SA. PHI GROUP

CODUTTI FORNITURE SRL

Privacy policy in accordance with Article 13 of EU Regulations No. 2016/679 (hereinafter also referred to as the GDPR) on the protection of personal data concerning natural persons Pursuant to EU Regulations No. 679/2016, we hereby provide you with the privacy policy regarding the processing of personal data that will be carried out by CODUTTI FORNITURE SRL with registered office in Pasian Di Prato (UD), Via Bonavilla 34, VAT No.14045811008 (hereinafter referred to as the "Company"), in relation to its supply of furnishing solutions and the submission of advertising and/or marketing material concerning the goods produced (the "Services").

First of all, below are listed the categories of personal data subject matter of the processing: name, surname, address, e-mail address, and tax code.

The processing of the above mentioned data, by CODUTTI FORNITURE SRL, may concern not only the processing of data related to the services for the supply of movable property, but also communications and/or submissions (by e-mail, text messages, snail mail, telephone contact, etc.) - also through automated means and as a result of you entering your data in the FORM of the website and providing consent to the processing - of information and commercial offers, advertising/information material related to promotional goods and/or services offered by CODUTTI FORNITURE SRL and invitations to participate to Exhibitions, after your express consent. The processing of the Data is carried out in compliance with the principles of fairness, lawfulness and transparency established by the Regulations and concerning the personal data of natural persons of which the undersigned Company may become aware by virtue of the supply of the aforementioned services.

a) IDENTITY AND CONTACT DATA OF THE DATA CONTROLLER
The Data Controller pursuant to Art. 24 of the GDPR is the Company CODUTTI FORNITURE SRL with registered office in Pasian di Prato (UD), Via Bonavilla 34 where the processing takes place. The interested party may exercise his/her rights pursuant to Articles 15 to 22 of the EU Regulations by submitting an e-mail to: codutti@codutti.it

b) CONTACT DATA OF THE DATA PROTECTION OFFICER
The Data Controller does not fall under the categories referred to in Articles 37 to 39 of the GDPR for which the appointment of the Data Protection Officer is mandatory.

c) PURPOSE OF THE PROCESSING AND LEGAL BASIS
The processing of personal data is aimed at the correct and complete implementation of the supply of furnishing solutions; in particular, the data are processed to fulfil the obligations related to the business activity of CODUTTI FORNITURE SRL and more specifically for the supply/sale of furniture, furnishings, and - with express consent - for the communication and/or submission (by e-mail, SMS, snail mail, telephone contact, invitations to exhibitions, etc.) also through automated means and as a result of you entering your data in the FORM of the website and providing consent to the processing of information and commercial offers, advertising/informative and promotional material concerning the goods and/or services of CODUTTI FORNITURE SRL also if different from those already purchased. In particular, in the case of sale/supply of goods, the data are processed to fulfil contractual obligations and administrative, fiscal and accounting obligations required by law; to carry out any further contractual obligation with clients and suppliers; to manage support services on goods and/or services provided by the company; to allow performing activities with external contractors and for any further operational-management activities related to the existing relationship. In the case of submission/communications of a commercial nature in the manner described above (letter C) paragraph 1), the data will be processed with your express consent. In the context of the aforementioned processing, common data (such as name, surname, subject, and contact details) concerning you - in your capacity as legal representative of the company - and common data concerning the shareholders and parties operating within the company or on behalf of the company, are also processed. In the case of supply/sale of goods, since the data processing is necessary to enter into and implement a contract to which the interested party is a party or to implement pre-contractual measures adopted on his/her request, the legal basis for the processing is that established in Article 6, paragraph 1, letter b) of the GDPR and therefore the fulfilment of an contract.

In the case of communication and/or submission (by e-mail, text messages snail mail, telephone contact, invitations to Exhibitions, etc.), also through automated means and as a result of you entering your data in the FORM of the website and providing consent to the processing of information and commercial offers, advertising and promotional material concerning the goods and services offered by CODUTTI FORNITURE SRL the legal basis of the processing is the express consent for the specific purpose pursuant to Art. 6 paragraph 1 letter a) of the GDPR.

d) LAWFULNESS OF THE PROCESSING PURSUANT TO ARTICLE 6 of the GDPR
The Data Controller does not process data based on legitimate interests pursuant to Art. 6 paragraph 1 letter f) of the GDPR.

e) RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA
The data may be communicated to parties pursuant to Art. 29 of the GDPR which carry out the processing under the authority of the Data Controller or Data Protection Officer which have legitimate access to the personal data as a result of a written appointment for the data processing; to parties whose access is required and governed by provisions of law or regulations; credit institutions for the management of receivables and payments, external parties pursuant to Art. 28 as Persons in Charges of the processing who carry out the activities on behalf of the Data Controller; parties that perform tasks related to the execution of the agreement such as lawyers, consultants, carriers, forwarders, IT service providers, and more.

f) TRANSFER OF DATA ABROAD
The Data Controller processes the data in a foreign country. In the event of transfer of data to third countries, the Data Controller must ensure the existence of adequate guarantees as required by the EU Regulations in order to ensure a high level of protection for natural persons; in the absence of such guarantees, the transfer will not be carried out.

2. In addition to the information referred to in paragraph 1. The Data Controller provides to the interested party the following additional information necessary to ensure correct and transparent processing:

a) DATA STORAGE PERIOD
The data are stored for a period that is no longer than strictly necessary to implement the purposes for which they were collected and processed and for additional tax obligations required by current legislations and to be able to assert or defend rights before the Courts.

b) RIGHT OF ACCESS TO PERSONAL DATA, RECTIFICATION, ERASURE, PORTABILITY , LIMITATION OR OPPOSITION TO THE PROCESSING BY THE INTERESTED PARTY
The interested party may exercise the rights referred to in Articles 15 to 22 of the GDPR; in particular, the right to access the data (Art. 15) allows the interested party to obtain confirmation whether or not the data are being processed and, if so, the right to access them; the right to rectification and integration (Art. 16) allows the interested party to request the correction of his/her data; the right to erasure/to be forgotten (art. 17) allows the interested party to request and obtain the erasure of his/her personal data when at least one of the following cases occurs: 1) the need for the processing for the original purpose no longer exists; 2) consent is withdrawn; 3) opposition to processing; 4) unlawfulness of the processing; the right to limitation (art. 18) applies to the interested party in the event of a dispute about the accuracy of the data for the time period necessary to check its accuracy; or if the processing is unlawful and the interested party chooses not to oppose but to exercise the right to limitation; the right to data portability (art. 20) allows the interested party to receive in a structured format that is commonly used and readable by an automatic device, his/her personal data and to obtain the transfer of the said data to another Data Controller specified by the interested party, the right to opposition (art. 21) allows the interested party to oppose at any time the processing of his/her data concerning when the legal basis which made the processing lawful is no longer applicable; the right not to be subjected to automated decision-making processes (profiling) (art. 22) which may give rise to legal effects capable of having a significant impact on the person, except where such a decision is necessary for signing or executing an agreement or is authorised by the EU or is based on the explicit consent of the interested party.

c) RIGHT TO WITHDRAW CONSENT FOR THE DATA PROCESSING
The interested party that provided consent to the processing of his/her personal data for one or more specific purposes pursuant to Art. 6 paragraph 1 letter a) (in this case withdrawal of consent to the submission of marketing communications) may withdraw said consent at any time, exercising this right by sending a notification by Certified email (PEC) to the following PEC E_MAIL address or by registered letter with notification of receipt to be sent to the registered office of the company as specified above. The interested party, as a result of entering his/her personal data in the FORM of the website and providing related consent to the processing for marketing purposes, may withdraw his/her consent at any time, even by clicking on the unsubscribe link shown below.

d) RIGHT TO LODGE A COMPLAIN
The interested party has the right to lodge a complaint at the Data Protection Authority against the processing of his/her data in the event that said processing does not comply with the EU Regulations.

e) DATA PROVISION AND CONSEQUENCES OF THE REFUSAL TO PROVIDE THE DATA
In case of supply/sale of furnishing items, the provision of the data by the interested party is a necessary requirement for entering into and executing the contract. Thus, the interested party must provide the data in order for the contract to be implemented. Refusal to provide data makes it impossible for CODUTTI FORNITURE SRL to supply/sell the goods. Regarding the data processed for communication and/or submission (by e-mail, text messages, snail mail, telephone contact, invitations to exhibitions, etc.) - also through automated means and a result of the interested party entering his/her data in the FORM of the website and providing related consent to the processing - of information and commercial special offers, advertising and promotional material on services similar to and additional to the ones subject matter of the contract signed between the parties, please note that this data processing is not mandatory. However, the consequence of refusal to provide the data will lead to the impossibility for CODUTTI FORNITURE SRL to carry out the marketing activities mentioned above concerning the interested party.

f) DATA PROCESSING THROUGH AN AUTOMATED DECISION-MAKING PROCESS (INCLUDING PROFILING)
In carrying out the purposes of the data processing established herein, the Data Controller does not apply any automated decision-making processes pursuant to Art. 22 paragraphs 1 and 4. In the event that the Data Controller wishes to process the data of the interested party for a purpose other than the one for which the data were collected, prior to such processing the Data Controller shall provide information related to such different purpose and any further information referred to in paragraph 2.


After acknowledging the Privacy Policy, I provide my free, specific, informed and unequivocal consent to the processing of my personal data by the Data Controller for the following purposes:

- for communication and/or submission (by e-mail, text messages, snail mail, telephone contact, etc.) - also through automated means and as a result of you entering your personal data in the FORM of the website and providing consent to the processing - of invitations to exhibitions, information and commercial offers concerning the supply of furniture produced by the Data Controller, advertising/information and promotional material on each category of goods produced by CODUTTI FORNITURE SRL, even if different from those already purchased.