Privacy Policy
INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
Movopack SB S.r.l. (hereinafter also referred to as the “Company,” “Movopack,” “Data Controller,” or simply the “Controller”), in its capacity as Data Controller of personal data and in compliance with current legislation—namely EU Regulation 2016/679 of 27 April 2016 concerning the processing and free movement of personal data of natural persons (General Data Protection Regulation, hereinafter also referred to as the “GDPR”)—is required to provide you with information regarding the processing of your personal data as a “data subject.”
Personal data processing refers to any operation or set of operations performed with or without the aid of automated processes and applied to personal data, such as, by way of example, collection, recording, storage, extraction, consultation, restriction, erasure, or destruction.
1. SOURCE AND NATURE OF PERSONAL DATA
We inform you that we will collect your personal data as described in this notice. Specifically, we will acquire your email address.
2. DATA CONTROLLER
The Data Controller is Movopack SB S.r.l., with its registered office at Via Sardegna 19, 20146 Milan. You may contact the Controller by writing to the above address or via certified email (PEC) at: movopack@legalmail.it.
3. DATA PROTECTION OFFICER (DPO)
The Controller has evaluated the nature, scope, and purposes of the data processing and determined that the conditions for mandatory appointment of a Data Protection Officer under Article 37 of the GDPR do not apply. Therefore, no DPO has been appointed at this time. The data subject may contact the Controller at info@movopack.com for information or to exercise their rights.
4. PURPOSE AND LEGAL BASIS OF PROCESSING
Your personal data will be processed by the Company for the following purposes:
a) Operational, managerial, administrative, and accounting obligations related to the management of the return and reuse operations of reusable packaging created and provided by the Company, such as the registration and tracking of packaging returns and the assignment of benefits associated with returning the packaging.
b) Technical management of the web apps used for returning the packaging, technical support, and customer care. (Legal basis: performance of a contract to which the data subject is a party and the legitimate interest of the Controller)
c) Marketing, commercial information, and promotional activities, including the sending of newsletters and advertising material via email or through messaging applications and/or advertising banners or pop-ups within the web apps dedicated to the reverse logistics service. (Legal basis: data subject’s consent)
d) Statistical and environmental sustainability analyses aimed at measuring the positive impact of the reusable packaging service. (Legal basis: legitimate interest of the Controller)
Regarding the above purposes, please note that:
Providing data for contractual purposes under points a) and b) is essential for participation in the initiative (without it, the reusable packaging service contract cannot be carried out);
You may object at any time to the processing of data for the purposes under points b) and d), as provided in Article 8 of this notice. Specifically: The legitimate interest under point b) lies in ensuring the proper functioning and technical support needed for the use of our web apps for the reverse logistics service. The legitimate interest under point d) lies in measuring the environmental impact of the reusable packaging service and drafting internal and external sustainability reports, with the goal of communicating the environmental benefits to customers and stakeholders.
For marketing purposes under point c), your explicit consent will be requested. You retain the right to revoke your consent at any time (without affecting the lawfulness of the processing carried out prior to the revocation). In any case, the collection of these data will follow the principle of necessity.
5. SPECIFIC CATEGORIES OF PERSONAL DATA (SO CALLED “SENSITIVE DATA”) AND DATA RELATED TO CRIMINAL CONVINCTIONS AND OFFENSES (SO CALLED “JUDICIAL DATA”)
In carrying out its activities and for the purposes outlined above, the Company informs you that it will not process special categories of personal data, i.e., “sensitive data,” such as personal data revealing: “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership,” as well as “genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a person’s sex life or sexual orientation” (Article 9 of the GDPR). Should sensitive personal data be processed outside of the legal or regulatory allowances, your specific consent will be required. Furthermore, the Company will not process any of your judicial data (Article 10 of the GDPR).
4. METHODS OF PROCESSING
The processing of data will be carried out on paper and/or using electronic and/or telematic tools and, in any case, in ways and using tools suitable to ensure the security and confidentiality of the data, in accordance with applicable regulations. Specifically, all technical, IT, organizational, logistical, and procedural security measures required by current legislation will be adopted to guarantee the minimum level of data protection required by law, allowing access only to individuals authorized to process the data by the Data Controller or by Data Processors appointed by the Controller.
5. SCOPE OF DATA COMMUNICATION
The Data Controller may share data with third parties, either as independent data controllers or as data processors appointed pursuant to Article 28 of the GDPR. In particular, your data may be communicated, within the limits of their specific responsibilities, to:
companies involved in the sale of products packaged using the reusable packaging developed by Movopack, for the purpose of recording and tracking usage, return, and reuse of the packaging;
companies that manage software and/or hardware for the Controller, or that maintain IT archives on its behalf;
parties to whom data communication is necessary or functionally connected to the management of the contractual relationship;
entities, including public bodies, who are granted access to data by legal, regulatory, or EU provisions (e.g., judicial authorities and law enforcement agencies, regulatory authorities, audit firms, rating agencies, etc.);
entities used by the Controller for packaging transportation or shipping activities, or for promotional, advertising, marketing, and communication activities.
For the same purposes listed above, the data provided may also be shared with authorized personnel (individuals acting under the authority of the Data Controller and individuals acting under the authority of Data Processors appointed by the Controller).
6. TRANSFER OF DATA ABROAD
Your personal data will be processed by the Controller within the European Union and will not be disseminated. If necessary for technical or operational reasons, or due to specific contractual agreements, the Controller reserves the right to transfer your personal data to countries outside the European Union that are covered by an adequacy decision of the European Commission or on the basis of appropriate safeguards or specific derogations as provided by applicable law.
7. DURATION OF DATA PROCESSING
The Company will retain your personal data for the time necessary to achieve the purposes specified in this notice, after which the data will be deleted in accordance with legal requirements. Specifically, in the event of termination of the relationship, the personal data will be retained from the date of the event to fulfill legal obligations regarding accounting records retention, as well as any additional retention requests for legal or tax audit purposes.
8. DATA SUBJECT RIGHTS
With respect to the processing described in this notice, and pursuant to Articles 15–22 of the GDPR, the data subject is informed that they have the right to:
request from the Controller access to personal data concerning them and information about how the data is being processed;
request correction or deletion of their data in the cases outlined in Article 17 of the Regulation, provided this does not conflict with the Controller’s legal obligations to retain data; withdraw previously given consent;
request restriction of processing in the cases provided under Article 18 of the Regulation;
request data portability, meaning the right to receive personal data concerning them in a structured, commonly used, and machine-readable format and to transmit such data to another controller without hindrance, where the processing is based on consent, a contract, or is carried out by automated means;
not be subject to a decision based solely on automated processing that produces legal effects or significantly affects them in a similar way. Any corrections, deletions, or restrictions requested by the data subject—unless impossible or requiring disproportionate effort—will be communicated by the Controller to all recipients to whom the personal data was disclosed. The Controller may provide the data subject with a list of such recipients upon request.
In addition to the rights described above, the data subject has the right to object at any time to the processing of personal data concerning them if such processing is carried out to pursue the legitimate interest of the Controller. In that case, the Controller will refrain from further processing unless it demonstrates compelling legitimate grounds that override the interests, rights, and freedoms of the data subject or are necessary for the establishment, exercise, or defense of legal claims.
The data subject also has the right to file a complaint with the Data Protection Authority if they believe their rights have been violated, following the procedures and guidance available on the official website of the Authority at: www.garanteprivacy.it.
11. UPDATES TO THE PRIVACY NOTICE
This privacy notice is published on the Controller’s website. Any updates will be posted in the same section, which we recommend checking regularly.
