INFORMATIVE MEMO ON PERSONAL DATA PROTECTION CODE OF PRACTICE
Legislative decree n. 196 of 30th June 2003
(Personal data protection code of practice)

Pursuant to article 13 of the aforementioned law, we would like to inform you that Galvamet S.r.l. processes generic details of customers, suppliers and others who have voluntarily provided our sales office or the telemarketing company on our behalf with such information personally, by phone, fax, e-mail or post.

In accordance with the aforementioned law (ref. Art. 2 – Scope). Galvamet S.r.l. guarantees that all personal data is processed lawfully respecting the owner’s fundamental human rights and dignity, particularly with regard to privacy and personal identity as well as ensuring protection of personal data.

Scope of processing personal data
All data provided is processed exclusively for trading and customer service purposes and specifically:

for recording company details in Galvamet S.r.l.’s database;
for company market analysis, research and statistics;
for recording training and / or technical assistance provided;
for issuing transport documents (delivery notes), invoices and credit notes;
for issuing sales offers and bids to old and / or new potential customers;
for requesting sales offers and bids to old and / or new potential suppliers;
for accounting and VAT return and registration purposes;
for managing customer and supplier payments;
for sending sales information regarding the company activity to old and /or new potential customers;
for exchanging company information related to financial, administrative and sales questions – by telephone, post, courier, fax, e-mail and through private access areas in Galvamet S.r.l ’s web site;
for fulfilling obligations required by the law, regulations, EU directives, civil and fiscal legislation.

Communication and disclosure of data
Personal data in the event considered necessary may be disclosed to:

 - 
 all subjects who under legislation have the right to access such information;
- 
 our collaborators, employees, sales agents and suppliers who in their capacity and / or due to contractual obligations are required to access such information to satisfy sales and trading relations with the data owner;
- 
 factoring companies, debt collection companies and credit insurance companies;
- 
 manufacturing companies and / or companies who produce under licence services / products in the event such disclosure of information is necessary to permit the end user to use the products/ services purchased;
- 
 postal offices, forwarding agents / freight companies and courier services to send documentation and / or materials;
- 
 providers of Unified Messaging internet services when letters and communications are sent to the interested parties for the purposes of processing such information utilising this type of technology;
- 
 natural and / or juridical persons (corporate bodies), public and / or private (Technical Assistance Centres, Legal practices, administrative and fiscal agencies, employment and HR consultants for preparing pay packets, Juridical Offices, Chambers of Commerce, Employment Offices / agencies etc.) for the aforementioned purposes utilising the processing methods described herein;
- 
 banks for effecting payments as per contractual obligations;

Collection and lack of consent
Consent for processing personal data by subjects who wish to have trade relations with our company even if purely informative for receiving information related to our production / services is optional, however lack of consent may cause such relations to cease, or not allow us to comply to contractual or legal and/or fiscal obligations. Personal data is stored in our operational headquarters and kept for the time prescribed by civil and fiscal legislation.

Processing methods
Personal data is processed within Galvamet S.r.l.’s operational headquarters utilising paper and electronic formats, telephone and telematic systems, automated tools for storing, managing and transmitting such data guaranteeing security and privacy. The categories of people designated to deal with personal data are: Administrative Department, Management Department, Export Department, Italian Department, Reception, Technical Department, Purchase Department, Production Department and Factory Department.

Data Controller
The data controller is Galvamet S.r.l. located in Viale dell’Industria, n. 10, 35014 Fontaniva (PD), Italy.

Rights to access personal data
The data owner has the right to receive confirmation that his/her personal data exists, even if not yet registered and to receive a copy of such personal data in an intelligible form.

The data owner has the right to know:

 the origins, processing methods and purposes for processing such information;
the logic applied for electronic processing methods;
details of the data controller;
subjects and categories of subjects who may access such information in the capacity of data processors.

The data owner has the right

to update, rectify or integrate data;
to erase, correct such information and become anonymous or to impede the use in case of law violation, including all data that is not considered necessary to be stored for the reasons why such information has been collected or subsequently processed;

The data owner has the right to oppose to such data processing in full or partial:

 for legitimate reasons even if said processing is considered pertinent to the purpose of such data collection;
for the purpose of receiving advertising material, direct sales or for market research or sales communications.

The aforementioned rights may be exercised by presenting an informal request to the data controller and such request may be presented by a delegated third party and shall be processed without delay. Requests presented to the data controller may be notified by registered post, fax or e-mail.

GALVAMET srl
CAPPE PER CUCINE
Viale dell'industria, 10 - 35014 Fontaniva (PD) - ITALY
Tel. 049 5942144 - Fax 049 5940061