Information Sheet on Data Processing

Subject: Disclosure pursuant to art. 13 of Legislative Decree 196/2003 as well as Integrated by Legislative Decree 101/2018 in application of EU Regulation no. 2016/679


Pursuant to art. 13 of Legislative Decree 196/2003 (hereinafter “Privacy Code”) and art. 13 of the EU Regulation n. 2016/679 (hereafter “GDPR 2016/679”), laying down provisions for the protection of persons and other subjects regarding the processing of personal data, we wish to inform you that the personal data you provide will be processed in compliance with the aforementioned law:

Data controller
The Data Controller is FRANCONIERI & PARTNERS, in the person of the legal representative FRANCONIERI DINO, who can be contacted at the email address

Purpose of the treatment
The personal data supplied by you are necessary for the fulfilments required by law, in particular your data may be processed for one or more purposes related to the implementation of the following obligations, related to legislative or contractual obligations:

·                   Personnel management in general (business tools such as computers and others);

·                   Management of working time and attendance at the company;

·                   Management of access to company premises;

·                   Management of video surveillance for security inside and outside the building (request extended information);

·                   Health and safety at work;

·                   Management of information, training and training;

·                   Scheduling of activities;

·                   Attendance register;

·                   Internal control services;

·                   Legal and economic treatment of personnel;

·                   Mandatory obligations by law in the fiscal and accounting fields;

·                   After-sales assistance;

·                   Litigation management;

·                   Customer management;

·                   Detection of customer satisfaction;

·                   Customer billing history.

The processing of functional data for the fulfillment of these obligations is necessary for a proper management of the relationship and their conferment is mandatory to implement the purposes indicated above. The Data Controller also states that any non-communication, or incorrect communication, of one of the mandatory information, may cause the Data Controller’s inability to guarantee the adequacy of the processing itself. For the purpose of the indicated processing, the Data Controller may be aware of data defined as common or particular, or sensitive and judicial according to the Privacy Code. Your sensitive data being processed are only those strictly relevant to the bligations, tasks or purposes described above and will be treated in compliance with the instructions contained in the relevant General authorizations of the Guarantor. Your personal data may also, with your consent, be used for the following purposes:

·                   To present company services and products on the site or on social networks FRANCONIERI & PARTNERS, by sharing photographic material or videos that could represent customers;

·                   to satisfy market surveys, statistics and promotional activities related to the sending of advertising and promotional material (subscription to newsletters or blogs).

The provision of data is optional for you in relation to the aforementioned purposes, and your refusal to treatment does not compromise the continuation of the relationship or the adequacy of the treatment itself, except the impossibility of serving the customer better. These data are used to optimize the relationship of an administrative and commercial nature and the eventual sending of promotional material. It is appropriate to specify that most of the treatments carried out are not subject to the obligation to acquire consent pursuant to art. 24 of Legislative Decree no. 196/2003 and art. 7 of the GDPR.

Methods of treatment and conservation
The treatment will be carried out in an automated and / or manual form, in compliance with the provisions of art. 32 of the GDPR 2016/679 and Annex B of the Legislative Decree 196/2003 (articles 33-36 of the Code) on the subject of security measures, by persons specifically appointed and in compliance with the provisions of art. 29 GDPR 2016/679.

Please note that, in compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to art. 5 GDPR 2016/679, subject to your free and explicit consent expressed at the bottom of this information, your personal data will be kept for the period of time necessary to achieve the purposes for which they are collected and processed. Your personal data may be processed in the following ways:

·                   Assignment to third parties of processing operations or legal provisions;

·                   Creation of profiles for internal use, relating to customers, suppliers or consumers;

·                   Processing by electronic calculators;

·                   Manual processing by paper archives.

Each processing takes place in compliance with the procedures set forth in Chapter II of the Regulation (EU) 2016/679 and the articles. 11, 31 and following of Legislative Decree 196/03.

Scope of communication and dissemination
We also inform that the collected data will never be disclosed and will not be communicated without your explicit consent, except for the necessary communications that may involve the transfer of data to public bodies, consultants or other subjects for the fulfillment of legal obligations.

Transfer of personal data
Your data may, upon your consent, be transferred to Member States of the European Union or to third countries outside the European Union.

Particular categories of personal data
Pursuant to articles 26 and 27 of Legislative Decree 196/2003 and articles 9 and 10 of EU Regulation no. 2016/679, you could confer, to FRANCONIERI & PARTNERS data qualifying as “particular categories of personal data” and that data that reveal “the racial or ethnic origin, political opinions, religious or philosophical convictions, or the union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data on the state of health or sexual life or sexual orientation of the person “. These categories of data may be processed only with your free and explicit consent, expressed in writing at the bottom of this information. Your sensitive data being processed are only those strictly relevant to the obligations, tasks or purposes described above and will be treated in compliance with the instructions contained in the relevant General Authorizations of the Guarantor.

Rights of the interested party
At any time, you can exercise, pursuant to art. 7 of Legislative Decree 196/2003 and articles from 15 to 22 of EU Regulation no. 2016/679, the right to:

a) request confirmation of the existence or otherwise of personal data;

b) obtain information on the purposes of the processing, the categories of personal data, recipients or categories of recipients to whom the personal data have been or will be communicated and, where possible, the retention period;

c) obtain the correction and deletion of data;

d) obtain the treatment limitation;

e) obtain data portability, ie receive them from a data controller, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without hindrance;

f) oppose the processing at any time and also in the case of treatment for direct marketing purposes;

g) to oppose an automated decision-making process concerning individuals, including profiling.

h) To ask the data controller to access personal data and to correct or cancel them or limit their processing or to oppose their treatment, in addition to the right to data portability;

i) withdraw the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;

j) to propose a claim to the Privacy Guarantor.

You can exercise your rights with a written request sent to Franconieri & Partners to the postal address of the registered office or to the email address