Contact Policy

PRIVACY POLICY
Processing of personal data relative to Clients, Suppliers and Businesses Partners

Pursuant to Articles 13 and 14 of EU Regulation 679/2016, this Privacy Policy concerns the processing of the personal data of the employees or consultants, of current or prospective clients, suppliers, business partners and professional contacts.
Sampsistemi S.r.l. considers the right to privacy and the protection of your personal data to be of utmost importance.
Sampsistemi S.r.l. protects users’ personal data in compliance with applicable law and its Data Protection Policies.

1. DATA CONTROLLER
Sampingranaggi S.r.l.
Via Saliceto 15,
40100 Bentivoglio (BO)
Italy
marketing@sampspa.com

2. PURPOSES OF THE PROCESSING AND TYPES OF DATA PROCESSED

a) To fulfil contractual or pre-contractual obligations
(e.g. in the case of quotes).
Sampsistemi S.r.l. collects personal data (email address, name, surname, job title, address, city and country and, if necessary, business contact numbers and payment details) of the employees or collaborators of current or prospective clients, suppliers, business partners or professional contacts.

i. Legal basis of the processing

Execution of a contract or execution of pre-contractual measures adopted at the request of the data subject.

ii. Data storage period

Sampsistemi S.r.l. stores your personal data only for the time strictly necessary. We adopt specific policies and procedures for the management and storage of information in order to ensure that your personal data is deleted after a reasonable period of time based on the following storage criteria:
• We store your personal data as long as a business relationship is maintained (pre-contractual phase, contract or purchase order);
• We store your personal data for the time necessary to comply with our legal, fiscal, accounting and regulatory obligations, including the provisions of Article 2946 of the Italian Civil Code.

b) For marketing purposes

The majority of the personal data collected and used by Sampsistemi S.r.l. for marketing purposes refers to professional contacts of employees or collaborators of our clients and other companies with whom a commercial relationship is maintained or is in a pre-contractual stage. We may also obtain contact details acquired from:
• business cards collected at events, meetings or conferences;
• publicly accessible sources, including content published online, to establish an initial contact with a certain person employed by a client or another company.

Sampsistemi S.r.l sends marketing emails in order to develop or maintain a commercial relationship, to notify recipients of new initiatives and to sponsor products and/or services, in compliance with data protection law and applicable marketing legislation.

Like most companies, (Company) uses CRM (Customer Relationship Management) technology to manage and monitor its marketing initiatives.

i. Legal basis of the processing
Consent

ii. Data storage period
36 months
Before the data storage period has elapsed, you will receive an email requesting that you renew your consent.

3) To follow up your contact requests

Data provided directly by users may be used to respond to contact requests.

i. Legal basis of the processing

Execution of a contract or execution of pre-contractual measures adopted at the request of the data subject.

ii. Data storage period

Except in the case that the user has not given their consent for the use of personal data for marketing purposes, once the execution period of the contact request has elapsed the personal data will be destroyed, deleted or made anonymous in line with the technical procedures for the deletion and backup of personal data.

3. COMPULSORY DATA TRANSFER

Except for certain information required by law, your decision to provide personal data to Sampsistemi S.r.l. is voluntary. As such, there will be no negative repercussions in the event that you choose to withhold your personal data. However, if you opt to withhold certain information we will be unable to fulfil some or all of the purposes indicated in this privacy policy and you may be unable to use certain tools or systems that require the use of such data.
If you provide Sampsistemi S.r.l. with the personal data of a third party (such as a representative, prospective customer or sub-contractor), you are responsible for ensuring that said third party is aware of the contents of this privacy policy and, where necessary, has given their consent for the disclosure of the information to Sampsistemi S.r.l.

4. RECIPIENTS OF THE DATA

Your personal data may be disclosed to parties operating as Data Controllers (including, but not limited to, Supervisory and Control Bodies and any public body entitled to request such data) or processed, on behalf of the Company, by appointed Data Processors in receipt of appropriate operating instructions.
In particular, your data may be disclosed to the following categories:
a) companies belonging to the Maccaferri Group who act as Data Processors or perform accounting or administrative activities on behalf of the same (e.g. purposes relating to the performance of internal organisational, administrative, financial and accounting activities);
b) natural and/or legal persons who provide services of various kinds on behalf of the Company (e.g. website management companies, system outsourcers, internet connectivity companies, etc.). Such parties may also act as Data Processors;
c) parties and/or public and private bodies to whom data may be transferred in order to comply with or fulfil specific obligations provided for by law, regulations or EU legislation. Such parties operate as Independent Data Controllers or Data Processors.

5. AUTHORISED DATA PROCESSORS

Data may be processed by employees or collaborators of the Company or external parties appointed as Data Processors who carry out technical and organisational website services on behalf of the Company.

6. TRANSFER OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN UNION

Data may be transferred to countries outside the European Union and, in particular, to:
a) Extra-EU countries whose data protection levels have been deemed adequate by the European Commission pursuant to Article 45 of “GDPR”
or
b) Extra-EU countries other than those described above which have “signed the Standard Contractual Clauses adopted/approved by the European Commission pursuant to Article 46, paragraph 2, letters (c) and (d)”
A copy of the aforementioned guarantees may be obtained by sending a written request to the Data Controller according to the methods described in the section “Rights of the Data Subject – Complaints to the Supervisory Authorities”.

7. RIGHTS OF THE DATA SUBJECT – COMPLAINTS TO THE SUPERVISORY AUTHORITIES
In certain circumstances and according to certain conditions, and except in the case of the exceptions established by applicable law, you are entitled to:

  • Request access to your personal data: this right entitles you to know if we possess your personal data and, if so, to obtain information about the data we hold and a copy of said data.
  • Request the correction of your personal data: this right allows you to correct your personal data in the case of inaccuracies or omissions.
  • Oppose the processing of your personal data: this right authorises you to request that your personal data is no longer processed.
  • Request the deletion of your personal data: this right entitles you to request the deletion of your personal data, including in the case that the data is no longer necessary to the intended purposes.
  • Request the limitation of the processing of your personal data: this right entitles you to request that your data is only processed in certain circumstances and with your express consent.
  • Request the portability of your personal data: this right entitles you to receive a copy (in a structured and commonly used electronic format) of your personal data, or request the transmission of such data to another Data Controller.

With regard to deceased data subjects, pursuant to Article 2 terdecies of Italian Legislative Decree no. 101/2018, the aforementioned rights may be exercised by anyone with a personal interest or otherwise acting in the interests of the data subject as the agent of the same, or for family reasons worthy of protection.

You may exercise the right to opt out of marketing communications using the opt-out mechanisms included in our email communications. Alternatively, you can write to DPO@maccaferri.it to notify us of your opt-out preferences.
In the event that you choose to withdraw your consent for the processing of your personal data for marketing purposes, your data will be removed from our CRM (Customer Relationship Management) database. This right does not affect the right to process any personal data received prior to the withdrawal of consent, or the right to continue with the partial processing in accordance with an alternative legal basis to that of consent.
In the event that, despite our commitment and efforts to protect your personal data, you believe that your rights to the protection of your personal data have been infringed, please contact DPO@maccaferri.it and we will attempt to resolve any query. This does not affect your right to make a direct complaint to the competent Supervisory Authorities or to take legal action before a competent court (in the country in which you live or work or the country in which you believe your rights have been infringed).