This web page describes the management modes of the aforementioned websites (hereinafter referred to as the "websites" and/or individually as the "website") with specific reference to the handling of personal data by the visitors who visit the website (hereinafter referred to as the “users” or individually as the “user”).

The following notice regarding the processing of personal data (hereinafter referred to as the "Data Protection Notice") is issued by the COMPANY as the processing controller of personal data which is collected on the websites and provided directly by the users or generated after website use. The COMPANY values the privacy of the users, which is why it provides this Data Protection Notice in order to allow users to make an informed decision with regard to the collection of requested information and logging in to portions of the website in order to use them.

Personal data refers to “all information that relates to an identified or identifiable natural person (the “data subject” in the following); a natural person is considered identifiable if they are directly or indirectly able to be identified by assignment of an identifier like a name, ID name, location data, an online ID, or according to one or more special characteristics that express information about the physical, physiological, genetic, psychical, economic, cultural, or social identity of this natural person”.

Processing refers to “any process completed with or without the help of automation or any sequence of processes in the context of personal data such as collection, organisation, arrangement, storage, adjustment, or alteration, exporting, querying, use, disclosure via transfer, distribution, or another form of provision, comparison, or connection, limitation, deletion, or destruction”.

As a general rule, all personal data (hereinafter referred to as the "personal data" and/or the "data"), which the user provides to the COMPANY via the website or which is collected in conjunction with the use of the COMPANY’s services (hereinafter referred to collectively as the "services" and/or individually as the "service"), as defined in more detail in the Section Purpose of processing personal data in this Data Protection Notice, is processed in accordance with the principles of data privacy recognised under applicable data protection legislation, e.g. transparency, correctness, legality, data minimisation, restriction of the purposes and retention, accuracy, integrity and confidentiality.

This Data Protection Notice was compiled on the basis of the principle of transparency. At the same time, an effort has been made to avoid the use of legal language in order to make the information easier to understand.

The Data Protection Notice is divided into individual sections (hereinafter referred to collectively as the "sections" and/or individually as the "section"), each covering a specific topic. This subdivision is intended to make the information quick and easy to read through or look up.

The COMPANY’s websites may contain links to third party websites in order to make them easier to use: The COMPANY has no control over these websites, nor is it responsible for their contents and/or for the data processing they practice or implement.

This Data Protection Notice is subject to change at any time. We therefore recommend that you refer to it regularly.

PURPOSE OF PROCESSING AND PERSONAL DATA PROCESSED

Within the applicable legal limitations, data is processed by the COMPANY for the following purposes:
 

1. For performing activities closely involved in the management of users’ interactions with us, e.g. managing responses to inquiries submitted with the contact forms; registering and processing your requests for technical customer support; registering and processing your applications as COMPANY suppliers; managing access to restricted portions of the website (such as the one for customers or suppliers) and offering to help users recover their login data; concluding purchase contracts for goods and/or services, managing and processing orders; scheduling the delivery of purchased products and monitoring interactions with users (provision of services);
2. enabling the COMPANY to properly perform their contractual obligations (contractual obligations) to the user and vice versa;
3. fulfilling the legally stipulated obligations, terms and community regulations or standards on the part of legal authorities and supervisory bodies, as well as performing required accounting and tax duties (legal obligations);
4. searching for information required in order to identify anomalies, fraudulent activities and/or abuses in conjunction with the use of the website (security);
5. conducting commercial information campaigns via email for the same type of products and/or services (soft spam) if you have utilised a service on the website or purchased a product or service from the COMPANY;
6. conducting information campaigns for our products and/or services, as well as advertising or commercial campaigns, market and marketing research using automated systems without operators (e.g. email), but also using conventional channels (e.g. regular mail), conducting activities to determine your level of satisfaction using questionnaires, conducting a survey or interviews (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).

The personal data for processing via the website is comprised of the categories listed below.
 

• 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 decide to communicate (even inadvertently) special categories of Personal Data, such as Data that disclose political opinions, religious or philosophical beliefs or trade union membership , as well as genetic Data, biometric Data to uniquely identify a natural person, Data pertaining to health, 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 any case you decide to share this data with the COMPANY, you will be considered as independent Controller and as such you will take on all obligations and legal responsibilities pertaining to this. Therefore, in this regards, the User provides the broadest indemnity against any claim, request, refund or damage due to processing, etc. that may come to the COMPANY from people whose Personal Data have been forwarded by you in breach of applicable personal data protection regulations. Since, in this case, the COMPANY does not collect the information directly from the Data Subjects (but from you indirectly), you ensure that this specific processing is based on the authorisation of these Data Subjects or on another suitable legal basis that authorises processing of this 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: 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.

• Navigation data and cookies

  In the course of normal operation, the IT systems and available software processes for operating the website gather certain personal data which is transmitted in conjunction with the use of the online communication protocols. This is not information collected by the COMPANY in order to associate it with identified data subjects – rather, it is information which, due to its nature, could potentially be used to identify the users by means of extrapolation and association with data in the possession of third parties.
  
  This data category includes IP addresses or names in the domain of the computers which the users use to connect to the website, the addresses for identifying the requested resources by URI (Uniform Resource Identifier), the time of the request, the methods used to make the request to the server, the size of the file received in response, the numerical code which indicates the type of reply from the server (successful, error, etc.) and other parameters pertaining to the operating system and the IT environment of the user.
  
  This data is only used for anonymous statistical information on the utilisation of the website, for checking to ensure correct operation and to search for anomalies and/or abuses.
  
  The information on the utilisation of cookies is provided in the Cookie Policy, which you should read on the next 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 BASES FOR PROCESSING, OBLIGATORY/OPTIONAL DISCLOSURE OF PERSONAL DATA AND CONSEQUENCES IN CASE OF NO RESPONSE

If a request for information is marked with an asterisk (*) on the page, this indicates that the COMPANY considers this information as mandatory and absolutely necessary for the following purposes. Described below are the legal bases used by the COMPANY for the processing of your personal data for the purposes indicated in the preceding section ("Purpose of processing and personal data processed").

The disclosure of the personal data and the relevant processing for the purposes of service provision and contractual obligations is closely associated with the performance of the desired service and the proper implementation of our contractual relationship with you. As such, the disclosure of this personal data constitutes a required condition for establishing the contractual relationship. If you fail to disclose the personal data required for this purpose or provide demonstrably unsuitable data, the COMPANY will not be able to perform the service and the contractual relationship. In such cases, the COMPANY is entitled to refuse or discontinue performance of the service or contract relationship.

The disclosure of the personal data and the associated processing for the purposes indicated under legal requirements is required by the COMPANY for compliance with the relevant legal requirements. If you provide personal data to the COMPANY, they must process the data in accordance with the applicable laws. These laws may require that the data be stored and transmitted to the relevant authorities for compliance with tax, customs or other legal requirements.

The disclosure of the personal data and the associated processing for security-related purposes is based on the COMPANY’s interest in identifying and preventing illegal activities and ensuring responsibility for any hypothetical cybercrime against the website or third parties. As such, this is a required condition for navigating the website. The COMPANY can therefore decline access to the website if the personal data is not disclosed for these purposes.

The disclosure of the personal data and the associated processing for soft spam purposes is based on the COMPANY’s interest in emailing you marketing announcements regarding products and services similar to those which you have previously purchased and/or which you use through the website. By using the special link included at the bottom of each message you receive, you can unsubscribe from these emails without any consequences whatsoever (other than no longer receiving these sorts of communications from 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.

The disclosure of the personal data and the associated utilisation of the data for marketing purposes is based on your express consent, as indicated by a specific signal of affirmation on your part (e.g. clicking the relevant checkbox/field). You are never required to give the COMPANY this consent, and, if you do, you can revoke it at any time without consequence (other than not receiving any marketing communications from the COMPANY). As per the information in the “Your rights as a data subject” section of this Data Protection Notice, you can revoke your consent for this purpose.

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 by pressing the "Reject all" button.


RETENTION OF PERSONAL DATA

Personal data processed for service provision and contractual obligations is stored by the COMPANY for as long as absolutely necessary to perform the requested service and properly fulfil our contractual obligations to you. The COMPANY retains your access data for the services on the website until you log off from these services. Since this personal data is made available for the purpose of service provision and contract performance, the COMPANY can retain it for a longer period of time if the interests of the COMPANY with regard to their responsibility for these processing activities must be protected. At the end of this time period, the data is deleted.

Inquiries submitted by you through the contact page of the website and the data contained therein are only stored for the period of time required in order for the COMPANY to properly process the inquiry. At the end of this time period, the data which directly or indirectly identifies a physical person (e.g. given name, surname, email) is anonymised and retained as compiled data for statistical purposes.

Personal data processed for legal requirements is retained by the COMPANY for the period designated in the specific legal provisions or the applicable standard.

Personal data processed for security purposes is retained for no longer than 6 months, unless it is used for determining responsibility for hypothetical cybercrimes against the website or third parties (e.g. for defence in court by providing this data to the relevant authorities).

Personal data processed for soft spam purposes is retained by the company until you will request to stop their processing  using the link at the bottom of every soft spam email you receive.

Personal data processed for marketing purposes is retained by the COMPANY until such time as you revoke your consent. After you revoke your consent, the COMPANY will no longer use your personal data for these purposes but will still retain it if the interests of the COMPANY with regard to the responsibility for these processing activities must be protected.

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.


Handling of business cards

When you give out or exchange business cards, you provide us your personal data, e.g. phone number, email address. We will only use this information for staying in contact with you. We will also send you additional information on our services. If you do not purchase any of our products or services, we will delete your contact information after 5 years.

You have the right to information, deletion or correction at all times.


Information on other data processing procedures

Specific information on the application procedure

Affected data:                                    Application information
Processing purpose:                          Implementation of application procedure
Categories of recipients:                   Public bodies in case of overriding legal provisions.
External service providers or other contractors.
Other external bodies, provided that the data subject has given consent or that disclosure is permissible based on overriding interest.
Transfers to non-EU countries:        In conjunction with contract performance, order processors from outside of the European Union may be used.
Data retention period:                        Application data is usually deleted within six months of the decision notice, unless you have agreed to have the data stored for a longer period.


Specific information on the processing of customer data/potential customer data

Affected data:                                      Data provided for the purposes of contract performance; if applicable, additional data for processing based on your explicit consent.
Processing purpose:                          Contract performance.
Categories of recipients:                    Public bodies in case of overriding legal provisions
External service providers or other contractors.
Other external bodies, provided that the data subject has given consent or that disclosure is permissible based on overriding interest.
Transfers to non-EU countries:        In conjunction with contract performance, order processors from outside of the European Union may be used.
Data retention period:                        The data retention period depends on the legal retention requirements and is usually 10 years.


Specific information on the processing of employee data

Affected data:                                      Data provided for the purposes of contract performance; if applicable, additional data for processing based on your explicit consent.
Processing purpose:                          Contract performance.
Categories of recipients:                    Public bodies in case of overriding legal provisions.
External service providers or other contractors.
Other external bodies, provided that the data subject has given consent or that disclosure is permissible based on overriding interest.
Transfers to non-EU countries:        In conjunction with contract performance, order processors from outside of the European Union may be used.
Data retention period:                        The data retention period depends on the legal retention requirements and is usually 10 years.


Specific information on the processing of supplier data

Affected data:                                      Data provided for the purposes of contract performance; if applicable, additional data for processing based on your explicit consent.
Processing purpose:                          Contract performance.
Categories of recipients:                    Public bodies in case of overriding legal provisions.
External service providers or other contractors.
Other external bodies, provided that the data subject has given consent or that disclosure is permissible based on overriding interest.
Transfers to non-EU countries:        In conjunction with contract performance, order processors from outside of the European Union may be used.
Data retention period:                        The data retention period depends on the legal retention requirements and is usually 10 years.


YOUR RIGHTS AS A DATA SUBJECT

As a data subject, at all times, you have the following rights:
 

1. the right to request access your personal data (and/or a copy thereof) and other information on the ongoing processing of said data;
2. the right to request that the COMPANY correct or update your personal data if it is incomplete or not up-to-date;
3. the right to request that the COMPANY delete your personal data if it is no longer required for processing or legal compliance;
4. the right request that the COMPANY restrict the processing of your personal data if you believe that your data is being handled incorrectly, illegally or despite your objection and/or unnecessarily;
5. the right to data transmission, i.e. the right to have the COMPANY provide you with a copy of your personal data in a structured format which can be read both normally and on automated devices or to have the data transmitted to another data controller;
6. the right to enter an objection, regarding your specific situation, against the processing of your personal data on a legal basis, prohibiting the COMPANY from processing your personal data;
7. the right to revoke your consent for marketing purposes or object to the use of your personal data for soft spam purposes. We also wish to note that the consent to receive marketing notifications does not only pertain to messages sent by automated systems without an operator (e.g. email or SMS) but also those sent by conventional means of contact (e.g. phone or mail). Consent for processing can always be revoked, even separately, if you decide, for example, that you only wish to receive such communications through automated systems (e.g. via email or SMS instead of by mail or by phone and vice versa).

 
See here to contact us by email or post [datenschutz@sama-online.com]. You also have the right to file a complaint with data protection supervisory authorities.


CHANGES TO THIS DATA PROTECTION NOTICE

Version 1.0 of this Data Protection Notice is effective as of 10.01.2022. The COMPANY reserves the right to modify its content in part or in whole based on changes to the applicable regulations or to simply update it. The COMPANY can notify you of these changes as soon as they are introduced or when they become binding upon publication on the website. The COMPANY encourages you to visit this section regularly to stay informed regarding the latest and most up-to-date version of the Data Protection Notice, as well as the collection and utilisation of personal data 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

a) Definitions, types and regulation application
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.

On the other hand, for profiling cookies, i.e. those aimed at creating profiles referred to users and used to send advertising messages in line with the preferences expressed by the latter when browsing the web, the user's prior consent is required. User consent is also required for third-party analytical cookies when tools are not used to reduce the identification power of cookies and the third party cross-references the collected information with other information that it already has.

b) Types of cookies used by the Site
The Site uses the following types of cookies:

• 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=i); 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).
  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=it; https://policies.google.com/technologies/partner-sites?hl=it
• 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.

With regards to third-party cookies, third parties typically act as autonomous data controllers with respect to the cookies they provide (and use the data they collect for their purposes and according to their own terms) or operate as Data Processors (i.e. they process Personal Data on behalf of the COMPANY). For further information on how these third parties may use your information, please refer to their personal data processing policies (privacy policies and consent forms), which are provided, where possible, for each cookie in the list accessible from the cookie banner or from the "Cookie settings" link in the footer of the Site.

c) List of cookies used by the Site
The cookies used by the Site can be viewed by the User by accessing, at any time, 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.

Social button and widgets

It is also possible to find social buttons/widgets on our Websites or specific "buttons" that depict the social network icons (for example, Facebook, Twitter, YouTube, Google Plus, etc.). These "buttons" allow the Users who are navigating the Websites to reach and interact with social networks directly with one "click". By clicking on Social buttons/widgets, the social network obtains data relating to the User visit. Aside from these cases where the User can share his or her own navigation data spontaneously with preselected social networks with one click, the COMPANY does not share any User navigation information or data obtained through the Websites with social networks that are accessible through Social buttons/widgets. For further information, refer to the privacy policies of the specific social networks that may be accessed through our Websites using the social buttons.

Facebook
https://it-it.facebook.com/about/privacy

Twitter
https://twitter.com/privacy

Linkedin
http://www.linkedin.com/legal/privacy-policy

You Tube e Google Plus
https://www.google.it/intl/it/policies/privacy/

d) How to manage or delete cookies
Most Internet browsers are initially set to accept cookies automatically. The User may modify these settings in order to block cookies or be warned every time cookies are sent to the navigation device. Furthermore, at the end of each navigation session, the User may delete the cookies that were collected from his or her device. There are various methods to manage cookies. Please refer to the specific instructions for the browser in use. If the User uses various devices to visit and access Websites (for example, computer, smartphone, tablet, etc.), then the User is responsible for ensuring that each browser of each device is set to reflect his or her expressed preferences regarding cookies. For more information on managing cookies, please refer to the page http://www.allaboutcookies.org/manage-cookies/

Select the following links to access specific instructions for managing cookies through some of the main navigation programs.

Microsoft Windows Explorer

http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Google Chrome

https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies

Mozilla Firefox

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Apple Safari

http://www.apple.com/legal/privacy/it/cookies/

If the User does not use any of the aforementioned browsers then the User may, in any case, select "cookies" in the relevant section of the guide to see where the cookies folder is located.

You can also manage your choices about third-party cookies by means of online platforms such as AdChoice.