Notice on the processing of Supplier data

pursuant to Articles 13 and 14 of Regulation 2016/679/EU

This notice is provided to individuals (Data Subjects) who act on behalf of the supplier (Supplier), whose personal data will be processed by the company TECNOBODY S.P.A. in its capacity as the "Data Controller" pursuant to Articles 12, 13, and 14 of the "European Regulation on the Protection of Personal Data 679/2016," relating to the protection of individuals with regard to the processing of personal data and the free movement of such data, as well as applicable legislative and contractual provisions, and for the purposes and in the manner outlined below.
Personal data may refer directly to the Supplier, an individual or sole proprietorship, or may consist of information related to individuals (e.g., personnel) who represent, belong to, or are otherwise connected to the Supplier, whether a natural person or a legal entity (e.g., a corporation) or another public or private entity.


Identity of the Data Controller

The Data Controller is TECNOBODY S.P.A. (hereinafter referred to as the "Data Controller"), Tax Code - VAT number 02323900163, represented by its legal representative, Mr. Alessandro Carminati, with its registered and operational office located in Dalmine (BG), Via Lodi n. 10.


Source and Type of Data Processed

The personal data processed are those provided by the Data Subject and/or the Supplier during:

  • Visits, phone calls, and contact requests;
  • Proposals for offers;
  • Communications of various kinds and through different communication means (phone, mobile phone, SMS, email, fax, paper mail, internet);
  • Transmissions and transactions following an order;
  • Management and execution of the contact and pre-contractual measures, including administrative and accounting activities related to the supply of products and services;
  • Data obtained from public sources (e.g., Chambers of Commerce).

These data include name, surname, contact details, email addresses, professional qualifications where relevant, any data related to wages and contributions paid, and regularity of contributions for the staff employed by the Supplier to provide services to us, when such data is necessary to conduct checks regarding compliance with worker protection regulations (e.g., subcontractor contracts), photographs, and any data of legal representatives, including judicial data where required by law.

In the case of an individual Supplier, data related to invoicing and payments (e.g., Tax Code, VAT number, SDI, PEC address), banking details, enrollment in professional registers, and economic-financial data may also be processed.


Purpose of the processing and legal basis

The processing of personal data is carried out by the company TECNOBODY S.P.A. for the establishment and execution, and in general for the fulfillment of the contractual or pre-contractual relationship with the Supplier, and to fulfill any requests from the Supplier or make requests to the Supplier; to comply with legal obligations, such as those related to tax and accounting matters, obligations arising from the regulation of supply contracts and workplace health and safety; for the administrative management of the contractual relationship (e.g., supplier registration, payment and invoice management) and pre-contractual measures, as well as for the internal and external organizational management of the relationship; for the management of potential disputes.

For the purposes outlined above, it is not necessary to obtain specific consent, as the processing is necessary for the performance of the contract or the implementation of pre-contractual measures, or to comply with a legal obligation to which the Data Controller is subject (art. 6, paragraph 1, letters b) and c) of the GDPR). Personal data may be processed, where necessary and without the need for consent, also to ascertain, exercise, or defend a right of the Data Controller in an out-of-court or judicial setting. Judicial data may only be processed if required by law or in cases provided by law or regulations that authorize the processing when necessary in relation to the nature of the relationship with the supplier.


Recipients of the data

The personal data processed by the Data Controller will not be disclosed, nor will they be made available or accessible to unspecified subjects, in any form, including making them available or simply consulting them. They may, however, be communicated to the employees of the Data Controller and to certain external subjects with whom they collaborate, who are specifically appointed. In particular, based on the roles and work duties performed, some employees have been authorized to process personal data within the limits of their responsibilities and in accordance with the instructions given to them by the Data Controller.

Without prejudice to communications made in compliance with legal and contractual obligations, the data may also be communicated, to the strictly necessary extent, to subjects who, for the purposes of issuing orders or requests for information and quotes, must supply goods and/or provide services, to tax or legal consultants, our collaborators, credit institutions, and public bodies and administrations. They may also be communicated to subjects authorized to access them based on laws, regulations, and EU legislation (e.g., judicial authorities and other public authorities). The data will be communicated, when necessary, to external subjects designated as "Data Processors" who carry out specific activities on behalf of the Data Controller (for example: activities carried out by companies or professionals related to tax and accounting obligations, insurance and regulatory compliance, collections and payments, IT system and software maintenance, auditing and control companies). The updated list of data processors is kept at the operational headquarters of the Data Controller.


Transfer of Data Abroad

Personal data may be transferred to countries and international organizations within the European Union (EU) and the European Economic Area (EEA) and, as a rule, will not be transferred to countries or international organizations outside the EU or EEA (third countries). However, when necessary for the purposes indicated in this notice, the data may be transferred to third countries. In such cases, to ensure an adequate level of protection for personal data, the transfer will be carried out in compliance with Articles 44 and following of the EU Regulation 2016/679 (GDPR), or to third countries for which the European Commission has issued adequacy decisions, based on Standard Contractual Clauses approved by the European Commission, or through the application of specific derogations provided by the GDPR. For the processing of the information and data that may be communicated to these entities, equivalent levels of protection adopted for the personal data of employees will be required. In any case, only the data necessary to pursue the indicated purposes will be communicated, and the regulatory tools provided by Chapter V of the GDPR will be applied. For more information regarding data transfers, you can send an email to the Data Controller.


Data Retention

The Data Controller processes personal data for the time necessary to fulfill the indicated purposes. Subsequently, personal data will be retained for the time specified by the applicable civil and tax regulations. In particular, the data will be stored for the entire duration of the contractual relationship and even after its termination, in compliance with civil and tax obligations.


Refusal to provide data

The Data Subject may refuse to provide their personal data to the Data Controller. However, providing personal data is necessary for the correct and efficient establishment and management of both pre-contractual measures and the contractual relationship, as well as to fulfill the contractual obligations that arise from it. Therefore, any refusal to provide data may compromise, in whole or in part, the contractual relationship, including its establishment.

With regard to personal data protection, the Supplier is invited, pursuant to Article 33 of the European Regulation 2016/679, to report to TECNOBODY S.P.A. as the Data Controller, any circumstances or events that could lead to a potential “personal data breach,” in order to allow an immediate assessment and the adoption of any actions aimed at addressing such an event.

Such reporting can be made by sending a communication to TECNOBODY S.P.A. at the email address: privacy@tecnobody.it


Automated Decision-Making Processes

The Data Controller does not carry out automated decision-making processes based on the personal data of the Data Subject.


Rights of the Data Subject

In accordance with, within the limits, and under the conditions set forth by the applicable regulations regarding the exercise of the Data Subject's rights (Chapter III of European Regulation 2016/679), in relation to the processing described in this Notice, the Data Subject has the right to:

  • Request confirmation of whether or not their personal data is being processed and access the data concerning them and related information (right of access);
  • In relation to the personal data concerning them, request correction and completion of incomplete data (right to rectification);
  • Request the restriction of processing in cases provided by Article 18 of the GDPR and deletion in cases provided by Article 17 of the GDPR, where applicable (right to restrict processing and right to erasure);
  • Obtain the portability of personal data, meaning receiving it from the Data Controller in a structured, commonly used, and machine-readable format, also for the purpose of transmitting it to another data controller, in cases where the legal basis of processing is a contract or consent, and processing is carried out by automated means (right to data portability);
  • Object, for reasons related to their particular situation and at any time, to the processing of their data in the cases provided by the GDPR (right to object);
  • Withdraw consent, where granted, without affecting the lawfulness of processing based on consent;
  • File a complaint with the supervisory authority (in Italy, the Privacy Guarantor) pursuant to Article 77 of the GDPR, if they believe that the processing concerning them violates the provisions of the GDPR.

The Data Subject may exercise their privacy and data protection rights by requesting and completing the appropriate form from the Data Controller and sending it via email to privacy@tecnobody.it or by registered mail to the Data Controller’s office.

Best regards,

The Data Controller
TECNOBODY S.P.A.