Design for Recycling Policy

Design for Recycling Policy

Dear user,

Pursuant to and for the purposes of Article 13 of European Regulation No. 2016/679 (hereinafter "Regulation"), we hereby provide you with the following information regarding the processing of personal data that you provide us for registration and access to the "Design for Recycling" area present on the website, which allows users to consult the documentation published therein and to leave comments (hereinafter “the Area”)


Data Controller

The Data Controller is CONAI – Consorzio Nazionale Imballaggi, with registered office in Rome, Via Tomacelli 132 and business offices in Milan, Via Pompeo Litta 5 (hereinafter CONAI).


Data Protection Officer

The Data Protection Officer appointed by CONAI can be contacted by sending a communication by e-mail to (hereinafter "DPO").


Personal data

Personal data means any information concerning an identified or identifiable natural person.

Specifically, the processing will concern the following data: name, surname, company, e-mail address and may also concern any additional personal data that may be provided by the data subject in comments made in the Area (hereinafter the “Data”).


Processing purpose

The Data will be processed for the following purposes:

  1. registration in the Area, creation of the related personal profile, sending of access credentials and management of strictly related obligations;
  2. consultation of the documentation in the Area and leaving comments;
  3. fulfillment of all legal and contractual obligations related to the creation of the personal profile and use of the Area;
  4. exercise and defense of CONAI's rights in any legal, administrative or other forum and in arbitration and/or mediation and conciliation procedures


Legal basis for processing

Processing of the Data for the purposes indicated in 4) above has as its legal basis:

  • with regard to letters a), b), and c), execution of the pre-contractual measures adopted at your request (Art. 6.1 (b) of the Regulation), performance of the contract (Art. 6.1 (b) of the Regulation) and fulfillment of related obligations to which CONAI is subject (Art. 6.1 (c) of the Regulation);
  • with regard to letter d), CONAI's legitimate interest (Art. 6.1, letter f) of the Regulation).


Processing method 

Within the scope of the above-mentioned purposes, processing of the Data takes place on paper and by electronic means, in compliance with the regulatory provisions on the processing of personal data, adopting appropriate security measures. Processing of the Data is managed by internal CONAI personnel who carry out activities related and instrumental to the Area and who are specifically authorised, trained and instructed to ensure adequate security and confidentiality, as well as to avoid risks of loss and/or destruction and access by unauthorised parties.


Disclosure of the Data

Comments left by data subjects in the Area are not disseminated or disclosed to third parties and are visible only by CONAI.

If necessary, the Data may be processed by the companies in charge of managing and maintaining the website and IT systems, specifically appointed as Data Processors.

The updated list of Data Processors is available at CONAI's business offices.


Data retention period

Data will be retained for the entire period of registration in the Area, subject to compliance with legal retention obligations and exercise of the right of defense in the event of a dispute.


Rights of data subjects

With reference to the Data, you have the right to ask CONAI, in the manner indicated in the Regulations and subject to the provisions and limitations pursuant to Legislative Decree 196/2003 (Part I - Title I - Chapter III):

  • access, in the cases provided for (Art. 15 of the Regulation);
  • rectification of inaccurate Data and the integration of incomplete Data (Art. 16 of the Regulation);
  • erasure of the Data for the reasons provided for (Art. 17 of the Regulation), such as when it is no longer necessary with respect to the purposes indicated above or is not processed in compliance with the Regulation;
  • restriction of processing for the cases provided for (Art. 18 of the Regulation), such as in the case in which the accuracy of the Data is disputed and its correctness needs to be verified;
  • portability, i.e., the right to receive, in the cases provided for (Art. 20 of the Regulation), the Data in a structured, commonly used, machine-readable format and to transmit said Data to another data controller;
  • objection to processing, in the cases provided for (Art. 21 of the Regulation).

All of the rights listed above may be exercised by sending a communication to CONAI by certified e-mail or by registered letter to the address of CONAI's business offices in Milan, Italy, Via Litta, 5.



If you believe that the processing of your Data violates the provisions contained in the Regulation, you have the right to lodge a complaint with the Data Protection Authority in accordance with the provisions of Art. 77 of the Regulation.


Nature of provision of the Data

The provision of your Data is of a necessary nature. Therefore, even partial failure to provide your Data will result in the objective impossibility of CONAI to allow the creation of your personal profile and access to the Area, as well as to properly fulfil all the related obligations.


Transfer of the Data abroad

The Data is kept at CONAI’s offices and on servers located in the European Union.