Data subject: Reference persons at client companies.

Pudel SB SRL, in its capacity as Data Controller with regard to the processing of your personal data pursuant to Regulation (EU) 2016/679 (hereinafter the “GDPR”), hereby informs you that the Regulation protects data subjects with regard to the processing of personal data and that such processing will be carried out in a fair, lawful and transparent manner, safeguarding your privacy and your rights.

Your personal data will be processed in accordance with the provisions of the law and the confidentiality obligations set forth therein.

Purposes and Legal Basis of Processing

Your personal data will be processed for the following purposes, necessary for the performance of contractual or pre-contractual obligations:

• Report management during sales operations;
• Activities scheduling and operational coordination.

Processing Methods

Your personal data may be processed using the following methods:

• Manual processing through paper-based filing systems;
• Computerised and digital processing systems.

All data are processed in compliance with Articles 6 and 32 of the GDPR, and with the adoption of appropriate technical and organisational security measures.

Authorised Persons

Your personal data will be processed exclusively by persons specifically authorised by the Data Controller, including the following departments:

• Administration Office;
• Marketing Office.

Disclosure to Third Parties

Your data may be disclosed to external entities strictly for the proper management of the professional and commercial relationship, and in particular to the following categories of recipients, including duly appointed Data Processors:

• Consultants and freelance professionals, including professional firms;
• Freight forwarders and logistics companies.

Distribution: Your personal data will not be distributed in any form.

International Data Transfers

Your personal data may be transferred, exclusively for the purposes stated above, to the following territories:

• Member States of the European Union;
• Non-EU countries deemed adequate or otherwise compliant with GDPR safeguards.

Data Retention Period

In accordance with the principles of lawfulness, purpose limitation and data minimisation under Article 5 of the GDPR, your personal data will be retained:

• For a period not exceeding the fulfilment of legal obligations and the protection of rights in legal proceedings;
• For no longer than is necessary to achieve the purposes for which the data were collected and processed in relation to contractual performance;
• In compliance with mandatory retention periods required by applicable law.

Data Controller

The Data Controller, as defined by law, is:
Pudel SB SRL
Via Saffi 20, 20123 Milano (MI), Italy
VAT No. IT10434110960

Rights of the Data Subject

You have the right to obtain, by submitting a request to the Data Controller, the erasure (“right to be forgotten”), restriction, updating, rectification and portability of your personal data, to object to their processing, and in general to exercise all rights provided for under Articles 15, 16, 17, 18, 19, 20, 21 and 22 of the GDPR.

Regulation (EU) 2016/679 – Summary of Rights

1. Right of Access
The data subject has the right to obtain confirmation as to whether or not personal data concerning them are being processed, and, where that is the case, access to such data in an intelligible form, as well as the right to lodge a complaint with the competent supervisory authority.

2. Right to Information
The data subject has the right to be informed of:

• The source of the personal data;
• The purposes and methods of processing;
• The logic applied in the case of processing carried out with electronic tools;
• The identification details of the Data Controller, Data Processors and any designated representatives;
• The entities or categories of entities to whom the personal data may be disclosed.

3. Right to Rectification and Erasure
The data subject is entitled to obtain:

• The updating, rectification or, where applicable, integration of the data;
• The erasure, anonymisation or blocking of unlawfully processed data;
• Certification that such actions have been communicated to recipients, where applicable;
• The portability of the data.

4. Right to Object
The data subject has the right to object, in whole or in part:

• On legitimate grounds, to the processing of personal data concerning them;
• To the processing of personal data for direct marketing, advertising, or market research purposes.