Information on the processing of personal data


Pursuant to Art. 13 of European Regulation no. 2016/679 (hereinafter “Regulations“), we provide the following information regarding the processing of the personal data you give us.

1.Holder of the treatment

The Data Controller is CONAI – Consorzio Nazionale Imballaggi, with registered office in Rome, Via Tomacelli no. 132 and operational headquarters in Milan, Via Pompeo Litta n. 5 (hereinafter “CONAI“).

2. Data protection officer

The Data Protection Officer appointed by CONAI, Attorney Simona Custer, can be contacted by sending a communication by e-mail to

3. Personal data

Personal data means any information that concerns you and is referable to you.
Specifically, the processing will cover the following data: first name, last name, country, region, company, role, e-mail address, any and further information indicated in the assessment test (hereinafter “Data“).

4. Purpose of processing

Your Data will be processed for the following purposes:

  1. registration to the area provided in the “Become an Environmental Labelling Specialist” section, creation of the relevant personal profile and management of strictly related tasks;
  2. Execution of the test to assess your skills in environmental labeling and management of closely related tasks, including sending communications containing the certificate if you pass the test;
  3. Publication of your Data in the list of environmental labeling experts provided on CONAI’s website (;
  4. Fulfillment of all legal and contractual obligations related to the creation of the personal profile and the use of the services provided therein;
  5. Exercise and defense of the Company’s rights in any forum including judicial, administrative, arbitration and/or mediation and conciliation procedures.

5. Legal basis for processing

The processing of your Data for the purposes indicated in 3) above has a legal basis:

  • As for the letters a), (b), and (d) in the execution of pre-contractual measures taken at your request (Art. 6.1 (b) Regulations), in the execution of the contract (Art. 6.1 (b) Regulations) and in fulfilling related obligations to which CONAI is subject (Art. 6.1 (c) Regulations);
  • As for (c) in the consent you have given (Art. 6.1 (a) Regulations);
  • As for the letter (e) in the legitimate interest of CONAI (art. 6.1 lett. (f) Regulations).

6. Processing methods

Within the scope of the above-mentioned purpose, the processing of your Data will be carried out in paper form and by means of electronic tools, in compliance with the legal provisions on the processing of personal data, taking appropriate security measures. The processing of your Data will be handled by CONAI’s in-house personnel, who are specially authorized, trained and instructed to ensure adequate security and confidentiality, as well as to avoid risks of loss and/or destruction and access by unauthorized parties.

7. Communication and Dissemination of Data

Your Data will be disseminated on CONAI’s website ( subject to your consent.

To the extent strictly relevant to the purposes stated in 3) above, your Data may be disclosed to:

  • subjects legitimated by law or regulation, such as by way of example and not limited to the Public and Judicial Authorities;
  • subjects who, as independent data controllers or data processors pursuant to art. 28 of the Regulations, are involved in the processing of Data (such as, but not limited to, the company in charge of managing and maintaining the computer systems and the Site).

The updated list of names of the Data Processors is available at the CONAI operational headquarters.

8. Period of Data Retention

Your Data will be kept for the period of time strictly necessary to achieve the purposes for which said Data was collected. Specifically, your Data for the purposes mentioned in 3) letter above:

  • a), b), (d) and (e) will be kept until you close your profile, which can be requested from CONAI at any time;
  • (c) will be kept until your consent is revoked.

Without prejudice, however, to the exercise of the additional rights set forth in Section 8) below, as well as to the fulfillment of specific statutory retention obligations and the exercise of the right of defense in the event of a dispute.

9. Rights of the interested party

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

  • Access, in the cases provided for (art.15 Regulations);
  • rectification of inaccurate Data and supplementation of incomplete Data (Art. 16 Regulations);
  • The deletion of Data for the reasons provided (Art. 17 Regulations), such as when they are no longer necessary in relation to the purposes stated above or are not processed in compliance with the Regulations;
  • Limitation of processing for the hypotheses foreseen (art. 18 Regulations), such as in case 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 Regulations), in a commonly used structured and machine-readable format the Data and to transmit said Data to another data controller;
  • Opposition to the processing, in the cases provided for (Art. 21 Regulations).

You also have the right to revoke consent at any time, without affecting the lawfulness of the processing given before revocation. All of the rights listed above can be exercised by sending a communication to CONAI by certified e-mail or by registered letter to the address of CONAI’s operational headquarters in Milan, Via Litta, 5.

10. Complaint

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

11. Nature of the provision of data

The provision of your Data is in the nature:

  • necessary for the pursuit of the purposes set forth in (3) above letters a), b), (d) and e). Therefore, the failure to provide even partial conferment of your Data entails the objective impossibility for CONAI to allow the creation of the personal profile for access to the area and the use of the services provided therein, as well as to correctly carry out all the related fulfilments;
  • Optional for the pursuit of the purpose mentioned in 3) (d) above. Therefore, failure to provide even part of your Data will result in the objective impossibility for CONAI to proceed with the publication of the same, without, however, affecting the performance of the test.

12. Transfer of Data Abroad

Your Data is not transferred abroad; it is stored at CONAI’s headquarters and on servers located in the European Union.