INFORMATION on Personal Data Processing

Pursuant to Art. 13 of Legislative Decree No. 196/2003 (Code regarding the protection of personal data), as well as Art. 13 of Regulation (EU) 2016/679, ITW Construction Products Italy s.r.l., with registered offices in Padua, at No. 5 viale della Regione Veneto (hereinafter “ITW” or “Controller”), as the Controller hereby provides you with information regarding the processing of your personal data.

Personal data supplied by you, and possibly acquired subsequently, will be processed by the Company in compliance with its confidentiality and the law, using manual, computerised and web tools, with a rational strictly related to the processing purposes.

1. Processing purpose.

Your personal data is processed for the following purposes:

1. fulfilling obligations established by law, regulation and community legislation, or provisions issued by authorities and/or legally appointed bodies;
2. fulfilling obligations under the contract agreed with ITW (e.g. accounting purposes, order, delivery, contacts and payment management and organisation, payment reconciliation);
3. those strictly connected and instrumental to customer relationship management (e.g. acquisition of preliminary information for concluding a contract, checks and assessments on relationship results and progress, as well as on their connected risks, messages about new price lists);
4. sending other messages about our activities (such as “service” messages, relating to sending out new catalogues, official announcements, invitations to take part in trade fairs, etc.);
5. managing Company litigation and protection of its rights, including in court and through third parties;
6. commercial, promotional and marketing purposes, to provide customers (including via email, fax, telephone, SMS, web marketing, including through third parties) with information about the characteristics of our products and our activities, to inform them of proposals, promotions and commercial offers, including by sending promotional advertising material or that related to initiatives and offers rewarding customers (including through third parties);
7. profiling choices, needs and consumption habits, to send commercial messages relating to products and/or services that could be of interest to customers;
8. marketing its products and services which are similar to those already supplied;
9. measuring customer satisfaction;
10. managing Company activities, its organisation and value assessment, as well as assessing opportunities to make legal or structural changes, total or partial (even just one branch), to the Company, mergers, de-mergers and other similar extraordinary events that may involve the Company as a whole or only in part;
11. market research, economic and statistical analysis;
12. auditing and discretionary certification of financial statements;
13. historical data storage.

The provision of your personal data for the purposes in points a), b), c) and e) is mandatory, and your refusal to provide data for such purposes will make it impossible to establish a contractual relationship with ITW and/or the continuation of such a relationship. However, the provision of data necessary for the purposes in point d) is optional and your refusal to provide such data has no consequences, other than hindering relationship management by preventing us, amongst other things, from keeping you updated about our activities and sharing other official messages with you. The provision of data for other purposes is optional and your refusal would have no consequences for you, other than preventing the processing of your data for the respective purposes.

2. Legal basis for processing

The legal basis for processing your data is provided by law for the purposes in point a) and by the contract for the purposes in points b), c), d) and h). Similarly, the communication of data to public authorities has its legal basis in law. Failure to disclose your data to the authorities could result in sanctions for the Company or make it impossible to establish an employment relationship with us.

The processing of your data for the purposes in points e), i) j), l) are instead based on our legitimate interest in the efficient management and operation of our economic activities and the protection of our rights.

Processing for the additional purposes listed above is instead based on your consent, which you can revoke at any time without prejudice to processing activities previously carried out.

3. Categories of subjects to whom personal data could be communicated or that could become aware of the data in their role as Processors or persons in charge of processing.

For the aforementioned purposes, your data may be communicated in Italy and abroad, including to countries outside the European Union, to the following categories of recipients:

1. public authorities and supervisory and control bodies;
2. other Company offices or subjects connected to the Company, controlling companies, subsidiaries, affiliates or in any case, forming part of the ITW Group;
3. subjects who collaborate in the performance of our activities or who provide services to our Company (for tasks of a technical or organisational nature or in providing IT services) company agents and other collaborators carrying out sales and commercial activities on behalf of the Company, subjects that carry out customer service activities; external subjects entrusted with payment management; studies and companies in the field of assistance and advice, including legal;
4. subjects that send, pack, transport and sort communications to the data subject;
5. subjects that carry out marketing and commercial promotional activities on behalf of ITW and market research companies;
6. subjects that carry out archiving and data entry activities;
7. subjects that carry out checks, audits and certification of activities carried out by ITW, also in the interest of its Customers and users;
8. subjects that provide services for credit risk management and fraud control (such as data processing centres, banks, risk centres, debt collection companies, law firms);
9. Banking institutions and credit card companies.

The subjects belonging to the above categories process personal data as separate Data Controllers or as Processors or persons in charge of processing where specifically appointed by ITW for this purpose.

Personal data may also be made known to ITW employees and/or consultants who carry out activities involving the processing of your data for the aforementioned purposes (for example, administrative staff and/or back office staff) and will be specifically appointed by the Controller as Processors or persons in charge of processing. The data will not be disclosed further. Your data may also be transferred abroad, including outside the European Union and in particular to the United States. Some of these countries are considered by the European Commission as guaranteeing an adequate level of protection, in other cases, the Company undertakes transfers according to standard contractual clauses approved by the European Commission to protect its data. Transfer to the United States is based on the Privacy Shield principles.

4. Processor

The Processors are the Head of Sales and Marketing and the Head of Finance and Control of the ITW Construction Products Italy division, who you can contact to exercise your rights in accordance with the law by email at the following address: info.privacy@itw-italy.com. The complete list of external processors and third parties to whom data may be communicated is available at ITW’s registered offices at No. 10 Via Lombardia, 30030 Cazzago di Pianiga (VE).

5. Retention period

The data processed for the purposes referred to in points a), b), c), d), e), h), i), j), l) and m) will be kept for the entire duration of the contractual relationship with our Company, as well as after its termination for the period necessary to protect the Company’s rights and allow it to demonstrate fulfilment of its obligations.

Data processed for the purposes referred to in points f), g) and k) will be processed for a period of 24 months or in any event until you revoke your consent and/or do not object to the related processing, as well as subsequently to allow the company to demonstrate compliance with the law in the related processing activities.

6. Rights of the data subject

You may at any time exercise the rights provided by law in favour of data subjects including the right to access your data, to have it rectified or erased or oppose its processing or have it restricted, as well as the right to the portability of your data.

You also have the right to lodge a complaint with a supervisory authority.

The Italian Data Protection Authority can be contacted at the following address:

Piazza di Monte Citorio, 121

00186 Roma

Tel. +39 06 69677 1

Fax +39 06 69677 785

email: garante@garanteprivacy.it

Website: http://www.garanteprivacy.it/

Declaration of consent

Dear

ITW Construction Products Italy srl,

No. 5 Viale della Regione Veneto

35127 Padua

I, the undersigned, duly informed about the nature of the processing of my personal data, declare to give my consent to the processing of optionally provided data, on the basis that the processing is carried out in accordance with the information provided above.

I, the undersigned declare to give my consent to data processing for marketing purposes, commercial information, including through interactive means (email, sms, fax, telephone, web marketing), including through third parties; commercial promotion, communication and provision of information through the sending of promotional advertising material (via telephone, SMS, MMS, video and similar methods, including automated methods) and participation in initiatives and offers to reward customers and potential customers (including through third parties); measuring customer satisfaction; market research, economic and statistical analysis; carrying out studies and statistical research, services and certification quality control.

I, the undersigned declare to give my consent to processing for profiling purposes carried out to identify services and/or products that may be of interest to me for the purpose of sending related targeted commercial messages

Finally, I, the undersigned declare to give my consent to the communication to third parties of the data that complies with the aforementioned and approved information.