Ecommerce Policy

Privacy policy for users of the e-commerce service pursuant to Art. 13 of EU Regulation 679/2016 General Data Protection Regulation (GDPR)

1. Identity and contact details of the data controller

The E-Commerce located on the website https://www.berlinpackaging.eu (following “Site”) is managed by Berlin Packaging Iberia S.L.U. (in the following “BPIberia”) in Carretera Córdoba Málaga, km 44, 14550 Montilla, Cordoba (España), CIF, NIF B96201801, tel. +34 955 67 50 06, e-mail, e-mail privacy.eu@berlinpackaging.com, in its capacity as Data Controller pursuant to the Regulation.

2. Purpose of the processing of your data:

The data you are providing us by completing the purchase process on the Site are necessary for:

1. complete the sale of the products you have selected and fulfil the contract concluded with you, as well as exercise our related rights, including in court;
2. comply with legal obligations, regulations and EU legislation relating to your purchase (e.g. tax, accounting, anti-money laundering, anti-fraud);
3. to manage the services connected to your purchase also in the post-sales phase (e.g. customer service).

The legal basis for the processing of your data will be the execution of the sales contract established with you and of the related services and the fulfilment of the relative legal obligations pursuant to Article 6, paragraph 1, letters b) and c) of the Regulations.

3. Your consent

The processing of your data will take place without the need for your consent, pursuant to Article 6, paragraph 1, letters b) and c) of the Regulation. However, in order to receive dedicated commercial offers and discounts related to your purchasing preferences, it will be necessary to give your consent to profiling during the activation of your account pursuant to Art. 6 letter a) of the Regulation. You will also be asked for this consent on an annual basis by means of a satisfaction questionnaire. You will not be able to benefit from a dedicated discount without consenting to profiling, as we will not be authorised to screen your preferences.

4. Mandatory data

We ask you to provide all the data requested as "mandatory" (*) because it is necessary for the management of your purchases and the services connected to them (e.g. delivery); if you do not fill in all or incompletely, your purchases cannot be completed. Failure to fill in the data indicated as 'optional' will have no consequences.

If you provide data of third parties (e.g. your family members, other customers or potential customers), you must ensure that these third parties are informed and have consented to the use of the data as described in this policy.

5. Method of processing your data

Your data will mainly be processed by computer in order to manage your purchases. In addition, the processing will be carried out in compliance with current legislation and, in any case, in such a way as to guarantee its security and confidentiality and to prevent its unauthorised disclosure or use, alteration or destruction.

Your data will not be disclosed or transferred to third parties for a fee. In order to manage your purchases, the personal data entered in the fields of the online shop will be disclosed (limited to their respective sphere of competence) to the persons authorised to process the data in the Marketing, Purchasing, Finance and Legal Departments. The data may also be shared with our business partners as well as with companies that provide us with services [1] useful for managing your purchases and related services, including after-sales services.

Your data may be processed not only by BPIberia but also by its European parent company Berlin Packaging Italy S.p.A. for specific marketing activities planned by the same.

6. Period of data retention

Your data will be processed for the time necessary for the management of your purchases and related services (e.g. Customer Support), as well as - limited to the necessary data - for the time required to comply with legal obligations regarding tax and accounting matters [2], after which the data will be deleted or made anonymous.

7. Place of data processing and transfers outside the European Union

Processing related to the services provided by the Site is carried out in the European Union.

Due to the organisational policy of the Berlin Packaging group, to which BPIberia belongs, your personal data may be transferred to the United States of America where the servers hosting the group's CRM (customer relationship management) system are physically located.

The applicable legislation provides that your specific consent to the transfer to third countries is not required as the transfer is made on the basis of the adoption of adequate safeguards as per articles 46 and 47 of the Regulation, such as the adoption of standard contractual clauses approved by the European Commission.

8. What are your rights

By means of a communication to be sent to privacy.eu@berlinpackaging.com you may at any time exercise your rights [3] as set out in Articles 15 to 22 of the Regulation, including knowing what data we are processing, how and for what purposes we use it, modify the data you have provided us with or delete it, ask us to restrict the use of your data, request to receive or transmit your data to another data controller.

9. To Whom You May Complain

We remind you that, if you consider that the processing of your personal data violates the provisions of the Regulation, you may always lodge a complaint with the Personal Data Protection Authority (www.aepd.es/es), or, if different, with the Data Protection Authority of the Member State in which you habitually reside or work or of the place where the alleged violation occurred.

Footnotes:

[1] Your data, provided for the purposes set out in c.1 of the Berlin Group's Privacy Disclaimer (contractual purposes and execution of pre-contractual measures), will be stored for as long as is necessary to fulfil the obligations assumed towards you in connection with the business relationship and in any event no longer than ten (10) years after the conclusion of the contractual relationship.

Should you decide to proceed with purchases, you will have to create your customer account by registering in the Account section, and your data will be processed as long as your account is active. You may close your account at any time and your request will be handled immediately or, in the case of a pending purchase order, immediately after it has been executed. Should your account remain inactive for three (3) years, BPIberia will contact you to find out whether you wish to maintain or close your account. If you do not wish to keep your account active, it will be closed and your data deleted.

Your purchase details will, however, be processed anonymously for analysis or promotional purposes.

Your bank details are only processed and stored securely by the operator of the payment service you have chosen ((Paypal, Redsys, Bizum, Adyen) for the time stipulated by national law.

[2] Your data may be processed by the company managing the Site only for the proper functioning of the Site. Furthermore, your personal data will be communicated, as external data processors, to:

1. payment management companies;
2. product shipping and delivery companies;
3. legal, tax and audit consultants
4. business partners
5. newsletter operator (only with your express consent)

[3] Articles 15 to 22 of the Regulation recognise specific rights including:

• 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
• obtain the rectification of inaccurate personal data concerning you without undue delay or the integration of incomplete personal data
• obtain the deletion of personal data concerning you without undue delay;
• 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;
• receive or transmit to another data controller in a structured, commonly used and machine-readable format the personal data concerning you;
• object at any time, on grounds relating to his/her particular situation, to the processing of personal data concerning him/her.

Update date: 19/03/2024