PRIVACY POLICY AND CONSENT FOR PROCESSING OF PERSONAL DATA
PURSUANT TO AND BY EFFECT OF ARTICLE 13 OF LEGISLATIVE DECREE NO. 196 DATED 30th JUNE 2003 AND ARTICLES 18 AND 14 OF REGULATION (EU) 2016/679 DATED 27th APRIL 2016

In compliance with the provisions of Article13 of Legislative Decree no. 196 dated 30th June 2003, as well as of articles 13 and 14 of Regulation (EU) 2016/679 dated 27th April 2016, we inform you that the Company Saimex Srl has updated its Privacy Policy.
The above mentioned regulations require that the persons concerned shall be informed about which personal data is processed and its associated processing. In any case, the data processing must be carried out with fairness, legality and transparency, safeguarding your confidentiality and your rights. Therefore, we hereby provide you with the following information:

  1. The nature of the data processed
    We process personal and fiscal data (related to the undertaking and/or company and to its members and administrators), as well as the economic data and your ordinary and certified email addresses.
    The data processed by us is provided directly by you or is from sources which are available to the public (for ex. Chamber of Commerce), by the forms on the website or directly by email.
  2. Purpose and duration of the Processing
    The Personal Data is processed for the following purposes:
    A– For the execution of the current pre-contractual and contractual relationship with you and the fulfillment of administrative, legal and tax obligations, while enabling an effective management of financial, commercial and administrative relations, in order to exercise or enforce our legal rights. Furthermore Your personal data may be used for internal purposes, such as statistical indicators, customer satisfaction and effective business relationship management with customers and suppliers.
    B– To send commercial and promotional information, direct selling, product market researches, services and events (altogether defined as marketing activities).
    The data will be processed throughout the duration of the relationship and also later, for the fulfillment t of legal obligations and for the purposes indicated above and, however, not more than 10 years after the cessation of relationship for the purposes referred to in point A and for no more than two years for the purposes referred to in point B.
  3. How data is processed
    Each processing is carried out in compliance with provisions referred to in Article 5 and 6 of Regulation (EU) and Articles 11, 31 et seq. of the Privacy Code and through the implementation of minimum security measures set forth.
    Data processing is done through the use of tools and procedures that are suitable to guarantee its security and confidentiality, and can be carried out either by means of paper media or electronic instruments by persons that have been specifically authorised to that.
    The data processing should include:
    a) the computer and paper-based input or update in our database;
    b) the conservative storage of documents received by physical or electronic means;
    c) the automatic processing by means of electronic computers;
    d) the manual processing using paper archives.
    The data processing for marketing activities shall occur through conventional means (paper mail) and through the use of means of distance communication, such as phone, electronic mail and messaging.
  4. Scope of communication and dissemination
    The data processing takes place related to the management of ordinary business relationships and the consequent fulfillment of administrative, legal and tax obligations, as well as to exercise or enforce our legal rights, apart from above-mentioned marketing activities.
    Furthermore, your data may be processed for exclusively internal purposes and shall not be disclosed to unidentified entities in any form whatsoever, including by making them available or having access thereto.
    Your data shall be processed inside our company by the following categories of authorized persons:
    • Administration Office;
    • Commercial Office;
    • Accounting Office.
    However, we may disclose your personal data to one or more specific entities within the European Union, as follows:
    • to subjects entrusted by our Company with the task to process your data and, in particular, to Office administration staff, Purchasing department staff, Accounting office staff and Staff Secretary;
  • to subjects who have the right to access your data under provisions of the law, regulation or Community law within the limits set by these rules;
    • to subjects who need to access the data for the relationship between you and us within necessary limits to perform their auxiliary functions (for example credit institutes, freight forwarders);
    • to professionals appointed by us to carry out activities relating to the contractual relationship between you and us (for example lawyers, accountants);
    • to our consultants or employees, to the extent necessary for carrying out their duties in our company after a letter of assignment that imposes a duty of confidentiality and safety.

Your data shall be kept at the company’s headquarters or at the office of professionals or external consultants, as indicated by the aforementioned lines.

  1. Provision of personal data
    A – As for the purposes specified under point 2 A, without prejudice to your right to allow processing of your personal data, insofar as we are obligated to know this data, in order to comply with the obligations provided for in by our pre-contractual and contractual relationship, as well as by laws, regulations and Community law, that it is to say by instructions given by the competent authority, any communication or wrong communication of one piece of compulsory information results in:
    the impossibility of establishing and continuing the contractual relationship to the extent that this data is required for it;
    • a possible mismatch between the processing results and obligations imposed by tax legislation, administrative rules and labour legislation, upon which it is directed.
    B – As for the purposes specified under point 2 B, the provision of the relevant personal data shall be optional.
  2. Your rights
    You can enforce the rights as provided for by articles 7 et seq. of the Privacy Code and by articles 15 et seq. of the Regulation (EU), by contacting the Data Controller and, in particular:

You have the right to obtain information and guidance on:
• the confirmation of the existence of your personal data processed;
• the origin of personal data;
• purposes and handling methods;
• the envisaged period for which the personal data will be stored;
• the existence of automated decision-making (including profiling) and the logic applied when processing by electronic means;
the subjects or categories of subjects to whom the data may be communicated;
• the subjects or categories of subjects to whom the data may be communicated or that may become aware of them, as appointed representative in the State territory, or as managers or appointees;
• the personal details of the holder, the persons in charge, the designated representatives and nominees, where appointed;
• Where personal data is transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 of Regulation (EU) relating to the transfer.

You have the right to:
• obtain the update, rectification or, when interested, integration of data;
• obtain the deletion, limitation, transformation into anonymous form or blocking of data processed unlawfully, including data whose storage is not required in relation to the purposes for which the data was collected or subsequently processed;
• a request for data portability, in accordance with Article 20 of Regulation (EU);
• request a copy of the personal data undergoing processing;
• to withdraw your consent for personal data processing, subject to the provisions set out under Article 5, letter A of this Privacy Policy and subject to withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
• submit a complaint to the Italian Data Protection Authority for the protection of your rights. You have the right to oppose, in whole or in part:
• for legitimate reasons the processing of data, even though it is relevant to the purpose of the collection;
• the processing of your own personal data for the purpose of sending advertising or direct marketing material or to conduct market research or commercial communication surveys.

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  1. The holder of personal data processing
    The holder of your personal data processing is Saimex Srl., with headquarters in Seregno (MB) Italy, Via Santino De Nova n.34/E, in the person of its legal representative,– telephone no. +39 0362 1572572, email address: info@saimex.it 

The document has been updated on 27th May 2018 in order to be compliant with the relevant regulatory provisions.

Document subject to periodic changes.
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