MARKETING VIA NEWSLETTER

Through the site, interested users are given the opportunity to subscribe to the newsletter service for the purpose of sending promotional and commercial communications. The processing of data for this purpose, if authorised, is carried out by BKT Europe Srl (hereinafter also the “Data Controller” or “Company”) according to the specifications set out below.

IMPORTANT INFORMATION

Subscription to the newsletter is reserved for users in possession of an email address, who are at least 14 years old. The newsletter concerns communications of a promotional and commercial nature.

WHO IS THE CONTROLLER AND HOW TO CONTACT THEM

The Processing Controller for the newsletter is BKT Europe Srl, represented by its pro tempore legal representative, with registered office in Viale Bianca Maria 25, 20122 Milan, and operating office in Viale della Repubblica 133, 20831 Seregno (MB), VAT number 05404270968. The Company can be contacted at the email address [email protected]

WHAT DATA IS PROCESSED

The data processed are the identification and contact data provided by the user by filling in the appropriate subscription form to the newsletter service.

The platform used by the data controller for the newsletter allows, through tracking systems, to detect information such as the opening of a message, clicks made on hyperlinks contained within the email, from which IP address or with which type of browser the email is opened, and other similar details.

WHAT ARE THE PURPOSES AND LEGAL BASES OF THE PROCESSING

The personal data provided by the user through the appropriate form are used to allow the interested party to subscribe to the newsletter and thus periodically receive the promotional and commercial communications subject to the newsletter at the e-mail address indicated.

The legal basis for data processing is consent (art. 6 lit. a GDPR), which can be revoked at any time. The withdrawal of consent does not affect the lawfulness of the processing previously carried out. The user who gives consent will receive a confirmation email.

The platform used to send emails allows, through tracking systems, to detect information such as the opening of a message, clicks made on hyperlinks contained within the email, from which IP address or with which type of browser the email is opened, and other similar details. This information is used by the controller for the sole purpose of deleting inactive users from the contact list; the legal basis, therefore, is represented by the legitimate interest of the controller to maintain only active contacts (art. 6 lett. f) GDPR); profiling is not carried out, but users can be catalogued to be segmented according to sectors of interest, country and professional role (in a B2B-oriented context), based on the legitimate interest of the controller to improve, where appropriate, the communication and services offered.

If necessary, the data may also be used in line with the legitimate interest of the controller, which consists of verifying the security and correct functioning of the computer systems used and in carrying out defensive activities.

HOW DATA IS HANDLED

The data collected is processed with electronic tools and residually on paper. Adequate security measures are adopted to prevent the loss of data, illicit or incorrect use and unauthorized access.

Transfer of data abroad

The e-mail box transfers data outside the European Union, transferring them to the USA with adequate guarantees: in particular, the transfer takes place in the presence of an adequacy decision of the EU Commission (Data Privacy Framework).

For the e-mail service, the data will also be transferred to non-EU countries (India), in the absence of adequacy decisions from the EU Commission, but the transfer will be assisted by adequate safeguards; in particular, standard contractual clauses will be used.

For the management of marketing campaigns, the data will be transferred abroad (USA) subject to an adequacy decision by the EU Commission; in particular, use is made of the Data Privacy Framework which the provider adheres to.

Retention period

The data are stored until any request for opposition by the user and in any case no longer than two years from the provision of consent to the processing.

This is without prejudice to any defensive needs, so the data may be stored even beyond the terms indicated.

WHAT HAPPENS IF THE DATA IS NOT PROVIDED?

The provision of data is optional but, in the absence of it, it will not be possible to receive the emails sent periodically via newsletter.

WHO CAN SEE THE DATA

The data will be processed by employees of the Controller who are authorised to process it.

The data may be accessed by the competent authorities in the event of specific requests which the Controller is required, by law, to follow up, by the parent company for the email service, by advertising agencies, by the supplier used to manage the form and marketing campaigns, by companies that provide IT services and by consultants for the management of disputes and for legal assistance in the event of any disputes for which their involvement is necessary.

It is noted that some of the indicated subjects act as processing controllers and others as data processors and that communication to those who operate as autonomous controllers is carried out since prescribed by legal obligations or is necessary to fulfil the obligations arising from the pre-contractual relationship or the legitimate interest of the Controller in maintaining the security of the IT systems and in adopting defensive initiatives.

The data subject may request a detailed list of the recipients of the data from the Data Controller, to the extent that it is possible to specifically identify them.

It should be noted that the communication of personal data is in any case limited only to the categories of data whose transmission is necessary for the performance of the activities and purposes pursued.

WHAT ARE THE DATA SUBJECT’S RIGHTS?

The law recognises the right of the data subject to ask the data controller for access to personal data and the rectification or erasure of the same or the limitation of the processing concerning him or her or to object to their processing, as well as the right to data portability.

In particular, we remind you of the possibility of objecting to the processing of data carried out for marketing purposes.

The data subject may assert their rights at any time, without formalities, by contacting the controller through the email address [email protected]

Here below is a breakdown of the rights recognised by the law in force on the protection of personal data.

The right of access, i.e. the right to obtain from the Data Controller confirmation that processing of personal data regarding the data subject is or is not happening and, if so, to obtain access to the personal data and to the following information: a) the purposes of the processing; b) the categories of personal data in question; c) the recipients or the categories of recipients to whom the personal data has been or will be communicated, in particular if recipients in other countries or international organizations; d) when possible, the retention period of the personal data envisaged or, if not possible, the criteria used to determine this period; e) the existence of the data subject’s right to ask the Data Controller to rectify or cancel personal data or to limit the processing of the personal data regarding them or to oppose its processing; f) the right to lodge a complaint to a supervisory authority; g) should the data not be collected from the data subject, all the information available on its origin; h) the existence of an automatic decision-making process, including profiling and, at least in these cases, significant information on the approach used, as well as the importance and consequences envisaged of this processing for the data subject. Should the personal data be transferred to another country or international organization, the data subject then has the right to be informed of the existence of adequate guarantees relating to its transfer.

The right to rectification, i.e. the right to obtain from the Data Controller the rectification of imprecise personal data regarding them without unjustified delay. Taking account of the purposes of processing, the data subject has the right to integrate incomplete personal data, also by providing an additional statement.

The right to cancellation, i.e. the right to obtain from the Data Controller the cancellation of personal data regarding them without unjustified delay if: a) the personal data is no longer necessary in regard to the purposes for which it was collected or otherwise processed; b) the data subject withdraws their agreement on which the processing is based and if there is no other legal basis for the processing; c) the data subject opposes the processing undertaken because necessary to carry out a public service or connected to the exercise of public powers with which the Controller is invested or to pursue a legitimate interest and there is no prevailing legitimate reason to proceed with the processing, or opposes the processing for direct marketing purposes; d) the personal data was illegally processed; e) the personal data must be cancelled to fulfil a legal obligation envisaged by the law of the European Union or of the Member state to which the Data Controller is subject; f) the personal data was collected in relation to the company’s offer of services for information to minors. The request for cancellation cannot, however, be accepted if the processing is necessary: a) to exercise the right to freedom of expression and information; b) to fulfil a legal obligation which requires processing as envisaged by the law of the European Union or of the Member state to which the Data Controller is subject or to execute a task undertaken in the public interest or in the exercise of public powers with which the Data Controller is invested; c) for reasons of public interest in the public health sector; d) for the purposes of archiving in the public interest, scientific or historic research or statistical purposes, to the extent to which cancellation risks making impossible or seriously compromising achieving the goals of such processing; or e) for verifying, exercising or defending a right in the courts.

The right to limitation, i.e. the right to obtain that the data is processed, other than for its retention, only with the agreement of the data subject or for verifying, exercising or defending a right in the courts or to defend the rights of another person or corporation or for reasons of significant public interest of the European Union or of a Member state if: a) the data subject challenges the preciseness of the personal data, for the period necessary for the Data Controller to verify the exactness of this personal data; b) the processing is illegal and the data subject opposes the cancellation of the personal data and instead asks that its use is limited; c) although the Data Controller no longer needs it for processing purposes, the personal data is necessary for verifying, exercising or defending a right in the courts; d) the data subject has opposed the processing undertaken because necessary to carry out a public service or connected to the exercise of public powers with which the Controller is invested or to pursue a legitimate interest of the Data Controller or of third parties, pending verification of the possible prevalence of the legitimate reasons of the Data Controller over those of the data subject.

The right to portability, i.e. the right to receive the personal data regarding them provided to the Controller in a structured form, for shared use which can be read by an automatic device and has the right to transmit this data to another controller without impediment by the Controller to whom they have provided the data, as well as the right to obtain direct transmission of the personal data from one controller to another, if technically feasible, should the processing be based on agreement or on a contract and the processing is carried out with automated means. This right leaves the right to cancellation unaffected.

In particular we note the right of objection, i.e. the right of the data subject to object at any time, for reasons connected to their particular situation, to the processing of personal data regarding them carried out because necessary to execute a task of public interest or connected to the exercise of public powers which the controller holds or to pursue the legitimate interest of the processing controller or of third parties. Should the personal data be processed for direct marketing purposes, the data subject has the right to oppose at any time the processing of the personal data regarding them undertaken for these purposes, including profiling to the extent this is connected to such direct marketing.

Based on the provisions of art. 22 of the GDPR, the data subject then has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision a) is necessary for the conclusion or performance of a contract between the data subject and a processing controller; b) is authorised by the law of the Union or of the Member State to which the controller is subject, who also specifies appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; c) is based on the explicit consent of the data subject.

The data subject is then informed that, should they consider that the processing of their personal data takes place in violation of the provisions of the GDPR, they have the right to make a complaint to the competent Authority (art. 77 of the Regulation) or to seek legal redress (art. 79 of the Regulation).

This privacy policy was last updated on 20 February 2026

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