Privacy informations on personal data processing

Commercial relationship management, administration and business promotion. The european General Data Protection Regulation (GDPR) in article 13, enforce data controller to inform data subjects on key elements of data processing.



The data controller is Oleodinamica Borelli di Borelli Claudio, VAT Number and tax code: IT00094250354/BRLCLD44R03A573H, established in Via Galvani 2 42011 Bagnolo In Piano (RE) – ITALY, e-mail address: (from here also “Data controller” o “Controller”).

Purposes of processing legal basis
A.    To carry out commercial and information requests received in order to establish a commercial partnership;

B.    To perform contractual agreements, to carry out pre-contractual needs and to manage the service provision;

C.    To manage the administration dependent to commercial relationship;

D.   To manage litigations;

E.    To perform business promotional activities (as to send advertising material and complete market researches) directly to data subjets.

·      To the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

·      Attempt to legal obligations;

·      Legitimate interest of Data Controller consisting in the management of litigations;

·      Legitimate interest of Data Controller concerning to promote his business performing promotional activities with Soft Spam modalities;



The personal data processing activities to achieve the aforesaid purposes are performed in compliance with the European law on personal data protection (GDPR) and subsequent amendments and additions.

The processing will be also performed with IT, papery and telematics means able to guarantee the effectiveness, the security and entirety of data processing, adopting the relevant security measures congruent to the risk caused by processing activities.

The data controller will process only the personal data required to manage the communication with data subjects to satisfy specific forwarded requests, to provide the agreed services (identification data, contact details and postal address, etc.), and to perform the administrative management of commercial relationship.

The marketing activities may be developed by data controller with methods that won’t affect in any way the rights and the freedoms of data subjects, keeping in mind their reasonable expectations.

The promotion activities performed with Soft Spam modalities will be carry out even in absence of data subject’s explicit consent, as far as the communications have the following features:

  • the communications consist in sending e-mail messages to recipients which have already entertained commercial relationship with Oleodinamica Borelli di Borelli Claudio and e-mail address has been communicate to manage the business relations;
  • the message’s content be relative to products or services related to those which reciepient has already purchased;

Anyway data subject has the faculty to excersice his rights, to oppose or to limit the processing activities. Data subjects could excercise this rights when personal data are collected or whenever a message with marketing purposes be sent by data controller.

The other processing executed pursuing the business promotion and marketing purposes different from soft spam will be eventually performed after the provision of the esplicit consent by the data subject.

Processing activities may change according to the services requested, so more information concerning the personal data processing methods are available on request from the data controller.



The provision of personal data is sometimes:

  • mandatory, if data transmission is required to attempt to legal obligations; the lack of provision will result in our incapacity to fulfill the obligations assumed in contractual relations;
  • conditioning, if data transmission is required to perform contractual agreements, to carry out pre-contractual needs and to manage the service provision; the lack of transmission will affect the ability to properly manage our commercial relationship;
  • optional for the pursuing of marketing and business promotion purposes.



The recipients or categories of recipients of the data are possible:

  • post office or other delivery companies;
  • banks, credit institutions, debt collection companies and insurance firms;
  • law and debt collection firms;
  • companies that provide maintenance/repair services of IT equipment;
  • professional firms, companies and consultants who perform business consultancy, processing or other technical and specialized services;
  • professional firms, companies, associations of companies and/or entrepreneurs who provide us certain services, such as accounting, tax service, etc.
  • companies that manage datacenter, database and application software;
  • public bodies and administrations;
  • companies and entities perfoming, on our behalf, marketing and promotion activities of our business and our products.

More information concerning the third parties who may be able to access your personal data are available on request from the data controller.



Your personal data will be stored in our customer’s databases for the period strictly necessary to achieve the processing purposes for which those data are collected, as following described.

Business relations and administration management

  • if business relationship take place, your data will be stored for the period of 10 years after the relationship ends, unless that legal obligations or litigation management needs enforce a longer period of retention;
  • if business relationship doesn’t take place, personal data collected to carry out pre-contractual needs will be stored not more than 3 years after collection.

Promotion and marketing activities management:

  • if the recipient of commercial messages is an acquired customer, the data retention period would be the same as for business and administration period (10 years after business relation ends), unless data subject excersice his rights to prevent data controller to perform this data processing activity;
  • if the reciepient is a potential customer or data processing is based on the explicit consent of data subject, your data will be stored until the revocation of your explicit consent, unless data subject excersice his rights to prevent data controller to perform this data processing activity.



You are informed of the existence of your right to request access to your personal data, rectify and cancel the same, restrict the processing of data concerning yourself, object to their processing, data portability (Articles 15 to 22 of the EU Regulations 2016/679 GDPR).

To exercise your rights and know the third parties to whom data may be communicated you can write to the following e-mail address:

If data processing has his foundation on your explicit consent (art. 6, § 1, lect. a), you have the right to revoke this consent whenever you want, without to prejudice the lawfulness of previous processing activities.

You are entitled to file your complaints with the control authority at the Supervisory Authority address for the protection of personal data, by sending a certified e-mail to the address, or with the control authority of another EU member country.