Supplier information notice

INFORMATION NOTICE PURSUANT TO ART. 13 OF EU REGULATION 2016/679 FOR SUPPLIERS AND CUSTOMERS (NATURAL PERSONS ONLY) - UPD 15/10/2024

(in force since 15/11/2024)

This document (“Privacy Notice”) was drawn up pursuant to art. 13 of EU Regulation 2016/679 (hereinafter referred to as “GDPR”) in order to inform you about our privacy policy with regards to the processing of your personal information (including, but not limited to, your name, surname, mobile phone number, e-mail address and in general the contact information of your referrals), which is collected in the course of the performance of the contract concluded between your company and Anemocyte S.r.l. (hereinafter “Anemocyte“) with registered offices in Gerenzano (VA), in Via R. Lepetit 34.

Anemocyte can also process information pertaining to professional qualification as well as information relating to the job activities that can be deduced from the supplier’s documentation consulted by us while carrying out check and audit activities. In some residual cases, in order to allow the correct fulfillment of its purposes, Anemocyte may also process information that fall into the category of sensitive data (e.g., data relating to your health status, religious or philosophical beliefs, trade union membership, etc.).

In any case, in accordance with minimization and necessity principles, Anemocyte will process your personal data only if they are strictly necessary for the purposes indicated in the following paragraph; should the supplier make available to us information that are not strictly relevant for the performance of the audit activities, we will take into consideration such information. If, on the other hand, the collection of sensitive data is necessary to carry out our processing activities, the processing will be based on your prior explicit consent.

According to the GDPR, the processing carried out by Anemocyte will be based on the principles of lawfulness, correctness, transparency, purpose and storage limitation, data minimisation, accuracy, integrity and confidentiality.

The Data Controller of the personal data is Anemocyte, as defined above. For any information regarding the processing of the personal data by Anemocyte, including the list of data processors, please write to the following e-mail address: privacy@anemocyte.com.

The processing that Anemocyte intends to carry out has the following purposes:

To administer and manage the Agreement between your company and Anemocyte (“Performance of the contract”);
To fulfil any legal, accounting and tax obligations (“Compliance”);
to carry out check and audit activities (e.g. regarding its soundness, solvency, reliability, and compliance with the various applicable laws, rules and regulations), through the execution of interviews and the consultation of the relevant documentation made available by the supplier, in accordance with the regulatory framework applicable to the data controller (“Audit”);
to prevent or detect any abuse against Anemocyte, or any fraudulent activity and thus enable Anemocyte to defend itself in the courts (“Abuse/Fraud”).

The legal basis of the processing of your personal data are as follows:

Performance of the contract: The processing of your personal data is necessary for the performance of the contract with you. You are not obliged to provide Anemocyte with your personal data, but otherwise, you will not be able to enter into the contract.
Compliance: The processing of your personal data is necessary to fulfill any legal obligations. Anemocyte will process your personal data in accordance with the applicable legislation. This may also require the storage and disclosure of your personal data to the relevant Authorities for accounting, tax, or other obligations.
Audit: The processing of your personal data is based on the legitimate interest of Anemocyte;
Abuse/Fraud: Any information collected for this purpose will be used on the basis of Anemocyte’s legitimate interest solely to prevent and/or detect any fraudulent activities or abuse and therefore allows Anemocyte to defend itself in the courts.

Your personal data may be shared, for above mentioned purposes, with:

subjects who typically act as data processors, i.e.: i) persons, companies or professional firms that provide assistance and advice to Anemocyte in accounting, administrative, legal, tax, financial and debt recovery matters (collectively “Recipients”);
subjects, bodies or authorities to whom it is obligatory to communicate your personal data pursuant to legal provisions or orders of the authorities;
natural persons authorised by Anemocyte to process your personal data necessary to carry out activities strictly related to the performance of the contract, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees and/or external collaborators of Anemocyte).

Your personal data will be processed both automatically and manually. Your personal data will not be disclosed in any case.

Your personal data may be stored, accessed, used, processed, and disclosed to recipients that could be located outside the European Economic Area. We take steps to ensure that the processing of your personal data by our recipients is compliant with the applicable data protection laws, including EU law to which we are subject. Where required by EU data protection law, transfers of your data to recipients outside of the EU will be subject to adequate safeguards (such as the relevant EU standard contractual clauses for data transfers between EU and non-EU countries), and/or other legal basis according to the EU legislation. For more information on the adequate safeguards we have implemented with regard to personal data that is transferred to third countries, please write to: privacy@anemocyte.com.

The personal data processed for the performance of a contract purposes will be retained for the period strictly necessary to achieve those purposes. In any case, since the processing is carried out for the performance of a contract, Anemocyte will process your personal data for the period allowed by Italian law for the purpose of protecting its interests (Art. 2946 et seq. of the Italian Civil Code).
The personal data processed for the compliance purposes will be retained for the period required by the specific obligation or by applicable law.
The personal data processed for Audit purposes will be retained until the aforementioned purpose is achieved and then deleted. In particular, in compliance with the principles of minimization and limitation of storage set forth in Article 5(1)(c) and (e) of the GDPR, Anemocyte will not retain your personal data for longer than is necessary to consult and properly analyze it.
The personal data processed to prevent Abuse/Fraud will be retained until it is strictly necessary to protect Anemocyte in court, to communicate such data to the competent authorities, or, eventually, until you decide to object.

Further information regarding the retention period can be requested by writing to Anemocyte at the following address: Via R. Lepetit 34, Gerenzano (VA) or at the following e-mail address:
privacy@anemocyte.com.

Pursuant to articles 15 et seq. GDPR, at any time, you can ask to:

Access your data: we will provide the personal data we have related to you and, if applicable, the source of your personal data (if, for example, it was disclosed to us by a third party).
Exercise your right to portability of your personal data: where applicable, we will provide you with an Excel file containing the personal data we have about you.
Correct your data: for example, you can ask us to modify your e-mail address or telephone number if they are incorrect.
Limit or object the processing of your personal data: for example, when you think that the processing of your personal data is unlawful or that processing based on our legitimate interest is not appropriate; In the latter case, Anemocyte reserves the right to examine such an application, which may not be accepted if compelling legitimate grounds for processing override your interests, rights and freedoms.
Delete your data: for example, if you do not want us to keep your personal data and there is no other reason for keeping it.

Requests should be sent in writing to Anemocyte at the following e-mail address: privacy@anemocyte.com or to Anemocyte’s physical address: Via R. Lepetit 34, Gerenzano (VA).

At any time, you may also:

Contact the Supervisory Authority (Garante per la protezione dei dati personali) whose contact details can be found here .
Take the appropriate legal actions.

This Privacy Notice entered into force on the date indicated at the beginning of this document. We reserve the right to modify or update this Notice, in full or in part, at our discretion or as a consequence of changes in applicable regulations. You will receive a message informing you of any substantial changes we may make to the Privacy Notice.