Privacy notice for suppliers
Privacy notice for suppliers according to art. 13 / 14 of the UE Regulation 2016/679 (GDPR)
This privacy notice concerns the processing of personal data of Suppliers and Business Partners (hereinafter “Supplier(s)”) of Avion Company S.p.A. It applies to individuals or partnerships as well as to personnel and employees of corporate entities. Avion Company S.p.A. does not carry out marketing activities towards suppliers who are natural persons. Personal data are processed in accordance with the provisions of EU Regulation 2016/679, Legislative Decree 101/2018, and as indicated in this notice.
Data controller is Avion Company S.p.A. with registered office in via G. Di Vittorio 37, Peschiera Borromeo (MI) – 20068 Italy, e-mail: firstname.lastname@example.org
Provision of personal data is necessary for the establishment, execution and proper management of the contractual relationship with the Supplier and for the fulfillment of legal obligations.
Categories of Personal Data
Purposes of processing
Legal basis of data processing
General &Contact Data: name, contacts (email, phone, mobile phone), name of the company, address.
Contractual Data: company position, skills, goods handled, events relating to the contract or to the business relationship.
Data from records and public registers.
Possession of certifications and legal requirements
Payments, financial & solvency information*.
Generally, the data marked with an asterisk * can be qualified as “personal data” if the Supplier (sender or recipient) is a natural person.
a. Establishment and management of the contractual relationship, and in particular:
Performance of pre-contractual requests and contractual obligations
Duration of the contractual relationship and for ten years after the closing of the contractual relationship pursuant to articles 2214 and 2220 of the Italian Civil Code.
Compliance of legal obligation / legitimate interest
b. Claims and litigation management, risk control (fraud, insolvency, etc.),
c. Statistical purposes (market research, profitability and/or statistical analysis).
d. Marketing or promotional purposes (Suppliers who are natural persons are excluded), including the proposal of access to the My Avion reserved area, commercial initiatives, presentation of new products, services and offers.
e. Newsletters and Informative Communications
The processing is carried out by the Controller through its own authorized personnel and/or by external data processors and their appointees, in compliance with the regulations in force. The Controller has adopted the necessary technical and organizational data protection measures to prevent unauthorized access, alteration, dissemination, loss or destruction of personal data.
Within the limits relevant to the processing purposes indicated, the data may be communicated to companies and branches of the Avion Group, transporters, logistics, air or maritime carriers, warehouses, customs authorities, insurance companies, credit institutions, software and IT companies and subcontractors, credit recovery companies, consultants, certification bodies, freelancers, representatives, retailers, agents and authorized brokers, as well as the competent authorities such as Customs, ENAC, Revenue Agency, Prefecture, Police Headquarters, Consulates, Police, Carabinieri, Authority for the protection of environmental, cultural and / or health, Judicial Authority, for the fulfillment of the law. These subjects may also be the source of collection of data relevant to the purposes of processing indicated above.
In case of international shipments to or from third countries at the request of or for the benefit of the data subject, the data subject’s consent is not required for the transfer, provided that at least one of the following conditions set forth in Article 49(b) and (c) GDPR is met:
-the transfer is necessary for the performance of a contract between the data subject and the controller or the implementation of pre-contractual measures taken at the data subject’s request;
– the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person.
Alternatively, we will put in place appropriate safeguards to ensure that your personal data are adequately protected at destination, verifying that the data is transferred to a country that provides a level of protection equivalent to that established by the GDPR. Alternatively, we will take appropriate measures, such as entering into specific agreements with data recipients, adopting the European Commission’s model clauses, or that other safeguards are in place. In other cases, consent will be required.
Data subject may exercise his/her rights at any time, and in particular:
Data subject may exercise his/her rights at any time by contacting the Controller by sending an email to email@example.com without any formality or payment of any additional cost. Every request received by the Controller will be taken into consideration after verifying the identity of the person entitled and safeguarding the rights of third parties. Requests will be satisfied as soon as possible and in any case within thirty days, except in the case of objective difficulties which will be communicated in writing within this period. In case of dissatisfaction on the modalities of processing and complaints and for any clarification data subject may write to the Controller, without prejudice to his right to apply to the Authority responsible for the protection of personal data www.garanteprivacy.it.
Peschiera Borromeo (MI), 9 March 2021
AVION COMPANY S.p.A.