Clients and suppliers privacy


SIRA S.r.l. with head offices in Caponago (MB) in Via Senatore Simonetta, no. 26, Italian Tax ID n. 03482660150 / V.A.T. 00752850966 (hereinafter, "Controller"), as the data processing controller, hereby informs you pursuant to Art. 13 of EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed using the methods and for the purposes outlined below.

1) Object of the data processing

The Controller will process the identifying personal data (name and surname, address, e-mail and/or direct telephone number, banking and payment coordinates) of the client and/or supplier, natural person or employee of the client and/or suppliers, legal entity that will be indicated by the same to carry out the supply management activity and the delivery of the product or services.

2) Purpose and legal basis of the data processing

Your personal data are processed without your express consent Art. 6 Letters b), e) GDPR) for the following purposes:

  • Manage relations with the client and/or supplier and for the coordination of the accounting tasks, orders, invoicing, and potential disputes; 
  • Legal basis; Fulfilment of a contract. 
  • carry out the preliminary operations connected and instrumental to the acquisition of information necessary for the conclusion of the contract; 
  • Legal basis; Execution of pre-contractual measures. 
  • To fulfil current legal and regulatory obligations in force, also community obligations;
  • Legal basis; Legal obligation. 
  • For the management of disputes concerning the contractual breaches, transactions, credit recovery, law suits; 
  • Legal basis; Processing during court proceedings.

3) Processing methods

The data will be processed in written form on paper or electronic supports, accessible only to corporate personnel who are assigned and trained, via the use of adequately updated and protected IT systems.

4) Access to the data

Your data may be made accessible for the purposes outlined in Art. 2:

  • to employees and collaborators of the Controller, as those charged with and/or as internal managers of the processing;
  • to subcontractors or other subjects (by way of example, credit institutes, professional offices, group subsidiaries and affiliates, expediters, transporters, etc.) who carry out outsourced activities on behalf of the Controller, nominated, if necessary, as external data processing managers.
The updated list of managers and data processors is kept and can be consulted at the Data Processing Controller's office.

5) Obligatory nature and the consequences of refusal

The granting of data for the purposes outlined in Art. 2 is obligatory in that it is necessary in order to instil, fulfil, and manage the contractual relations correctly. Therefore, refusal to provide said data makes it impossible to instil the relationship of collaboration and to provide the services requested.

6) Duration of the processing and storage of the data

The data provided will be stored in our archives for the purposes outlined above for a period of 10 years from the termination of relations, as established by Art. 2220 Italian Civil Code, with the exception of delayed payments of sums due and/or disputes that justify the prolonging of said period.

7) Transfer of data

Your data will not be transferred outside of the European Union.

8) Rights of the person involved

In conformity with the provisions outlined in Chapter III, Section I, GDPR, you may exercise the rights therein indicated and, in particular:

  • Right to access -Obtain from the controller confirmation as to whether or not your personal data are being processed, and, where that is the case, access to the personal data and the envisaged period for which the personal data will be stored, the recipients or categories of recipient to whom the personal data have been or will be disclosed (Article 15, GDPR); 
  • Right to correction - Obtain from the controller without undue delay, the rectification of inaccurate personal data and have incomplete personal data completed (Article 16, GDPR); 
  • Right to erasure - Obtain from the controller the erasure of your personal data without undue delay, in the cases outlined in the GDPR (Article 17, GDPR); 
  • Right to restriction of processing - Obtain from the controller restriction of processing, in the cases outlined in the GDPR (Article 18, GDPR); 
  • Right to data portability - Receive your personal data previously provided to the controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in the cases outlined in the GDPR (Article 20, GDPR); 
  • Right to object - Object to the processing of your personal data, unless the controller demonstrates compelling legitimate grounds to continue with the processing (Article 21, GDPR); 
  • Right to lodge a complaint to the control authorities - Lodge a complaint with the Control Authority for the protection of personal data at Piazza di Montecitorio no. 121, 00186 Roma (RM).

9) Methods for exercising rights

You will be able to exercise your rights at any time by sending:
- a certified return receipt letter to SIRA S.r.l. Via Senatore Simonetta no. 26, 20867 Caponago (MB).
- an e-mail to: 
Please remember that you always have the right to lodge a complaint with the Authority for the protection of personal data (

10) Modifications to this Informative Declaration

This Informative Declaration may be subject to changes. It is therefore recommended that you regularly control this Informative Declaration and refer to the most recent version. The updated version of the Client and Supplier Privacy Policy, in any case, is published on this page with the date of its most recent update clearly indicated.


Last updated on 25 May 2018.

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