Version: 2 - Policy date: 19/11/2018

1. DATA CONTROLLER

The Data Controller of the personal data collected is Galba Srl, with registered office in Via Industriale Trav. 3°, 20, 25060 Cellatica (BS), VAT Number and Fiscal Code 00351210174, registration number with the Brescia Companies Register no.: 00351210174, fully paid-up share capital 1.500.00,00. The Controller is the holder of your personal data (hereafter “Galba” or “Data Controller”)

2. DEFINITION OF PERSONAL DATA AND INFORMATION REGARDING THE PURPOSES OF THE PROCESSING

2.1 According to the GDPR, personal data is defined as: “any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number, location data, online identifier or to one or more factors specific to his or her physical, physiological, genetic, economic, cultural or social identity” (“personal data” or “data”).

2.2 Galba collects the personal data obtained when the contract is signed and subsequently processes it in order to execute that contract for any of the following purposes:

• Fulfilling tax and administrative requirements resulting from the existing relations with the customer/supplier;
• Providing assistance as “customer service” and “back office”;
• Fulfilling the obligations required by Italian laws and Community legislation or arising from a judicial writ, a regulation, a compulsory order given by a public authority;
• Exercising the data controller’s rights (e.g. right to legal defence).

The provision of data for such purposes is mandatory as otherwise Galba may not be objectively able to fulfill all contractual and legal obligations.

If Galba intends to use such data for purposes other than those abovementioned, Galba will be responsible for providing adequate communication by updating this document on the website www.galba.it

2.3 In addition, only with your explicit consent, Galba may process your personal data for statistical or marketing purposes in order to send you e-mails, letters and/or text messages and/or phone calls with commercial information about its special offers, new products and/or services.

The provision of data for such purposes is optional. You can therefore decide not to provide any data or to deny the treatment of the previously conferred data at a later stage: in this case you will not receive any commercial information about the services offered by Galba S.r.l.

3. DATA PROCESSING PROCEDURES

The data processing is carried out lawfully, adequately and transparently, only in order to provide a service, also by communications to third parties if necessary, and with the following procedures: recording, organization, storing, consulting, processing, testing, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, erasure and destruction of data.

Your personal data will be processed and recorded on paper support or with electronic or automated means, and in all cases with adequate means to ensure its security.

4. DATA TRANSFER TO DATA PROCESSORS WITHIN THE EU

Galba may disclose your personal data to third parties located within the EU territory. These external parties are expressly appointed by the data controller and they may process your data strictly for the purposes indicated in Art. 2.2, while for those indicated in Art. 2.3 only with your explicit consent.

Anyway you may obtain the full and updated list of our external data processors at the data controller’s headquarter or request it to the contacts detailed in Art. 7.

5. APPLICABLE RETENTION PERIOD

Galba will process your data for the entire duration of the contract for the purposes indicated in Art. 2.2 (“end of purpose”).

The same personal data will be stored for 10 years starting from the “end of the purpose”, for the purposes indicated in Art. 2.2 in accordance with Arts. 2214 and 2220 of the Italian Civil Code.

The personal data stored for the purposes indicated in Art. 2.3 will be erased within three years starting from the “end of purpose”.

6. YOUR RIGHTS AS DATA SUBJECT

Since Galba has obtained and processed your personal data, you are entitled, as data subject, to exercise any of the following rights:

• Right of access → You are entitled to obtain confirmation of the existence of any process concerning your data and to receive every information about it;
• Right to rectification → You are entitled to rectify your data whether incorrect or incomplete;
• Right to erasure → You are entitled to obtain the erasure of your data stored in our archives or databases;
• Right of processing restriction → You are entitled to obtain a processing restriction of your personal data;
• Right to data portability → You are entitled to obtain a copy of your personal data in a structured and commonly used format, readable with an automatic device. You are also entitled to transfer your data to another data controller without any hindrance;
• Right to object → You are entitled to object to the processing of your data;
• Right to lodge a complaint → You are entitled to lodge a complaint with supervisory authorities if your personal data have been processed in breach of the GDPR.

7. RIGHTS EXERCISE PROCEDURE

You are entitled at any time to exercise any of the abovementioned rights by sending a written communication to Galba S.r.l., via Industriale Trav. 3°, 20 – Cellatica (BS), or to the e-mail address: info@galba.it, specifying the contact details to receive our feedback.

8. DPO CONTACT DETAILS

You may contact the Data Protection Officer (DPO) appointed at corporate level by Galba S.r.l at this e-mail address: info@galba.it:

GALBA SRL: VIA INDUSTRIALE TRAV. 3°, 20 – 25060 CELLATICA (BS)