PRIVACY STATEMENT PURSUANT TO ARTICLES 13 AND 14 OF EU REGULATION 679/2016 ON THE PROTECTION OF PERSONAL DATA ("PRIVACY REGULATION")

Last updated on 30.09.2022

Protecting the security and privacy of personal data is important for the Berlin Packaging group, which acts in accordance with the laws currently in effect regarding the protection and security of personal data.

By providing the information below, we hope to help you understand what kind of data the Berlin Packaging group collects, how it is used and stored, and with whom it is shared pursuant to Articles 13 and 14 of the Privacy Regulation. We would like to inform you that your personal data will be processed in accordance with the principles of lawfulness, fairness and transparency, and that the processing will guarantee your privacy and rights and will be compliant with the applicable data protection and security legislation. In particular, we would like to inform you of the following:

a. Data controller
The data controller is the company of the Berlin Packaging group that organized the trade fair event or the company of the Berlin Packaging group that you have or will have a business relationship with. Each company acts as an autonomous data controller for the individual customers with whom it has or will have business relationships with.

b. Source of personal data
The personal data in our possession are those provided by you during a visit to one of the companies of the Berlin Packaging group, a visit to our website, a visit to our stands during trade fairs in which you have participated, or those personal data acquired by us through a network of agents/commercial representatives operating in the territory, or obtained by us from other public sources and processed in strict compliance with the rules for their use, where applicable, or in the course of a contractual relationship between you and the companies of the Berlin Packaging Group. The data so acquired will not be transferred or sold to third parties; however, at trade fairs/events, the data will be collected on site and subsequently transferred to the relevant company for the management of the business relationship.

c. Legal basis and purposes of processing

c.1 Contractual purposes or execution of pre-contractual arrangements
The legal basis for the data processing is Article 6 par.1 lett(b) of the Privacy Regulation.
The data is collected for the following purposes: to establish pre-contractual negotiations; to fulfil your possible requests for information regarding the characteristics, nature or price of products which you have expressed an interest in; to invite you to new initiatives or trade fair events organized by a company of the Berlin Packaging group.

c.2 Marketing and commercial communication purposes
While remembering that e-mail is personal data – after collecting your consent – we may send you information about our business activities or send you promotional material as well as offers related to our products. In the absence of consent, the material will be sent by letter and on paper to the official generic company addresses, without indication of any personal data.

d. Treatment methods
The data will be processed manually or electronically, in such a way as to guarantee their security in relation to the purposes for which they were communicated and collected, and to prevent unauthorized access by third parties and, in any case, in compliance with national and European legislation. The processing is undertaken by the data controller, by data processors, by persons authorized to process data, and by system administrators appointed for this purpose. The complete and updated list of the above-mentioned subjects can be requested to the data controller.

e. Nature of provision, consequences of refusal and withdrawal of consent
The provision of data in relation to the purposes set out in point c.1 is mandatory; consequently, in the event of your denial to provide the data, we will not be able to process your requests.

The provision of data in relation to the purposes set out in point c.2 is optional but is a necessary requirement in order to be able to receive commercial communications at the company/personal addresses from the companies of the Berlin Packaging group. In the event of refusal to provide such data, you will not be able to be contacted or to receive such commercial communications.

In relation to this optional consent, you may revoke it at any time by making a request to the data controller in the manner set out in point i below.
You may also easily refuse further mailings by exercising the so-called “opt-out” right provided for and applied in all our electronic communications.
Once you have revoked your consent, you will receive an e-mail confirming this request.
However, we inform you that, even after the exercise of this right of withdrawal of the consent, it is possible that, for technical and operational reasons (e.g. the formation of contact lists already completed shortly before the receipt of the revocation itself), you will continue to receive some further commercial communications. In the event that you continue to receive commercial communications after exercising the aforementioned right, please report the problem using the contact details set out in point i below.

f. Data communication
Your personal data may be disclosed to the employees and/or collaborators of the companies of the Berlin Packaging group appointed to carry out activities necessary to achieve the purposes of the processing referred to in point c..

g. Dissemination of data
The data controller and the various companies of the Berlin Packaging group will not disseminate, transfer or sell your personal data to third parties not belonging to the Berlin Packaging group.
h. Transfer of data outside Europe
Your personal data may be transferred abroad to countries that are not members of the EEA (European Union, Iceland, Liechtenstein and Norway) and, in particular, to the company Berlin Packaging L.L.C., located at: 525 West Monroe Street – Chicago, IL 60661, on the basis of a data transfer contract shared with all the companies of the Berlin Packaging group, including standard contractual clauses and guidelines approved by the European Committee for the Protection of Personal Data, stipulated between Berlin Packaging Italy S.p.A. (exporter) and Berlin Packaging L.L.C. (importer) with the consequent guarantee of data processing in compliance with European standards.

i. Rights of the data subject
Finally, we wish to inform you that you may, at any time, exercise the rights granted to you by law, which are set out below:
• access the data provided;
• obtain the rectification of the data provided, their cancellation, transformation into anonymous form, as well as the blocking of data processed in violation of the law or the restriction of the processing of your data;
• object to the processing of your data;
• withdraw your consent;
• obtain the portability of your data;
• obtain confirmation of the existence or non-existence of your data, know its content and origin, verify its accuracy or request its integration or updating, know the purposes and methods of processing, the logic applied in the case of processing carried out with the aid of electronic instruments, the identification details of the data controller and of the data processors;
• lodge a complaint with the competent national supervisory authority if you do not receive a response to your request from the data controller;
• oppose any automated decision-making process related to you, including profiling;
• obtain, without undue delay, notice of a breach of your personal data.

Requests should be addressed by e-mail to: privacy.it@berlinpackaging.com.

j. Period of data retention
The data provided by you for the purposes set out in point c.1 will be kept for as long as is necessary to fulfil our obligations to you in connection with the business relationship and in any case, for no longer than 10 years after the collection of the data.

The data you have provided in relation to the purposes set out in point c.2 will be kept for the estimated time adequate to achieve the purposes for which they are collected (Art. 5 letter e of the Privacy Regulation) and until you revoke the consent you have given. In the event of withdrawal of your consent and/or in the event that, for whatever reason, the storage of your personal data is no longer justified on the basis of evaluations carried out by the data controller, which take into account the principles of necessity, proportionality, adequacy and relevance of the processing, the data controller itself will delete or anonymize the data without delay.