WEBSITE - DATA CONTROLLER POLICY DATA
PRIVACY AND PERSONAL DATA PROTECTION INFORMATION NOTICE
Fabbrica d’Armi Pietro Beretta S.p.A., GMK Limited , consider of fundamental importance the protection of the personal data of data subjects during processing. It assures all data subjects that the processing of their personal data, performed using both automated and traditional methods, takes place in compliance with the safeguards and rights recognised by the Italian Personal Data Protection Code with particular reference to confidentiality, to the safeguarding of personal identity and dignity and to the right to personal data security and protection.
This information notice is organised into sections, each of which deals with a specific topic which may be investigated further at the discretion of the data subject.
Where required, the information notice is accompanied by a specific consent form, tailored based on the type of use of the information.
b) The roles and responsibilities of companies in relation to personal data protection
The following table shows the role of each company in relation to personal data processing and the typical data processing operations carried out (collection, registration, organisation, storage, elaboration, selection, extraction, utilisation).
Personal Data Protection Role
Data processing activities
Fabbrica d’Armi Pietro Beretta
Data controller for marketing and profiling purposes.
Data controller for management and maintenance of shared data base managed via CRM, under specific mandate received from other Group companies in their capacity as joint data controllers
- Collection and utilisation for marketing and profiling purposes
- Registration, organisation, storage, elaboration, selection and extraction for CRM management purposes
• Joint data controller for marketing and profiling purposes.
• Responsible of processing for promotional activities involving local marketing initiatives or events (by geographical area) via email on behalf of the Group’s other production companies
Collection and utilisation for marketing and profiling purposes
Each company listed above:
· acts as joint data controller for marketing and profiling purposes
· is jointly responsible with the other companies for the phases involving the collection and subsequent utilisation of personal data
· determines, jointly, how the data will be stored, who may access the data present on the CRM platform and which integrated marketing and profiling activities should be carried out
· appoints, Fabbrica d’Armi Pietro Beretta S.p.A. as data processor in relation to management of the CRM, the shared data base for the personal data of customers and leads of the other Group companies as well.
Area of circulation of data
Personal data may be circulated between individuals appointed as internal data processors within their respective organisations or between third party/external data processors i.e. third parties which carry out relevant activities on behalf of the joint data controllers. It may also be used by individuals specifically designated as persons in charge of processing in relation to the service in question and who have received specific instructions on the security and proper use of the data.
More detailed information on the names of internal and external data processors may be obtained by writing to firstname.lastname@example.org.
a) Definition of types of “personal data” processed
"Personal data” is intended as "any information relating to a physical person that has been or can be identified, also indirectly, with reference to any other information, including a personal identification number ".
Fabbrica d’Armi Pietro Beretta S.p.A., GMK Limited ay acquire the following types of personal data:
· Personal data including name, surname, home/residential address, date of birth, email address, fixed and/or mobile numbers input to registration form or provided voluntarily in the case of communications with telephone operators or sent by email.
· Data relating to consumer tastes, preferences, habits, needs and decisions as deducted from data relating to web site navigation.
b) Purposes and methods of processing
Fabbrica d’Armi Pietro Beretta S.p.A., GMK Limited may find itself processing one or more of the types of personal data listed in point c) using electronic devices or traditional methods for the purposes described below:
1. Purposes connected with and regarding handling of a request submitted
This category includes all activities for the provision of services or specific activities requested voluntarily by completing a form, sending an email or making a call to a telephone number.
As regards the completion of the form, data indicated with an asterisk (*) and responses to questions indicated with an asterisk (*) must be provided in order to proceed with the request. If such data/ responses are not provided, it shall not be possible to fulfil the request.
2. Purposes related to promotional and/or marketing activities
This category includes all activities carried out to promote products and services related to the product categories of the joint data controller companies, as indicated above. Commercial offers may also be made on behalf of third parties without the any communication of data in this case. The personal data collected – with the consent of the data subject – may be passed on to third party businesses for the same purposes and they will act as autonomous data controllers (see the subsequent paragraph e) “Categories of persons/entities to which data may be communicated”).
3. Purposes related to profiling and regarding market research and statistical analysis
This category includes all activities relating to profiling of the data subject and intended to identify their consumer tastes, preferences, habits, requirements and decisions in order to improve the quality of the services provided by the joint data controller companies as indicated above.
Provision of data on voluntary basis– Data for purposes 2 and 3 above is provided on a voluntary basis and is subject to free consent being given for the use of personal data for said purposes on the conditions indicated above; consent may be given using the attached form.
Methods of contact– The methods of contact for promotional and profiling activities under 2 and 3 above – assuming consent has been given – may be automated (email, SMS, fax, operator-less phone call) or traditional (phone call by operator, mailshot). The data subject may, at any time, withdraw consent previously given, even partially e.g. by consenting only to traditional methods of contact.
c) Categories of persons/entities to which data may be communicated
In the course of its activities and for the purposes stated under d) above, Fabbrica d’Armi Pietro Beretta S.p.A., GMK Limited wish to communicate your personal data to the following persons/entities:
1. Companies belonging to the Beretta Holding Group for the purposes stated above.
2. Persons, companies, associations or professional firms that provide consulting and assistance services to our Company;
3. Companies, entities, associationswhich provide services relating to fulfilment of the purposes indicated above (courier for delivery of catalogues and/or products purchased, our stores, customer care service, market research and analysis services, management of credit card payments, IT systems maintenance)
4. Public sector bodies or Judicial Authoritieswhere requested by law or to prevent an offence from being committed.
Where your consent is required, you may use the attached form.
d) Transfer of data to other countries
The personal data may also be transferred abroad, to companies belonging to the Beretta Holding Group, but only within the European Economic Area (EEA).
e) Distribution of data
The personal data gathered is not and shall not be distributed except for statistical studies performed on an anonymous, aggregate basis.
f) Rights of the data subject
The data subject has the right to access its personal data, requesting that it be amended and updated if incomplete or inaccurate. The data subject may also request the deletion of the personal data if it was collected in violation of the law and may oppose its processing for specific, valid reasons.
Withdrawal of consent previously given for the purposes of marketing, profiling or communication to third parties shall cause such personal data processing activities to cease.
In order to exercise rights, find out the names of internal and external data processors, obtain information about the Beretta Holding Group companies or third party companies on whose account promotional activities are carried out or to which the personal data may be communicated and to withdraw consent, the data subject should contact Fabbrica d’Armi Pietro Beretta spa, the company responsible for processing,by writing to Fabbrica d’Armi Pietro Beretta S.p.A. FAO the Data Protection Manager - Via Pietro Beretta, n°.18 - 25063 Gardone Val Trompia (BS) - email@example.com.