This page describes how the above-mentioned websites (hereinafter also referred to collectively as the “Websites” or individually as the “Website”) are managed, with specific reference to the processing of personal data relating to visitors who access them (hereinafter also referred to collectively as “Users” or individually as a “User”).

This privacy notice on the processing of personal data (hereinafter also referred to as the “Privacy Policy”) is provided by the COMPANY in its capacity as Data Controller of the personal data collected through the Websites and directly provided by Users, or otherwise generated as a result of their use of the Website. The COMPANY considers respect for Users’ privacy to be of fundamental importance and makes this Privacy Policy available to enable Users to make informed choices when the requested information is collected and when registering for sections of the Website in order to access their content and services. 

Personal Data means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”

Processing means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”

In general, all personal data (hereinafter also referred to as “Personal Data” and/or “Data”) provided by Users to the COMPANY through the Website, or collected in connection with their use of the COMPANY services (hereinafter collectively referred to as the “Services” or individually as a “Service”), as further described in the section entitled “Purposes of Processing and Personal Data Processed” of this Privacy Policy, shall be processed in accordance with the principles established by the applicable personal data protection legislation, including the principles of transparency, fairness, lawfulness, data minimization, purpose limitation, storage limitation, accuracy, integrity and confidentiality.

This Privacy Policy has been drafted in accordance with the principle of transparency, while seeking to avoid excessively legalistic language in order to make the information provided easier to understand.

The Privacy Policy is divided into individual sections (hereinafter collectively referred to as the “Sections” or individually as a “Section”), each addressing a specific subject in order to make the information as easy as possible to find and understand.

For Users’ convenience, the COMPANY Websites may contain links to third-party websites. The COMPANY does not control such websites and accepts no responsibility for them, their content or the processing of Personal Data carried out by or through them.

This Privacy Policy may be updated from time to time. Users are therefore invited to refer to it periodically.

DATA CONTROLLER AND CONTACT DETAILS

The Data Controller responsible for the processing of Personal Data is the COMPANY identified above in the heading.
Where the COMPANY has appointed a Data Protection Officer, the relevant contact details are provided in the heading.

PURPOSES OF PROCESSING AND PERSONAL DATA PROCESSED

Within the limits established by applicable law, the COMPANY shall process Data for the following purposes:

1. to carry out operations strictly connected with and necessary for managing our relationship with you, such as responding to enquiries submitted through the relevant contact forms or through any of the addresses/contact details provided on the Websites; recording and processing your technical support requests; recording and processing your applications to become a supplier to the COMPANY; where applicable, completing contracts for the sale of goods and/or services through the Website, managing and fulfilling orders; ensuring delivery of purchased products and monitoring the progress of the relevant business relationship (Provision of Services and Contractual Obligations);
2. to comply with obligations arising under laws, regulations and EU legislation, or with orders issued by authorities legally empowered to issue them and by supervisory and control bodies, as well as to fulfill accounting and tax obligations (Legal Obligations);
3. to obtain information necessary to identify anomalies, fraudulent activities and/or misuse of the Website (Security);
4. where you have purchased or previously purchased a good or service from the COMPANY, to provide commercial information by e-mail concerning the same type of product and/or service (Soft Spam);
5. to provide information about our products and/or services and to conduct promotional and commercial activities, market research and marketing activities through automated systems without human intervention (e.g. e-mail), as well as through traditional contact methods, such as postal mail; and to measure your level of satisfaction by sending questionnaires, conducting surveys or carrying out polls (Marketing);
6. to collect individual information concerning the opening of e-mail communications sent to you by means of tracking technologies embedded in the communications themselves (so-called tracking pixels). Such information may include technical message and contact identifiers, opening timestamps, IP address, user agent/mail client, device or platform information, geographical data derived from the IP address, and any technical information useful for distinguishing human interactions from openings generated by automated systems or bots. With specific reference to promotional e-mail communications, the COMPANY uses these tracking pixels to analyze email opening rates and opening times in order to measure the effectiveness of promotional campaigns and optimize their performance, as well as to understand individual recipients’ interactions, improve the relevance and attractiveness of communications, and adjust their frequency (Tracking of Promotional Emails);
7. to carry out remarketing and retargeting activities directed at Users by displaying personalized online advertisements, posts and promotional content (for example, on social media platforms such as LinkedIn or Facebook) based on Users’ previous visits to our Websites, subject to their prior consent to the use of third-party profiling cookies and tracking pixels, as provided through the relevant cookie banner displayed on the Website; to analyze Users’ use of the Website, assess the effectiveness of advertising and promotional campaigns, and compile aggregated statistics on browsing behavior and activities on the Website, with a view to improving the Website usability and better tailoring it to Users’ interests and preferences. For further details concerning the cookies and pixels used to carry out these profiling activities for remarketing and retargeting purposes, please refer to the Cookie Policy section of this Privacy Policy and to the list of cookies, including third-party cookies, accessible through the cookie banner by clicking the “Cookie Settings” button or through the “Cookie Settings” link in the Website footer (Profiling).

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

• Identification and Contact Data

  Depending on the circumstances, the COMPANY may ask you to provide information such as your first and last name, company, job title, country, contact details such as telephone number and address, and business e-mail address.
  Additional Data may be collected in the course of managing any relationship through the Website or may consist of information that Users choose to provide to the COMPANY through the Website “Contact Us” section.
  Certain sections of the Website contain free-text fields in which Users may provide the COMPANY with information that could include Personal Data. As these are free-text fields, you may choose to disclose, including inadvertently, special categories of Personal Data, such as data revealing political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data concerning health, or data concerning a person sex life or sexual orientation. The COMPANY asks you not to disclose any of these categories of Data and states that, should such special categories of Data nevertheless be provided, the COMPANY will refrain from using them.

• Personal Data Relating to Other Individuals

  As mentioned in the preceding paragraph, since the Website contains free-text fields through which any type of message may be submitted, such messages may in fact contain Personal Data relating to other individuals. Whenever you decide to share such Data with the COMPANY, you shall be considered an independent Data Controller and, in that capacity, shall assume all related legal obligations and responsibilities. Accordingly, you shall provide the COMPANY with the broadest possible indemnity against any objection, claim or request for compensation for damage arising from processing that may be brought against the COMPANY by individuals whose Personal Data you have submitted in breach of the applicable personal data protection legislation. Since, in such circumstances, the COMPANY would not collect this information directly from the data subjects concerned but indirectly through you, you warrant that such specific processing is based on the consent of those individuals or on another appropriate legal basis permitting the processing of the information in question.

• Recruitment and Personnel Selection

  If you wish to apply for a job opportunity within the Group or submit an unsolicited application for future vacancies, please refer to https://careers.sacmi.com/ (“Careers”). The Personal Data you provide for this purpose shall be processed in accordance with the specific Privacy Policy made available on that website.

• Browsing Data and Cookies

  The IT systems and software procedures used to operate the Website acquire, in the course of their normal operation, certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected by the COMPANY for the purpose of associating it with identified data subjects. However, by its very nature, it could, through processing and association with data held by third parties, make it possible to identify Users.
  This category of Data includes the IP addresses or domain names of the computers used by Users connecting to the Website; the URI (Uniform Resource Identifier) addresses of the requested resources; the time of the request; the method used to submit the request to the server; the size of the file received in response; the numerical code indicating the status of the server response (successful outcome, error, etc.); and other parameters relating to the User’s operating system and IT environment. This Data is used to monitor the proper functioning of the Website and identify anomalies and/or misuse.
  Information regarding the use of cookies is available in the Cookie Policy section, which we invite you to read further down this (under the heading COOKIE POLICY).

• Data Processed Through Interactions with Social Networks

  In addition to completing the forms available on the Website, you may request certain services and provide your Personal Data through your Facebook, Google or LinkedIn profile. In such cases, the third parties Facebook (Meta), Google and LinkedIn will automatically transmit your Personal Data to the COMPANY, and you will not need to complete any additional forms.

LEGAL BASIS FOR PROCESSING AND MANDATORY/VOLUNTARY NATURE OF PROVIDING PERSONAL DATA 

The COMPANY considers Data fields on the Website marked with an asterisk (*) to be necessary and essential for the relevant processing purpose. The legal bases relied upon by the COMPANY to process your Personal Data in accordance with the purposes indicated in the preceding section (“Purposes of Processing and Personal Data Processed”) are set out below.

The provision of Personal Data and the related processing for the purposes of Provision of Services and Contractual Obligations are strictly necessary for the performance of the requested Service and the proper performance of the contractual or pre-contractual relationship with you. Consequently, providing such Data is a necessary condition for establishing the relevant pre-contractual or contractual relationship. Failure to provide the Personal Data requested for this purpose, or the discovery that the Data provided is inaccurate, will make it impossible for the COMPANY to provide the Service and perform the contractual relationship, and shall entitle the COMPANY to refuse to provide the Service or discontinue its provision.

The provision of Personal Data and the related processing for purposes associated with Legal Obligations are necessary to enable the COMPANY to comply with its relevant legal obligations. When you provide Personal Data to the COMPANY, the COMPANY must process it in accordance with applicable laws, which may require the retention of such Data and its disclosure to the competent authorities for compliance with tax, customs or other obligations.

The provision and collection of Personal Data and the related processing for Security purposes are based on the COMPANY legitimate interest in identifying and preventing unlawful conduct and establishing liability in the event of suspected cybercrime affecting the Website or third parties. The collection of such Data is necessary for browsing the Website. Consequently, failure to provide such Data will make it impossible for the COMPANY to grant you access to the Website.

The provision of Personal Data and the related processing for Soft Spam purposes are based on the exemption provided for under Article 130 (4) of the Italian Personal Data Protection Code (Privacy Code), which permits the use of the e-mail addresses of existing customers to send promotional communications concerning products or services similar to those already purchased. Your consent is therefore not required for this purpose. You may stop receiving these communications and object to the processing at any time, without any consequences other than no longer receiving further commercial communications from the COMPANY, by using the specific link provided at the bottom of each e-mail sent for this purpose or by following the instructions in the “Your Rights as Data Subjects” section of this Privacy Policy.

The provision of Personal Data and the related processing for Marketing purposes, including Tracking of Promotional Emails, are based on your explicit consent, obtained through a specific affirmative action (e.g. clicking a dedicated checkbox). You are never obliged to give such consent to the COMPANY and, if you choose to do so, you may withdraw it at any time without any consequences other than no longer receiving further commercial communications from the COMPANY. You may also withdraw your consent separately for the specific purpose of Tracking of Promotional Emails by following the instructions in the “Your Rights as Data Subjects” section of this Privacy Policy.

The provision of Personal Data and the related processing for Profiling purposes are based on your explicit consent, given either by clicking the relevant button in the cookie banner or by accessing the cookie preference center through the “Cookie Settings” button in the cookie banner. You are never obliged to give such consent to the COMPANY and, if you choose to do so, you may withdraw it at any time without any consequences other than no longer being able to benefit from the personalization of the COMPANY commercial communications. You may withdraw your consent for this purpose by following the instructions in the “Your Rights as Data Subjects” section of this Privacy Policy or by accessing the cookie preference center through the “Cookie Settings” button in the cookie banner. From the cookie preference center, Users may withdraw their consent to the activation of all cookies for which consent is required at any time by clicking the “Technical Cookies Only” button. In this case, the default settings will remain in place, and the Website may be browsed without cookies or tracking tools other than strictly technical ones.
 

RECIPIENTS AND TRANSFER OF PERSONAL DATA

Personal Data will be made available to the COMPANY personnel responsible for developing and managing the Website, who are authorized to process such Data for the purposes indicated above and are bound by confidentiality obligations or are subject to an appropriate statutory duty of confidentiality.
 
Personal Data processed for the purposes indicated above may be shared, used and transferred within the companies belonging to the SACMI Group for internal administrative and accounting purposes.
Where such companies act as independent Data Controllers and process Data solely to the extent strictly necessary for the purposes mentioned above, they shall provide you with a specific privacy notice concerning any processing they carry out, to the extent that such processing is not covered by this Privacy Policy. The updated list of SACMI Group companies is available on the Group’s official website at www.sacmi.it.
 
Personal Data will be disclosed to third parties appointed as Data Processors where they process Data on behalf of the COMPANY. These may include, for example, companies responsible for managing and fulfilling sales orders; service providers whose involvement is necessary to deliver the Services, such as hosting providers; providers of e-mail delivery platforms; providers of services enabling interaction with social networks for targeting activities; parties responsible for technical maintenance, including maintenance of network equipment and electronic communications networks; software developers; providers of the technological platform and payment gateway for product orders processed through e-payment systems; and payment service providers involved in e-payment activities. Personal Data strictly necessary to complete commercial transactions or provide the requested Services may be shared with third parties with whom the COMPANY has contractual relationships for services supporting its business activities. These may include carriers responsible for product delivery, auditing firms, and individuals, companies or professional firms providing administrative, legal, tax, financial or debt recovery assistance and consultancy in connection with the provision of the Services.
 
Finally, Personal Data will be disclosed, where required, to the competent authorities (for example, in the event of fraudulent activities and/or misuse of the Website), tax authorities or other public administrations, in accordance with applicable laws.
The Data is not intended for publication or dissemination.
Given SACMI international presence, some of your Personal Data may be shared with recipients located in countries outside the European Union or the European Economic Area. The COMPANY states that such transfers will be carried out using appropriate safeguards, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, together with the adoption of supplementary legal, technical and organizational measures, or other safeguards intended to ensure an adequate level of protection for Personal Data in accordance with the relevant European provisions.
 
Further information is available by writing to the email address privacy@sacmi.it.

RETENTION OF PERSONAL DATA

Personal Data processed for the purposes of Provision of Services and Contractual Obligations shall be retained by the COMPANY for the period strictly necessary to provide the requested Service and properly perform the contractual relationship with you. In any event, since such Personal Data is processed to provide the Services and perform the contractual relationship, the COMPANY may retain it for a longer period where necessary, particularly to protect the COMPANY interests against potential liabilities relating to the Services. At the end of that period, the Data will be deleted.
 
Your requests, and the Data contained therein, collected through the Website “Contact Us” section will be retained only for as long as necessary to enable the COMPANY to determine that the relevant request has been properly resolved. At the end of that period, any Data that directly or indirectly identifies a natural person, such as first name, last name and e-mail address, will be anonymized and retained in aggregated form for statistical purposes.
 
Personal Data processed for the purpose of Legal Obligations shall be retained by the COMPANY for the period required by the relevant legal obligations or applicable legislation.
 
Personal Data processed for Security purposes shall not be retained for more than six months, except where such Data is used to establish liability in connection with suspected cybercrime affecting the Website or third parties, for example to protect the COMPANY interests in legal proceedings by disclosing the relevant Data to the competent authorities.
 
Personal Data processed for Soft Spam purposes shall be retained by the COMPANY until you object to its processing, including through the link provided at the bottom of the relevant e-mails.
 
Personal Data processed for Marketing and Tracking of Promotional Emails purposes shall be retained by the COMPANY until you withdraw your consent. Once the relevant consent has been withdrawn, including where withdrawal relates solely to Tracking of Promotional Emails, the COMPANY will no longer use your Personal Data for those purposes. However, it may retain such Data where necessary to protect its rights and interests against potential liabilities arising from such processing.
 
Personal Data processed for Profiling purposes shall be retained by the COMPANY until you withdraw your consent. Once consent has been withdrawn, the COMPANY will no longer use your Personal Data for these purposes but may retain it in aggregated form for statistical purposes. For information on the retention periods applicable to Data processed through cookies and similar technologies, please refer to the Cookie Policy section and the list of cookies, including third-party cookies, accessible through the cookie banner by clicking the “Cookie Settings” button or through the “Cookie Settings” link in the Website footer.

YOUR RIGHTS AS DATA SUBJECTS

As data subjects whose Personal Data is being processed, you have the right, which may be exercised at any time subject to the limits established by applicable law, to:

• request access to your Personal Data and/or a copy of such Data, as well as further information about the processing activities being carried out;
• request the rectification or updating of your Personal Data processed by the COMPANY if it is incomplete or outdated;
• request the erasure of your Personal Data from the COMPANY databases if you consider that the processing is unnecessary or unlawful;
• request the restriction of the processing of your Personal Data by the COMPANY if you consider that your Personal Data is inaccurate, unnecessary or being processed unlawfully, or if you have objected to its processing;
• exercise your right to data portability, namely to obtain a copy of the Personal Data concerning you that you have provided to the COMPANY in a structured, commonly used and machine-readable format, or to request that it be transmitted to another Data Controller;
• object to the processing of your Personal Data on grounds relating to your particular situation, where you consider that such grounds should prevent the COMPANY from processing your Personal Data.

Withdrawal of Consent and Objection to Processing

You may withdraw your consent or object to processing by contacting the following e-mail address privacy@sacmi.it. Please note that consent given for the sending of Marketing communications covers not only communications sent through automated systems without human intervention (e.g. e-mail), but also traditional contact methods, such as telephone and postal mail. You may always withdraw your consent to processing separately for individual communication channels, for example by choosing to receive such communications only through automated systems such as e-mail. 

Furthermore, notably:

• for Marketing and Soft Spam purposes, you may respectively withdraw your consent or object to the processing and stop receiving the relevant commercial communications at any time. For communications received electronically, you may do so by following the procedure indicated at the bottom of the relevant communication, using the “Unsubscribe” key;
• for Tracking of Promotional Emails purposes, you may withdraw your consent and stop tracking at any time by following the procedure indicated at the bottom of the relevant communication, using the “Tracking Preferences” key. Please also note that tracking pixels are generally downloaded into a User e-mail when the automatic image-download function is enabled. The COMPANY therefore informs you that you may configure your e-mail application to display messages exclusively in plain-text format. In this way, the tracking pixel, like any other image, will not be downloaded and will therefore be unable to track your behavior as a recipient of the communication.
• For Profiling purposes, you may withdraw your consent by following the instructions for disabling cookies provided in the Cookie Policy section or by accessing the cookie preference center through the “Cookie Settings” button in the cookie banner. From the cookie preference center, Users may withdraw their consent to the activation of all cookies for which consent is required by clicking the “Technical Cookies Only” button. In this case, the default settings will remain in place, and the Website may be browsed without cookies or tracking tools other than strictly technical ones.

AMENDMENTS TO THIS PRIVACY POLICY

This Privacy Policy, version 1.2, shall enter into force on xx/xx/2026. The COMPANY reserves the right to amend or update this Privacy Policy, in whole or in part, including as a result of changes to the applicable legislation. The COMPANY may inform you of such changes as soon as they are introduced. The changes shall become binding as soon as they are published on the Website. The COMPANY therefore invites you to visit this section regularly to familiarize with the latest version of this Privacy Policy and remain informed about the Personal Data collected and how the COMPANY uses it.

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.