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.

Data controller

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;

A.    To manage disputes with partners;

D.   To perform business promotional activities (as 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 – Purposes A. and B.

·      Attempt to legal obligations – Purpose C.

·      Legitimate interest of Data Controller, consisting in the:

o  management of litigations – Purpose D.

o  business promotion, performing marketing activities with Soft Spam modalities – Purpose E.


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 telematic 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 and fulfill legal obligations..

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:

  • it consists 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;
  • t the content is related to products or services related to those which reciepient has already purchased;

However, data subject has the faculty to exersice his rights, to oppose or to limit the processing activities. Data subjects may exercise his rights when personal data are collected or whenever a message with marketing purposes will be sent by data controller.

The processing activities may change according to the services requested and more information related to personal data processing methods are available on request from the data controller.

Data PROVISION and consequences of refusal to provide the data

The provision of personal data is sometimes:

  • mandatory, if data transmission is required to attempt to legal obligations; the provision denial will result in our failure to fulfill the obligations assumed in commercial and contractual relations; Purposes A., B., C. and D.
  • conditioning, if data transmission is required to perform contractual agreements, to carry out pre-contractual requests or to provide the service; the provision denial will affect the ability to manage properly our commercial relationship and services provision;
  • optional for the pursuing to carry out marketing and business promotion purposes; Purpose E.


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


Bagnolo In Piano, _____________  
    Oleodinamica Borelli di Borelli Claudio

(Data controller)