Information pursuant to art. 13 of Legislative Decree no. 196/2003 (Code regarding the protection of personal data) and EU Regulation 2016/679 (GDPR – General Data Protection Regulation).


FRASTEMA SRL wishes to inform the interested parties subject to the processing, that the personal data referred to or referable to the interested party, are processed by the undersigned Company in full compliance with the current legislation on data processing and the confidentiality obligations that have always inspired us. “Treatment of personal data” means any operation or complex of operations, carried out even without the aid of electronic tools, concerning the collection, registration, organization, storage, consultation, processing, modification, the selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database.


Pursuant to art.13 of Legislative Decree 196/2003 and art.13 of the GDPR, in relation to the personal data that we process following the establishment of mutual contractual and working relationships, we disclose the information below.


The Data Controller “for all legal purposes is FRASTEMA Srl with administrative headquarters in via BONICALZA 138 21012-CASSANO MAGNAGO (VA); tel. 0331/201009 email


Personal data are always collected from the interested party and may also concern contact company names provided by companies with which the undersigned Company has contractual / commercial relationships.


The personal data of the interested party are processed (processing purposes) in relation to contractual needs and the consequent fulfillment of legal and tax obligations, as well as to allow effective management of financial and commercial relationships; this treatment will take place for the entire duration of the contractual relationship and also subsequently, for the fulfillment of legal obligations and for administrative and commercial purposes. The provision of personal data is mandatory in order to fulfill the indicated purpose.

As part of the purpose for which personal data is collected, FRASTEMA Srl processes said data according to the principles of correctness, lawfulness, transparency and protection of the confidentiality of the data subject’s rights.


The processing of data takes place through the use of tools and procedures suitable for guaranteeing their security and confidentiality and can be carried out both through paper and through the use of electronic tools.


Personal data will not be disclosed in any way, while it may be communicated by us to the persons appointed, appropriately appointed, for their treatment within our Studio; moreover they can be communicated to subjects who need to access such data for purposes auxiliary to the relationship between our. Company and the interested party, within the limits strictly necessary to perform the auxiliary tasks entrusted to them, such as for example: credit institutions, administrative consulting firm (accountant).

The provision of personal data is mandatory in order to fulfill contractual obligations; any refusal to provide such data could result in the failure or partial realization of the contractual object.

The treatment is carried out with the use of adequate security measures to minimize the risk of unauthorized access to data by third parties, their destruction and / or deterioration, and to guarantee confidentiality, pursuant to art. 32 of the GDPR.


Particular categories of personal data.

On the occasion of sending CVs, pursuant to articles 26 and 27 of the Privacy Code and of the articles 9 and 10 GDPR 2016/679, the interested party could voluntarily provide the undersigned company with data qualifiable as “particular categories of personal data” (ie those data that reveal “racial or ethnic origin, political opinions, religious beliefs or philosophical, or union membership … genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person “). This category of data may be processed by FRASTEMA SRL only with the consent of the interested party, expressed in writing.


The person interested in the treatment, can exercise the rights referred to in art. At any time 7 “Right of access to personal data and other rights” of the Code regarding the protection of personal data, the content of which is reported below in full:

    1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in an intelligible form.
    2. The interested party has the right to obtain the indication:
    3. a) the origin of personal data;
    4. b) the purposes and methods of treatment;
    5. c) the logic applied in case of treatment carried out with the aid of electronic instruments;
    6. d) the identity of the owner, manager and the representative appointed under article 5, paragraph 2;
    7. e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents.
    8. The interested party has the right to obtain:
    9. a) updating, rectification or, when interested, integration of data;
    10. b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
    11. c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment occurs proves impossible or involves the use of means manifestly disproportionate to the protected right.
    12. The interested party has the right to object, in whole or in part:
    13. a) for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;
    14. b) to the processing of personal data concerning him for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication “.


Furthermore, pursuant to the GDPR, we point out that the interested party may exercise the following rights towards the undersigned Company:

– Obtain confirmation that personal data processing is or is not in progress and, in this case, to obtain access to personal data and to all the information required by art. 15 of the GDPR.

– Obtain the correction of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, also by providing an additional declaration.

– Obtain the cancellation of personal data concerning you without undue delay.

– Obtain the limitation of treatment when one of the hypotheses provided for by art. 18 of the GDPR.

– Receive in a structured format, commonly used and readable by an automatic device, the personal data concerning the interested party provided to the undersigned Company. – Oppose at any time, for reasons related to your particular situation, to the processing of personal data concerning you pursuant to Article 6, paragraph 1, letters e) or f) of the GDPR. In this case, the company will refrain from further processing personal data except for the existence of binding legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or defense of a right in court.

– Do not be subjected to a decision based solely on automated processing, which produces legal effects concerning you or which similarly significantly affects your person. This right does not apply in cases governed by art. 22, paragraph 2 of the GDPR.

– Contact the Supervisory Authority to complain if you believe that your data has been processed illegitimately.



The Data Controller