This page includes the descriptions of the management methods for the aforementioned Websites (hereafter referred to as “Sites” and/or individually as “Site”) with specific reference to the processing of personal data by visitors who view the Websites (hereafter referred to as "Users" or "User" when referring to a single individual).

The following information about the processing of personal data (hereafter referred to as “Privacy Policy”) is provided by the COMPANY as Controller of personal data that are collected on the Sites and provided directly by the Users, or generated following the use of the Site. The COMPANY believes that respecting the privacy of Users is fundamental and provides this Privacy Policy to allow informed choice when collecting the required information and when registering to sections of the Site to use them.

Personal data is “any information pertaining to a natural person that is or can be identified (“Data Subject”); natural persons are identifiable if they can be identified directly or indirectly, with particular reference to identifying elements such as name, identification number, location data, online ID or one or more elements that are characteristics of their physical, physiological, genetic, psychological, economical, cultural or social identity”.

Processing means “any operation or set of operations performed with or without the help of automated processes and applied to personal data or set of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by means of transmission, dissemination or any other type of distribution, comparison or interconnection, limitation, deletion and destruction”.

Generally speaking, all personal data (hereafter also called “Personal Data” and/or “Data”) that the User provides to the COMPANY by means of the Site or that are collected when using the services of the COMPANY (hereafter called "Services" and/or individually as “Service”) as defined in greater detail in the Purposes for processing of Personal Data paragraph of this Privacy Policy, will be processed in compliance with the principles set out by current personal data protection regulations, such as transparency, fairness, lawfulness, data minimisation, limitation of purposes and storage, accuracy, integrity and confidentiality.

This Privacy Policy was written on the basis of the principle of transparency while trying to avoid an excessively legal language to provide greater ease of understanding of this information.

The Privacy Policy is divided into individual sections (hereinafter referred to collectively as “Sections” and/or individually as “Section”), each of which deals with a specific area, in order to allow a more immediate and easier reading and search of topics.

The sites of the COMPANY may contain links to websites of third parties, to be useful to the User: the COMPANY does not control nor is responsible in any way for these sites, their content and/or the processing of Personal Data that these sites apply and/or perform.

This Privacy Policy is subject to amendments and so we invite you to refer to it periodically.

CONTACT DETAILS AND DATA CONTROLLER

The data Controller is the COMPANY as defined in the header above. If the COMPANY has assigned a Data Protection Officer, contact data are found in the header.

PURPOSE OF PROCESSING AND PROCESSED PERSONAL DATA

The Data will be subject to processing by the COMPANY, according to the limits set out by the applicable legislation, for the following purposes:

1. allow performing operations that are strictly associated with and instrumental in managing our relationship with you, such as answering queries received via our contact modules; recording and processing your requests for technical support; recording and processing your applications as suppliers of the COMPANY; allowing access to reserved sections of the Site (such as those of the Customer Area or the Supplier Area) and provide support to recover login data for your account; ensuring the finalisation of sales agreements for goods and/or services, managing and fulfilling orders; ensuring delivery of purchased products and checking the trend of relationships (Supply of services);
2. allow proper performance of contractual obligations taken by the COMPANY toward the User and vice versa (Contractual obligations);
3. to allow the fulfilment of obligations provided for by laws, regulations and EU standards, or instructions given by authorities empowered to do so by law and supervisory and control bodies, as well as to allow the execution of any accounting and fiscal obligations (Legal Obligations);
4. obtain information necessary to identify anomalies, fraudulent activities and/or violations in the use of the Site (Security);
5. performing commercial information activities via e-mail, if you are using a service on the Site or are proceeding or have proceeded to purchase goods or services from the COMPANY, by means of emails about the same type of products and/or services (Soft Spam).
6. providing information about our products and/or services as well as promotional and commercial activities, market research and marketing by means of automatic systems without the input of an operator (e.g. emails), as well as through traditional contact methods, such as by post; measuring your satisfaction by means of questionnaires, surveys or focus groups (Marketing);
7. perform remarketing and retargeting activities towards Users, showing online personalised ads/posts/adverts (for example through social media, such as LinkedIn or Facebook) following a previous visit to our Sites and subject to the user’s consent to the use of third-party profiling cookies/tracking pixels expressed by clicking on the appropriate banner on the Site; analyse the use of the Site by Users, examine the effectiveness of advertising, promotions and contests and, in aggregate form, statistics relating to Site browsing and performed activities, in order to simplify the use of the Site and better adapt it to the User's interests and choices. With reference to the details of the cookie and pixel activities that make these profiling activities effective for remarketing and retargeting purposes, refer to what is specified in the Cookie Policy Section of this Privacy Policy and to the list of cookies, including third-party cookies, accessible from the cookie banner through the "Cookie Settings" button or from the "Cookie Settings" link located in the footer of the Site (Profiling);

Personal Data processed by means of the Site fall within the following categories.

• Personal data, contact data and any other particular category of Personal Data

  Depending on the services required by the User, the COMPANY may request information, such as: Supplier code assigned by the COMPANY, Company name, Name of the inquirer, Company role of the inquirer, Country, Telephone, Fax, Company e-mail, etc.

  Further data may be collected during the management of each relationship through the Site or can comprise data the User decides to provide to the COMPANY by means of the Contact Us area of the Site.

  Some sections of the Site contain free-text fields that can be used to provide information to the COMPANY that may contain Personal Data. Since these are free-text fields, you may choose to provide us (even inadvertently) with special categories of Personal Data such as Data that revealing political opinions, religious or philosophical beliefs or trade union membership , as well as genetic Data, biometric Data for the identification in a univocal manner of an individual, data relating to health or sexual life or sexual orientation.

  The COMPANY asks you not to disclose any of these Data types. Since providing this information is totally optional, if you decide to do so, the COMPANY can choose whether to proceed with processing of entered data belonging to the special categories listed above, or to process that information only with your explicit authorisation and in compliance with current regulations.

• Personal Data of other people

  As mentioned in the previous paragraph, since any type of message can be entered in the free-text fields of the Site, they may indeed contain Personal Data of other people involved. In all cases in which you decide to share such Data with the Company, you will be considered as independent Controller and, as such, you will have to take on all legal obligations and responsibilities. Therefore, in this regard, the User grants the COMPANY the widest indemnity with respect to any dispute, claim, request for compensation for damage caused by processing, etc. by persons whose Personal Data have been forwarded by you in violation of applicable data protection regulations. Since, in such a case, the Company would not collect this information directly from the data subjects (but, indirectly, from you), you guarantee that such specific processing may be based on the consent of such data subjects or on another appropriate legal basis that legitimises the processing of the concerned information.

• Searching and hiring personnel

  If you decide to apply for a work opportunity within our Group or desire to send a spontaneous application for future openings, please see the following address: https://careers.sacmi.com/en-us/ ("Work with Us"). Personal data provided by you for this purpose will be processed according to what is set out in the specific Privacy Policy provided there. Personal data provided by you for this purpose will be processed according to what is set out in the specific Privacy Policy provided there.

• Navigation data and cookies

  Information technology systems and software procedures used to operate the Site acquire some Personal Data during their normal operation, whose transmission is implicit in using Internet communication protocols. This information is not collected by the COMPANY to be associated with identified Data Subjects, but it may, by its very nature, allow identifying users through processing or association with Data held by third parties.
  This category of Data includes IP addresses or domain names of computers used by Users connecting with the Site, the URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to send the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters about the operating system and software environment of the User.
  This Data is used only for anonymous statistical information about use of the Site, to check its proper operation and to identify any unusual activity and/or abuses.
  Information about cookies is found in the Cookie Policy; please read it below on this web page (under the heading COOKIE POLICY).

• Data processed during the interaction with social networks

  In addition to filling out the forms on the Site, you can also request certain services and provide your Personal Data through your Facebook, Google and LinkedIn profile. In these cases, Facebook, Google and LinkedIn will automatically send your Personal Data to the COMPANY and there will be no need for you to fill out any other form.

LEGAL BASIS FOR PROCESSING, COMPULSORY/OPTIONAL NATURE OF PROVISION OF PERSONAL DATA AND CONSEQUENCES IN THE EVENT OF NO ANSWER

Data preceded by an asterisk (*) within the Site are considered by the COMPANY to be necessary and indispensable to fulfil the relevant purposes. The following are the legal bases used by the COMPANY to process your Personal Data, according to the purposes listed under the previous Section (“Purpose of processing and processed Personal Data”).

Provision of Personal Data and their processing for the purposes associated with the Supply of Services and other Contractual obligations is strictly functional to perform the required service and to properly perform the contractual relationship signed with you, respectively; therefore they are a necessary condition to establish the contractual relationship. Consequently, failure to provide Personal Data required for this purpose, or the provision of wrong data, will make it impossible for the COMPANY to perform the Service and the contractual relationship and will entitle the COMPANY to refuse to perform them or to stop their performance.

The provision of Personal Data and their processing for the purposes of the Legal Obligations is required by the COMPANY to meet the relevant legal obligations. When you provide Personal Data to the COMPANY, it needs to process it in compliance with applicable laws that may include storing them or communicating them to pertinent authorities for compliance with taxation, customs or other obligations.

Provision of Personal Data and their processing for the purposes of Security, is based on the commitment of the COMPANY to identify and prevent illegal behaviours and to ascertain responsibility in the event of any cybercrime against the Site or third parties, therefore they are a necessary condition to navigate the Site. Consequently, failure to provide Personal Data required for this purpose will make it impossible for the COMPANY to provide access to the Site.

The provision of Personal Data and relevant processing for the purposes of Soft Spam is based on the interest of the COMPANY to send you marketing communications via email pertaining to similar products and services to those you have already purchased and/or used by means of the Site. You can stop receiving these communications, without any consequence (other than no longer being able to receive similar communications by the COMPANY) by means of the specific link in the footer of each of the emails that you receive for this purpose or by exercising your right to object to the processing by following the instructions contained in the "Your Rights as a Data Subject" section of this Privacy Policy.

Provision of Personal Data and the relevant processing for purposes of Marketing is based on your explicit authorisation provided by means of a specific positive action (e.g. clicking on a specific checkbox). You are never obligated to provide this authorisation to the COMPANY and, if you do, you are always free to withdraw it at any moment without any consequences (other than not receiving commercial communications by the COMPANY). You can withdraw your authorisation by following the instructions under the Section “Your rights” of this Privacy Policy.

The provision of Personal Data, and the related data processing for Profiling purpose, is based on your explicit consent collected through a specific button on the cookie banner, i.e. by accessing the cookie preference centre, through a button on the cookie “Cookie settings” banner. You are never obligated to provide this authorisation to the COMPANY and, if you do, you are always free to withdraw it at any moment without any consequences (other than not being able to benefit from the personalisation of the COMPANY’s commercial communications). You may withdraw your consent to do so by following the instructions in the "Your Rights as a Data Subject" section of this Privacy Policy, i.e. by accessing the cookie preference centre via the "Cookie Settings" button on the cookie banner. From the cookie preference centre the User can withdraw the consent given for the activation of all cookies for which it is requested by pressing the "Only technical cookies": in this way, the default settings will remain in place and you will proceed with browsing the Site without cookies or additional tracking tools other than technical ones.

RECIPIENTS AND TRANSFER OF PERSONAL DATA

Personal Data will be provided to personnel of the COMPANY employed to develop and manage the Site, who is authorised to process them in order to fulfil the previously described purposes and who is committed to confidentiality or has received a suitable legal confidentiality obligation.

Personal Data processed for the previously described purposes can be shared, used and transferred among the companies of the SACMI Group for internal accounting and administrative purposes, having registered headquarters both within and outside countries of the European Union and/or the European Economic Area (given the international reach of Sacmi). In this case, the COMPANY ensures that Data will be processed by these subjects in compliance with applicable regulations. Therefore transfers are made by means of suitable guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other suitable guarantees. More information is available by writing to the email address: privacy@sacmi.it.

These companies act as independent Controllers who process the data as strictly necessary for the aforementioned purposes; for anything not mentioned in this Privacy Policy, these subjects shall provide you with a specific policy on how they will potentially carry out the Data processing. The up-to-date list of companies of the SACMI Group can be viewed on the website of the Group https://www.sacmi.it/en-us/.

Personal Data will be supplied to third parties, called Processors, since they process Data on behalf of the COMPANY (e.g. companies managing and fulfilling sales orders, companies with whom it is necessary to interact to provide Services, such as hosting providers, providers of emailing services, providers of services enabling interaction with social networks for targeting activities or other companies tasked with technical maintenance, including maintenance of network equipment and electronic communication networks, software developers, companies providing the payment technological platform and gateway for product orders in the sector of e-payments, payment service providers and e-payment service providers). Personal Data that is strictly required to perform commercial operations or required Services may be shared with third parties with whom the COMPANIES has agreements for services that are functional to its operations (such as product delivery companies, auditing firms, people, firms or professional offices that provide support and consultancy services in the fields of administration, law, taxation, financial services and debt collection services, for the purpose of providing these Services).

Finally, Personal Data will be communicated, upon request, to the relevant authorities (e.g. in the event of frauds and/or abuses when using the Site), to financial offices or to other Public Institutions according to the provisions of current regulations.

The Data shall not be circulated ("circulation" meaning making unspecified subjects aware of the Data).

STORAGE OF PERSONAL DATA

Personal Data processed for the purposes of Supply of Services and Contractual Obligations will be stored by the COMPANY for the time that is strictly required to perform the requested Service and to properly fulfill our contractual relationship with you. The COMPANY will keep active your authentication credentials for the Site Services until you decide to unsubscribe from those Services. In any case, since this Personal Data is processed to provide Services and to allow the contractual relationship to be fulfilled, the COMPANY may store them for a longer period, in particular as necessary in order to protect the interests of the COMPANY from any liability pertaining to the Services. Data will be deleted at the end of this period.

Your requests and the Data contained within them collected by means of the Contact Us area of the Site will be kept only for the time required to allow the COMPANY to identify proper fulfillment of the request. After this period, Data that allows identification, even if indirectly, of a natural person (such as name, surname, email) will be made anonymous and will be stored, in aggregate form, for statistical purposes.

Personal Data processed for the purpose of Legal Obligations will be stored by the COMPANY for the period set out by specific legal applications or by applicable regulations.

Personal data processed for the purpose of Security will not last more than 6 months, except when it is used to ascertain responsibility for any cybercrime against the Site or third parties (e.g. to protect from legal actions by providing this data to the relevant Authorities).

Personal Data processed for the purpose of Soft Spam will be stored by the COMPANY until you will request to stop their processing by means of the link in the footer of each Soft Spam email sent.

Personal Data processed for the purpose of Marketing will be stored by the COMPANY until you withdraw your authorisation to do so. After withdrawing your authorisation, the COMPANY will no longer use your Personal Data for this purpose, but will still be able to store them, particularly when necessary to protect the interests of the COMPANY against any liability based on this processing.

Personal Data processed for the purpose of Profiling will be retained by the COMPANY until you withdraw your authorisation to do so. Once your consent has been withdrawn, the COMPANY will no longer use your Personal Data for such purposes, but may still retain them in aggregate form for statistical use. With regard to the retention period of data processed through cookies and other similar technologies, read the Cookie Policy Section and the list of cookies, including third-party cookies, accessible from the cookie banner through the "Cookie Settings" button or from the "Cookie Settings" link located in the footer of the Site.

YOUR RIGHTS AS DATA SUBJECTS

As Data subjects, you have the right, exercisable at any time, to:

• request access to your Personal Data (and/or a copy of this Personal Data) as well as to further information on the processing in progress;
• ask to correct or update your Personal Data processed by the COMPANY, when incomplete or not up to date;
• request your Personal Data to be deleted from the COMPANY databases, when you believe processing to be unnecessary or illegal;
• request that processing of your Personal Data by the COMPANY is limited when you believe that your Personal Data are not correct, necessary or illegally processed or when you opposed their processing.
• exercise your right to Data portability, i.e. obtaining a copy of Personal Data managed by the COMPANY and pertaining to you in a structured, commonly used and machine-readable format, or to request it to be transferred to a different Controller;
• oppose processing of your Personal Data, using a legal basis for your particular situation which you believe would prevent the COMPANY from processing your Personal Data;
• withdraw your authorisation for Marketing and Profiling purposes or oppose processing for Soft Spam purposes. Remember that the authorisation given for Marketing communications covers not only communications sent by means of automatic systems without operator intervention (such as emails or SMS) but also traditional contact methods such as the phone or postal service. You can always withdraw authorisation to processing also separately, for example deciding to receive these communications only by means of automatic systems such as email or SMS but not through the postal service or phone and vice versa

The COMPANY wishes to inform you that Personal Data you supply can be modified at any moment, by means of the relevant sections within the Site or by writing to the email address: privacy@sacmi.it.

Other rights can be exercised by writing to the email address: privacy@sacmi.it.

For Marketing purposes, you can ask to withdraw or cease sending the relevant commercial communications at any moment by writing to the email address privacy@sacmi.it, when communications are received by means of computer tools, follow the procedure described in the footer of the communications (by means of the “Delete” button).

You can also stop receiving Soft Spam by means of the relevant link in the footer of every received email (by means of the “Delete” button).

Please note that for Profiling purposes you can withdraw your consent also by following the instructions on how to disable cookies in the Cookie Policy Section, or by accessing the cookie preference centre through the "Cookie Settings" button on the cookie banner. From the cookie preference centre the User can withdraw the consent given for the activation of all cookies for which it is requested by pressing the "Only technical cookies": in this way, the default settings will remain in place and you will proceed with browsing the Site without cookies or additional tracking tools other than technical ones.

The COMPANY wishes to inform you that you always have the right to complain to the relevant Control Authority (e.g. the Authority of the Country of your usual residence by writing to the email address: privacy@sacmi.it which in Italy is The Italian Data Protection Authority), if you believe that treatment of your Data is contrary to actually applicable regulations pertaining to the protection of personal data.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy version 1.1 is in force as of 10/01/2022. The COMPANY reserves the right to change or update its content, partially or fully, also as a consequence of changes in the applicable regulations. If such changes result in substantial derogation from your rights under this policy, you will be reminded by prominently notifying on the page before the changes take effect. In this case, if you continue to use the services we provide, it will be deemed you agree and subject to the revised policy. Therefore the COMPANY invites you to periodically check this section to familiarise with the latest and most up to date version of the Privacy Policy in order to always be up to date with Personal Data that is collected and used by the COMPANY.

COOKIE POLICY

LIST OF SECTIONS

1. Definitions, types and regulation application
2. Types of cookies used by the Site
3. List of cookies used by the Site
4. How to manage or delete cookies

Cookies are small text files sent by the websites visited by the user and recorded on the user's computer or mobile device and retransmitted to the same websites on the subsequent visit. Cookies allow a website to remember the user's actions and preferences (such as login details, language chosen, font size, other display settings, etc.) avoiding the need to indicate them again when the user returns to the website or browses through its web pages.

Therefore, cookies are used for login, session tracking and retention of information regarding a user's activities when accessing a website. They may also contain a unique identification code that allows keeping track of the user’s navigation experience within the website for statistical or advertising purposes. Some operations could not be carried out without the use of cookies, which, in some cases, are technically necessary for the website to operate correctly.

For further information on cookies and their general functions, the User can visit the information Website allaboutcookies.org.

Cookies may be those set directly by the website or web server that the user is visiting or those of the website whose address was typed by the user and displayed in the URL window (so-called "first-party” cookies).

While browsing a website, users may also receive on their devices cookies from websites or web servers other than the one they are visiting (so-called "third-party" cookies). Third-party cookies are relevant in cases when the user visits a website and a third party, with respect to the manager of the website visited, sets a third-party cookie using said website.

There are also various types of cookies, depending on their characteristics and functions, which remain on the user’s computer for different periods of time: session cookies, which are automatically deleted when the browser is closed; persistent cookies, which remain on your device until a predetermined expiration time.

According to the current regulation applicable in Italy, the user's consent is not always required for the use of cookies. In particular, technical cookies, i.e. those used for the sole purpose of transmitting a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. Technical cookies, which do not require express consent for their use, include:

• first-party analytical cookies, used to collect information, in aggregate form, about the number of users and how they use the website;
• third-party analytical cookies, when tools are used to reduce the identification power of cookies and the third party does not cross-reference the collected information with other information that it already has;
• browsing or session cookies, used for authentication and access to a service;
• functionality cookies, which allow the user to navigate based on a number of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided.

• browsing technical or session cookies, strictly necessary for the operation of the Site or to allow the User to take advantage of the contents and Services requested;
• functionality cookies, used to activate specific functionalities of the Site and to configure the Site according to the User's choices (e.g. language) in order to improve the browsing experience. Please note that by disabling browsing, session and/or functionality cookies, the Site may be unavailable or certain Services or functions of the Site may be unavailable or not work properly and users may be forced to modify or manually enter certain information or preferences each time they visit the Site;
• analytical cookies, which allow the COMPANY to understand how the site is used by users and to track the website incoming and outgoing traffic. It is hereby specified that the COMPANY uses the Google Analytics service (provided by Google Inc. or “Google”) complying with the following conditions: measures taken to decrease the identification power of these cookies by masking parts of the IP (as described in the following link: https://support.google.com/analytics/answer/2763052?hl=en); the COMPANY has accepted the data protection amendment with Google Inc. by which the latter refers to its commitment to use such cookies exclusively for the provision of the service, to store them separately and not to “enhance” them or “cross-check” them with other information it has. Furthermore, it is reminded that an add-on can always be installed on the browser to disable Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=en).
  For more information on the way the third party, Google, may use the User information, here is the link to their Privacy Policy: https://policies.google.com/privacy?hl=en; https://policies.google.com/technologies/partner-sites?hl=en
• profiling cookies used in order to comply with the preferences set by the User through the use of the Site and to send advertising messages in line with these preferences.