Who are we and what do we do with your personal data?
Benelli Armi S.p.A., based in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees the necessary protection from any event that may put it at risk of infringement.
Benelli Armi S.p.A. implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@benelli.it if you have questions about the policies and practices implemented by Benelli Armi S.p.A.
How does Benelli Armi SpA collect and process your data? 1) For the management of the websites belonging to the controller and to follow up on your request for information
The Data Controller collects and / or receives data about you, like: IP address, identifying personal data (like email address) issued while browsing the www.benellidefense.com site and / or individual with products and promotions of Benelli Armi. They are used by the Data Controller to manage the individual websites and to follow up on your request for information. Your personal data is disclosed primarily to third parties and / or recipients whose involvement is necessary for the performance of activities related to the aforementioned purposes and also to meet certain legal obligations. Any disclosure that does not correspond to these purposes requires your prior consent. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.
2) For disclosure to third parties and recipients
The processing of your personal data takes place depending on the contract and the legal and / or regulatory obligations deriving from it.
Your data will be disclosed to third parties/recipients, if:
Your data will not be disclosed to third parties/recipients for their own purposes unless:
The personal data that Benelli Armi S.p.A. processes for this purpose is, among others:
3) For information security purposes
Benelli Armi SpA and its suppliers (third parties and / or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through Benelli Armi SpA websites to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data. For these purposes, Benelli Armi SpA provides procedures for the management of data breaches in compliance with legal obligations.
4) For business promotion
The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like e-mail address) can be done by:
The processing in question can be carried out:
During processing your data may be disclosed to third parties like: marketing services companies, companies that provide advice or solutions for business information, direct marketing, geomarketing, etc. These parties process your data (email) for marketing purposes on behalf of the Data Controller.
5) For the disclosure of data to partners and/or the companies of the group to which Benelli Armi S.p.A. belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them
The disclosure of your personal data (e.g. digital address) to Benelli Armi SpA’s commercial partners (agents, representatives, sellers, companies operating in the same sector, etc.) and / or the companies of the group to which it belongs may take place for their own marketing purposes, only if you consent to such processing.
The communication may be made to commercial partners (agents, representatives, sellers, companies operating in the same sector, etc.) and/or companies of the Benelli Armi Spa group located in non-EEA countries (as shown in the link in the paragraph “How and how long your data is stored – Where”), if the Benelli Armi SpA Newsletter is subscribed in one of these countries. The communication will be made only to the partners and/or companies of the group which the Data Controller belongs to located in the non-EEA country where the purchase took place, only if you give your consent to the processing.
6) For profiling
Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences.
The processing in question can be carried out:
In case of processing, your data may be disclosed to third parties like: profiling services companies, companies that provide advice or solutions for business information, direct marketing, etc. These parties process your data (name, surname, physical address, email, telephone number and cell phone number, information related to your commercial and / or work activity and / or family condition, information regarding your last purchases, etc.) for the purpose of profiling on behalf of the Controller.
What happens if you do not provide your data?
Your personal identifying data is necessary to fulfil any request you make using the “Contacts” section. If you do not provide such data then it is impossible for the Controller to respond to your request.
What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market research) by Benelli Armi SpA or to disclosure to third parties / recipients for marketing purposes pursued by them independently or for profiling?
Your personal data will not be processed for these purposes. This will not affect the processing of your data for the main purposes or for which you have already given your consent, if required. If you have given consent and subsequently withdraw it or chosen not to consent to processing for marketing and/or profiling purposes and/or for communication to third parties/recipients for marketing purposes pursued by them independently, your data will no longer be processed for such purposes with no negative effect on you nor on the contract you have signed.
How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of the Data Controller and specifically authorized and trained for this purpose.
The data is stored in paper, computerized and digital archives located within the European Economic Area, with the exception of the cases listed below, and adequate security measures are ensured.
Your personal data (as better specified below) may be stored in paper, computerized and digital archives located outside the European Economic Area only if the subscription to the newsletter took place in one of the non-EEA countries listed at the following link.
Specifically, your personal data will only be transferred to the partners and/or companies of the group the Data Controller belongs to located in the non-EEA country where the subscription took place in order to:
Personal data is stored as needed in electronic archives protected by means of effective and adequate security measures to counter the risks of violation considered by the Data Controller. The data is kept for the time necessary to fulfil the requests for information and for the Data Controller to send communications for this exclusive purpose following your request, and in any case for a term not exceeding a maximum of 5 years, except for events that require the involvement of competent Authorities (also in collaboration with third parties / recipients that are responsible for the Data Controller’s computer security) to carry out any investigations into the causes of the event. The personal data processed by Benelli Armi SpA for marketing purposes (direct marketing, research and market surveys) will be kept for 5 years by Benelli Armi SpA, subject to withdrawal of the consent you have given and / or subject to your opposition to such processing . The personal data processed by Benelli Armi SpA for profiling will be kept for 2 years by Benelli Armi SpA, subject to withdrawal of the consent you have given and / or subject to your opposition to such processing.
What are your rights?
Without prejudice to the limits established above for the processing of your personal data, you have the right to always be in control of your data. You have the following rights with regard to your data:
Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:
For further information and in any case to submit any requests, please contact privacy@benelli.it.
Who can you submit complaints to?
Without prejudice to any other administrative or judicial proceedings, you may lodge a complaint with the competent supervisory authority, i.e. the one having jurisdiction where you reside or work in Italy or in a different Member Nation where the violation of Regulation (EU) 2016/679 occurred.
Who are we and what do we do with your personal data?
Benelli Armi S.p.A., with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees it the necessary protection from any event that may put it at risk of infringement.
Benelli Armi S.p.A. implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@benelli.it if you have questions about the policies and practices implemented by Benelli Armi S.p.A.
How does Benelli Armi SpA collect and process your data?
Benelli Armi SpA collects and/or receives information about you, like: name, surname, tax code, place and date of birth, physical and digital address, telephone and/or cell phone number, bank account number, firearms license number, firearm model and serial number. This information is used by Benelli Armi SpA to respond to your request for the issuance of the Certificate of Warranty for the product purchased from Benelli Armi SpA or the authorized armoury and for the fulfilment of the legal and regulatory obligations Benelli Armi SpA is subject to due to its line of business. Your personal data is primarily disclosed to third parties and/or recipients whose activity is necessary for the proper performance of the service (firearms repairs or carrying out aesthetic treatments on the weapon ) or to improve the products (armoury and similar) that Benelli Armi SpA offers you and also to respond to specific legal obligations or prescribed for the control and supervision of the activities performed by Benelli Armi Spa. Any disclosure that does not correspond to these purposes requires your consent.
Your data (name, surname, physical or digital address, mobile phone number and/or telephone number) may also be processed by the Data Controller for the purposes of commercial promotion, surveys and market research with regard to products and services that Benelli Armi SpA offers, or may be communicated to partners and/or companies of the group Benelli Armi SpA belongs to for marketing activities (direct, research and market surveys) carried out by them independently only if you have given your consent to the processing and/or if you do not object to it. Your data (such as name, surname, physical address, email, landline and mobile phone number, information relating to commercial and/or work activities and/or family conditions, information regarding your latest purchases) may be processed for profiling purposes, only if you have given your consent and/or if you do not object to it.
Benelli Armi SpA may transfer your personal data outside the European Economic Area, if the purchase of the product took place from one of the partners and/or companies of the group Benelli Armi SpA belongs to located in a non-EEA country (such as better identified in the dedicated paragraph), or if the registration on the dedicated site to get the Warranty Certificate on the Benelli Armi SpA product purchased took place in one of these countries, in order to manage and for the fulfilment of legal obligations and consequent regulation and/or if the communication of the data is aimed at allowing the third party to carry out marketing activities (direct, research and market surveys) independently (only for the latter purpose, only if you have given your consent and/or if you do not object to it). Your personal data will in no way be disseminated or disclosed to indeterminate or non-identifiable subjects, not even if they are third parties.
Your personal information will be processed:
1) For the management of your warranty claim on the Benelli Armi SpA product
Your data will be processed to respond to your request for the issuance of the Certificate of Warranty for the product purchased from Benelli Armi SpA or the authorized armoury to give proper execution to the contract and to the services and benefits related to it (e.g. weapon repairs or execution of aesthetic treatments on the weapon), or to improve Benelli Armi SpA products, as well as for the fulfilment of legal and regulatory obligations to which Benelli Armi SpA is required to obey in relation to the activity carried out.
Your personal data is also collected from third parties such as:
The personal data that Benelli Armi SpA deals with for this purpose are, among others: name, surname, physical and digital address, telephone number and/or cell phone number, model of firearm and serial number of the firearm.
The obligations with which Benelli Armi SpA must comply based on the contract and specific pertinent regulations include, among other things:
2) For disclosure to third parties and recipients
The processing of your personal data takes place depending on the contract and the legal and/or regulatory obligations deriving from it.
Your data will be disclosed to third parties/recipients, if:
Your data will not be disclosed to third parties/recipients, unless:
The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:
3) For business promotion
The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like name, surname, physical and digital address, telephone number and/or cell phone number) can be done by:
The processing in question can be carried out:
Your data will be disclosed to third parties, including: marketing services companies, companies that provide business information consulting or solutions, direct marketing, geomarketing, etc. These parties process your data (name, surname, physical address, email address, telephone number and cell phone number) for marketing purposes carried out on behalf of the Data Controller.
4) For profiling
Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences.
The processing in question can be carried out if you consent to the use of the data for the processing just mentioned.
In case of processing, your data may be disclosed to third parties like: profiling services companies, direct marketing, etc. These parties process your data (name, surname, physical address, email, telephone number and cell phone number, information related to your commercial and/or work activity and/or family condition, information regarding your last purchases, etc.) for the purpose of profiling on behalf of the Controller.
5) For the disclosure of data to partners and/or the companies of the group to which Benelli Armi SpA belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them.
The disclosure of your personal data (like name, surname, physical and digital address, cell phone number and/or telephone number) to Benelli Armi SpA’s commercial partners (agents, companies operating in the same sector, etc.) and/or the companies of the group to which it belongs may take place for their own marketing purposes, only if you consent to such processing.
The communication can take place with commercial partners and/or companies of the Benelli Armi Spa group (as identified above) located in non-EEA countries (indicated in the link in the paragraph “How and for how long your data is stored – Where”), if the purchase of the product and/or the registration on the dedicated site to get the Warranty Certificate on the Benelli Armi SpA product purchased took place in one of these countries. The communication will be made only to the partners and/or companies of the group which the Data Controller belongs to located in the non-EEA country where the purchase/registration took place, only if you have given your consent to the processing.
The data used for this purpose are your name, surname, physical address, email address, telephone number and cell phone number.
6) For information and public security
Benelli Armi SpA and its suppliers (third parties and/or recipients) process your personal data, your digital data (e.g. accesses), traffic data or other data obtained for services made available through the Benelli Armi SpA website to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data.
For these purposes, Benelli Armi SpA provides procedures for the management of data breaches in compliance with legal obligations.
Benelli is also required to comply with specific obligations deriving from Public Safety purposes as envisaged by TULPS and related regulations. Based on these obligations, Benelli will process your personal data (like personal data and the firearm’s serial number) to ensure full compliance with the aforementioned regulations.
What happens if you do not provide your data?
If you do not provide your personal data, Benelli Armi SpA will not be able to issue the Certificate of Warranty, and it will not be able to proceed with the processing associated with the management of the contract and the services associated with it or with the obligations that depend on it, including the proper management of the services and benefits envisaged in the product warranty.
What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market surveys) by Benelli Armi SpA or to disclosure to third parties / recipients for marketing purposes pursued by them independently or for profiling?
Your personal data will not be processed for these purposes. This will not affect the processing of your data for the main purposes (the provision of warranty services) or for which you have already given your consent, if required.
If you have given consent and subsequently withdraw it or chosen not to consent to processing for marketing and/or profiling purposes and/or for communication to third parties/recipients for marketing purposes pursued by them independently, your data will no longer be processed for such purpose/s , without this having any detrimental consequences or effects for you and for the contract you signed.
How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi SpA and specifically authorized and trained for this purpose. The paper and especially electronic archives where your data is archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi SpA Benelli Armi SpA provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data is stored for the time necessary to complete the activities related to the management of the contract with Benelli Armi SpA and for the fulfilment of related obligations, legal or otherwise. For data intended for marketing purposes (direct marketing, research and market surveys) of communication to third parties/recipients for marketing purposes pursued by them independently and profiling that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw your consent.
How
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
The Data Controller periodically verifies the tools through which your data is processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data is stored with the guarantee of integrity and authenticity and use for the purposes of processing actually performed.
Where
Personal data is stored in paper, computerized and digital archives located in the European Economic Area, with the exception of the cases listed below, where proper measures are ensured to maintain security.
Your personal data (as better specified below) may be stored in paper, computerized and digital archives located outside the European Economic Area only if the purchase of the product and, therefore, the collection of your personal data has taken place from one of the third parties indicated in paragraph 1 (“the management of your warranty request on the Benelli Armi SpA product”), as companies of the Benelli Armi SpA group, and/or partner companies (commercial agents, representatives and sellers, companies operating in same sector), located in one of the non-EEA countries listed at the following link, or if you have registered (in one of these countries) on the site to get the Warranty Certificate on the Benelli Armi SpA product purchased.
Specifically, your personal data will only be transferred to the partners and/or companies of the group the Data Controller belongs to located in the non-EEA country where the purchase took place and, therefore, the collection of personal data, in order to:
How long
The personal data processed by Benelli Armi SpA are kept for the time necessary to complete the activities related to the management of the contract with Benelli Armi SpA and up to:
Except in cases where the rights deriving from the contract are to be exercised in court, in which case your data – only those necessary for such purposes – will be processed for the time necessary.
The personal data processed by Benelli Armi SpA for marketing purposes (direct marketing, research and market surveys) will be kept for five years by Benelli Armi SpA subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
The personal data processed by Benelli Armi SpA for profiling will be kept for two years by Benelli Armi SpA subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.
Personal data processed by Benelli Armi SpA for the purposes of Public Safety will necessarily be kept for at least 50 years as envisaged by TULPS and related regulations, without any possibility for you to withdraw consent pursuant to Italian Legislative Decree no. 204 of 26 October 2010.
What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:
Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:
Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:
Benelli Armi SpA must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi SpA In such cases, Benelli Armi SpA will inform you within one month of receiving your request and will inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi SpA at the address privacy@benelli.it .
How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest or if it is for marketing purposes (direct marketing, research and market surveys), sending your request to Benelli Armi SpA at the address privacy@benelli.it.
You have the right to the erasure of your personal data if there is no other prevailing legitimate reason with respect to your request, and in any case if you object to processing for marketing purposes (direct marketing, research and market surveys).
Who can you submit complaints to?
Without prejudice to any other action in administrative or judicial proceedings, you can lodge a complaint with the competent supervisory authority or with the authority carrying out its duties and exercising its powers in Italy, without prejudice to the cases in which the jurisdiction of the supervisory authority established in another member state is recognized in accordance with the provisions of the law.
You will be promptly informed by appropriate means each time this policy is updated, and you will be notified if Benelli Armi SpA processes your data for purposes other than those referred to in this policy before proceeding and in time for you to provide your consent if necessary.
Who are we and what do we do with your personal data?
Benelli Armi S.p.A., with registered office in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A. implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you can contact at the following email address privacy@benelli.it if you have questions about the policies and practices implemented by Benelli Armi S.p.A.
How does Benelli Armi S.p.A. collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself. They are used by Benelli Armi S.p.A. to document and publicise the event that you participated in and to promote and publicise Benelli Armi S.p.A.’s business. Your personal data is primarily disclosed to third parties and/or recipients whose activity is necessary to allow the collection of data during the event, the event’s promotion and the products and services of Benelli Armi S.p.A. Any disclosure that does not correspond to these purposes requires your consent. Your data may be disseminated for the purposes represented and in any case processed as described above. The dissemination of images and sound/video recordings that include you will occur only if you authorise the processing and/or if you do not object to it. In particular, your personal data may be published on the company’s websites, on the platforms used to stream the event, in magazines or in any other medium intended for dissemination and used to promote the activity carried out by Benelli Armi S.p.A. Benelli Armi S.p.A. does not transfer your personal data abroad.
Specifically, your personal information will be processed:
1) To document, promote and publicise the event you participated in, and Benelli Armi S.p.A.’s business
During the event you participate in, Benelli S.p.A. will be able to acquire images and/or audio/video recordings that include you, directly or through third parties that have been appointed for this purpose.
The acquisition of images is subject to your prior consent to their use. For this purpose, Benelli Armi S.p.A. invites you to sign a specific waiver issued pursuant to the terms of art. 10 and 320 of the Italian Civil Code and articles 96 and 97 of Italian Law no. 633 of 22 April 1941 (Copyright Law).
Your personal data are also collected from third parties like, for example:
The personal data that Benelli Armi S.p.A. processes for this purpose are, among others: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself.
2) For the dissemination and publication of data on Benelli Armi S.p.A.’s websites and/or in corporate and trade newspapers, also available online and on public and social platforms
Your data may be disseminated for the purposes represented and in any case processed as described above, i.e. for documentation and promotional purposes related to the event organised by Benelli Armi S.p.A. and to the products and services that Benelli Armi S.p.A. offers, and in any case to promote its business, and only if you authorise the processing and/or if you do not object to it. In particular, they can be published and then disseminated on:
3) For disclosure to third parties and recipients
Your data will not be disclosed to third parties/recipients for their own purposes unless:
The personal data that Benelli Armi S.p.A. processes for this purpose are, among others: name, surname, place and date of birth, residential address and video and photo images, as well as sound recordings involving yourself.
4) For information security purposes
Benelli Armi S.p.A. and its suppliers (third parties and/or recipients) process your personal data to the extent strictly necessary to ensure the security and ability of a network or servers connected to it to withstand at a given level of security unforeseen events or illicit or malicious acts that compromise the availability, authenticity, integrity and confidentiality of stored or submitted personal data. For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.
What happens if you do not provide your data?
If you do not provide your data, including images, Benelli Armi Spa will not process your data as described in the waiver for image use.
Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:
What happens if you do not give your consent to the disclosure of your personal data for promotional purposes regarding the event organised by Benelli Armi S.p.A. and Benelli Armi S.p.A.’s products and services?
Your personal data will not be processed, which could affect the management of the event you intend to participate in.
If you give your consent and subsequently withdraw it or refuse the dissemination of your data, they will no longer be disseminated by Benelli Armi S.p.A. Benelli Armi S.p.A. specifies that the withdrawal will take effect from the date of receipt of the request. Benelli Armi S.p.A. will be required to certify the removal of photographic images and/or audio/video recordings subject to the withdrawal. It is understood that the withdrawal will have no effect with respect to the processing already carried out or in the event that the erasure/removal of data has become impossible or otherwise excessively difficult, for example in the case of storage by third parties on computers or other media and their publication in company brochures or catalogues.
How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. Benelli Armi S.p.A. provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored, especially if belonging to particular categories.
Personal data are stored for the time necessary to complete the activities related to the management of the authorisation for use of images and their dissemination and for the fulfilment of related obligations, legal or otherwise. For data intended for dissemination that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw consent,
The computer files are located within the borders of the EU (or EEA) and do not connect or interact with databases located abroad.
1) How
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.
2) Where
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.
3) How long
The personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the authorisation to use the images and audio/video recordings that include you and that you have released to Benelli Armi S.p.A. pursuant to Italian Law no. 633 of 22 April 1941 (Copyright Law). Specifically, your personal data, including the images and audio/video recordings that include you, will be stored by Benelli Armi S.p.A. for 20 years from the date of realisation as they are considered non-creative works (pursuant to art. 87 et seq. of Italian Law no. 633 of 22 April 1941).
In any case, you retain the right to withdraw your consent and authorisation and to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.
What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:
Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:
Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:
Benelli Armi S.p.A. must respond without delay and, in any case, no later than one month after receiving your request. The deadline may be extended by two months if necessary, considering the complexity and the number of requests received by Benelli Armi S.p.A. In such cases, Benelli Armi S.p.A. must inform you within one month of receiving your request and inform you of the reasons for the extension.
For further information and in any case to submit any requests, please contact Benelli Armi S.p.A. at the address privacy@benelli.it.
How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest, sending your request to Benelli Armi S.p.A. at the address privacy@benelli.it.
You have the right to the erasure of your personal data if there is no legitimate reason that takes precedence over your request, and in any case Benelli Armi S.p.A. notes that the withdrawal will have no effect with respect to the processing already carried out of the images or in the event that their erasure/removal has become impossible or otherwise excessively difficult, for example in the case of storage by third parties on computers or other media and publication of company brochures or catalogues.
Who can you submit complaints to?
Without prejudice to any other administrative or judicial actions, you can lodge a complaint with the Personal Data Protection Authority (following the instructions given by the Authority at the link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524), unless you reside or work in another member state. In the latter case or if the violation of the legislation on the protection of personal data takes place in another EU country, the local supervisory authorities will have jurisdiction over the complaint.
You will be promptly informed by appropriate means each time this policy is updated, and you will be notified if Benelli Armi S.p.A. processes your data for purposes other than those referred to in this policy before proceeding and in time for you to provide your consent if necessary.
Who are we and what do we do with your personal data?
Benelli Armi S.p.A., based in Via della Stazione 50, 61029 Urbino (PU), as data controller works to ensure the confidentiality of your personal data and guarantees them the necessary protection from any event that may put them at risk of infringement.
Benelli Armi S.p.A. implements policies and practices regarding the collection and use of personal data and the exercise of the rights that you have under the applicable legislation. Benelli Armi S.p.A. updates its policies and practices for the protection of personal data whenever this becomes necessary and in any case in the event of regulatory and organisational changes that may affect the processing of your personal data.
Benelli Armi S.p.A. has designated an internal privacy representative who you may contact at the following email address privacy@benelli.it should you have questions about the policies and practices implemented by Benelli Armi S.p.A.
How and why does Benelli Armi S.p.A. collect and process your data?
Benelli Armi S.p.A. collects and/or receives information about you, like: name, surname, VAT number and tax code, place and date of birth, physical and digital address, telephone and/or cell phone number, bank account number, firearms licence number, firearm model and serial number, or digital data (logical accesses, IP addresses, device identification number).
The data collected are used by Benelli Armi S.p.A. to fulfil instrumental and functional purposes useful for responding to the request for registration in the Benelli+ section of the website www.benelli.it and for carrying out activities closely related to and/or associated with it (allowing warranty extensions, receiving discounts, etc.) and also for any related administrative and accounting activities (e.g. management of the contractual and/or pre-contractual relationship, to allow compliance with legal obligations, regulations). Your personal data are disclosed primarily to third parties and/or recipients whose involvement is necessary for the management of the website and the relationship established with Benelli Armi S.p.A. and also to satisfy certain legal obligations.
Any disclosure that does not correspond to these purposes requires your consent. Your data (like name, surname, physical or digital address, mobile phone number and/or telephone number) may also be processed for the purposes of commercial promotion, profiling, surveys and market research with regard to products and services that Benelli Armi S.p.A. offers you only if you consent to the processing and/or if you do not object to it.
Benelli Armi S.p.A. does not transfer your personal data abroad. Your personal data will not be disseminated or disclosed to indeterminate and non-identifiable parties, even as third parties.
Your personal information will be processed:
1) To respond to the request for registration in the Benelli+ section of the website www.benelli.it and to obtain a warranty extension
The processing of your personal data takes place to carry out preliminary activities and related to the management of your request for registration in the Benelli+ section of the website www.benelli.it and to perform activities closely related to and/or associated with it, and also for any pertinent administrative and accounting activities.
Specifically, the processing has the following purpose:
The processing activities will also be instrumental to and functional for registering on the website and managing the relationship established.
The obligations with which Benelli Armi S.p.A. must comply based on the relationship established and the provisions governing it are:
Your personal data can also be collected from third parties like, for example:
The personal data that Benelli Armi S.p.A. processes for this purpose are, among others:
Finally, your own information like
will be processed to provide you with assistance on the services offered by Benelli Armi S.p.A. and all corresponding information.
2) For disclosure to third parties and recipients
The processing of your personal data takes place depending on the corporate relationship and the legal and/or regulatory obligations deriving from it.
Your data will not be disclosed to third parties/recipients for their own purposes unless:
The personal data that Benelli Armi S.p.A. processes for this purpose can be, among others:
3) For information security purposes
Benelli Armi S.p.A. processes your personal data, including digital data (e.g. logical accesses, IP addresses, device identification number) or related to traffic collected or obtained through services offered on the website or on platforms associated with Benelli Armi S.p.A. (e.g. for the management of a personal area or other services accessible after registering on the Benelli Armi S.p.A. website or after filling in specific forms, or even through applications reserved for shareholders), to the extent strictly necessary and proportionate to ensure the security and ability of a network or servers connected to it to withstand unforeseen events or illicit or malicious acts of a given level of security that compromise the availability, authenticity, integrity and confidentiality of personal data stored or transmitted.
For these purposes, Benelli Armi S.p.A. provides procedures for the management of data breaches in compliance with legal obligations.
4) For business promotion
The processing of your personal data takes place to offer you products and services in addition to those related to your purchase, to send you advertising material. The processing of your data (like name, surname, physical and digital address, telephone number and/or cell phone number) can be done by:
The processing in question can be carried out:
During processing your data may be disclosed to third parties like: marketing services companies, companies that provide advice or solutions for business information, direct marketing, geomarketing, etc. These parties process your data (name, surname, physical address, email, phone number and cell phone number) for marketing purposes on behalf of the Data Controller.
5) For the disclosure of data to partners and/or the companies of the group to which Benelli Armi S.p.A. belongs for marketing activities (direct marketing, research and market surveys) autonomously carried out by them.
The disclosure of your personal data (like name, surname, physical and digital address, cell phone number and/or telephone number) to Benelli Armi S.p.A.’s commercial partners (agents, companies operating in the same sector, etc.) and/or the companies of the group to which it belongs may take place for their own marketing purposes, only if you consent to such processing.
6) For profiling
Your personal data may be processed for analysis of consumption habits and choices, defining individual profiles in order to send commercial and promotional information relevant to your latest purchases and preferences.
The processing in question can be carried out:
In case of processing, your data may be disclosed to third parties like: profiling services companies, companies that provide advice or solutions for business information, direct marketing, etc. These parties process your data (name, surname, physical address, email, telephone number and cell phone number, information related to your commercial and/or work activity and/or family condition, information regarding your last purchases, etc.) for the purpose of profiling on behalf of the Controller.
What happens if you do not provide your data?
The personal data collected or otherwise obtained by Benelli Armi S.p.A. that are specified as mandatory are considered necessary for the registration on the website and the use of the services present therein, and failure to provide them makes it impossible for Benelli Armi S.p.A. to carry out processing, specifically:
Benelli Armi S.p.A. intends to carry out certain processing based on certain legitimate interests that do not affect your right to privacy, like those that:
The data that are not necessary for the establishment of the corporate relationship are optional and the failed provision thereof does not affect the main processing.
What happens if you do not consent to the processing of personal data for marketing purposes (direct marketing, research and market surveys) by Benelli Armi S.p.A. or to disclosure to third parties/recipients for marketing purposes pursued by them independently or for profiling?
Your personal data will not be processed for these purposes. This will not affect the processing of your data for the main purposes or for which you have already given your consent, if required.
If you have given consent and subsequently withdraw it or chosen not to consent to processing for marketing and/or profiling purposes, your data will no longer be processed for marketing and/or profiling purposes without this having any detrimental consequences or effects for you and for the contract you signed.
How and for how long are your data stored?
The processing of your data is carried out using electronic and manual means and tools made available to parties acting under the authority and on behalf of Benelli Armi S.p.A. and specifically authorised and trained for this purpose. The paper and especially electronic archives where your data are archived and stored are protected by effective security measures that are able to counter the risks of breach considered by Benelli Armi S.p.A. The company provides for periodic and constant verification of the measures implemented, especially for electronic and online tools, to guarantee the confidentiality of personal data that are thereby processed, archived and stored.
Personal data are stored for the time necessary to complete the activities related to the management of the contract with Benelli Armi S.p.A. and for the fulfilment of related obligations, legal or otherwise. For data intended for marketing purposes (direct marketing, research and market surveys) and/or profiling that you have consented to you are always allowed to object to the corresponding processing and/or to withdraw consent.
The computer files are located within the borders of the EU and do not connect or interact with databases located abroad.
Personal data processed by Benelli Armi S.p.A. for the purposes of Public Safety will necessarily be kept for at least 50 years as envisaged by TULPS and related regulations, without any possibility for you to withdraw consent pursuant to Italian Legislative Decree no. 204 of 26 October 2010.
How
The processing of data is performed through paper supports or computerized procedures by internal, specially authorised and trained, personnel. This personnel is allowed to access your personal data in the measure and within the limits necessary for performing the processing procedures that regard you.
Benelli Armi S.p.A. periodically verifies the tools through which your data are processed as well as the related security measures that are constantly updated; verification, also through persons authorised to process the data, that personal data not necessary for collection are not collected, processed or stored; verification that the data are stored with the guarantee of integrity and authenticity and their use for the purposes of processing actually performed.
Where
Data are stored in paper, computerized and electronic archives located in the European Economic Area where proper measures are ensured to maintain their security.
How long
The personal data processed by Benelli Armi S.p.A. are kept for the time necessary to complete the activities related to the management of the relationship and up to ten years after its conclusion or from when the rights that depend on it may be exercised (pursuant to art. 2935 and 2947 of the Italian Civil Code) in addition to the time required for erasure or anonymisation; as well as for all the time necessary to demonstrate the fulfilment of the obligations (e.g. fiscal, accounting, corporate with particular reference to those inherent in the specific legal nature of the company Benelli Armi S.p.A.) that remain even after the conclusion of the contract (art. 2220 of the Italian Civil Code), for which Benelli Armi S.p.A. must keep only the data necessary for compliance. Except in cases where the rights deriving from the contract are to be exercised in court, in which case your data – only those required for such purposes – will be processed for the time necessary.
The personal data processed by Benelli Armi S.p.A. for marketing purposes (direct marketing, research and market surveys) will be kept for 5 years by Benelli Armi S.p.A., subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
The personal data processed by Benelli Armi S.p.A. for profiling will be kept for 2 years by Benelli Armi S.p.A. subject to withdrawal of the consent you have given and/or subject to your opposition to such processing.
In any case, you retain the right to object to processing at any time based on a legitimate interest for reasons associated with your particular situation.
Once all the purposes that legitimise the storage of your personal data are exhausted, Benelli Armi S.p.A. will erase them or make them anonymous.
What are your rights?
Regulations give you the right to always have control of your data. You have the following rights with regard to your data:
Your rights are guaranteed without any particular obligations or procedures for their exercise, which is essentially understood to be free of charge. You have the right:
Essentially, at any time and free of charge and without any particular obligations or procedures for your request, you can:
For any further information and in any case to send your request, contact Benelli Armi S.p.A. at the address of the registered office as specified above or at the email address privacy@benelli.it.
How and when can you object to the processing of your personal data?
For reasons related to your particular situation, you may object at any time to the processing of your personal data if it is based on a legitimate interest, sending your request to Benelli Armi S.p.A. at the address of the registered office as specified above or at the email address privacy@benelli.it.
You have the right to the erasure of your personal data if there is no other prevailing legitimate reason with respect to your request, and in any case if you object to processing for marketing purposes (direct marketing, research and market surveys).
Who can you submit complaints to?
Without prejudice to any other administrative or judicial actions, you can lodge a complaint with the Personal Data Protection Authority (following the instructions given by the Authority at the link: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524), unless you reside or work in another member state. In the latter case or if the violation of the legislation on the protection of personal data takes place in another EU country, the local supervisory authorities will have jurisdiction over the complaint.
You will be promptly informed by appropriate means each time this policy is updated. Furthermore, if Benelli Armi S.p.A. processes your data for purposes other than those set out in this policy, before proceeding your consent will be requested, if necessary.
Essential Notice – WHISTLEBLOWING
Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
This notice is addressed to all interested parties to whom the protections provided by Legislative Decree 24/2023 apply (whistleblower, facilitator, persons in the same work environment, and colleagues of the whistleblower) as well as the reported individual. The unified notice, in accordance with the indications of the ANAC Guidelines, aims to prevent excessive informational flows that could reveal the involvement of the person in a report, thereby nullifying the confidentiality protections established by Legislative Decree 24/2023 concerning Whistleblowing.
The Data Controller protects and guarantees the confidentiality of the personal data of the data subject and ensures the necessary protection from any event that could put them at risk of violation. The Data Controller can be contacted at the following email address: privacy@benelli.it
Personal Data, Purposes, and Legal Bases for Processing
The personal data concerning you, such as:
will be processed for the following purposes:
1) the execution and management of the whistleblowing procedure and the activities related to this procedure
Your personal data are processed by the Data Controller in the execution of their tasks. In particular, the processing will be aimed at ascertaining, through specific investigative activities, the validity of the fact subject to reporting, concerning the alleged unlawful acts reported in the interest of the Data Controller’s integrity. Your data may be processed by specifically authorized and trained internal subjects, and, if necessary for investigation or related to its outcome, may be shared with the employer and with internal subjects as provided by law or regulatory provisions. The processing of your personal data is legally based on the fulfillment of legal obligations and the execution of obligations arising from the existing relationship.
[For the Whistleblower] your personal data may be collected through the dedicated Whistleblowing platform, either by your direct input or by input from an authorized individual designated by the Data Controller in the case where the report is made through the oral channel (voice message recording) or in a direct meeting. In the first case, the system ensures the masking of your voice to prevent your identification.
2) for communication to recipients and/or third parties based on the established relationship and the obligations that arise from it
In order to properly carry out all processing activities necessary to achieve the purposes of this notice, the following recipients may find themselves in a position to process your personal data:
Communication to these parties occurs in compliance with specific legal obligations that the Data Controller adheres to on their behalf. Any communication that does not respond to these purposes will be subject to your consent.
3) for cybersecurity purposes
The Data Controller processes your personal data, also through its suppliers (third parties and/or recipients), to the extent strictly necessary and proportionate to ensure the security and capability of a network or the connected servers to withstand, at a given level of security, unforeseen events or unlawful or malicious acts that compromise the availability, authenticity, integrity, and confidentiality of the personal data stored or transmitted. For these purposes, the Data Controller has procedures in place for managing personal data breaches.
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The data subject (excluding the reported individual, pursuant to Article 2-undecies of Legislative Decree No. 196 of June 30, 2003) may exercise the right to lodge a complaint with the competent Authority at any time, and may also exercise other rights provided for by Articles 15 et seq. of the European Regulation (EU) 2016/679 by contacting the aforementioned Data Controller.
For more information, the data subject can consult the complete notice published on the dedicated platform.
Complete Whistleblowing
Notice Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR)
This notice is addressed to all interested parties to whom the protections provided by Legislative Decree 24/2023 apply (whistleblower, facilitator, persons in the same work environment, and colleagues of the whistleblower) as well as the reported individual. The unified notice, in accordance with the indications of the ANAC Guidelines, aims to prevent excessive informational flows that could reveal the involvement of the person in a report, thereby nullifying the confidentiality protections established by Legislative Decree 24/2023 concerning Whistleblowing.
The Data Controller protects and guarantees the confidentiality of the personal data of the data subject and ensures the necessary protection from any event that could put them at risk of violation.
The Data Controller has established policies and practices regarding the collection and use of personal data and the exercise of the rights granted to you by applicable law. The Data Controller is committed to updating the policies and practices adopted for the protection of personal data whenever necessary and in any case in the event of legal and organizational changes that may affect the processing of your personal data.
How and why does the Data Controller collect and process your data?
The personal data concerning you, such as:
will be processed for the following purposes:
1) the execution and management of the whistleblowing procedure and the activities related to this procedure
The processing will be aimed at managing the whistleblowing procedure, specifically to ascertain, through specific investigative activities, the validity of the fact subject to reporting, concerning the alleged unlawful acts reported in the interest of the Data Controller’s integrity. Your data may be processed by specifically authorized and trained internal subjects, and, if necessary for investigation or related to its outcome, may be shared with the employer and with internal subjects as provided by law or regulatory provisions.
[For the Whistleblower only] your personal data may be collected through the dedicated Whistleblowing platform, either by your direct input or by input from an authorized individual designated by the Data Controller in the case where the report is made through the oral channel (voice message recording) or in a direct meeting. In the first case, the system ensures the masking of your voice to prevent your identification.
[For other interested parties other than the whistleblower] your personal data are collected through third parties, specifically from the report received by the Data Controller via dedicated internal channels.
The processing of your personal data is legally based on the fulfillment of legal obligations. The provision of data is necessary; failure to provide it will prevent the Data Controller from carrying out the verification activity.
2) for communication to third parties
In order to properly carry out all processing activities necessary to achieve the purposes of this notice, the following recipients may find themselves in a position to process your personal data:
Communication to these parties occurs in compliance with specific legal obligations that the Data Controller adheres to on their behalf. Any communication that does not respond to these purposes will be subject to your consent.
Your personal data will not be disseminated or disclosed to undetermined and unidentifiable subjects, not even as third parties.
3) for cybersecurity activities
| Purpose | Legal Basis |
|
Conducting activities dependent on the established relationship
Fulfillment of legal obligations (detection and notification of data breach events) Legitimate interest |
How, where, and for how long is your data stored?
The processing of your data occurs through electronic or paper means and tools provided to individuals acting under the authority of the Data Controller for authorized and trained purposes. They are allowed access to your personal data to the extent and within the limits necessary for the execution of processing activities concerning you. The Data Controller periodically verifies the tools through which your data is processed and the security measures in place, which are subject to constant updating. They also ensure, through the authorized processing subjects, that no personal data is collected, processed, stored, or retained unnecessarily; they verify that the data is stored with guarantees of integrity and authenticity and is used for the purposes of the actual processing carried out.
The data is stored in paper, electronic, and telematic archives located within the European Economic Area.
If personal data processing occurs in countries outside the European Economic Area, the appropriate guarantees required by data protection legislation for such transfers will be ensured.
Personal data is also stored in electronic archives protected by effective and adequate security measures to counter the risks of breaches considered by the Data Controller for the time necessary to fulfill the requirements following the requested verification, and in any case not beyond 5 years from the date of communication of the final outcome of the reporting procedure, pursuant to Article 14, paragraph 1, Legislative Decree 24/2023, unless there is an initiation of internal disciplinary proceedings or litigation for the time necessary for defense in court and related proceedings. Once all purposes justifying the retention of your personal data have been exhausted, the Data Controller will ensure their deletion or anonymization.
What are your rights?
It is specified that the exercise of the rights indicated below is excluded for the reported individual, as the exercise of such rights could harm the confidentiality protection of the whistleblower’s identity and other interested parties, pursuant to Article 2-undecies of Legislative Decree No. 196 of June 30, 2003.
The rights granted to the data subject allow them to always have control over their data. The rights of the data subject are as follows:
In essence, the data subject can, at any time and free of charge and without any special formalities for their request:
The Data Controller must proceed in this regard without delay and, in any case, no later than one month from the receipt of the data subject’s request. The deadline may be extended by two months if necessary, taking into account the complexity and number of requests received. In such cases, the Data Controller will inform the data subject within one month of receiving their request and will provide them with the reasons for the extension. For any further information and to submit their request, the data subject should refer to the email address privacy@benelli.it
To whom can you submit a complaint?
Without prejudice to any other administrative or judicial action, when violations are perceived to their detriment arising from the processing of personal data, the data subject may file a complaint with the Data Protection Authority, unless there are conditions or the violation of data protection legislation occurs in another EU country, in which case the competence to receive and consider the complaint will lie with the supervisory authorities established there.
Pursuant to Article 2-undecies of Legislative Decree No. 196 of June 30, 2003, the reported individual is precluded, in the absence of a response from the whistleblower, from filing a complaint with the Privacy Guarantor (pursuant to Article 77 of Regulation (EU) 2016/679).
Any updates to this notice will be communicated to the data subject promptly and by appropriate means, and they will also be informed if the Data Controller intends to continue processing their data for purposes other than those outlined in this notice, before proceeding and to comply with the resulting obligations.
