Supplier Privacy Policy

Information pursuant to Article 13 of EU Regulation 2016/679 on the Processing of Personal Data 

Data Controller 

We inform you that, pursuant to EU Regulation 2016/679 (hereinafter: "Regulation"), your Personal Data will be processed by Value Partners S.p.A., located in Milan, Largo Francesco Richini 6, as the data controller ("Controller"). 

Types of Data Subject to Processing 

The Controller will process your personal data (Article 4.1 of the Regulation), collected in the context of the contract and/or for the purpose of concluding the same, which may include, by way of example and not limitation, your first name, last name, mobile phone number, email address, and generally your contact details as the representative of the supplier. 

Purposes, Legal Basis, and Optional Nature of Processing 

Your Personal Data will be processed, without the need for your specific consent, for the following purposes: 

a) Execution of Pre-Contractual Measures 
The legal basis for processing is the execution of pre-contractual measures (Article 6.1.b of the Regulation) (e.g., evaluation of new suppliers, tendering processes). 

b) Execution of the Contract 
The legal basis for processing is the execution of the contract or pre-contractual measures (Article 6.1.b of the Regulation); 

c) Compliance with Legal Obligations Related to the Contract 
The legal basis for processing is the fulfillment of legal obligations to which the Controller is subject (Article 6.1.c of the Regulation). 

The provision of your Personal Data for the purposes indicated above is optional, but failure to provide it will make it impossible to finalize the contract. 

• Recipients of Personal Data 
• Your Personal Data may be shared with: 
• Individuals authorized to process your Personal Data in accordance with Articles 29 and 32, paragraph 4 of the Regulation and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who need to process your Personal Data in the course of their work duties, system administrators); 
• Entities that, in providing services on behalf of the Company, process data on behalf of the Company and typically act as data processors (e.g., contractors in the case of outsourcing work, even partially, to external companies; third parties involved in the management of information systems and web platforms; external collaborators that the Company uses for specific technical and/or organizational services - such as IT service providers, collaborators, and external consultants); 
• Entities and authorities that normally act as independent data controllers pursuant to Article 4, no. 7 of the Regulation, to whom it is mandatory to communicate your Personal Data in accordance with applicable regulatory provisions for the Company or based on contractual obligations or in execution of pre-contractual measures. 
• Regarding any transfer of Data to Third Countries, the Controller informs that the processing will occur according to one of the methods permitted by current law, such as, for example, the consent of the data subject, the execution of a contract concluded between the data subject and the data controller, or the execution of pre-contractual measures taken at the request of the data subject; the conclusion or execution of a contract stipulated between the data controller and another natural or legal person for the benefit of the data subject; the adoption of Standard Clauses approved by the European Commission, the selection of entities operating in countries considered safe by the European Commission. More information is available, upon request, from the Controller at the contacts provided above. 

 Methods of Data Processing 

In relation to the stated purposes, the processing of personal data is carried out using manual, computer, and telematic tools, with methods strictly related to the purposes themselves and, in any case, in a manner that ensures the security and confidentiality of the data, as well as compliance with the specific obligations established by law. 

Retention of Personal Data 

Your Personal Data will be retained only for the time necessary for the purposes for which they were collected, in compliance with the principle of minimization set forth in Article 5, paragraph 1, letter c) of the GDPR. In any case, your personal data will be retained for the time necessary to fulfill the obligations set forth in the contract. Further retention may be required by applicable regulations, including that provided for by Article 2946 of the Civil Code. More information is available from the Controller. 

Your Privacy Rights (pursuant to Articles 15 et seq. of the Regulation) 

You have the right to request the Controller, at any time, access to your Personal Data, rectification or deletion of the same, or to object to their processing. You have the right to request the limitation of processing in the cases provided for by Article 18 of the Regulation, as well as to obtain in a structured, commonly used, and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulation. 

Requests should be addressed in writing to the Controller at the following address: privacy@valuepartners.com. 

In any case, you always have the right to lodge a complaint with the Data Protection Authority, pursuant to Article 77 of the Regulation, if you believe that the processing of your data is contrary to the applicable regulations.