Privacy Policy


Direct collection of data — Customers and Suppliers

FAP ITALIA SRL, the Data Controller, located in Trezzo sull’Adda (Milan), in Via Francesco Baracca 4/6, (hereinafter, in its capacity as Data Controller), would like to inform you, pursuant to art. 13 of EU Regulation no. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following ways and for the following purposes:

  1. Object of processing
    The Data Controller will process the personal data that identify you (the only personal data that will be handled by our company will be contacts regarding your workers in order to continue with the collaboration, for example name, surname, telephone number, e-mail address, etc.) – hereinafter, the “personal data” or the “data” – and that you provide when concluding Contracts for the services of the Data Controller.
  2. Purposes of processing
    Personal and company data are processed without your explicit Consent (art. 6 letters b), e) of the GDPR), for the following Service Purposes:
    -to conclude contracts for the services of the Data Controller;
    -to comply with pre-contractual, contractual and fiscal obligations deriving from relations with you;
    – to comply with obligations provided for by law, regulations, EU regulations or orders from the Authority (for example regarding the prevention of money laundering);
    -to exercise the rights of the Data Controller, for example the right to defence in court;
  3. Processing methods
    Your personal data will be processed by means of the operations indicated in art. 4 no. 2) of the GDPR, and specifically: collection, recording, organisation, storage, consultation, processing, modification, selection, retrieval, alignment, combination, blocking, transmission, erasure and destruction of data. Your personal data will be processed both on paper and by electronic and/or automated means.
    The Data Controller will process the personal data for the time necessary to comply with the aforementioned purposes, and in any case for no longer than 10 years following the end of the relationship.
  4. Access to data
    Your data may be made accessible for the purposes indicated in point 2
    -to employees and collaborators of the company FAP ITALIA SRL, in their capacity as in-house data processors and/or Data Supervisors and/or system administrators;
    -to third-party companies or other subjects (indicatively, credit institutes, professional firms, consultants, a etc.) that carry out activities outsourced by the Data Controller, in their capacity as external Data Supervisors.
  5. Transmission of data
    Without explicit consent being required (art, 6 letters b) and c) of the GDPR), the Data Controller may transmit your data for the purposes indicated at point 2) to Supervisory Bodies, Legal Authorities, insurance companies for the provision of insurance services, and to subjects to whom transmission is compulsory by law for the carrying out of the purposes indicated. These subjects will process the data in their capacity as independent data controllers. Your data will not be disclosed.
  6. Data transfer
    Personal data are held in servers in the European Union. The Data Controller may, however, if necessary, move the servers outside of the EU. In such cases, the Data Controller guarantees forthwith that any transfer of data outside of the EU will be conducted in compliance with the applicable legal provisions and with the signing of the standard contract clauses contemplated by the European Commission.
  7. Nature of the provision of data and consequences of refusal to provide data
    The provision of data for the purposes indicated at point 2 is mandatory, otherwise we will be unable to provide you with the Services.
  8. Rights of the data subject
    In your capacity as data subject, you are entitled to exercise the rights contemplated in art. 15 of the GDPR, and specifically, the right to:
    – obtain confirmation as to whether or not data regarding you exist, even if not yet recorded, and the communication thereof in an intelligible form;
    -obtain indications regarding: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied to any processing carried out with the aid of electronic tools; d) obtain the identification details of the Data Controller, the Data Supervisors and the appointed representative, pursuant to art. 3, para. 1 of the GDPR, and e) of the subjects or categories of subjects to whom the personal data may be transmitted, or who may access the personal data in their capacity as appointed representative in Italy, Data Supervisors or data processors;
    – obtain: a) the updating, rectification, or, if in your interest, the integration of data; b) the erasure, anonymization or blocking of data processed in breach of the law, including data that need not be stored for the purposes for which they were collected or subsequently processed; c) attestation that the operations mentioned at letters a) and b), and their content, have been notified to those to whom the data have been transmitted or disclosed, except for cases in which this is impossible or would involve a use of resources that is manifestly disproportionate compared to the right thus safeguarded;
    -object, in full or in part: a) for legitimate reasons, to the processing of personal data that regard you, even where pertinent to the purpose for which they were collected; b) to the processing of personal data that regard you for the sending of advertising or direct sales material or for carrying out market research, or commercial communications, through the use of automated calling systems without the intervention of an operator, via e-mail and/or using traditional marketing methods by phone and/or mail. Please note that the data subjects’ right to object, set forth in point b) above, for direct marketing by automated means also extends to traditional means, and that, in any case, the data subject may exercise his/her right to object in part only. Therefore, the data subject may choose whether to receive only communications using traditional methods, or only automated communications, or neither of the two types of communication.
    Where applicable, the data subject may also exercise the rights set forth in arts. 16-21 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability and right to object), as well as the right to file a complaint with the Data Protection Authority.
  9. How rights may be exercised
    You may, at any time, exercise your rights by sending:
    -a registered letter to FAP ITALIA SRL (business office), Via Francesco Baracca 4/6, Trezzo sull’Adda (Milan);
    -an e-mail to
  10. Data Controller, Data Supervisor and Data Processors
    The Data Controller is FAP ITALIA SRL.
    Via Francesco Baracca 4/6, Trezzo sull’Adda (Ml);
    An updated list of Data Supervisors and Data Processors is held at the registered office of the Data Controller.
  11. Amendments to this Disclosure
    Amendments may be made to this Disclosure. In this case, you will be provided with an updated copy.