Privacy Policy

PRIVACY POLICY DISCLOSURE CONAI

Informational Disclosure to CONAI consortium members (art. 13, Legislative Decree 196/2003) To fulfil obligations set forth in the cited standard, and in the cases of exemption, for greater transparency in relationships with its stakeholders, CONAI hereby states that the personal data and other information (mainly classified as “”data about the development of economic activities””) attributable to the Associates, its customers/suppliers and representatives/respondents, collected (including electronic communications) in requesting/withdrawal , verifications/inspections or as a result of receiving/processing of complaints, statements, and other forms of data collection, are being processed on the premises of CONAI solely for the purpose of permitting proper undertaking of the activities set forth in internal and European Community legislation governing packaging and packaging waste, and in statutory provisions and regulations, in particular for the purposes of liquidation, assessment and collection of contributions due. Omitted or inaccurate communication of mandatory information may result in administrative sanctions. The collected data are processed primarily using computerised methods and logic in accordance with the objectives that must be obtained, also through:

  • verification of the data contained in the declarations with any other data held by CONAI;
  • verifications/exchanges of data presented in statements and/or in other forms provided for by the CONAI Guide with data held by other entities acquired by according to legal standards or specific agreements.

The data deposited in the Business Registry or in any other public registries, lists, records or documents may become known by anyone, without prejudice to the limits and methods allowed by the law, regulations or European Community standards that govern public data records. Other data held by CONAI may be communicated to third parties, when they are legitimate and back up by a justified request, according to law or regulations, or where, for the performance of official duties by Conai corporate functionaries or said subjects, the Consortium has initiated corporate relationships/collaborations with the same for the monitoring, control, study or research on the management of packaging and packaging waste. Communication or disclosure of the requested data, in accordance with the law, to law enforcement, judicial authorities, intelligence and security institutions or any other public subjects in accordance with article 58, section 2, for purposes of defence of the State or the prevention, detection or repression of crime are excluded. It may happen that, for the achievement of its goals, the Consortium entrusts the processing of data to trusted external parties, which are assigned with specific tasks of a technical or organisational nature (for example, data entry and storage of documentation); these entities, although operating independently as distinct “”data controllers””, are formally bound to respect current legislation governing the protection of personal data, where applicable. Within CONAI, the persons who may gain knowledge of the data shall be appointed as “managers” or “authorised persons” for the handling of the data, and shall have access to the data according to a precise distribution of tasks and responsibilities, pertinent to the appointees, as briefly represented in the following table:

Model Persons in charge of data processing (*)
Membership application-downloads: Consortium Members Area – Members Registry
Request for withdrawal – downloads: Consortium Members Area – Members Registry
Data change statement – downloads: Consortium Members Area – Members Registry
Periodical declaration for manufacturing packaging and/or packaging materials. The form provided for each of the six packing materials: steel, aluminium, paper, wood, plastic and glass (form 6.1) Members Area – Management Contribution
Periodical declaration for manufacturing packaging and/or packaging materials (form 6.2) – Download: Members Area – Management Contribution
Exemption quantity sheet (form 6.3) – Download: Members Area – Management Contribution
Self-Producer declaration (form 6.4) – Download: Members Area – Management Contribution
Declaration by the Consortium member user for export – Simplified procedure “”ex ante”” (form 6.5 – CONAI) – Download: Members Area – Management Contribution
Declaration by the Consortium member user for export – Simplified procedure “”ex ante”” (form 6.5 – Suppliers) – Download: Members Area – Management Contribution
Request for reimbursement of the Environmental Contribution – regular procedure “”ex post”” (form 6.6) – Download: Members Area – Management Contribution
Periodical declaration for import/export of packaging and/or packaging materials (form 6.10) – Download: Members Area – Management Contribution
Exemption – Primary packaging for medical devices (form 6.12) – Download: Members Area – Management Contribution
Exemption – Primary packaging in direct contact with pharmaceutical products (form 6.13) – Download: Members Area – Management Contribution
Simplified Procedure for labels (form 6.14) – Download: Members Area – Management Contribution
Simplified Procedure for cork packaging (form 6.17) – Download: Members Area – Management Contribution
Exemption – aluminium foil (form 6.18) – Download: Members Area – Management Contribution
Exemption – Disposable plastic kitchenware (cups and plates) (form 6.19) – Download: Members Area – Management Contribution
Memorandum procedure CONAI 5.04.2012 (form 6.20) – Download: Members Area – Management Contribution
Exclusion – Rolls, tubes, cylinders on which flexible material is rolled (form 6.21) – Download: Members Area – Management Contribution
Declaration “net export company” (form 6.22) – Download: Members Area – Management Contribution
Self-declaration template – Download: Members Area – Controls
Application for use of trademark – Download: General and Legal Affairs
Voting proxy template – Download: General and Legal Affairs

(*) The same information may be used by other Conai offices as part of their duties The right to access their personal information, the request for rectification, updating and cancellation, if incomplete or erroneous, as well as the opposition to handling of the data for legitimate reasons (to be specified), pursuant to articles 7-10 of the Privacy code (Legislative Decree no. 196/2003), can be exercised by contacting the Holder of the data handling, located at the offices at Via Litta, 5, Milan.

List of external managers to treatment

ex art. 13, Legislative Decree 196/2003 (Code regarding the protection of personal data)

Name VAT number Date of appointment
Ambient & Auditing Srl 05396890658 13/01/2017
Audirevi Srl 05953410585 16/01/2017
BAC – Business Auditing & Consulting Srl 06800471002 9/01/2017
Cred 11 Srl 09631650968 20/01/2017
Datacontact Srl 01037060777 14/01/2016
GDA – Revisori Indipendenti Spa 08744230155 16/01/2017
Linetech Italia Srl 07235510968 14/01/2016
LS Facility Srl 07412590965 14/01/2016
Prime BPO Srl 07412600962 07/01/2015
Service & Consulting Srl 07598730963 14/01/2016
TEL.TE Srl 06128140966 02/02/2016
Life Cycle Engineering 07732560011 29/04/2016
WIIT Spa 01615150214 29/06/2016