Client privacy policy in compliance with the EU Regulation no. 679/2016 on the protection of individuals with regard to personal data processing

Foreword
Pursuant to the EU Regulation no. 2016/679 (hereunder referred to as "GDPR"), establishing the provisions for the protection of persons and other subjects regarding the processing of their personal data, the company Newfren srl with registered office in Via Ettore de Sonnaz, 19 - 10121 Turin (TO) - Italy, (hereunder referred to as the "Company" or the "Data Controller") informs all the persons concerned that their personal data will be processed in accordance with the above mentioned regulation.

1. Data Controller
Pursuant to Article 4, no. 7, of the GDPR, the Data Controller is Newfren srl with registered office in Via Ettore de Sonnaz, 19 - 10121 Turin (TO), Italy, E-mail info@newfren.it Tel: +39 011 9200111 Fax +39 011 9200100, in the person of its legal representative.

2. Purpose and legal basis of data processing
Personal data are processed in order to provide adequate compliance with legal and fiscal requirements, as well as with those related to the execution of the contract and in particular for the management of orders, billing and shipment of goods and for marketing purposes such as sending promotional-advertising material or newsletters where explicitly consented in this document under the section "CONSENT TO RECEIVING NEWSLETTERS AND PROMOTIONAL-ADVERTISEMENT MATERIAL".

3. Reasons for data provision and consequences of its refusal
The provision of personal data to the Company is mandatory only to the extent that it is functional to the execution of the contract; should the Client fail to provide one or several compulsory personal data, the Company may be unable to perform the contract.

4. Data processing method
Data processing will be carried out in a paperless manner, through electronic or computer-based instruments and in compliance with provisions set to ensure security and confidentiality, as well as, inter alia, accuracy, updating and relevance of personal data to the stated purposes. Data processing will be carried out in compliance with the provisions of art. 32 of the GDPR regarding security measures by specifically appointed persons.

5. Data processing duration
Please note that, in compliance with the principles of lawfulness, purpose limitation and data minimization, without prejudice to art.5 of the GDPR, personal data will be kept for the period of time required to achieve the purposes for which they are collected and processed, as well as, subsequently, to fulfil any legal obligation related to or arising from the contract entered into with the Company and, in any case, for a period not exceeding I0 years from the conclusion of the last contract for the purchase of products or services of the Company.

6. Recipients of personal data
Without prejudice to the communications made in compliance with a legal obligation, regulation or Community legislation, communications, even through simple consultation or by making the personal data of the concerned person available the following subjects may decide to take action:
a) public bodies, supervisory bodies, authorities or institutions;
b) natural or legal persons providing specific services, such as: data processing, logistics and postal services, legal advice, tax administration and accounting, organization of trade fairs and communication events;
c) commercial brokers, banks and credit institutions, financial intermediation companies, natural persons or legal entities in charge of credit recovery, auditing and/or certification of financial statements and quality systems, independent collaborators of the Company, insurance agents and brokers;
d) trade agents acting on behalf of the Company. In any case, mentioned subjects would only receive aggregated, anonymous personal data, as well as data that are strictly necessary and pertinent for the purposes of data processing. Furthermore, in the management of your personal data, the following categories of persons in charge, identified in writing and to whom specific written instructions have been given, may receive your personal data:
f) any persons authorised and entrusted by law by the Data Controller;
g) professionals or service companies for administration and business management who operate on behalf of the Company.
h) Transfer of data to a third country and/or international organizations. 
Newfren srl does not share, sell, transfer nor otherwise disseminate your personal data to third parties and will continue not to do so in the future, except as required by law, unless it is necessary for the purposes of the contract or if you have given your explicit consent to such processing. For needs strictly related to the execution of the contract and the provision of services, some of your personal data may be disclosed to other companies owned by Newfren and which are based in non-European third countries.

7. Rights of the concerned party
In accordance with articles 15 to 22 of the EU Regulation No. 2016/679, at any time, the concerned party may exercise the right to:
a) ask for confirmation of the existence or not existence of your personal data;
b) obtain information on the purposes of data processing, on the categories of personal data, on the recipients or categories of data of recipients to whom the personal data have been or will be communicated and, where possible, the period of storage:
c) obtain correction and deletion of data;
d) obtain treatment limitation;
e) obtain data portability, i.e. receiving data from a data controller, in a structured format of use, common and readable by automatic device, and send them to another data controller without hindrance;
f) oppose processing at any time and, also, oppose processing for direct marketing purposes;
g) oppose automated decision making concerning physical persons, including profiling:
h) ask the data controller for access to amend or delete personal data, to request limitation of processing data concerning him or to oppose their processing, as well as the right to data portability;
i) withdraw consent at any time without prejudice to the lawfulness of the processing based on consent granted before revocation;
j) complain with a supervisory authority.

You can exercise your rights by sending a written request to the operational headquarters to Newfren srl, Via S. Pertini, 1 – 10073 Ciriè (TO) - Italy, to the mailing address of the registered office or to the email address: info@newfren.it 

Please note that any amendment, deletion or limitation of data processing carried out on request, unless this proves to be impossible or it involves disproportionate efforts, will be communicated by the Company to each of the recipients to whom such personal data have been transmitted to.

The Company may notify the interested party of such addressees if the interested party so requests.

A vademecum on your rights, as per the EU Regulation/2016, is available at http://www.garanteprivac.it/diritti-degli-interessati.

Company data
Legal Site: TORINO (TO) Via Ettore de Sonnaz 19 CAP 10121
Official Site: CIRIE’ (TO) Via Sandro Pertini 1 CAP 10073
Tax (VAT) Code: 00882690019
Share Capital Euro: 500.000,00 i.v.