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Privacy Policy for Clients and Suppliers for the processing of Personal Data in accordance with D. Lgs. 196/2003, as amended by D. Lgs. 101/2018, and by art. 13 of General Data Protection Regulation (UE) 2016/679

F.lli Tognella S.p.A., with registered office in Via Goito, 60 - 21019 Somma Lombardo (VA), CF and VAT number 00185410123 (referred as "Data Controller"), as controller, informs You under D.Lgs. 196/03, as amended by D. Lgs. 101/2018 (referred as "Privacy Code"), and by art. 13 General Data Protection Regulation UE 679/2016 (referred as "GDPR") that Your data will be processed for the following purposes.

1. Object of processing data

The Data Controller processes personal, identifying data (as name, surname, business name, address, phone number, e-mail, bank and payment details) – afterwards indicated as, "personal data" or also "data" notified us during pre-contractual activities or conclusion of a contract of supply of goods and/or services of the Data Controller.

2. Purposes of processing of personal data

Your personal data are processed without Your express consent (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following purposes.

Contractual. Conclusion of contracts for supply of goods and/or services of the Controller; fulfil the pre-contractual, contractual and tax obligations arising from relationship with You.

Administrative-accounting. For the purposes of applying of rules on personal data protection, processing operations for administrative-accounting purposes are connected to the carrying out of the organizational, administrative, financial and accounting nature activities, regardless the nature of the data processed. Particularly, those purposes are pursued for internal organizational activities, for the achievement of contractual and pre-contractual obligations, for the management of working relationship during all its phases, for keeping the accounts and for the applications of all the tax, trade union, benefits, health, hygiene and occupational safety rules.

Information and promotional. The use of e-mail coordinates supplied by the customer in the context of the sale of a product or a service for direct sale of its products or services, is permitted for the purposes of information and newsletters dispatch. The interested party, at the time of collection and in occasion of any communication, is informed about the opportunity to object anytime to the collection, easily and free of charge (art. 130 paragraph 4 of D.Lgs. 196/03). To cancel from mailing list it will be necessary to write to the e-mail address tognella@tognella.it or by post to the physical address of the Controller above mentioned (registered office) with subject line "unsubscribing mailing list".

Security, pursuant to D.lgs. 81/2008. With particular reference to the identifying data freely conferred by guest/visitor at our headquarters (name, surname, entity or company), the collection has the exclusive purposes of ensuring the respect of the security company procedures formally implemented, also under the current legislation (ex. Entries in visitors database, assignment of temporary key card, applications of working safety requirements).

Exercising the Controller rights and the legal action in defence in court proceedings.

3. Processing methods

Processing of Your personal data is carried out through the operations indicated on art. 4 Privacy Code and on art. 4 n. 2) GDPR and specifically: collection, registration, organization, storage, consulting, development, modification, selection, extract, comparison, use, interconnection, block, communication, cancellation and destruction of the data. Your personal data are subject to both paper and electronic and/or automated treatment.

The Data Controller will process the personal data for the time necessary to fulfil the purposes above mentioned and however for not more than 10 years from the end of the relationship for the Purposes of the Service and for not more than 5 years from data collection for informative and promotional Purposes.

4. Access to data

Your data could be accessible for the purposes on the paragraph 2 of the present document to:

1. employees and collaborators authorized by the Data Controller;

2. responsible for processing and System Administrators nominated by Data Controller;

3. third companies or other subjects (as a guide, credit institutions, professional offices, consultants, insurance firms for provision of insurance services, third-parties suppliers of technical services, couriers, hosting provider, computer companies, communication agencies etc.) carrying out activities in outsourcing on behalf of Data Controller, put in charge, if necessary, as responsible for processing;

4. subjects supplying services for information system management used by Data Controller and for telecommunication networks, and maintaining the technological area (including e-mail and newsletters service);

5. self-employed individuals, offices or companies as part of advisory/consultancy reports;

6. subjects performing control, audit and certification of activities put in place by Data Controller;

7. competent authority for law requirements and/or arrangement of public authorities, on their request.

Your data could be processed, on behalf of the writing company, by traders and/or companies instructed to perform technical, development, management, administrative-accounting activities.

5. Data transfer

The Data Controller processes personal data adopting the appropriate safety measures aimed at inhibiting the access, the disclosure, the modification or the unauthorized destruction of personal data. The processing is made through computer and/or telematics devices, with organisation arrangements and with logical closely related to the purposes indicated.

Personal data are processed at the registered office of F.lli Tognella S.p.A., at the operational sites and through the use of server, made available by Provider of third-parties located within the European Union; for further information contact the Data Controller. It is however understood that Data Controller, if necessary, will have the right of moving server also extra-EU. In that case, the Data Controller ensures right now that data transfer extra-EU will take place in accordance with rules of applicable law, after conclusion of contracts providing the methods referred to in Chapter V of GDPR.

6. Nature of data conferral and consequences of the refusal to answer

As concerns the data we are obliged to know, in order to fulfil the obligations arising from the Community legislation existing contracts and from law, regulations, or provisions issued by Authorities entitled by the law and by monitoring and control supervisors; their lack of transfer will involve the impossibility of establishing or continuing relationship, to the extent that those data are necessary for the execution of itself. The data transfer to allow Data Controller the provision of commercial communication is optional; the interested party can oppose anytime to the processing, easily and free of charge. To cancel from mailing list, it will be sufficient to write to the e-mail tognella@tognella.it or by post to the physical address of the Controller above mentioned (registered office) with subject line "unsubscribing mailing list".

7. Rights of Data Subjects

As Data Subject, has rights as mentioned on artt. 15-21 GDPR and specifically of: obtaining confirmation as to whether or not personal data, knowing the content and the origin, verifying the accuracy, demanding integration, update, correction, cancellation, restriction of processing, portability, as well as opposing, for legitimate reasons, to their processing.

If applicable, he also has the right to oblivion, as well as the right to complain to the Privacy Protection Authority.

8. Procedure of the exercise of the rights

Anytime it will be possible to exercise the rights sending:

Registered letter to F.lli Tognella S.p.A., in Via Goito, 60 - 21019 Somma Lombardo (VA);

e-mail to the address tognella@tognella.it

The updated list of Responsibles and of persons in charge for the processing is kept at the registered office of Data Controller.

Last update: 07/01/2026