Customers

Dear Customer,

In accordance with Article 13 of Regulation (EU) No. 679/2016 of the European Parliament and of the Council of April 27, 2016, concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter referred to as Regulation (EU)), we provide you with the following information regarding the processing of your personal data:

Contact details of the data controller:

The data controller of your personal data is BRAVI‑PLATFORMS S.R.L., with its registered office located at via Strada Statale Adriatica, km. 314,600 60022 Castelfidardo AN, and can be contacted at the telephone number +39 071 7819090 or at the email address ‘info@bravi-platforms.com’.

Decision to appoint a Data Protection Officer:

A decision has not been made to appoint a Data Protection Officer, as BRAVI‑PLATFORMS S.R.L., in accordance with Articles 37, paragraphs 1 and 4 of Regulation (EU), is not required to appoint one, and has assessed such an appointment as currently unnecessary.

Purposes and legal bases for the processing of your personal data:

Your personal data, which is adequate, relevant, and limited to what is necessary, will be processed by BRAVI‑PLATFORMS S.R.L. lawfully, fairly, and transparently in relation to you and in a manner that ensures an adequate level of security for the following purposes:

The execution of preliminary activities leading to the signing of a transfer contract between you and BRAVI‑PLATFORMS S.R.L., including the management of the pre-contractual relationship: the legal basis is the necessity of taking pre-contractual measures at the request of the data subject, pursuant to Article 6, paragraph 1, letter b) of Regulation (EU);
The execution of the transfer contract between you and BRAVI‑PLATFORMS S.R.L., including the management of the contractual relationship, product design, product production, product delivery, and payment management: the legal basis is the necessity to execute a contract to which the data subject is a party, pursuant to Article 6, paragraph 1, letter b) of Regulation (EU);
Compliance with a civil and tax obligation by BRAVI‑PLATFORMS S.R.L., including the registration, maintenance, and communication of invoices and the processing and maintenance of accounting records: the legal basis is the necessity to fulfill a legal obligation to which the data controller is subject, pursuant to Article 6, paragraph 1, letter c) of Regulation (EU);
Compliance with a personal data protection obligation by BRAVI‑PLATFORMS S.R.L., including the drafting, delivery, and maintenance of the information notice for data subjects: the legal basis is the necessity to comply with a legal obligation to which the data controller is subject, pursuant to Article 6, paragraph 1, letter c) of Regulation (EU);
Legal protection of the data subject by BRAVI‑PLATFORMS S.R.L., including managing disputes and debt recovery: the legal basis is the necessity of pursuing the legitimate interest (legal protection) of the data controller, pursuant to Article 6, paragraph 1, letter f) of Regulation (EU);
Protection of the company’s assets by BRAVI‑PLATFORMS S.R.L., including the maintenance of hardware, software, and email systems: the legal basis is the necessity of pursuing the legitimate interest (protection of company assets) of the data controller, pursuant to Article 6, paragraph 1, letter f) of Regulation (EU);
Marketing activities by BRAVI‑PLATFORMS S.R.L., including the management of advertising campaigns: the legal basis is the consent to process personal data for this specific purpose provided by the data subject, pursuant to Article 6, paragraph 1, letter a) of Regulation (EU).

Potential recipients of your personal data:

For the processing of your personal data by BRAVI‑PLATFORMS S.R.L. for the purposes outlined above, the potential categories of recipients of your personal data may include:

Employees (commercial area) of BRAVI‑PLATFORMS S.R.L., as authorized to process your personal data, in order to carry out preliminary activities leading to the signing of a transfer contract between you and BRAVI‑PLATFORMS S.R.L., execute the transfer contract, provide legal protection, and perform marketing activities: all such subjects are adequately trained regarding the measures to be taken to protect your personal data, in accordance with Article 29 of Regulation (EU);
Employees (accounting and tax area) of BRAVI‑PLATFORMS S.R.L., as authorized to process your personal data, in order to fulfill a civil and tax obligation and provide legal protection: all such subjects are adequately trained regarding the measures to be taken to protect your personal data, in accordance with Article 29 of Regulation (EU);
Administrators (general management area) of BRAVI‑PLATFORMS S.R.L., as authorized to process your personal data, in order to carry out preliminary activities leading to the signing of a transfer contract between you and BRAVI‑PLATFORMS S.R.L., execute the transfer contract, fulfill civil and tax obligations, fulfill personal data protection obligations, provide legal protection, protect company assets, and carry out marketing activities: all such subjects are adequately trained regarding the measures to be taken to protect your personal data, in accordance with Article 29 of Regulation (EU);
External private entities, such as commercial agents and agencies, as data processors, in order to execute preliminary activities leading to the signing of a transfer contract and execute the transfer contract: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as banking intermediaries, as data processors, in order to execute the transfer contract: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as tax and accounting firms, as data processors, in order to fulfill civil and tax obligations: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as SAEV s.r.l., personal data protection consultants, as data processors, in order to fulfill personal data protection obligations: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as lawyers, as data processors, in order to provide legal protection: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as hardware technicians, software technicians, and website technicians, as data processors, in order to protect company assets: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU);
External private entities, such as marketing agencies, as data processors, in order to carry out marketing activities: these entities are bound by a contract with BRAVI‑PLATFORMS S.R.L. to ensure adequate protection of your personal data, in accordance with Article 28 of Regulation (EU).

Decision to transfer your personal data to a third country or international organization:

No decision has been made to transfer your personal data to a third country or international organization, as BRAVI‑PLATFORMS S.R.L. has assessed such transfer as currently unnecessary.

Retention period for your personal data:

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by it for the purpose of performing preliminary activities leading to the signing of a transfer contract between you and it for a period allowing identification of you for the duration of these preliminary activities, and for an additional period of 1 year for the legitimate interest of the data controller, after which your data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by it for the purpose of executing the transfer contract and complying with personal data protection obligations for a period allowing identification of you for the duration of these activities, and for an additional period of 10 years for any further processing within the ordinary prescription period, after which your data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by it for the purpose of fulfilling a civil and tax obligation for a period allowing identification of you for the duration of these activities, and for an additional period of 10 years to comply with legal obligations, after which your data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by it for the purpose of providing legal protection in relation to you for a period allowing identification of you only for the duration of these legal protection activities, after which your data will be destroyed or deleted. BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by it for the purpose of marketing activities only for the duration of your consent to process your data for this specific purpose, after which your data will be destroyed or deleted.

Your rights:

As the Data Subject, you have the right to exercise the following rights:

Access your personal data, pursuant to Article 15 of the EU Regulation, in order to verify whether your personal data is being processed and, if so:
obtain information on the purposes of such processing;
obtain information on the categories of your personal data being processed;
obtain information on any categories of recipients of your personal data;
obtain information on the period for which your personal data will be stored;
obtain information on your right to request rectification or erasure of your personal data, or restriction of processing;
obtain information on your right to lodge a complaint with the Data Protection Authority;
obtain information on the possible use of automated decision-making, including the logic involved and the envisaged consequences of such processing for you;

Rectify your personal data, pursuant to Article 16 of the EU Regulation, if its accuracy is contested;
Complete your personal data, pursuant to Article 16 of the EU Regulation, if its completeness is contested;
Erase your personal data, pursuant to Article 17 of the EU Regulation, unless it is necessary to comply with a legal obligation or to establish, exercise or defend a legal claim, in cases where:

the data is no longer necessary for the stated purposes;
you have exercised your right to object to the processing, and BRAVI‑PLATFORMS S.R.L.’s legitimate interest does not override your rights and freedoms;
the processing has been found to be unlawful;
there is a legal obligation to erase the data;
Restrict the processing of your personal data, pursuant to Article 18 of the EU Regulation, in cases where:
the accuracy of the data is contested, for the time needed for BRAVI‑PLATFORMS S.R.L. to verify its accuracy;
the processing is unlawful and you oppose erasure;
the data is no longer needed for the stated purposes but is required for the establishment, exercise, or defense of a legal claim;
you have objected to the processing, for the time needed for BRAVI‑PLATFORMS S.R.L. to verify whether its legitimate grounds override yours;
Receive your personal data in a structured, commonly used, and machine-readable format, and, where technically

feasible, have it transmitted to another data controller, pursuant to Article 20 of the EU Regulation, for purposes related to marketing activities carried out by BRAVI‑PLATFORMS S.R.L.;

Object to the processing of your personal data, pursuant to Article 21 of the EU Regulation, if you contest that BRAVI‑PLATFORMS S.R.L.’s legitimate interest overrides your rights or fundamental freedoms.

BRAVI‑PLATFORMS S.R.L. is required to comply with the exercise of any of your above-listed rights without undue delay.

Right to Lodge a Complaint:

As the Data Subject, you have the right to lodge a complaint with the Data Protection Authority if you contest the compliance of BRAVI‑PLATFORMS S.R.L.‘s processing of your personal data with the EU Regulation, pursuant to Article 77 of the same Regulation. This can be done by submitting the appropriate form to the email address: protocollo@pec.gpdp.it.

Nature of Providing Your Personal Data:

Providing your personal data to BRAVI‑PLATFORMS S.R.L. is a contractual requirement for the execution of preliminary activities related to the signing of a transfer agreement between you and the company, as well as for the execution of the signed contract.

Please note that failure to provide such data would prevent BRAVI‑PLATFORMS S.R.L. from fulfilling the above-mentioned purposes.
Providing your personal data to BRAVI‑PLATFORMS S.R.L. is neither a contractual nor a legal obligation in relation to marketing activities. However, please note that failure to provide such data would make it impossible for BRAVI‑PLATFORMS S.R.L. to carry out the marketing activities mentioned above.

Use of Automated Decision-Making:
No decision has been made to use automated decision-making systems in the processing of your personal data, as BRAVI‑PLATFORMS S.R.L. has assessed such use to be currently unnecessary.

Suppliers

Dear Supplier,

In accordance with Article 13 of Reg. (EU) No. 679/2016 of the European Parliament and the Council of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data, as well as the free movement of such data – hereinafter referred to as Reg. (EU) – we provide you with the following information regarding the processing of your personal data:

Contact details of the data controller:

Decision to appoint a data protection officer:

No decision has been made to appoint a data protection officer, as BRAVI‑PLATFORMS S.R.L., in addition to not being required to do so under Article 37, paragraphs 1 and 4 of Reg. (EU), has assessed that such an appointment is currently unnecessary.

Purposes and legal bases for the processing of your personal data:

Your personal data, adequate, relevant, and limited to what is necessary, will be processed by BRAVI‑PLATFORMS S.R.L. lawfully, fairly, and transparently, in a manner that ensures an adequate level of security for the following purposes:

the execution of preliminary activities for the conclusion of a purchase contract (products and/or services) between you and BRAVI‑PLATFORMS S.R.L., including the management of the pre-contractual relationship: the legal basis is the necessity of executing pre-contractual measures taken at the request of the data subject, pursuant to Article 6, paragraph 1, letter b) of Reg. (EU);
the execution of the purchase contract (products and/or services) concluded between you and BRAVI‑PLATFORMS S.R.L., including the management of the contractual relationship and payment processing: the legal basis is the necessity of performing a contract to which the data subject is a party, pursuant to Article 6, paragraph 1, letter b) of Reg. (EU);
compliance with a civil and tax obligation by BRAVI‑PLATFORMS S.R.L., including the receipt, registration, and maintenance of invoices and the processing and maintenance of accounting records: the legal basis is the necessity of complying with a legal obligation to which the data controller is subject, pursuant to Article 6, paragraph 1, letter c) of Reg. (EU);
compliance with a personal data protection obligation by BRAVI‑PLATFORMS S.R.L., including the preparation, delivery, and maintenance of the privacy notice to the data subjects, the drafting of company regulations, the preparation of the record of processing activities, and the stipulation of the contract with data processors: the legal basis is the necessity of fulfilling a legal obligation to which the data controller is subject, pursuant to Article 6, paragraph 1, letter c) of Reg. (EU);
the potential legal protection of your interests by BRAVI‑PLATFORMS S.R.L., including the management of litigation: the legal basis is the necessity of pursuing the legitimate interest (legal protection) of the data controller, pursuant to Article 6, paragraph 1, letter f) of Reg. (EU);
the protection of company assets by BRAVI‑PLATFORMS S.R.L., including the maintenance of hardware, software, and email systems: the legal basis is the necessity of pursuing the legitimate interest (protection of company assets) of the data controller, pursuant to Article 6, paragraph 1, letter f) of Reg. (EU).

Potential categories of recipients of your personal data:

Regarding the processing of your personal data carried out by BRAVI‑PLATFORMS S.R.L. for the above-mentioned purposes, the potential categories of recipients of your personal data may include:

Employees (acquisitions area) of BRAVI‑PLATFORMS S.R.L., as data processors, for the execution of preliminary activities for the conclusion of a purchase contract (products and/or services) between you and the company, the execution of the purchase contract (products and/or services) concluded between you and the same, and potentially legal protection in your regard: all such persons are duly trained regarding the appropriate measures to be taken to protect your personal data, pursuant to Article 29 of Reg. (EU);
Employees (accounting and tax area) of BRAVI‑PLATFORMS S.R.L., as data processors, for the compliance with a civil and tax obligation and potentially legal protection in your regard: all such persons are duly trained regarding the appropriate measures to be taken to protect your personal data, pursuant to Article 29 of Reg. (EU);
Administrators (general management area) of BRAVI‑PLATFORMS S.R.L., as data processors, for the execution of preliminary activities for the conclusion of a purchase contract (products and/or services) between you and the company, the execution of the purchase contract (products and/or services) concluded between you and the same, the compliance with a civil and tax obligation, compliance with a personal data protection obligation, potentially legal protection in your regard, and the protection of company assets: all such persons are duly trained regarding the appropriate measures to be taken to protect your personal data, pursuant to Article 29 of Reg. (EU);
External private entities outside our organizational structure, such as – by way of example – banking intermediaries, as data processors, for the execution of the purchase contract (products and/or services) concluded between you and BRAVI‑PLATFORMS S.R.L.: all such persons are bound to BRAVI‑PLATFORMS S.R.L. by an appropriate contract requiring them to take measures to protect your personal data, pursuant to Article 28 of Reg. (EU);
External private entities outside our organizational structure, such as – by way of example – accounting and fiscal firms, as data processors, for the compliance with a civil and tax obligation: all such persons are bound to BRAVI‑PLATFORMS S.R.L. by an appropriate contract requiring them to take measures to protect your personal data, pursuant to Article 28 of Reg. (EU);
External private entities outside our organizational structure, such as – by way of example – SAEV S.r.l., data protection consultant, as data processors, for the compliance with a personal data protection obligation: all such persons are bound to BRAVI‑PLATFORMS S.R.L. by an appropriate contract requiring them to take measures to protect your personal data, pursuant to Article 28 of Reg. (EU);
External private entities outside our organizational structure, such as – by way of example – lawyers, as data processors, for the potential legal protection in your regard: all such persons are bound to BRAVI‑PLATFORMS S.R.L. by an appropriate contract requiring them to take measures to protect your personal data, pursuant to Article 28 of Reg. (EU);
External private entities outside our organizational structure, such as – by way of example – hardware and software technicians, as data processors, for the protection of company assets: all such persons are bound to BRAVI‑PLATFORMS S.R.L. by an appropriate contract requiring them to take measures to protect your personal data, pursuant to Article 28 of Reg. (EU).

Decision to transfer your personal data to a third country or international organization:

No decision has been made to transfer your personal data to a third country or an international organization, as BRAVI‑PLATFORMS S.R.L. has assessed such a transfer as currently unnecessary.

Retention period of your personal data:

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by the company for the execution of preliminary activities for the conclusion of a purchase contract (products and/or services) between you and the company in a form that allows your identification for a period equal to the execution of preliminary activities for the conclusion of a purchase contract (products and/or services) between you and the company and for an additional period of 1 year for the pursuit of the legitimate interest of the data controller, after which the data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by the company for the execution of the purchase contract (products and/or services) concluded between you and the company and for the compliance with a personal data protection obligation in a form that allows your identification for a period equal to the execution of the purchase contract (products and/or services) concluded between you and the company and the compliance with a personal data protection obligation and for an additional period of 10 years for potential further processing within the ordinary prescription term, after which the data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by the company for the compliance with a civil and tax obligation in a form that allows your identification for a period equal to the compliance with a civil and tax obligation and for an additional period of 10 years for compliance with a legal obligation, after which the data will be destroyed or deleted.

BRAVI‑PLATFORMS S.R.L. will retain your personal data processed by the company for potential legal protection in your regard in a form that allows your identification only for a period equal to the potential legal protection, after which the data will be destroyed or deleted.

Your rights:

You, as the Data Subject, may exercise the following rights:

access your personal data, pursuant to Art. 15 of the Regulation (E.U.), in order to verify the processing of your personal data and, if applicable:
obtain information on the purposes of such processing;
obtain information on the categories of your personal data being processed;
obtain information on any categories of recipients of your personal data;
obtain information on the retention period of your personal data;
obtain information on the existence of your right to rectify or delete your personal data or to restrict the processing thereof;
obtain information on the existence of your right to lodge a complaint with the Data Protection Authority;
obtain information on the possible use of an automated decision-making process in the processing of your personal data, including the logic involved and the expected consequences for you due to such processing;
rectify your personal data, pursuant to Art. 16 of the Regulation (E.U.), in case of a subsequent dispute regarding their accuracy;
complement your personal data, pursuant to Art. 16 of the Regulation (E.U.), in case of a subsequent dispute regarding their completeness;
delete your personal data, pursuant to Art. 17 of the Regulation (E.U.), unless it is necessary to comply with a contrary legal obligation or to establish, exercise or defend a legal claim, in the event of:

subsequent lack of necessity to process such personal data for the stated purposes;
subsequent exercise of your right to object to the processing, excluding the overriding legitimate interest of BRAVI‑PLATFORMS S.R.L. over your interests or fundamental rights and freedoms;
subsequent determination of the unlawfulness of the processing of your personal data;
subsequent existence of a legal obligation requiring the deletion of such personal data;
restrict the processing of your personal data, pursuant to Art. 18 of the Regulation (E.U.), in the event of:
subsequent dispute regarding the accuracy of such personal data, even if only for the period necessary for the corresponding verification by BRAVI‑PLATFORMS S.R.L.;
subsequent determination of the unlawfulness of the processing of your personal data, followed by your objection to their deletion;
subsequent lack of necessity to process such personal data for the stated purposes, accompanied by the concurrent necessity to process them to establish, exercise or defend a legal claim;
subsequent exercise of your right to object to the processing, even if only for the period necessary for the corresponding verification by BRAVI‑PLATFORMS S.R.L.;
object to the processing of your personal data, pursuant to Art. 21 of the Regulation (E.U.), in case of a subsequent dispute regarding the overriding legitimate interest of BRAVI‑PLATFORMS S.R.L. over your interests or fundamental rights and freedoms.

BRAVI‑PLATFORMS S.R.L. is required to comply with any exercise of your above-mentioned rights without undue delay.Suo diritto di proporre un reclamo:

Your right to lodge a complaint:
You, as the Data Subject, may exercise the right to lodge a complaint with the Data Protection Authority, in case of a subsequent dispute regarding the compliance with the Regulation (E.U.) of the processing of your personal data carried out by BRAVI‑PLATFORMS S.R.L., pursuant to Art. 77 of the same Regulation (E.U.), by submitting the appropriate form to the e-mail address ‘protocollo@pec.gpdp.it’.

Nature of the communication of your personal data:

The communication of your personal data to BRAVI‑PLATFORMS S.R.L. constitutes a contractual obligation regarding the execution of preliminary activities for the stipulation of a purchase contract (products and/or services) between you and the company, and the execution of the purchase contract (products and/or services) stipulated between you and the same.
In fact, please note that your refusal to communicate such personal data would make it impossible for BRAVI‑PLATFORMS S.R.L. to fulfill the above-mentioned purposes.

Decision to use an automated decision-making system in the processing of your personal data:
No decision has been made to use an automated decision-making system in the processing of your personal data, as BRAVI‑PLATFORMS S.R.L. has assessed such use as currently unnecessary.