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According to the applicable laws concerning personal data protection, personal data such as name, address, function, etc. you directly provided, which could include also special categories of personal data such as racial or ethnic origin, religious, political opinions, etc. (hereinafter referred to as “Data”) are collected for providing the services you are requesting (hereinafter referred to as "Services"). The Data will be treated confidentially and respectfully.
The Data shall be processed by the company/ies established and operating in the country involved in the complaint (“Marelli Companies”). Each Company shall act as independent data controller.
The controlling and processing of the Data you provided in connection with the Services is based on your consent to the controlling and processing activities as requested.
2. PURPOSE AND PROCEDURE FOR THE PROCESSING OF PERSONAL DATAThe processing of the Data by this system will be carried out for reporting on topics that are especially concerned with corruption and white-collar crimes as well as for the purpose of the opening, processing, investigation and closing of the case that has been opened about alleged situations, events, or actions in areas such as financial, accounting, banking and anti-bribery (and in any case according to the local laws) and that could have a negative impact on company or shareholder or are detrimental to morality, productivity, or personal safety.
The processing of the Data by this system will be carried out also for conflict of interests disclosures (potential or existing), submitted by employees or third parties (hereinafter a “Case”).
This system may not be used knowingly to submit false or slanderous statements or information. Cases that denounce other persons or defame them against better judgement can give rise to consequences under civil or criminal law.
We would like to expressly encourage you to include your name when submitting a Case. Whether you do so or not, we ask that you establish a secured postbox. This simplifies your communication with us. Your reports will be handled strictly confidentially.
3. MODALITY OF THE DATA PROCESSINGThe Data you report will be evaluated by Marelli Europe S.p.A. (hereinafter “ME”), on behalf of the Marelli Companies under specific contractual obligations.
The Data may be also processed by the employees or other third parties of Marelli Companies within the respective tasks and functions.
The Data shall be exclusively processed in accordance with the terms described in this Privacy notice and in compliance with the privacy, fairness, necessity, relevance, lawfulness and transparency principles as provided by the applicable laws, by the European Directive 2002/58/EC, by the Regulation (EU) 2016/679 of the European Parliament and of the Council and by any other applicable regulations.
The Data could be processed in hardcopy, automated or electronic format and, in particular, via post or electronic mail and telephone, telefax and any other electronic channel. Appropriate security measures are adopted in order to prevent any loss, any unlawful or unfair use or unauthorized access to the Data.
The system is operated on behalf of the respective data controllers by GCS Compliance Services Europe Limited, Boston House, Littlegreen, Richmond Upon Thames, Surrey, UK TW9 1QE, who acts as the provider of the Services.
By submitting a Case, you authorize Marelli Companies, to collect, process, store and otherwise use the Case and related information submitted as Marelli Companies deems appropriate.
4. CONSEQUENCES OF FAILURE TO PROVIDE DATAProvision of the Data marked as mandatory is needed for the purpose mentioned under point 2 above. Therefore, any refusal of providing mandatory Data may, partially or totally, prevent Marelli Companies to provide the Services.
Any refusal of other Data does not prevent Marelli Companies to carry out the Services. Moreover, investigation of anonymous communications concerning alleged violations may be rejected.
5. DISCLOSURE OF THE DATAThe Data may be communicated to third parties in connection with the fulfilment of legal obligations, by order of public authorities or to exercise a legal right.
6. DURATION OF DATA PROCESSINGThe Data shall be processed as long as is necessary to open, investigate and archive the Case and related alleged violation communicated via the Services according to the following principles:
The following rights, among others, shall be granted to you:
You may exercise such rights to the appointed data processor in charge for all countries by writing an e-mail to ME at the following e-mail address: privacy@marelli.com.
Be aware that the use of the system is optional and there will be no consequences for employees who do not use the system.
Moreover, using the system in good faith, will not expose the reporter to any disciplinary sanctions even if the Cases are later proven as inaccurate or closed by Marelli Companies.
By giving the consent and sending this communication requesting the Services I declare that I act in good faith concerning such circumstances of which I am aware of / I reasonably assume to be true.