELT SYSTEMS S.r.l. – ITALY; – without prejudice to communications and dissemination carried out in compliance with legal obligations, the data may be disclosed in Italy to: banks, post offices or other courier companies, credit institutions and debt collection companies, insurance companies, consultants, professionals, IT equipment maintenance companies, training providers and in any case all those third parties appointed for the identified purposes; your information will not be disseminated; – data will be processed for the entire duration of the established contractual relationships and also

subsequently for the fulfilment of all legal obligations; – data will be processed within the European Union and, if necessary, outside the European Union. The data Controller ensures, as of now, that any transmission of data to a non-EU Country will be carried out in compliance with the applicable legal provisions.

Rights of the data subject (Articles. 15 – 22 EU Regulation 2016/679) With regard to the mentioned data, you can exercise the rights foreseen by articles 15 – 22 of EU Regulation 2016/679 (a copy of which is attached). These rights may be exercised by sending a written communication to the data Controller SBS STEEL BELT SYSTEMS S.r.l. – ITALY, with registered office in Via Roncaglia 14 – 20146 Milan – Italy – Mail: info@steelbeltsystems.it

 

INFORMATION DISCLOSURE FOR COMMERCIAL AND MARKETING PURPOSES

  1. The information you provide will be processed by our Company for any commercial and marketing purposes

including the mailing of information and advertising or promotional material. 2. Solely to the above mentioned purposes, the provision of data is optional, therefore any refusal will not entail

any consequences for the data subject; the data will not be disclosed to third parties nor disseminated. 3. The data processing is carried out by appointed and specialized personnel, by paper, electronic and computerized means and by any other type of technology considered suitable; the processing of data will be carried out in a lawful and correct manner and in any case in compliance with the above mentioned law, by suitable means that guarantee security and confidentiality; the data will be stored at the relevant offices of SBS STEEL BELT SYSTEMS S.r.l. – ITALY until revocation of the consent. 4. Data will be processed within the European Union and, if necessary, outside the European Union. The data Controller ensures, as of now, that any transmission of data to a non-EU Country will be carried out in compliance with the applicable legal provisions. 5. The data Controller is SBS STEEL BELT SYSTEMS S.r.l. – ITALY, with registered office in Via Roncaglia 14

– 20146 Milan – Italy – Mail: info@steelbeltsystems.it 6. The data subject can at any time exercise the rights provided for by the art. 7 of Legislative Decree. n. 196/2003 and by the articles 15 – 22 of the EU Regulations 2016/679 (a copy of which is attached) by sending a written communication to the data Controller, SBS STEEL BELT SYSTEMS S.r.l. – ITALY, with registered office in Via Roncaglia, 14 – 20146 Milan – Mail: info@steelbeltsystems.it 7. The list of data processing responsibles and appointed personnel is kept at the registered office and at the operational offices.

Articles from 15 to 22 Eu Regulation 2016/679
Article 15 – Right of access of the interested party 1. The data subject has the right to obtain from the data controller confirmation that the processing of personal data concerning him or her is in progress and, in this case, to obtain access to personal data and the following information: a) the purposes of the processing; b) the categories of personal data in question; c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third countries or international organizations; d) whenever possible, the period of retention of personal data provided or, if not possible, the criteria used to determine that period; e) the existence of the right of the interested party to request the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment; f) the right to lodge a complaint to a supervisory authority; g) if the data are not collected from the data subject, all information available on their origin; h) the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4 and, at least in such cases, significant information on the logic used, and the importance and expected consequences of such processing for the interested party. 2. Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the existence of adequate safeguards pursuant to Article 46 relating to the transfer. 3. The data controller provides a copy of the personal data being processed. In case of further copies requested by the interested party, the data controller may charge a reasonable fee contribution based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format. 4. The right to obtain a copy referred to in paragraph 3 shall not affect the rights and freedoms of others
Article 16 – Right of rectification. The data subject has the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.
Article 17 – Right to cancellation (“right to be forgotten”) 1. The data subject has the right to obtain from the data controller the deletion of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay if one of the following reasons exists: a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the data subject revokes the consent on which the processing is based in accordance with Article 6, paragraph 1 (a) or Article 9, paragraph 2 (a) and if there is no other legal basis for the processing ; (c) the data subject opposes the processing pursuant to Article 21, paragraph 1 and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21, paragraph 2; d) personal data have been processed unlawfully; e) personal data must be deleted to fulfill a legal obligation foreseen by the Union or by the member state law to which the controller is subject; f) the personal data have been collected in relation to the services offer of the information company referred to in Article 8 paragraph 1. 2. The controller, if he / she has made personal data public and is obliged, pursuant to paragraph 1, to delete them, taking into account the available technology and implementation costs, shall take reasonable steps, including technical measures, to inform the data controllers, who are processing personal data, of the request of the person concerned to delete any link, copy or reproduction of his personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for exercising the right to freedom of expression and information; b) for the fulfilment of a legal obligation requiring treatment foreseen by the Union or the member state law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority of which the data controller is invested; c) for reasons of public interest in the field of public health in accordance with Article 9, paragraph 2 (h) and (i) and Article 9, paragraph 3; d) for archiving purposes in the public interest, for scientific or historical research or for statistical purposes in accordance with Article 89, paragraph 1, insofar as the right referred to in paragraph 1 risks making it impossible or seriously prejudices the achievement of the objectives of this treatment; or e) for the assessment, exercise or defense of a right in court.
Article 18 – Right of limitation of treatment 1. The data subject has the right to obtain from the data controller the limitation of processing when one of the following hypotheses occurs: a) the interested party disputes the accuracy of personal data for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is illegal and the interested party opposes the cancellation of personal data and asks instead that its use is limited; c) although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to verify, exercise or defend a right in court; d) the interested party has opposed the treatment pursuant to Article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party. 2. If the processing is restricted pursuant to paragraph 1, such personal data shall only be processed, except for storage, with the consent of the data subject or for the establishment, exercise or defense of a right in court. or to protect the rights of another natural or legal person or for reasons of significant public interest of the Union or of a member state. 3. The data subject having obtained the processing restriction pursuant to paragraph 1 shall be informed by the controller before the limitation is revoked.
Article 19 – Obligation to notify in case of rectification or cancellation of personal data or limitation of processing The controller shall inform each of the recipients to whom the personal data have been transmitted of any correction or cancellation or limitation of the processing carried out in accordance with Article 16, Article 17, paragraph 1) and Article 18, unless this proves to be impossible or involves a disproportionate effort. The data controller informs the recipient of these recipients if the data subject requests it.
Article 20 – Right to data portability 1. The data subject shall have the right to receive personal data concerning him / her provided to a data controller in a structured, commonly used and readable form through an automatic device and has the right to transmit such data to another data controller without impediments on the part of the data controller to whom he has provided them if: (a) the processing is based on consent pursuant to Article 6, paragraph 1 (a) or Article 9, paragraph 2 (a) or on a contract within the meaning of Article 6, paragraph 1; and b) the treatment is carried out by automated means. 2. In exercising its rights relating to the portability of data in accordance with paragraph 1, the data subject shall have the right to obtain direct transmission of personal data from one controller to another, if technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall leave without prejudice Article 17. This right does not apply to the treatment necessary for the performance of a task carried out in the public interest or in connection with the exercise of official authority as the data controller is invested. 4. The right referred to in paragraph 1 must not affect the rights and freedoms of others.
Article 21 – Opposition law 1. You have the right to object at any time, for reasons connected with your particular situation, to the processing of your personal data pursuant to Article 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions. The data controller refrains from further processing personal data unless he demonstrates the existence of binding legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or the defense of a right in court. 2. If personal data are processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him / her for such purposes, including profiling in so far as it is related to such direct marketing. 3. If the data subject objects to processing for direct marketing purposes, personal data are no longer processed for these purposes. 4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the interested party and shall be presented clearly and separately from any other information at the latest at the time of the first communication with the data subject. 5. In the context of the use of information society services and without prejudice to Directive 2002/58 / EC, data subjects may exercise their right to object by automated means using technical specifications. 6. Where personal data are processed for the purposes of scientific or historical research or for statistical purposes in accordance with Article 89, paragraph 1, the data subject shall have the right to object to the processing of personal data for reasons connected with his particular situation concerning him, unless the processing is necessary for the performance of a task in the public interest.
Article 22 – Automated decision-making process concerning natural persons, including profiling 1. You have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning yourself or which significantly affects your person. 2. Paragraph 1 shall not apply where the decision: a) is necessary for the conclusion or execution of a contract between the data subject and a data controller; b) is authorized by the law of the Union or of the member state to which the controller is subject, which also specifies appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; c) is based on the explicit consent of the interested party. 3. In the cases referred to in paragraph 2 (a) and (c), the controller shall implement appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least the right to obtain human intervention from the holder of the treatment, to express their opinion and to challenge the decision. 4. The decisions referred to in paragraph 2 shall not be based on the particular categories of personal data referred to in Article 9, paragraph 1, unless Article 9, paragraph 2 (a) or (g) applies, and adequate measures to protect the rights, freedoms and legitimate interests of the data subject are not in force.

Rev. 00 dtd. 23rd May 2018