Terms & Conditions

1 Premises

This Code of Ethics (hereinafter “Code”) identifies and draws together the ethical principles and the values of Fabbrica d'Armi Pietro Beretta S.p.A. (hereinafter the "Company") which must of necessity inspire, further to and independently from that which is provided for by law, the conduct and behaviour of those operating in the interests of the Company, both within and outside the company organisation.

The Code is an essential element of the organisation, management and control model that was adopted by the Company in accordance with Legislative Decree no. 231/2001, insofar as the Code integrates such model under the aspect of the expression and communication of those values and behaviour regulations that are considered imperative by the Company.

The duty of ensuring that the Code of Ethics is observed, diffusing its ethical principles and values, and clarifying any doubts in its interpretation, lies with the Supervisory Board which was established by the Company in accordance with Legislative Decree 231/2001.

2 The objectives of Fabbrica D’Armi Pietro Beretta S.p.A.

Fabbrica d’Armi Pietro Beretta S.p.A. is among the oldest and most prestigious arms manufacturers in existence, and is the sector global leader. Operating in Italy since the beginning of the 1500s, today Fabbrica d’Armi Pietro Beretta S.p.A. is a successful enterprise operating within the international market.

The competitive strength of the Company is based on the extraordinary tradition of excellence of its products, its technological and research skills, and the exceptional quality and professional expertise of its employees and collaborators.

The Company mission is to improve its economic efficiency while continually while maximising client satisfaction, with the aim of maintaining and enhancing the value of the company.

The stated objectives are pursued by adopting a logic of efficiency and openness to the market, in a context of fair competition with other operators, and by attributing a high priority to the continual improvement in product quality and offered services.

Being aware that an enterprise is valued not only on the basis of the economic results it achieves and the quality of its production, but also on the basis of its ability to produce value and increase wellbeing for the community, with this Code Fabbrica d’Armi Pietro Beretta S.p.A. intends:

• to define and state expressly the values and principles that shape its activity and its relations with employees, collaborators, business partners, shareholders, institutions, and stakeholders in general;
• to outline the behavioural principles to which the recipients of this Code are bound;
• to render those operating within the action sphere of Fabbrica d'Armi Pietro Beretta S.p.A. responsible for the observance of said principles, employing a suitable penalty system which ensures the effectiveness and efficacy of this Code.

Fabbrica d’Armi Pietro Beretta S.p.A. hopes that the Code, which was strongly desired by Company management, expresses – irrespective of any compulsion and/or company directive – the shared feelings of the community, and respond to the need to communicate the Company values both inside and outside the Company.

The Company undertakes to adopt every prevention and control measure which is considered suitable for guaranteeing the full compliance with applicable laws and regulations, supervisory legislation, sector self-regulation procedures, and internal rules and regulations in every geographical context and at all decisional and executive levels.

The recipients, who are already bound to respect the law and applicable rules and regulations, are further obliged to adapt their actions and behaviour to the principles, objectives and commitments specified by this Code.

This Code represents the application of measures relevant to article 6 of Legislative Decree 8th June 2001 no. 231, integrating the regulatory framework to which the Company is subject.
 

3 The values of Fabbrica D’Armi Pietro Beretta S.p.A.

Fabbrica d’Armi Pietro Beretta S.p.A. and all those involved, for any reason, in the activities of the Company, are called to observe the following operational values and principles:

• Legality: the scrupulous observance of all the laws, regulations, administrative measures, and, more generally, all legislative measures which may be directly applicable to the Company activity or that have a more general application;
• Tradition and a ties with the territory: the belief that the Company entrepreneurial history, with its continual interaction with the territory, and with the imprint left by its founders and their successors, constitutes a precious heritage which must be kept alive and active through an innovative vision and openness to change;
• Economic efficiency: the efficiency and practicality of management systems for the continual improvement of the profit levels and competitiveness of the Company;
• Development of human resources: through respect for the physical and cultural integrity of the individual and his/her involvement in professional enhancement courses, and participation in the Company aims;
• Research and development: constant commitment to research in all areas of intervention, in order to facilitate and attain - in the pursuit of a strategic design - the highest level of innovation for products and industrial processes, also through technological development opportunities aimed at the containment costs and at the improvement of quality;
• Respect for and protection of the environment: awareness of the crucial importance of minimising the environmental impact of production activities and of ensuring that employees and collaborators may work in a healthy and safe place;
• Correctness and transparency: the adoption of a management system which conforms to the regulations and conventions in force, with regard to both the internal and external components of the Company;
• Sense of responsibility: grounded on the correctness of actions, the transparency of responsibilities, and the continuity of relations with all stakeholders (clients, shareholders, employees, and the community in general), which are guaranteed by due observance of regulations and of correctness in operation, as well as by dialogue and clarity, which constitute the foundation of long-lasting relations;
• Fairness and integrity of relations with the Public Administration: in the management of any relations or contact with representatives of the Public Administration, both fair treatment and honest conduct must be guaranteed while fully respecting institutional functions. Fabbrica d'Armi Pietro Beretta S.p.A. dismisses any form of pressure, favouritism or "special" treatment aimed at the attainment of free or undue benefits in the personal interest of operators, public actor and/or Fabbrica d'Armi Pietro Beretta S.p.A. itself;
• Impartiality: in its relations with all those with whom it operates, the Company will avoid any and every form of discrimination based on age, sex, health conditions, nationality, race, sexual preference, religion or political beliefs

4 The Recipients

This Code of Ethics concerns the behaviour of all the members of the Company Bodies, employees and collaborators, as well as all those working towards the achievement of the Company objectives. The recipients are bound to protect, through their behaviour, the respectability and image of Fabbrica d’Armi Pietro Beretta S.p.A. and the Company assets.

It falls to the managerial company bodies to give a concrete substance to the values and principles contained in the Code, being responsible toward both the inside and the outside of the Company, reinforcing trust, cohesion and group spirit.

The principles contained in this Code integrate the rules of behaviour which each recipient is bound to observe, both in deference to the general obligations of diligence, correctness, and loyalty which must always characterise operational performance as provided by articles 2104 and 2105 of the Italian Civil Code, and the collective bargaining or company regulations, with reference to any further codes adopted by the Company to regulate particular aspects, or for the addition of sector-related behaviour regulations.

The Code shall be communicated to all its recipients via suitable means of communication. In particular, each employee is obliged to make himself/herself familiar with the Code, to contribute in an active way to its implementation, and report any possible lack in it.

All those establishing any form of collaborative relation with the Company are obliged to observe the regulations and principles determined by this Code.

Under no circumstances does the claim of acting in the interests of the Company justify the adoption of a behaviour which is in contrast with that which is stated in the Code of Ethics of Fabbrica d'Armi Pietro Beretta S.p.A..

The Code also applies to activities performed by the Company abroad, though differences from a legislative, social, economic and cultural point of view must be taken into consideration.

Violation of this Code will damage the trust relation established with the Company, and may result in disciplinary actions and compensation for damages, without prejudice to the procedures specified in article 7 of Law 300/1970 regarding collective work contracts and disciplinary codes adopted by the Company for its employees.

5 Relations with employees and collaborators

• 5.1. Employed staff Human resources are considered a fundamental element for the Company. The dedication and professionalism of employees are values and conditions which are decisive for achieving the objectives of Fabbrica d'Armi Pietro Beretta S.p.A. The Company therefore undertakes to develop the abilities and proficiency of each employee so that the energy and creativity of the individual may find expression, allowing for each member of the staff to express his/her potential. For this purpose, the Company offers all its employees the same opportunity for professional development, doing so in such a way so that each may enjoy a treatment which is equal, based on meritocracy, void of any form of discrimination based on sex, age, disability, religion, nationality or racial origins, political views and union affiliation. The Company at the same time expects employees on all levels to collaborate in order to maintain an atmosphere of reciprocal respect for the dignity, honour, and reputation of everyone within the Company. If anyone while operating in the interest of the Company believes that they have been subject to molestation or discrimination for any reason, or have witnessed it, they may report the event to the Supervisory Board. Any act of retaliation against an employee who refuses complains about, or reports such facts is prohibited.
• 5.2. Staff selection Fabbrica d’Armi Pietro Beretta S.p.A. offers the same work and/or professional development opportunities without discriminating in any way. The assessment of candidates participating in the selection process is centred on checking that the candidate fulfils the professional and psycho-aptitude requirements of the role, while respecting his/her dignity, personality, private life and opinions. Favouritism and forms of clientelism are not permitted.
• 5.3. Formation of labour relations Candidates are hired by way of a regular labour contract which fully conforms to the relevant laws and to the applied C.C.N.L. [National Collective Labour Agreement], facilitating the insertion of young people into the work environment.
• 5.4. Staff management Fabbrica d’Armi Pietro Beretta S.p.A. offers the same career opportunities to those who possess the characteristics required for accessing higher departments, roles, and/or profits. This is carried out on a meritocratic basis and without any form of discrimination, taking professional expertise into account and, in all cases, on the basis of strictly professional parameters. The Company considers staff training and ongoing refresher training according to specific topics to be an incontrovertible necessity for the Company. Fabbrica d’Armi Pietro Beretta S.p.A. promotes team spirit and reciprocal collaboration.
• 5.5. Health and safety Fabbrica d’Armi Pietro Beretta S.p.A. undertakes to diffuse and consolidate a culture of safety by fostering risk awareness, and promoting the responsible behaviour of all employees and collaborators; in addition, it takes actions, above all through preventative actions, to ensure the health and safety of employees. The objective of Fabbrica d’Armi Pietro Beretta S.p.A. is to the protect the human, capital and financial resources of the Company by constantly seeking for the necessary synergies, not only from within, but also with the suppliers, enterprises and clients involved in the its activities, while fully respecting the applicable regulations regarding prevention and protection.
• 5.6. Privacy Fabbrica d’Armi Pietro Beretta S.p.A. conforms to the applicable legal regulations regarding the treatment of personal information. With particular reference to the treatment of the employees’ personal information, Fabbrica d’Armi Pietro Beretta S.p.A. takes special care to inform each employee about the nature of the personal data to be processed by the Company, the way it will be processed, the information disclosure policies, and all other information relative to him/her in general.
• 5.7. Employee commitments Every employee must act loyally and in good faith, respecting the obligations signed in the labour contract and ensuring the required performance, as well as being familiar with and observing the deontological regulations contained within this Code, imbuing his/her conduct with reciprocal respect, cooperation, and reciprocal collaboration. All the actions, operations, negotiations, and behaviour in general which are carried out during the implementation of operational activities must be characterised by the principles of honesty, correctness, integrity, transparency, legitimacy, clarity, and reciprocal respect, as well as being open to checks and controls in accordance with the applicable regulations and internal procedures. All activities must be carried out with professional commitment and rigour. Each individual must supply adequate professional contributions to the duties and responsibilities assigned to them and must act in such a way as to protect the prestige of the Company. The staff of Fabbrica d’Armi Pietro Beretta S.p.A., aside from the function exercised and/or level of responsibility assumed, must be familiar with and implement what has been put forward by the Company concerning environmental protection, safety and privacy protection.
• 5.8. Conflict of interest The employees of Fabbrica d’Armi Pietro Beretta S.p.A. must abstain from carrying out activities which may be in conflict with the interests of Fabbrica d’Armi Pietro Beretta S.p.A. It is forbidden to benefit personally from business opportunities, or to do so vicariously, when these opportunities were discovered while carrying out one’s own duties and tasks within the Company. Before accepting a consultant, managerial, administrative or other role for another subject, or should the employee encounter a situation of a potential or real conflict of interests, he/she is obliged to communicate this to his superior, who, according to the procedures in place, shall inform the Supervisory Body.
• 5.9. Use of Company facilities and IT systems Employees shall use and take care of the facilities made available to them for work or office purposes. Facilities and resources belonging to the Company are not allowed to be used for purposes that differ from the above. Each employee is directly and personally responsible for the protection and legitimate use of the facilities and resources entrusted to him/her for carrying out his/her duties and tasks. The Company adopts the necessary measures in order to prevent other forms of use, according to the laws in force. With regard to the use of IT systems, each employee is responsible for the safety of the systems used and is subject to the legislative regulations in force and to the conditions of the license contracts. Without prejudice to that which is provided for by the civil and penal law, the use of internet connections for purposes that differ from those linked to work duties, or to send offensive messages, or that that may bring harm the image of the Company, will always be considered as an improper use of Company facilities and resources. Each employee is furthermore bound to help preventing possible crimes being committed through the use of IT systems.
• 5.10. Image protection La buona reputazione e/o l'immagine di Fabbrica d'Armi Pietro Beretta S.p.A. rappresenta una risorsa immateriale essenziale. I dipendenti di Fabbrica d'Armi Pietro Beretta S.p.A. si impegnano ad agire in conformità ai principi dettati dal presente Codice nei rapporti tra colleghi, clienti, fornitori e terzi in generale, mantenendo un contegno decoroso conforme agli standards comuni alle aziende del rilievo e delle dimensioni di Fabbrica d'Armi Pietro Beretta S.p.A.
• 5.11. Accounting and documentation Those who have been assigned the role of keeping accounting records are obliged to carry out each registration in an accurate, compete, truthful and transparent way and to allow for any checks by the internal or external subjects in charge. Financial records must be based on precise and verifiable information and must completely respect internal accounting procedures. Each employee must collaborate in order to ensure the correct accounting of every management act and take care of the supporting documentation for activities performed according to the correct criteria, in order to ensure that they are easily available. What precedes is aimed at preserving the reliability of the Company's communications, to protect a correct and truthful representation of the economic, capital and financial results of Fabbrica D’Armi Pietro Beretta S.p.A., and to guarantee that the overall activity undertaken is coherent with the organisational structure and the internal delegation system, as well as conforming to supervisory laws, regulations and norms.
• 5.12. Gifts, gratuities and other concessions It is forbidden for any employee or collaborator to request or accept gratuities, gifts and other concessions for him or for others, from whoever may gain or has gained advantage from the activity of Fabbrica D’Armi Pietro Beretta S.p.A., or who intends to enter into contact with it. Gratuities, gifts or concessions of modest value which conform to commercial and social uses and practices are exempt from this regulation. Gratuities, gifts or concessions offered to an employee or collaborator which exceed this modest value must be reported by the employee or collaborator to their supervisor and then, taking the circumstances into consideration, to the Supervisory Board. It is forbidden for any employee or collaborator to offer or propose gratuities, gifts and other concessions to any subject from which favourable treatment may be obtained in the execution of any activity which is ascribable to Fabbrica D’Armi Pietro Beretta S.p.A. Illicit advantages may not be offered or attributed to public or private clients and suppliers.
• 5.13. Commitments of external collaborators The behaviour of all external collaborators must be imbued with the same obligations of correctness, good faith and respect for the applicable laws and regulations. Signing of the terms contained in this Code may be requested from these collaborators based upon the existing procedures and on the type of activity provided by the competent company bodies.

6 Client relations

With regard to client relations, Fabbrica D’Armi Pietro Beretta S.p.A. tailors its conduct to the principles of transparency, reliability, responsibility and quality.

• The employees and collaborators of Fabbrica D’Armi Pietro Beretta S.p.A. must therefore:
• scrupulously observe the terms set out in this Code and the internal procedures relevant to the management of client relations;
• ensure the quality and reliability of the products or any services offered by monitoring that the services provided by third-party suppliers conform entirely to the quality standards of Fabbrica D’Armi Pietro Beretta S.p.A.;
• supply all information regarding the conditions and contractual terms relative to the sale of company products to the client in order that the client is completely aware when improving the agreement;
• be entirely truthful with regard to publicity communications, avoiding any form of misleading practice;
• adopt a behaviour which is focused towards availability, respect and courtesy, and is in line with the standards of Fabbrica D’Armi Pietro Beretta S.p.A., which are characterised by the utmost level of professionalism;
• take special care over consumer satisfaction activities in order to facilitate the continual improvement in the quality of products offered, courteously gathering any suggestions or complaints made by clients and making use of them to improve the suitability and rapidity of communication systems.

7 Supplier relations

• 7.1. The supply process The sale processes seek to find the greatest competitive advantage, operating under the criteria of loyalty, correctness and impartiality towards potential suppliers in such a way that no supplier, in possession of the required requisites, is blocked from competing in the stipulation of contracts. The selection of suppliers and the determination of sales conditions are based on objective and documented criteria which take into account the price and the ability to supply and ensure services of a suitable level quickly. Each business agreement must be in writing and must clearly state the services and products object of the supply, the timetable for that supply, the applicable price and fee, and the payment conditions and methods.
• 7.2. Accepting and giving gifts, favours and invitations With regard to relations with third parties, it is forbidden to pay out, offer, request or solicit payment in money or material benefits of any sort or size which are not owed by the Company. Acts of commercial courtesy such as gratuities or forms of hospitality are permitted when they are of modest value and do not compromise the integrity or reputation of one of the parties, and when they cannot be perceived as having been carried out in order to gain advantage in an improper way. In any case, this type of initiative must always be authorised and documented. The acceptance of occasional gifts or invitations may be permissible if carried out for the purpose of developing business relations or promoting the business interests of the Company and if they are not excessive relative to business norms. It is appropriate to report these situations to a superior. Employees receiving gratuities or favourable treatment which are not directly ascribable to normal courteous relations, must inform their superiors and return the gifts with a letter explaining the company code of conduct, or send the gifts to charitable organisations.

8 Relations with the Public Administration

The relations between Fabbrica D’Armi Pietro Beretta S.p.A. and the Public Administration, or relations involving publicity in general, must aim for the most rigorous observance of the applicable legal and regulatory measures and may not in any way compromise the integrity or reputation of Fabbrica D’Armi Pietro Beretta S.p.A..

The assumption of commitments and the management of relations of any type with the Public Administration and/or relations which are involved with publicity are assigned exclusively to the regularly authorised company departments in charge.

Fabbrica D’Armi Pietro Beretta S.p.A. must not seek to influence the decisions of the institution concerned when working with the Public Administration.

In any case, in the course of business negotiations or relations with the Public Administration, in Italy or abroad, as well as in the case of occasional checks/inspections/verifications by the competent Authority, Fabbrica D’Armi Pietro Beretta S.p.A. undertakes:

• not to offer job and/or business opportunities to the staff of the Public Administration involved in the negotiations, relation or controls/inspections/verifications, or to their families;
• not to offer gratuities, gifts or any form of amenity to the Public Administration or to their families, except when referring to acts of commercial courtesy of modest value and respecting the value limits specified by the relevant procedure;
• to behave in a way which conforms with the ethical principal and values adopted in this Code;
• not to solicit or obtain confidential information which could compromise the integrity or the reputation of both parties.

With regard to relations with the Public Administration in Italy or abroad, representatives and/or employees of Fabbrica D’Armi Pietro Beretta S.p.A. are not permitted to pay out or offer sums of money or gifts of any type or size directly or via third parties to public officials or those in the public sector, government representatives, public employees and private citizens, both in Italy and in other counties, with whom Fabbrica D’Armi Pietro Beretta S.p.A. has business relations, in order to compensate or repay them for an act carried out by their office, or to achieve an act which goes against the duties of their office.

Acts of commercial courtesy including gratuities, forms of hospitality or any other form of benefit (including concessions) are permitted only when they are of modest value, contained within the limits specified by the relevant procedure (which will also list the goods categories which constitute gifts), and such that they do not compromise the integrity and reputation of the parties, as well as conforming to norms.

Such acts must always be authorised and suitably documented.

9 Relations with audit committees and company bodies

Employees of the Company are obliged to guarantee the maximum level of collaboration and transparency in relations which may be called to consult with the Board of Auditors, independent auditors and partners, relative to the auditing activity performed by them.

In particular, Company employees must abstain from any commissive or omissive behaviour which may result in a denial to auditors or partners, or that may lead to the obstruction of research or avert the attention of auditors or partners during the course of their respective auditing activities.

10 Relations with supervisory authorities

Fabbrica D’Armi Pietro Beretta S.p.A. undertakes to observe the regulations set out by national, municipal and international supervisory authorities regarding the current legislation applicable to the Company in a full and scrupulous manner, offering maximum collaboration and transparency.

The Company does not deny, hide or block any information requested by the supervisory authorities in their role as inspectors, and actively collaborates during the course of preliminary procedures.

In order to guarantee maximum transparency, Fabbrica D’Armi Pietro Beretta S.p.A. undertakes not to find itself in a conflict of interests with the employees and families of any supervisory authority.

The Company recognises that, at times, some doubts may arise regarding the correct interpretation of rules and regulations: in this case, employees and collaborators may request the opinion of the supervisor of the legal department of Fabbrica D’Armi Pietro Beretta S.p.A. using the suitable channel.

11 Relations with third parties

• 11.1. Competing companies Fabbrica D’Armi Pietro Beretta S.p.A. rigorously respects the legal regulations regarding competition and abstains from engaging in deceptive or collusive behaviour, or any behaviour which may constitute unfair competition.
• 11.2. The press and mass media Fabbrica D’Armi Pietro Beretta S.p.A. only communicates with the press and organisations of mass communication via the company bodies to which it is delegated, in an expression of utmost correctness, availability and transparency, respecting the communication policy defined by the Company. Employees of Fabbrica D’Armi Pietro Beretta S.p.A. cannot therefore supply information of any nature to representatives of the press and the media in general; neither can they have any form of contact aimed at the diffusion of company information without the authorisation of the competent company body. In the case of participation in conferences, congresses, seminars and other events, as well as in case of the publishing of articles, essays and publications, information supplied which refers to the Company’s activities, results, positions or strategies may only be divulged if previously made public or if authorised by the direct supervisor regarding the text of any document to be reported.
• 11.3. Contributions and sponsorship Fabbrica D’Armi Pietro Beretta S.p.A. may grant contribution requests but only when these proposals originate from non-profit organisations or those that have a high cultural or charitable value. Sponsorship activities may fall within the themes of social, environment, sport, theatre or art. In any case, when choosing which proposals to grant, Fabbrica D’Armi Pietro Beretta S.p.A. pays particular attention to possible conflicts of interest.

Privacy Policy (UK)

Protection of your personal data is of a particularly high priority for GMK Ltd/Beretta. The use of the Internet pages of GMK Ltd/Beretta is possible without any indication of personal data; however, if a data subject wants to use certain services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to GMK. By means of this data protection declaration, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, GMK Ltd/Beretta has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of GMK Ltd/Beretta is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

• a) Personal data

  Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.

• b) Data subject

  Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

• c) Processing

  Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• d) Restriction of processing

  Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

• e) Profiling

  Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's personal preferences, interests or location.

• f) Pseudonymisation

  Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

• g) Controller or controller responsible for the processing

  Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

• h) Processor

  Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

• i) Recipient

  Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

• j) Third party

  Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

• k) Consent

  Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

GMK Ltd

Bear House

Concorde Way

PO15 5RL

Fareham

UK

Phone: 01489 559999

Fax: 01489 579950

Website: www.gmk.co.uk

3. Cookies

The Internet pages of the GMK Ltd/Beretta use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, GMK Ltd/Beretta can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The website of GMK Ltd/Beretta collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, GMK Ltd/Beretta does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, GMK Ltd/Beretta analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address-assigned by the Internet service provider (ISP) and used by the data subject-date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. A Data Protection Officer particularly designated in this data protection declaration, as well as the entirety of the controller's employees are available to the data subject in this respect as contact persons.

6. Subscription to our newsletters

On the website of GMK Ltd/Beretta, users are given the opportunity to subscribe to our company's newsletter. The input mask used for this purpose determines what personal data is transmitted, as well as when the newsletter is ordered from the controller.

GMK Ltd/Beretta informs its customers and business partners occasionally by means of a newsletter detailing offers and promotions. GMK Ltd/Beretta's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for marketing. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

7. Newsletter-Tracking

The newsletter of GMK Ltd/Beretta contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, GMK Ltd/Beretta may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. GMK Ltd/Beretta automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website

The website of GMK Ltd/Beretta contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

10. Rights of the data subject

• a) Right of confirmation

  Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

• b) Right of access

  Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

  Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

  If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

• c) Right to rectification

  Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

  If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

• d) Right to erasure (Right to be forgotten)

  Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

  If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by GMK Ltd/Beretta, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of GMK Ltd/Beretta or another employee shall promptly ensure that the erasure request is complied with immediately.

  Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of GMK Ltd/Beretta or another employee will arrange the necessary measures in individual cases.

• e) Right of restriction of processing

  Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

  If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by GMK Ltd/Beretta, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of GMK Ltd/Beretta or another employee will arrange the restriction of the processing.

• f) Right to data portability

  Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

  Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

  In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by GMK Ltd/Beretta or another employee.

• g) Right to object

  Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

  GMK Ltd/Beretta shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

  If GMK Ltd/Beretta processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to GMK Ltd/Beretta to the processing for direct marketing purposes, GMK Ltd/Beretta will no longer process the personal data for these purposes.

  In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by GMK Ltd/Beretta for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

  In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of GMK Ltd/Beretta or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

• h) Automated individual decision-making, including profiling

  Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

  If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, GMK Ltd/Beretta shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

  If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Officer of GMK Ltd/Beretta or another employee of the controller.

• i) Right to withdraw data protection consent

  Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

  If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our Data Protection Officer of GMK Ltd/Beretta or another employee of the controller.

11. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased six months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

12. Data protection provisions about the application and use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject-and for the entire duration of their stay on our Internet site-which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook, e.g. the Facebook blocker of the provider Webgraph, which may be obtained under http://webgraph.com/resources/facebookblocker/. These applications may be used by the data subject to eliminate a data transmission to Facebook.

13. Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

14. Data protection provisions about the application and use of Twitter

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called "tweets," e.g. short messages, which are limited to 140 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Further information about the Twitter buttons is available under https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.

15. Data protection provisions about the application and use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.

YouTube's data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

16. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

17. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

18. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

19. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

20. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

Privacy Policy (USA)

Privacy Policy (EU)

PRIVACY POLICY WITHIN THE MEANING OF ARTICLES 13 AND 14 OF THE 2016/679 EUROPEAN REGULATION AND OF THE ITALIAN HARMONIZATION REGULATIONS

Purpose of Registration

 

The provision of data for the purposes referred to in paragraph b), points 3, 4  is optional and the Holder will pursue the purposes only if expressly and individually authorized by you. Your refusal or the provision of inaccurate and / or incomplete information could prevent the Fabbrica d'Armi Pietro Beretta SpA. to carry out the activities indicated therein, but will not prevent registration to the site and the completion of purchases.

The processing of personal data for these purposes requires your specific and informed consent for each of the purposes indicated in accordance with Article 6, lett. a, of the GDPR.

In any case, you may revoke the consent expressed at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation.

d) Processing methods and data retention times

Your personal data will be processed and stored either on paper or with the aid of automated tools according to logic strictly related to the aforementioned purposes and, in any case, to ensure the security and confidentiality of your data.

Your personal data processed for the registration purposes referred to in paragraph b) point 1. will be retained until you request to revoke your registration to the site.

Your personal data processed for the contractual and legal purposes referred to in paragraph b) point 2. will be kept for the time necessary to execute the contract and, in any case, in compliance with the time limits indicated by the applicable regulatory and regulatory provisions.

The data processed for the purposes of profiling, marketing, and marketing of third parties referred to in paragraph b), points 3, 4. shall be retained until you request the withdrawal of consent given to the pursuit of the aforementioned purposes, with the exception of data relating to the details of purchases that will be kept for 12 months from registration for profiling purposes and for 24 months from registration for marketing purposes in accordance with the provision of the Guarantor for the protection of personal data on "Fidelity cards and guarantees for consumers" of 24/02/05.

After this period the data will be deleted or anonymised.

 

e) Scope of communication, transfer abroad and disclosure of personal data

The processing of personal data will be carried out by the internal personnel of the Data Controller as Data Processors and Data Processors. Furthermore, the processing may be carried out by a trust company of the Data Controller as data controllers.

Their list is constantly updated and is available, upon request, by sending a communication to the address below or an e-mail to: privacy@beretta.com.

Personal data will not be disseminated in any way.

f) Rights of the interested party

In relation to the processing of data, it is your right to exercise the rights provided for in articles 15 to 22 of the 2016/679 European Regulation, (reproduced in abbreviated form at the bottom of this policy). To exercise your rights you can contact the Data Controller by sending a written notice to the address below or an e-mail to: privacy@beretta.com.

g) Data Controller and Data Processor

The data controller is Fabbrica d'Armi Pietro Beretta S.p.A.

The Data Processor is:

The Owner has appointed the External Managers of the treatment. The complete and updated list of External Processors is available free of charge by sending an email to: privacy@beretta.com

 

RIGHTS OF THE INTERESTED PARTY

Articles 15 to 22 European Regulations 2016/679

Pursuant to articles 15 to 22 of the 2016/679 European Regulation, the interested party has the right to obtain from the holder the rectification, integration or cancellation (so-called right to be forgotten) of his personal data; the right to obtain the processing limitation and the right to data portability, the right to object to the processing of personal data, including profiling and finally the right to lodge a complaint with the Guarantor.