Privacy Policy based o EU Regulation 679/2016 General Data Protection Regulation and Data Protection ACT 2018

With this policy Berlin Packaging UK Ltd (hereafter “Berlin Packaging UK”) would like to inform users visiting the website “www.berlinpackaging.co.uk” (hereafter the “Site”) of the policy adopted with regard to the Protection of Personal Data and would like to underline its commitment and attention to the protection of the data protection of visitors of the Site. Please read our Privacy Policy carefully, which applies both if you access the Site and decide simply to browse through it using our services, without requesting any product, and if you decide to place an order.

Navigation within the Site is free and does not require any registration, with the exception of certain areas in which the user may freely and expressly provide a variety of data concerning him or her in order to access specifically identified services (e.g. to, subscribe to the newsletter, receive marketing/commercial information or request information through the “Contact Us” section, etc.). Where, therefore, you intend to provide your personal data in order to access such further services, you will be expressly informed in respect of the EU Regulation 679/2016 General Data Protection Regulation (the “EU Regulation”) and the Data Protection Act 2018 (the “DPA2018”) with an indication (by way of example) of the purposes and methods of use of the data by Berlin Packaging UK as well as the right to request the deletion of the data or its update at any time.

Under the terms and for the purposes of the “EU Regulation” (European General Data Protection Regulation) and the “DPA2018” (UK Data Protection Act), Berlin Packaging UK provides you with the following information.

1. Identity and contact details of the Data

The website www.berlinpackaging.co.uk (the “Site”) is operated by Berlin Packaging UK Ltd. with registered office at Lady Lane, Hadleigh, Suffolk, IP7 6AS, United Kingdom, , tel. +44 (0)1473 823 011, e-mail privacy.uk@berlinpackaging.com, as Data Controller.

2. Types of personal data processed

No registration is required to access the Site. However, there are services available within the Site for the use of which you must provide your data (e.g. to access newsletter services, to receive information requested by you, to contact us, etc.) [1].

With reference to the data on navigation within the Site, see also point 6 below concerning the profiling tools used by the Site.

3. Purpose and legal basis of processing

Data are collected and processed for purposes strictly related to the use of the Site and its services. The purposes for which the data is used are explained in detail in the specific notices provided by the Site in all cases of data collection. We therefore ask you to read the information notices that, from time to time, illustrate the characteristics of the processing operations that will be carried out by Berlin Packaging UK (e.g. to subscribe to the newsletter service, to send requests through the “Contact us” section, etc.). In particular, your data will be processed in order to manage the use of the Services requested through the Site, to fulfil the related legal obligations, to respond to your requests, and, on the basis of your consent, to perform marketing activities and analysis of your preferences.

Your data will be processed in full compliance with local and European privacy regulations [2].

4. Optional communication of personal data

The provision of personal data is generally optional. Only in certain cases, failure to provide data may make it impossible to access specific services and to obtain what may be requested (e.g. the provision of personal data, e-mail address, delivery address, and telephone number – are necessary to proceed with the sending of free samples, newsletters and communications, where requested by the website visitor); failure to provide such data may therefore prevent Berlin Packaging UK from allowing access to the services of the Site or from responding to user requests.

The data required from time to time are indicated in the data collection forms on the Site – e.g. by marking them with an asterisk (*) – and the consequences of failure to provide such data are set out in the specific information on the data collection pages.

5. Modalities of data processing and scope of communication

The data may be processed both electronically and on physical media. Berlin Packaging UK guarantees that the personal data provided through the Site will be processed lawfully and in accordance with the principle of fairness, in full compliance with the regulations in force, as well as the maximum confidentiality of the data provided during registration.

The data will not be disseminated and will be processed by persons expressly authorised to manage the Site and the ERP and CRM (Enterprise Resources Management and Customer Relationship Management) systems.

For organisational and functional requirements only, we have appointed a number of service providers, functional to the management of the Site, as external processors of users’ personal data for purposes strictly connected and related to the provision of the services offered. A full list of external data processors can be obtained by contacting privacy.uk@berlinpackaging.com.

The data may also be made available to the companies of the Berlin Packaging group as well as to the companies that provide us with services [1] useful for the management of your requests and related services.

6. Links to other websites

This information is only provided for the Berlin Packaging UK website: https://www.berlinpackaging.co.uk and not for any other websites that the user may visit via links. Berlin Packaging UK cannot be held responsible for personal data provided by users to external parties or any websites linked to this Site.

7. Profiling and/or customisation tools

Berlin Packaging UK does not engage in any promotional and/or advertising activities without the prior express consent of the user.

The Site uses “cookies”, both technical (i.e. to facilitate navigation and use of the Site) and profiling cookies (i.e. to analyse users and their behaviour and preferences, and to provide them with personalised advertisements).

For a detailed explanation of the cookies used by the Site and how to disable them, please read our Cookie Policy.

8. Place of data processing and transfers outside the European Union

The processing operations connected to the services provided by the Site are done at the offices of Berlin Packaging UK.

The processed data collected and processed through the Site may be transferred to countries outside the European Union, where the Parent Company is based, as well as to countries outside the European Union where our business partners are present.

Applicable law provides that your specific consent to the transfer to non-EU countries is not required as the transfer is made on the basis of the adoption of adequate safeguards referred to in Articles 46 and 47 of the EU Regulation and Article 49 of the DPA2018, such as the adoption of standard contractual clauses approved by the EU Commission.

The transfer of your data to any further third countries, where necessary, will take place in full compliance with the guarantees, measures and rights as provided by the Regulation. By simple request to be made to the references indicated in Article 47 paragraph j), you may receive more information about the transfer of your data and the guarantees provided for their protection as well as the means of obtaining a copy of such data or the place where they have been made available.

9. Data retention period

Your data will be processed for the periods of time foreseen in the specific information provided at the time of collection [4].

Regarding the retention times of data collected through the use of profiling tools (e.g. cookies), see our Cookie Policy.

10. Rights of the data subjects

By sending a communication to privacy.uk@berlinpackaging.com you may at any time exercise your rights [5], including knowing what data we collect, how and for what purposes we use it, modify the data you have provided us with or delete it, ask us to limit the use of your data, request to receive or transmit your data, without prejudice to the possibility of changing your consent (if any). You can also always object to the processing of your data, in particular for marketing purposes or the analysis of your preferences.

11. To whom you may address a complaint

We remind you that if you consider that the processing of your personal data violates the provisions of the DPA2018, you may always lodge a complaint with the UK Data Protection Authority (https://ico.org.uk/make-a-complaint/), or, if different the EU Regulation, you may always lodge a complaint with the Data Protection Authority of the Member State where you habitually reside, work or where the suspected violation occurred.

12. Applicable law

This Privacy Policy is governed by the DPA2018 and EU Regulation, which ensure that the processing of personal data is carried out with respect for the fundamental rights and freedoms and dignity of the data subject, with particular reference to confidentiality, personal identity and the right to protection of personal data.

13. Revision Clause

Berlin Packaging UK may review, modify or simply update this Privacy Policy, in whole or in part, at its exclusive option, in any manner and/or at any time, without prior notice to you, including in consideration of changes in data protection laws or regulations. Changes and updates to the Privacy Policy may be notified to users by (i) sending e-mails to registered users of the Site and/or (ii) posting on the Home Page of the Site, as the case may be, and will be binding as soon as published and/or communicated. We therefore ask you to regularly access this section to check the publication of the most recent and updated Privacy Policy or to check your e-mail inbox. The full text of the DPA 2018 can be consulted on the website of the Information Commissioner Office https://ico.org.uk; the EU Regulation can be consulted on the website of the Data Protection Authority of the Member State in which you normally reside or work.

Footnotes:

[1] Whenever Berlin Packaging UK acquires information and personal data it will, from time to time, inform users in advance of the purposes for which such data is required and how it will be used. Where necessary, Berlin Packaging UK will seek the specific consent of the user for the relevant use of the data. For example, we may ask for personal information such as your first and last name, telephone number, e-mail address and other information that you agree to provide in order to use the services of the Site by completing a specific registration form. Berlin Packaging UK will only use the personal data collected on-line for the purposes indicated during registration.

The data relating to connection and navigation within the Site (such as the URI-Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment) are collected for the only purpose of obtaining anonymous statistical information on the use of the Site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site: to the exclusion of this possibility, the data will be deleted after the time required to provide the services illustrated on the Site has elapsed.

[2]The processing of your data will take place:

– on the basis of your consent, pursuant to Art. 6(1)(a) of the EU Regulation, and pursuant to Art. 7 of the DPA2018 to carry out marketing activities and analysis of your preferences.

In any event, the processing will be carried out in accordance with the provisions set out in the applicable provisions – and their subsequent amendments and/or supplements – issued by the Personal Data Protection Authority.

[3] Your data will be communicated to:

  1. shipping companies for the delivery of samples and publications;
  2. legal, tax and audit consultants;
  3. Sales companies of the Berlin Packaging Group.
[4] Your data, collected via the “Contact Us” section of the Site, will be processed for the time necessary to handle your request correctly and subsequently deleted.

Data concerning the details of your requests will, on the other hand, be processed anonymously for analysis or promotional purposes.

Data processed for the purpose of sending you communications about Berlin Packaging UK branded products, offers, news and events will be retained for five (5) years from the date of collection or from the date of your last contact with Berlin Packaging UK. At the end of this period, Berlin Packaging UK may contact you to find out if you wish to continue to receive communications about Berlin Packaging UK products, services, offers, news and events. If you withdraw your consent for these marketing purposes, your details will be deleted immediately.

[5] The EU Regulation and the DPA2018 recognise specific rights of data subjects, including:

  • obtain confirmation as to whether or not personal data concerning you is being processed;
  • obtain access to your personal data and the information specified in the DPA2018 and the EU Regulation ;
  • obtain the rectification of inaccurate personal data concerning You without undue delay or the integration of incomplete personal data
  • obtain the deletion of personal data concerning you without undue delay;
  • obtain the restriction of the processing of personal data concerning you;
  • to be informed of any rectification or erasure or restriction of processing of personal data concerning you;
  • receive or transmit to another data controller in a structured, commonly used and machine-readable format the personal data concerning you;
  • object at any time, on grounds relating to his/her particular situation, to the processing of personal data concerning him/her.

In particular, your right to revoke at any time any processing consents you may have given and to object to our analysis activities remains unaffected.

Furthermore, you shall have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you carried out in pursuance of the legitimate interests of the Controller.