INFORMATION TO DATA SUBJECTS CONCERNING PROCESSING OF COMMON AND SENSITIVE PERSONAL DATA.
Information to the user

Pursuant to Section 13 of the Italian Legislative Decree of 30 th June 2003, N° 196, and in relation to the personal data undergoing processing, please be informed of the following:

1. The processing of common and sensitive personal data requested or acquired both before establishing the employment and during and after the termination thereof, shall be carried out for social-security purposes and in the employment context, in order to fulfil the relevant obligations arising out of the individual and collective labour agreements, laws, regulations and Community legislation in the employment context, also with regard to occupational hygiene and safety, as well as to social-security and assistance purposes, and in particular to fulfil the wage, contribution, insurance and tax obligations, relating to the payment of salaries and the relevant provisions of law, as well as to the sectoral statistical surveys, the corporate statistical data processing and to perform the processes for evaluating the job-related competencies, training needs and corporate environment.

2. The data processing is carried out in obedience to those procedures and requirements as laid down by Section 11 of the Italian Legislative Decree N° 196/03 and the Codes of Conduct and professional Practice of Section 111 of the Italian Legislative Decree N° 196/03; it will include any operation, or set of operations, as provided for by Section 4, paragraph 1, lett. A), of the of the Italian Legislative Decree N° 196/03, necessary for the data processing at issue, including the communication to the subjects mentioned under article 5) hereinbelow, as well as the dissemination within the scope referred to under article 7) of this information; data processing shall be carried out in compliance with the general authorisations for processing of sensitive and judicial data of the Garante and shall be carried out as follows:

- data processing is carried out with or without the use of electronic instruments and managed by personnel in charge thereof;
- data shall be kept on conventional hard copy and/or on magnetic/computer/optical media;
- manual processing shall be carried out by data collection on proper registers and/or filing cards, which shall be kept by traditional filing in proper filing units available only to the persons in charge of the processing.

3. Providing of personal data relating to the processing at issue has an obligatory nature, by virtue of the regulations in force on the subject of employment and national and corporate collective labour agreements in force. Providing of personal data of voluntary nature is, likewise, necessary for the due and complete performance of the employment relationship.

4. Any partial or total failure to reply will result in a partial or total impossibility to achieve the purposes provided for by article 1) hereinabove.

5. Personal data relating to the processing at issue, for the purposes provided for by article 1) hereinabove, shall be communicated:

- to the Public Administrations, in order to discharge their institutional tasks, according to those principles and within those limits as provided for by the rules and regulations in force;

- to the labour organizations, for performance of the formalities incidental to the implementation of check-offs;

- to social-security and assistance funds, as well as to specific complementary superannuation fund for Rubber and Plastic Industries' Workers (Rubber Plastic Fund), in order to conform with welfare insurance and social-security regulations;

- to the organizations and/or enterprises belonging to Confindustria [Italian Manufacturers' Association], in order to comply with contractual regulations;

- to the insurance companies and Financial Institutes, in order to regulate and collect premiums relating to policies covering risks and investment of termination indemnities, etc.;

- to the Health Corporations, Department of Labour, Provincial Offices, Inland Revenue, in obedience of the relevant provisions of law;

- to the company doctor and the relevant occupational health care centre, in order to carry out the pre-employment fitness for work and annual medical examinations, according to the provisions of the Programma di Sorveglianza Sanitaria [Programme of Health Surveillance];

- to the Organismo Paritetico Provinciale [Provincial Joint Authority], relating to the appointment of a Rappresentante dei Lavoratori per la Sicurezza [Workers' Representative for Safety];

- to the workers' representatives for safety, in case they exercise the right to access to data, as provided for by Section 10, paragraph 5, of the Italian Legislative Decree N° 626/94;

- to the personnel of outsourcing Companies responsible for administration and maintenance of Information Technology systems;

- to the consulting Companies, in order to supply the services relating to the personnel administration;

- to the Ufficio per il Collocamento Obbligatorio [Office for Compulsory Placement], in order to fulfil the obligations provided for by the regulations in force concerning placement of persons with recognised disablement;

- to the Board of Auditors, in order to carry out the surveillance and control duties pertaining thereto;

- to the payroll processing Companies, in order to manage their services;

- to ISTAT [Italian Central Statistics Institute], trading associations, Chambers of Commerce, for the relevant cumulative and statistical recording of periodical data.

6. The data being supplied may be notified to the data processor set out under article 9) hereinbelow and the following persons in charge of the processing:

- Employees of Personnel Department and Human Resources, as regards the employees' absences/presences, wages and salaries data, medical examinations, occupational accidents and diseases registers, corporate benefits management, hiring (including curricula vitae and data collection forms), employment agreements for temporary personnel, on-the-job training personnel data, evaluation forms of working performances;

- Employees of Administrative Office, only as regards the data required to credit the monthly wages to current account;

- to outsourcing payroll processing Company, only as regards the data required to duly carry out the activities it has been entrusted with.

7. The personal data at issue may be disseminated, only with reference to the names and the office held in the company, through the publication on the corporate websites. The said data may likewise be disseminated abroad, only to the extent necessary for organizing the missions abroad of commercial personnel.

8. The data subject of the processing at issue is entitled to exercise the rights provided laid down by Section 7 of the Italian Legislative Decree N° 196/2003, the full text thereof is transcribed hereinafter:

1) A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and communication of such data in intelligible form;

2) A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5, paragraph 2;
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.

3) A data subject shall have the right to obtain:
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4) A data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

9. Data controller of the processing at issue is the company ECB COMPANY s.r.l., having its registered office in via Calvenzano no. 10, Treviglio (BG – Italy). Data processor is the Administrative Manager, having business domicile at the aforesaid registered office.


INFORMATION PURSUANT TO ITALIAN LEGISLATIVE DECREE N° 196/2003.
Information to the customers and suppliers

Further to the coming into force of the Italian Legislative Decree N° 196/2003 containing “legislation concerning protection of individual and other entities with regard to the processing of personal data”, ECB COMPANY s.r.l. (having its registered office in Treviglio , via Calvenzano 10 – Tax Payer's and VAT N° 04101120964), in its capacity as “Data Controller” of the processing, hereby informs you that it is in possession of your personal data collected within the framework of the activities it carries out, directly c/o your company, in your capacity as data subject, or c/o third parties.

In obedience of the provisions of law, we hereby point out:

A) Purposes of Processing and nature of providing data.
The data collection aims at fulfilling the contractual obligations existing between ECB COMPANY s.r.l. and the data subject, as well as at acquiring and communicating and/or disseminating information for pre-contractual, statistical, market research, promotion and sale of product, supply of services, purchase of products and/or services purposes, or at fulfilling legal obligations for which the providing thereof is obligatory; in this last case, any failure to provide such data will result, as a matter of fact, in an impossibility on the part of ECB COMPANY s.r.l. to keep the relationship with the data subject.

B) Methods of processing.
ECB COMPANY s.r.l. guarantees that your data shall be processed in full compliance with the provisions of the Italian Legislative Decree N° 196/2003, through hard copy and/or magnetic media for a period of time necessary to achieve the purposes for which they have been collected or processed.

The processing and the safekeeping of the said data shall be carried out according to such methods as to guarantee the confidentiality and the safety thereof in compliance with logics that are strictly related to the aforementioned purposes.

C) Entities or categories of entity to whom or which the personal data may be communicated and consent to such communication.
In compliance with the legislation in force as applying to industrial secrecy and confidentiality, both on national and international basis, ECB COMPANY s.r.l. shall be entitled to communicate and disseminate the aforesaid data to third parties, such as: its own area agents, trade representatives, legal or tax advisers, subsidiary companies, marketing and market research companies.

The processing of the above-mentioned data, in case of communication and dissemination to third parties, requires the data subject's consent. In the absence of such consent, the data controller will not be able to communicate and disseminate the aforesaid data.

In any case, such consent shall not be required if the processing concerns:

a) data taken from public registers, lists, documents or records that are publicly available;

b) data processed in compliance with an obligation imposed by a law or, however, to establish or defend a legal claim.

Pending formalization of consent by the data subject, the data subject's request of performance of a specific operation shall be deemed as a temporary consent to the said operation.

D) Rights provided for by of the Italian Legislative Decree N° 196/2003.
Pursuant to Section 7 of the Italian Legislative Decree N° 196/2003, your Company is entitled at any moment to obtain, at Data Controller's care, the name of the Data Processors, information concerning the processing of your data, the methods and purposes and the logic applied thereto, as well as:

- confirmation as to whether or not personal data exist and the communication of such data and their origin;

- the identification data concerning Data Controller, Data Processors as well as entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as Data Processors or persons in charge of the processing;

- updating, rectification and integration of the data;

- erasure, anonymization or blocking of data that have been processed unlawfully;

- to object on legitimate grounds, to the processing of personal data, even though they are relevant to the purpose of the collection; to the processing of personal data, where it is carried out for the purpose of sending advertising materials or else for the performance of market or commercial communication surveys.

E) Data Controller
With reference to the contents of this information, please be informed that:

- “Data Controller” is ECB COMPANY s.r.l.