Newsletter Policy

Privacy policy for users subscribing to the Newsletter pursuant to Art. 13 of EU Regulation 679/2016 General Data Protection Regulation (GDPR)

1. Identity and contact details of the data controller

Berlin Packaging Italy S.p.A., with registered office in Viale C. Colombo, 12/14, - 20090 Trezzano sul Naviglio (MI), tax code and VAT number 01746490158, e-mail privacy.eu@berlinpackaging.com (hereinafter referred to as "BPItaly", "we", "our"), is the company that, as data controller, collects and processes your personal data, pursuant to EU Regulation 679/2016 (the "Regulation").

2. Purpose of processing

The data that you are providing by filling in the electronic form on the website https://www.berlinpackaging.eu (the "Site") are necessary for us to allow your subscription to our newsletter and to update you by sending you promotional material (by e-mail) on Berlin Packaging brand products, services (e.g. purchasing methods, home delivery, etc.), initiatives and events, as well as to carry out market research (to better understand your interests and to be able to improve our offer).

3. Legal basis of processing

The legal basis for the processing of your data is your consent in accordance with Art. 6 paragraph 1 letter a) of the Regulation.

In order to be able to update you on our products, services, initiatives and events, to send you promotional material, also personalised according to your country, or to carry out market research, we need your explicit consent (pursuant to Art. 6, par. 1, letter a) of the Regulations). If you do not give your consent, we will not be able to proceed with your registration for our newsletter. Your consent is freely revocable (see letter h) of this policy) without prejudice to the lawfulness of the processing prior to revocation, including by simply using the link in all our newsletters or by writing to privacy.eu@berlinpackaging.com.

4. Mandatory data

We ask you to provide all the data requested as "mandatory" (e-mail address) because it is necessary for your subscription to our newsletter; if you do not provide this data or if it is incomplete, your subscription cannot be completed.

5. Methods of data processing and scope of communication

Your data will be processed electronically in compliance with the regulations in force, in accordance with the requirements of the provisions in force - and their subsequent amendments and/or additions - issued regarding the protection of personal data, and, in any case, in such a way as to guarantee their security and confidentiality and to prevent their unauthorised disclosure or use, alteration or destruction.

Your data will not be disseminated. In order to allow you to receive our newsletter and to be contacted by BPItaly, your data may be disclosed (limited to their respective sphere of competence) to the persons authorised to process the data of the companies of the Berlin Packaging group, as well as of the companies which provide us with services [1] useful for the management of our Site or which carry out marketing activities on our behalf.

6. Data retention period

Your data will be processed for the duration of your subscription to our newsletter service or - in any case - until you revoke your consent (which can be requested at any time, also using the link in all our newsletters); thereafter, the data will be deleted or anonymised [2].

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

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

Due to the organisational policy of the Berlin Packaging group, your personal data may be transferred to the United States of America where the servers hosting the group's CRM (customer relationship management) applications 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 EU Commission.

8. Rights of data subjects

By means of a communication to be sent to the e-mail address 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, modifying 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 to another data controller, without prejudice to the possibility of changing or revoking your consent.

You can also always object to the processing of your data, in particular for marketing purposes, by using the link in the footer of the Newsletter to unsubscribe.

9. Who you can contact to complain:

We would like to remind you that if you consider that the processing concerning you violates the provisions of the Regulation, you can always lodge a complaint with the Personal Data Protection Authority (www.gpdp.it), or with the supervisory authority of the country in which you normally reside.

Footnotes:

[1] Your data will be disclosed to the following recipients as external data processors:

1. companies in charge of processing, managing and sending newsletters and promotional material;
2. commercial partner companies of the Berlin Packaging group;
3. companies that organise and manage market research on our behalf
4. companies entrusted with the management of our website and related computer files.

The names of all external data processors can be requested by sending a communication to privacy.eu@berlinpackaging.com.

[2] The processing of your data for marketing purposes (including the sending of the newsletter) may only take place with your prior consent. When this consent is about to expire, BPItaly may contact you to find out whether you wish to continue to receive communications and newsletters about new products, services, offers from the Berlin Packaging group and, therefore, renew your consent. Your consent to the processing of your data for marketing purposes is also freely revocable at any time.

The data processed for the purpose of sending you answers to your enquiries, communications on Berlin Packaging branded products, offers, news and events, marketing communications (including newsletters), will be stored for five (5) years from the date of collection or from the date of your last contact for non-contractual purposes.

[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;
• to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you.

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 paragraph 1 letter f) of the Regulation.

Update date: 19/03/2024