Fontana Rava-Toscano & Partners s.r.l. Capital stock: € 100.000,00 fully paid-in Chamber of Commerce for Industry, Crafts and Agriculture (Registration no.): Mi 1398792 Single Register of Insurance Brokers registration no.:B000014325
Registered office: Via Filippo Turati 40 – 20121 Milan (MI) – ItalyTax code and VAT no: 10717900152 Company Register no: Mi 328027 
Member of AIBA (the Italian Association of Insurance and Reinsurance Brokers)
INFORMATION GIVEN TO THE DATA SUBJECT ON THE PROCESSING OF PERSONAL DETAILS FOR INSURANCE PURPOSES
In accordance with article 13 of the Italian Privacy Code (Law Decree no. 196 of 10/06/03)
With effect from 1st January 2004 the Privacy Code came into force, combining Law no. 675 of 1996 and other decrees, regulations and codes of practice that have come into force in recent years. In accordance with the above-mentioned article, the Broker, in its capacity as the “Data Controller” shall provide certain information regarding the use of personal data.
Some of this data (personal details, tax code or VAT no., details from ID documents) must at any rate be acquired by the broker in order for it to carry out its economic and/or professional activities and some or all of it may be requested depending on the type of contract to be drawn up.
The personal data requested is strictly relevant and instrumental in managing the relationship with the client.
1. Purposes of data processing.
Personal data shall be processed within the scope of the normal business of the Broker for the following purposes:
a) exclusively for carrying out its brokerage activities with insurance and reinsurance companies on behalf of the Client indicated in Law 192/84.
b) in connection with the obligations set out by laws, regulations and European legislation, as well as by provisions issued by authorised authorities and supervisory boards and watchdogs, anti-money laundering legislation, provisions laid down by ISVAP (the Italian supervisory body for private insurance), etc.
c) when it is useful in developing the Broker’s activity, to which the data subject may or may not give its consent to receive advertising information or material.
2. Sensitive information.
Normally, data subjects are not required to provide data defined as sensitive by article 4 of the Italian Privacy Code.
Nonetheless, in relation to some specific transactions or products requested by the client, the Broker may request some “sensitive” data, that is, data from which information on the client’s state of health may be gleaned.
In order to process such data the law requires that the data subject give specific consent, with the attached declaration of consent.
3. Methods of data processing.
The data shall be processed mainly using manual, electronic, IT and computerised tools, for reasons strictly related to the purposes indicated above, and will be stored both digitally and in hard copy form, as well as on any other suitable means of support, in respect of the minimum security measures in accordance with the Technical Specifications concerning minimum security measures, Annex B of the Italian Privacy Code.
4. Granting of data.
Without prejudice to the personal autonomy of the data subject, personal data, be it general or sensitive in nature, may be provided if this is:
a) obligatory in accordance with laws, regulations or European legislation;
b) strictly necessary for entering into new relationships or managing and maintaining existing legal relationships or managing and settling claims;
c) optional for the purposes indicated in point one letter c)
5. Failure to provide data.
If the data subject fails to provide one or more pieces of obligatory personal data requested in points a) and b), the requested service may not be provided.
The instance indicated in point 4.c) does not have any impact on existing legal relationships or those being formed, but does preclude the possibility of carrying out the activities indicated in point 1.c)
6. . Entities to which personal data may be communicated.
The personal data related to the processing in question may be communicated for the purposes indicated in points 1.a) and b) to other entities in the insurance sector such as, by way of example but not limited to: insurers, co-insurers and reinsurers, companies that process the data, Risk Managers, asset valuation companies, legal experts, service providers appointed to manage claims; service providers such as IT companies that archive transactions and/or service requested by the Client; associations and consortiums that are part of in the insurance sector; and other databases to which the communication of data is obligatory.
7.Data circulation.
Personal data is not subject to circulation
8. Transfer of data abroad..
For the same purposes indicated in point 1, personal details may be transferred outside of Italy.
9. Rights of the data subject.
In relation to the processing of personal data, the data subject is entitled, in accordance with article 7 (Right to access personal data and other rights) of the Italian Privacy Code to obtain confirmation as to whether or not personal data concerning him/her exists, even if this has not yet been registered, and communication of this in an intelligible form, and is entitled to be informed of:
a) the source of the personal data;
b) the purposes and methods of processing;
c) the reasons for processing the data electronically, if this is the case;
d) the personal details of the data controller, data processors and representative designated as per the second paragraph of article 5)
e) the entities or categories of entities to which personal data may be disclosed or who may come to know of it in their capacity as designated representatives in the State’s territory, data processors or persons in charge of the processing.
The data subject is entitled to:
a) update, amend or, when in their interests, make additions to their personal data;
b) cancel, transform into an anonymous form or block any data processed in violation of the law, including that which is not necessary to retain for the purposes for which it was collected or subsequently processed;
c) a statement that those to whom the data was communicated or disclosed have been notified, even in terms of content, of the transactions indicated in letters a) and b), unless this is impossible or requires the use of resources clearly disproportional to the right being protected.
The data subject is entitled to oppose, either entirely or partially:
a) for legitimate reasons, the processing of personal data concerning them, even if this is relevant for the purpose of collecting it;
b) the processing of special data concerning them for the purposes of sending them advertising or direct sales material or for carrying out market research or sending business communications.
10. Data Controller
The Data Controller is:
Fontana Rava – Toscano & Partners S.r.l.
through its Legal Representative
11. Data Processor
The Data Processor is:
Giancarlo Fontana Rava
To exercise the rights provided for by article 7 of the Italian Privacy Code, outlined above, the data subject must send a written request to:
Fontana Rava – Toscano & Partners S.r.l.
Phone: +39 (02) 6572730
Fax: +39 (02) 6572760
e-mail: info@frtbrokers.it
F.A.O. the Data Processor.