Privacy statement to customers and suppliers
Information to the customer and supplier issued by System S.p.A. pursuant to Article 13 of Legislative Decree 196/2003

This new information processed pursuant to Article 13 of Legislative Decree 196/2003, is issued following amendments introduced by Legislative Decree dated 6 December 2011 no. 201, which brought about considerable changes to certain normative definitions.

This new information, therefore, updates any previous versions issued in the past.
That being said, the following is pointed out:
1) By effect of the establishment of the business relationship and during the course of its execution, our company will be collecting and processing your personal data.
2) we henceforth specify for clarity, the following definitions provided by Legislative Decree 196/2003:
Processing: any operation, carried out with or without the aid of electronic means, concerning the collection, recording, organisation, storage, interrogation, elaboration, modification, selection, retrieval, comparison, utilisation, interconnection, blocking, communication, dissemination, erasure and destruction of data;
Personal data: any information relating to natural persons, identified or identifiable, even indirectly, by reference to any other information including a personal identification number.

Pursuant to Article 13 of Legislative Decree 196/2003 (Privacy Code), therefore,


we inform you

that the collection and processing of your personal data will be performed by the undersigned company in compliance with the following:
a) purpose: data will be processed for the proper conduct of accounting, tax, trade and technical obligations and for company activities in general related to the relationship in existence;
b) marketing purposes: your data subject to your prior specific and explicit consent, even for the sending of marketing material/advertisements via mail, e-mail, telephone, fax, sms and the like; after providing consent, it is however your right to object at any time and without charge, to the treatment of your data for this purpose;
c) method: personal data will be processed both via electronic and paper means, in compliance with the provisions of the law, according to the principles of correctness, legality, in order to protect your privacy;
d) optional conferment: conferment of the data is optional and not compulsory;
e) consequences of a possible refusal: the refusal to provide your data or the integral objection to their processing, may however, entail the impossibility to continue the trade or any other relationship with our company; refusal to allow the use of the data for the purposes of sending marketing material/advertisements, instead, will not have any effect on future or present relationships;
f) subjects or subject categories to whom the personal data can be communicated or disclosed: personal data may be disclosed to third parties only when necessary for the purposes of the law or for contractual purposes; Data will not be disclosed in any case;
g) managers and company staff in charge of processing personal data: data shall be processed exclusively by managers or company employees in charge of processing personal data from the administrative and trade departments;
h) rights of the data subject: the data subject is entitled to all the rights under Article 7, which is annexed in its entirety to the bottom of this information statement and constitutes an integral part;
i) Data Controller: the Data Controller for the processing of personal data is System S.p.A., with headquarters in Fiorano Modenese (MO), Via Ghiarola Vecchia no. 73, in the person of its legal representative pro tempore;
j) Data Processor/s: the Data Processor designated to provide responses to data subjects is Mr. Luigi Panzetti, available at our corporate headquarters; any requests for clarification or information may be addressed to this manager. The full list is constantly updated by the managers and available for consultation on this web site and/or on the appropriate paper document available at our corporate offices.

This information may be supplemented, orally or in writing, with further elements and indications, to better cater for any need relating to further details on “Privacy” and any updating of the regulations on the subject.



Fiorano Modenese (MO), 22/05/2014

The Data Controller
System S.p.A.



Article 7 Legislative Decree 196/2003 (Right to access personal data and other rights).

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed: a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) of the identification data concerning data controller, data processors and the representative designated as per Section 5 paragraph 2; e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market research or trade communication.



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