PERSONAL DATA PROTECTION POLICY OF THE BERLIN PACKAGING GROUP IN EUROPE
Last updated on 05.10.2023
Protecting the security and privacy of personal data is important to the Berlin Packaging Group, which acts in accordance with the laws currently in force regarding the protection and security of personal data.
By providing the information below, we believe we are helping you to understand what kind of data Berlin Packaging Group collects in general, how it is used and stored and with whom it is shared Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“Privacy Regulation“), we wish to inform you that your personal data will be processed in accordance with the principles of lawfulness, fairness and transparency, and will guarantee your privacy and your rights and will comply with the applicable regulations on data security and protection. In particular, we inform you of the following:
a. Data controller
The data controller is the company of the Berlin Packaging group that organised the trade fair or the company of the Berlin Packaging group with which you have or will have business relations. The company Berlin Packaging Italy S.p.A., based in Viale Colombo, 12/14 – 20090 Trezzano S/N (MI), Italy, acts as the European representative for the Berlin Packaging group to which all the other companies of the group in the EMEA area refer. Each company acts as an autonomous data controller of the individual customers with whom it has or will have business relations (by clicking on this link you will see the list of Berlin Pagkaging group companies in EMEA and worldwide).
b. Source of personal data
The personal data in which we hold are those that you have provided on the following occasions: a visit to our company, a visit to the websites of one of the companies in the Berlin Packaging group, a visit to our stands at trade fairs in which you have participated, or acquired by us through a network of agents/commercial representatives operating in the territory, or obtained by us from other publicly accessible 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 group. Data acquired through our channels are neither transferred nor sold to third parties, however, at trade fairs/events, data will be collected on site and subsequently transferred to the competent company of the group 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 processing is Article 6(1)(b) of Privacy Regulation.
The purpose of collecting the data is to establish pre-contractual negotiations; to fulfil your possible requests for information on the characteristics, nature or price of products in which you have expressed an interest; to invite you to new initiatives or trade fair events organised by companies in the Berlin Packaging group.
c.2 Marketing, commercial communication and profiling purposes
The legal basis of the processing activities is Article 6(1)(a) of Privacy Regulation.
Remembering that e-mail is personal data – after having obtained your consent – we may send you information about our business activities, or send you promotional material, offers related to our products. On periodic basis, the data controller may contact you to find out if you wish to continue receiving communications and newsletters about news, products, services, and offers from the Berlin Packaging group and, therefore, renew your consent.
In the absence of consent, the material will be sent by post and by paper to the generic official company addresses, without indication of personal data.
Based on your specific consent, which is requested when browsing the Berlin Packaging group’s websites, your preferences may be analysed in order to send you personalised advertising.
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 unauthorised access by third parties and, in any case, in compliance with national and European legislation. Processing is carried out by the Data Controller, the Processors, the persons authorised to process data, and the System Administrators appointed for this purpose. The complete and updated list of the above-mentioned subjects can be requested from the Data Controller.
e. Nature of provision, consequences of refusal and withdrawal of consent
The provision of data in connection with the purpose referred to point c.1 is mandatory; consequently, in the event of your refusal to provide the data, we will not be able to comply with your request.
The provision of data in relation to the purposes set out in point c.2 is optional but it is a necessary requirement in order to be able to receive commercial communications at the company/personal addresses of the companies of the Berlin Packaging group. In case of your refusal to provide the data, you cannot be contacted or receive such commercial. In relation to optional requests for consent, you may revoke them at any time by making a request to the Data Controller in the manner set out in point i below.
You may also easily oppose to further mailings by exercising the so-called ‘opt-out’ right provided for and applied in all our electronic communications.
Once you withdraw your consent, you will receive a confirmation e-mail.
However, the Data Controller informs you that after having exercised this right of revocation of consent, it is possible that, for technical and operational reasons (e.g. the formation of contact lists already completed shortly before receipt of the revocation), you will continue to receive some further commercial communications. Should you continue to receive commercial communications since the exercise of the aforementioned right, please report the problem, using the contact details set out in point i below
When browsing the websites of the Berlin Packaging Group, if you do not give your consent to profiling, your preferences cannot be analysed and we cannot send you personalised advertisements.
f. Persons entitled and communication of data
Your personal data may be disclosed to the employees and/or collaborators of the companies of the Berlin Packaging group entrusted with carrying out activities necessary for the pursuit of the purposes of the processing referred to in point c. above.
Suppliers of IT and logistical services functional to the Company’s operations, suppliers of outsourcing services, professionals and consultants, companies in charge for the transmission of promotional e-mails and text messages or commercial communications (where you have given your consent) may also become aware of them. These parties, formally nominated by Berlin Packaging Italy S.p.A. and/or the companies of the Berlin Packaging group as “appointees”, Data Processors and/or System Administrators, will process your data in compliance with and exclusively for the purposes indicated in this information notice and under the control and supervision of the Berlin Packaging group. The complete and up-to-date list of parties to whom your data has been disclosed can be requested from the Data Controller, whom you can contact by writing to the e-mail address given in point i. Your personal data may also be communicated to third-party suppliers and/or forwarding agents who will process them, solely for the purpose of shipping the products you order, as the Data Controller’s appointed data processors or, as the case may be, as autonomous data controllers.
g. Data diffusion
The data controller and the individual companies of the Berlin Packaging group will not disseminate, transfer or sell your personal data to third parties neither that are not part of the Berlin Packaging group or that are not partners or companies that provide services useful for the management of the data. For marketing purposes, the data you provide will be shared with Berlin Packaging Italy S.p.A., the European representative, and with the other companies in the Berlin Packaging group.
h. Transfer of data outside the EU
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 Data Protection, 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 would like to inform you of the possibility of exercising your rights recognised by law at any time, which are set out below:
• access the data provided;
• obtain the rectification of the data provided, their deletion, transformation into anonymous form, the blocking of data processed in breach of the law or the restriction of the processing of data concerning you;
• To deny 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 Processors;
• to submit a claim to the competent national monitoring authority if you do not receive a response to your request from the Controller;
• to oppose to an automated decision-making process relating to you, including profiling;
• obtain, without undue delay, notice of a violation of your personal data
Requests should be addressed by e-mail to: [email protected].
j. Period of data retention
The data provided by you as a customer for the purposes referred to in point c.1 will be kept for as long as necessary to fulfil the obligations towards you in connection with your order for our products and in any case no longer than 10 years after the date of the last business relationship with you.
The data provided by you in relation to the purposes set out in point c.2 above will be kept for the estimated time adequate to achieve the purposes for which they are collected (Art. 5 letter e of Privacy Regulation) and, in any case, no later than five (5) years from the date of collection or from the date of your last contact with the Berlin Packaging group (for extra-contractual reasons).