note on rights to privacy In accordance with Privacy Law 196/2003, Art. 1
We inform you that your personal data that we have acquired or are currently in the process of acquiring will be processed in complete respect of the law and the rights granted to you as the “party directly involved”.
A) Such processing will involve the following operations: the collection by telephonic, telematic or written means from public registers, lists of public acts and documents, and/or public and/or private databases (supplied from commercial information companies), the recording, organisation, conservation and processing using paper, magnetic, automated or telematic support systems, the processing of data collected by third parties, the modification, selection, extraction, comparison, use, and inter-connection also to data supplied from other parties on the basis of recurring qualitative, quantitative, and temporal criteria, or others to be defined case by case, the temporary processing for the purpose of the rapid grouping or transformation of the data themselves, the adoption of decisions in automated and/or discretionary form, the creation of profiles and informative notes, the communication, cancellation and destruction of data, or in other words, the combination of two or more of the above-mentioned operations.
B) In addition to the communication of your personal data to third parties in execution of the obligations prescribed by law or derived from EEC regulations or other directives, we may also communicate such data -even abroad – to the following parties:
1) banks and credit institutes for the purpose of making payments;
2) insurance companies for the purpose of stipulating coverage during shipping;
3) credit recovery, insurance and/or credit granting companies;
4) commercial information companies;
5) consultants and professionals;
6) individual professionals ad professional studios (legal, business expert, auditor, etc.);
8) other companies, agencies and/or individual persons who perform activities useful for the support or execution of the contracts or services that you have requested (e.g. commercial correspondence and mailing companies, shippers and handlers, sub-contractors). In their role as the “handlers” of these data as per the sense and effect of Privacy Law 196/2003 Art. 28, such parties will proceed to the processing and communication of such data in turn in complete autonomy.
C) Your personal data will be processed and communicated for the following purposes:
1) the satisfaction of pre-contractual needs (e.g. instructions for offers or your orders, checks into solvency );
2) the fulfilment of contractual (linked to the supply or purchase of goods and/or services) and legal obligations (e.g. for purposes of accounting, taxation, administration, and liquidity positions);
3) the management of clients and suppliers;
4) the management of credit and risk control (fraud, insolvency, etc.);
5) the management of disputes and granting of credit);
6) financial services instrumental in the management of clients/suppliers and management of electronic payment instruments;
7) insurance services required for the management of clients/suppliers.
D) You are required to provide your personal data only for the purposes specified in the above-mentioned Point C) from 1 to 7 and therefore your previous consent for the processing of data for such purposes is not necessary. Such data will be processed for the entire duration of the contractual relationship stipulated, and subsequently for the duration required for our fulfilment of our legal obligations and for the conservation of your company profile for the rationalisation of our selection of clients and/or suppliers. Although you have the right to freely refuse consent, such failure to provide the data requested will render the execution of the contractual relationship in force impossible.
E) The handler of your personal data is Progetti s.r.l. Strada del Rondello 5 – 10028 – Trofarello (TO) – Italy. Please contact the handler for any request regarding your exercise of the rights specified in Articles 7, 8 and 9 of Privacy Law 196/2003 below.
F) As regards your personal data, you are in any case entitled to the exercise of the following rights prescribed by Privacy Law 196/2003:
Art. 7 Section 1 (…): to obtain the confirmation of the existence or inexistence of your personal data even if not yet recorded, together with the communication of such data in intelligible form;
Section 2 (…):to also obtain indication of
a) the origin of such personal data;
b) the purposes and methods to be used for such processing;
c) the logic applied in the case of electronic data processing;
d) the identification data of the processing handler and managers of such processing, the parties or categories of party to which such data may be communicated or who might come to acquire knowledge of the same in their role as designated national territory representative and the latter’s managers or operatives.
Section 3 (…):to obtain
a) the updating, correction or – if you so desire – the integration of such data;
b) the cancellation, the transformation into anonymous form or freezing of such data processed as prescribed by law, including such data for which conservation is not required in regard to the purposes for which they have been originally collected or subsequently processed;
c) certification that the operations mentioned in Letters a) and b) have been communicated or distributed – also in regard to their content – except in the case in which such obligation proves to be impossible or requires the use of means manifestly incommensurate with the right subject to protection;
Section 4 (…): to totally or partially oppose
a) on legitimate grounds, the processing of your personal data even if pertinent to the purpose of collection;
b) the processing of your personal data for the purposes of the transmission of advertising material, direct sales, or the performance of market research or commercial communication (Note: in our processing of your personal data collected for the purposes indicated in above-mentioned 4th Section of Art. 7, we will request your previous and express written consent solicited by means of the appropriate Informative note).
Art. 8 Section 1 (…): the rights mentioned in Art. 7 can be exercised through an informal request submitted to the handler of such data or party appointed for the same also by means of a representative provided with suitable power of attorney without delay.
Section 2 (…): the rights mentioned in Art. 7, whenever data of objective nature are not involved – can also be exercised by representative unless the correction or integration of evaluative-type personal data regarding subjective-type judgements, opinions or other assessments are involved, together with the indication of conduct to be respected or decisions currently being made by the handler of personal data.
Art. 9 Section 1 (…): the request submitted to the processing handler or delegated party responsible for processing can be transmitted a) also by means of registered letter, telefax or e-mail, b) whenever pertinent to the exercise of the rights mentioned in Article 7 Sections 1 and 2, even orally, and in such case summarised in written form by the processing handler or delegated party responsible for processing.
This Code of Conduct defines the basic requirements placed on Progetti ‘ suppliers of goods and services concerning their responsibilities towards their stakeholders and the environment. Progetti reserves the right to reasonably change the requirements of this Code of Conduct due to changes of the Progetti Compliance program. In such event Progetti expects the supplier to accept those reasonable changes.
The supplier declares herewith:
> Legal compliance
– to comply with the laws of the applicable legal system(s).
> Prohibition of corruption and bribery
– to tolerate no form of and not to engage in any form of corruption or bribery, including any payment or other form of benefit conferred on any government official for the purpose of influencing decision making in violation of law.
> Respect for the basic human rights of employees
– to promote equal opportunities for and treatment of its employees irrespective of skin color, race, nationality, social background, disabilities, sexual orientation, political or religious conviction, sex or age;
– to respect the personal dignity, privacy and rights of each individual;
– to refuse to employ or make anyone work against his will;
– to refuse to tolerate any unacceptable treatment of employees, such as mental cruelty, sexual harassment or discrimination;
– to prohibit behavior including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative;
– to provide fair remuneration and to guarantee the applicable national statutory minimum wage;
– to comply with the maximum number of working hours laid down in the applicable laws;
– to recognize, as far as legally possible, the right of free association of employees and to neither favor nor discriminate against members of employee organizations or trade unions.
> Prohibition of child labor
– to employ no workers under the age of 15 or, in those countries subject to the developing country exception of the I LO Convention 138, to employ no workers under the age of 14.
> Health and Safety of employees
– to take responsibility for the health and safety of its employees;
– to control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases;
– to provide training and ensure that employees are educated in health and safety issues;
– to set up or use an occupational health & safety management system according to OHSAS 18001 or equivalent.
> Environmental protection
– to act in accordance with the applicable statutory and international standards regarding environmental protection;
– to minimize environmental pollution and make continuous improvements in environmental protection;
– to set up or use an environmental management system according to ISO 14001 or equivalent.
> Supply Chain
– to use best efforts to promote among its suppliers compliance with this Code of Conduct;
– to comply with the principles of non discrimination with regard to supplier selection and treatment.