Privacy Policy
EU Regulation 679/2016 General Data Protection Regulation
With this policy Premi S.p.A. (hereinafter “Premi“), a company established in Italy and specialized in the development and production of primary and secondary packaging for the fragrance, skincare, colour cosmetic and home fragrance sectors, and a company belonging to the Berlin Packaging group, intends to inform users visiting the website “www.premispa.com” (hereinafter the “Website“) of the policy adopted with regard to the protection of personal data, underlining its commitment and attention to the protection of the privacy of visitors to the website. Please read this privacy policy (the “Privacy Policy“) carefully, which applies in the event that you access the website and decide to navigate within it using our services.
Browsing within the Website is free and does not require any registration, with the exception of certain areas in which the user may freely and expressly provide a series of data concerning him or her in order to access specifically identified services (for example, to request information through the “Contacts”, “Catalogue”, “Events” section, to subscribe to the newsletter, etc.). Where, therefore, you intend to provide your personal data in order to access such additional services, you will be expressly informed in accordance with EU Regulation 679/2016 General Data Protection Regulation (the “Regulation“) with an explanation (by way of example) of the purposes and methods of use of the data by Premi as well as the right to request at any time the deletion of the data or its updating.
Pursuant to Article 13 of the Regulations, Premi provides to you the following information.
a. Identity and contact details of the data controller
The website www.premispa.com is managed by Premi S.p.A. with registered office at Via Gera, 16-18, Gessate (MI), Italy, tax code and VAT no. 09313920960, tel. +39 02 95929811, e-mail privacy.eu@berlinpackaging.com, in its role of data controller pursuant to the Regulation.
b. Categories of personal data processed
No registration is required to access the website. However, within the Website there are sections that require personal data such as name, surname, e-mail and/or telephone number (e.g. to access newsletter services, to request information, to download the product catalogue, to book participation at events, etc.) [1].
There is also a ‘Work with us’ section for those interested in applying for open positions or for a self-application.
With reference to data relating to navigation within the Website, see also point g. below concerning the profiling tools used by the Website.
c. Purpose and legal basis of the data processing
Data are collected and processed for purposes strictly related to the use of the Website and its services. The purposes for which the data are used are indicated in detail in the specific information notices provided by the Website in all cases of data collection. We therefore invite you to read the information notices that, from time to time, illustrate the features of the processing operations that will be performed by Premi (e.g. for subscription to the newsletter service, etc.). In particular, your data will be processed in order to manage the use of the services (including after-sales services) requested through the Website, to fulfil the relevant legal obligations, to respond to your requests, if any, as well as, on the basis of your consent, to carry out marketing activities and analysis of your preferences.
Your data will be processed in full compliance with privacy regulations [2].
d. Optionality of the provision of personal data
The provision of personal data is generally optional. Only in certain cases the non-provision of data may imply the impossibility to access specific services or the impossibility for Premi to answer to what has been requested (e.g., where requested, refusing to provide personal data like name, surname, e-mail address and telephone number).
The data requested from time to time in the collection forms on the Website are the minimum necessary to offer the relevant requested service.
e. Method of data processing and scope of communication
Data may be processed both in electronic and paper form. Premi guarantees the lawful and correct processing of the personal data provided through the Website, in full compliance with the regulations in effect, as well as the utmost confidentiality of the data provided during collection.
Data shall not be disseminated and shall be processed by persons expressly authorised to manage the website and the CRM system.
For purely organisational and functional requirements, Premi has appointed a number of service providers functional to the management of the Website as external processors of users’ personal data for purposes strictly connected and related to the provision of the services provided. A complete list of external data processors can be requested by writing to privacy.eu@berlinpackaging.com.
The data may also be made at the disposal of companies in the Berlin Packaging group as well as companies that provide us with services [3].
f. Links to other websites
This information is provided only for the Website and not for other websites that the user may consult through links. Premi cannot be responsible for personal data provided by users to external parties or to any websites linked to this Website.
g. Profiling and/or personalisation tools
Premi does not carry out any promotional and/or advertising communication activities without the user’s previous explicit consent.
The website uses “cookies”, both technical (i.e. to facilitate navigation and use of the website) and profiling (i.e. to analyse users and their behaviour and preferences, and to provide them with personalised advertising).
Profiling cookies will only be activated with the express consent of users. For a detailed explanation of the cookies used by the website and how to deactivate them, please read our Cookie Policy.
h. Place of data processing and transfers outside the European Union
Processing related to the services provided by the website is carried out at the premises of Premi.
The data collected and processed through the website may be transferred to countries outside the European Union, where the worldwide parent company Berlin Packaging L.L.C. is based, as well as to countries outside the European Union where our business partners are present.
Under the applicable law, your specific consent to the transfer to third countries is not required, as the transfer is carried out on the basis of the adoption of adequate safeguards in accordance with Articles 46 and 47 of the Regulation, such as the adoption of standard contractual clauses approved by the EU Commission.
The transfer of your data to any further third countries, where necessary, will take place in full compliance with the guarantees, measures and rights as provided by the Regulation. By simple request to be made to the references indicated in paragraph j, you may receive more information on the transfer of your data and the guarantees provided for their protection as well as the means of obtaining a copy of such data or the place where they are made available.
i. Data retention
Your data will be processed for the time periods provided for in the specific information provided at the time of collection [4].
Regarding the retention period of data collected through the use of profiling tools (e.g. cookies), please see our Cookie Policy.
j. Rights of data subjects
By sending a communication to privacy.eu@berlinpackaging.com, you may at any time exercise your rights [5] as set out in Articles 15 to 22 of the Regulation, including knowing which your personal data we are processing, how and for what purposes we use it, changing the data you have provided us with or deleting it, asking us to limit the use of your data, requesting to receive or transmit your data, without prejudice to the possibility of changing your consent (if any). You can also always object to the processing of your data, in particular for marketing purposes or the analysis of your preferences.
k. Who you can contact to complain
We would like to remind you that, if you believe that the processing of your data violates the provisions of the Regulation, you can always submit a complaint to the data protection authority (www.gpdp.it), or, if different, to the data protection authority of the Member State in which you normally reside or work or of the place where the alleged violation occurred.
l. Applicable law
This Privacy Policy is ruled by the Regulation, which ensures that personal data is processed in compliance with the fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to protection of personal data.
m. Revision clause
Premi reserves the right to revise, amend or simply update, in whole or in part, at its sole discretion, in any way and/or at any time, without prior notice, this Privacy Policy, also in consideration of changes in laws or regulations on the protection of personal data. Changes and updates to the Privacy Policy may be notified to users by (i) sending e-mails to registered users of the website and/or (ii) posting on the home page of the website, as the case may be, and will be binding as soon as published and/or communicated. We therefore ask you to regularly access this section to check the publication of the most recent and updated Privacy Policy or to check your e-mail inbox. The full text of the Regulation can be consulted on the website of the Authority of personal data protection www.gpdp.it.
Footnotes:
[1] Where Premi acquires information and personal data, it shall inform users in advance of the purposes for which such data is required and the methods by which it will be used. Where necessary, Premi shall acquire the user’s specific consent to the relevant use of data. By way of example, personal data such as name and surname, telephone number, e-mail address and other information that the user agrees to provide in order to use the services of the Website may be requested by filling in a specific data collection form. Premi shall use the personal data collected on-line only for the purposes indicated during collection.
The data relating to the connection and navigation within the Website (such as the addresses in URI-Uniform Resource Identifier notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment) are collected for the sole purpose of obtaining anonymous statistical information on the use of the website and to check its correct functioning, and are deleted when their use is complete. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the website: to the exclusion of this possibility, the data will be deleted after the time required to provide the services illustrated on the website has elapsed.
[2] Your data will be processed:
– pursuant to Article 6(1)(b) and (c) of the Regulation, to manage your orders and guarantee you the use of the Services (including after-sales services) requested through the website, to fulfil the related legal obligations, and to respond to your requests, if any;
– on the basis of your consent, pursuant to art. 6, paragraph 1, letter a) of the Regulation, to carry out marketing activities and analysis of your preferences by Premi and the parent company in the EMEA region, Berlin Packaging Italy S.p.A. .
In any case, the processing will be carried out in compliance with the provisions in the current regulations – and their subsequent amendments and/or additions – issued by the Personal Data Protection Authority.
[3] Your data will be communicated to:
(i) companies of the Berlin Packaging group;
(ii) third party companies for the management of the Website services and for sending the newsletter;
(iii) third party companies for the management of your eventual purchases or events organised by Premi.
[4] Your data, collected through the “Contacts”, “Catalogue”, “Events” sections of the Website, will be processed and stored for the time necessary to handle your request correctly.
Data processed for the purpose of sending you communications on Premi and/or Berlin Packaging brand products, offers, news and events shall be kept for five (5) years from the date of collection or from the date of your last contact with Premi. Data processed for the purpose of sending you the Newsletter shall be retained for two (2) years from the date of collection and of your consent. Near the end of said periods, Premi may contact you to find out whether you wish to continue to receive communications on products, services, offers, news and events or whether you wish to continue to receive the Premi Newsletter. Should you withdraw your consent for said marketing purposes, your data shall be promptly deleted.
[5]
Articles 15 to 22 of the Regulation grant you specific rights including:
· to obtain confirmation as to whether or not personal data concerning you are being processed;
· to obtain access to your personal data and to the information indicated in Article 15 of the Regulation;
· to obtain the rectification of inaccurate personal data concerning you without undue delay or the integration of incomplete personal data
· to obtain the deletion of personal data concerning you without undue delay;
· to obtain the restriction of the processing of personal data concerning you;
· to be informed of any rectification or erasure or restriction of processing of personal data concerning you;
· to receive or transmit to another data controller in a structured, commonly used and machine-readable format the personal data concerning you;
· to object at any time, on grounds relating to his/her particular situation, to the processing of personal data concerning him/her.
In particular, your right to revoke at any time any processing consents you may have given and to object to our analysis activities remains unaffected.
Furthermore, pursuant to Art. 21 of the Regulation, you shall have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you carried out in pursuance of the legitimate interests of the controller pursuant to Art. 6(1)(f) of the Regulation.
