INFORMATION ON THE PROCESSING OF PERSONAL DATA
Pursuant to and in accordance with Articles 13-14 of EU Reg. 2016/679.
Dear Data Subject,
transparency and fairness towards those who interact with us are a fundamental part of our activity. In this section you will find information on the manner in which Sirman S.p.A.("Sirman") processes the personal data collected, complying with legal obligations in accordance with the provisions of EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data ("Regulation"), as well as Legislative Decree 196/2003 as subsequently amended ("Privacy Code")
For specific information on the processing of your personal data using cookies, please also review our Cookie Policy, available at the link: Cookie Policy
Data controller
The Data Controller of your personal data is Sirman S.p.A. , which is responsible for its law and correct use. You can contact Sirman S.p.A. for any information or request on the processing of your data by writing to dataprivacy@sirman.com or to the following address: Privacy contact form
Sirman S.p.A.
Sede: Viale dell’Industria 9, Curtarolo(PD)
Contatti: +39 0499698666
e-mail: dataprivacy@sirman.com
1. PRIVACY POLICY
Purpose of data collection
Your personal data are collected and processed for the purposes listed below along with the relevant legal basis:
| Purpose | Processed data | Legal Basis | Retention Time |
|---|---|---|---|
| A) Management of customers, including potential customers and contractual relationship | Tax code and other personal identification numbers; name, address or other personal identification elements; contact data (telephone number, e-mail, etc.) | Execution of contract or pre-contractual measures (art. 6, co. 1, lett. b) of the Regulations) | In case of contractual relationship: 10 years starting from the end of the relationship. If no contractual relationship is reached: 3 years starting from the collection of the data. |
| B) Promotional activities of products and/or services Sirmano | Name, address or other elements of personal identification; contact data (telephone number, e-mail, etc.) | Sirman's legitimate interest in proposing commercial offers to the interested party in relation to Sirman products and/or services similar to those already purchased by the interested party (art. 6, co. 1, lett. f) of the Regulations; art. 130, paragraph 4 of the Privacy Code) | 5 years from the last interaction of the interested party with Sirman in relation to products/services marketed by Sirman. |
| C) Fulfilment of legal obligations on Sirman, of an administrative, fiscal and accounting nature, related to the conduct of its business | Tax code and other personal identification numbers; name, address or other personal identification elements; contact data (telephone number, e-mail, etc.); or any additional data legitimately required by the competent authority | Fulfilment of legal obligations (art. 6, co. 1, lett. c) of the Regulations) | To be determined according to the applicable legal obligation. |
| D) Sending of informative and/or advertising material also by telephone or newsletter | Tax code and other personal identification numbers; name, address or other personal identification elements; economic, commercial activities; contact data (telephone number, e-mail, etc.) | Consent (art. 6, co. 1, lett. a) of the Regulations) | 5 years from the last interaction of the data subject with Sirman in relation to products/services marketed by Sirman. |
| E) Profiling of the data subject | Tax code and other personal identification numbers; name, address or other personal identification elements; economic, commercial activities; contact data (telephone number, e-mail, etc.) | Consent (art. 6, co. 1, lett. a) of the Regulations) | 5 years from the last interaction of the data subject with Sirman in relation to products/services marketed by Sirman. |
| F) Survey of satisfaction with the quality of Sirman's products/services | Name, address or other personal identification; contact details (telephone number, e-mail, etc.) | Sirman's legitimate interest in improving the management of the sale of Sirman's products and/or provision of services (Art. 6, co. 1(f) of the Regulations) | 5 years from the data subject's last interaction with Sirman in relation to products/services marketed by Sirman. |
| G) Search for personnel to be placed in the company | Tax identification number and other personal identification numbers; name, address or other personal identification elements; Job (current, previous occupation, resume,etc.); Education and culture; Professional quality certificates; E-mail address; Province of residence; Declared profession; Topics of interest; Sex m/f; Job | Sirman's legitimate interest in assessing the suitability of candidates to work with the company (Art. 6, co. 1, lett. f) of the Regulations) | 4 years starting from the receipt of the application. |
2 Recipient categories
Your data may be sent to the categories of recipients listed below for the purposes and on the relevant legal bases set out in the table above:
Consultants and freelancers in individual or associated form
Banks and credit institutions
Companies and enterprises (companies operating in the field of logistics)
Competent authorities where required by applicable regulations.
As the case may be, the above recipients may be duly appointed as authorized entities for processing under Article 29 of the Regulations or as data controllers under Article 28 of the Regulations.
Notwithstanding the above, your personal data will not be disseminated.
3)Mandatory or optional nature of data collection.
The provision of your personal data for the purposes:
of customer management and fulfillment of legal obligations is necessary for the pursuit of these purposes. Therefore, failure to provide such personal data will result in the inability to conclude the contract and manage contractual relationships;
of promotional activities, sub B), is optional. Therefore, failure to provide such personal data will result in the impossibility for Sirman to send you promotional communications, as described above, and to carry out qualitative analysis. In addition, please note that you may object at any time to the processing of your personal data for the purposes of promotional activities sub B) of Sirman products and/or services as described above by contacting Sirman at the contact details made available in this notice. Any opposition by the data subject will in no way affect the possibility of concluding the contract and the management of contractual relations;
of marketing is optional. Therefore, failure to provide such personal data will make it impossible for Sirman to send you informative and/or advertising material for marketing purposes
of profiling is optional. Therefore, failure to provide such personal data will make it impossible for Sirman to use your personal data to assess, analyze or predict certain aspects related to you;
of satisfaction survey on the quality of Sirman's products/services is optional. Therefore, failure to provide such personal data will result in Sirman's inability to contact you to survey your degree of satisfaction;
of personnel recruitment is optional. Therefore, failure to provide such personal data will result in Sirman's inability to assess your suitability to work with the company and to carry out any pre-contractual measures.
4 Modalities of processing
The processing of your personal data is carried out by means of the operations indicated in Article 4 No. 2) of the Regulations, namely: collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, deletion or destruction. Your personal data are subject to both paper and electronic and/or automated processing (however suitable to ensure the security and confidentiality of the data).
Your personal data referred to in the above table will be retained in accordance with the principle of proportionality and until the purposes for which they were processed have been fulfilled.
In any case, personal data whose retention is not necessary in relation to the purposes for which they were processed, and in any case upon expiration of the retention period referred to above, shall be deleted.
5 Transfer of personal data abroad
In the performance of its activities, and in any case within the limits of the processing purposes set out in this policy, Sirman will process your data mainly within the territory of the European Union. In case of transfer outside the territory of the European Union, Sirman will take all necessary measures to ensure that your data enjoy an adequate level of protection based on the mechanisms provided by the Regulation in case of transfer outside the European Union, such as adequacy decision, binding corporate rules, standard data protection clauses.
6 Rights of the data subject and how to exercise them
In your capacity as a data subject, you have the following rights in relation to your personal data and the related processing carried out by Sirman (Articles 15-22 of the Regulations):
- Access them and request a copy;
- Request its rectification;
- Request its deletion;
- Obtain the restriction of processing;
- Object to processing based on Sirman's legitimate interest;
- Withdraw your consent; In this case, the right to object to the processing of data for marketing purposes carried out through automated means also extends to the processing of data carried out through non-automated means, unless you only partially object to the processing;
- Receive in a structured, commonly used and machine-readable format, and transmit without hindrance such data to another data controller, where technically feasible and where the legal requirements are met.
The data subject also has the right to lodge a complaint with the Garante per la protezione dei dati personali, by registered letter with advice of receipt addressed to Garante per la protezione dei dati personali, Piazza Venezia, 11 00187, Rome; e-mail to: protocollo@gpdp.it, or protocollo@pec.gpdp.it; and/or fax to: 06/69677.3785.
You may exercise your rights at any time by sending a registered letter with advice of receipt to the writer at Viale dell'Industria 9, Curtarolo (PD) or an e-mail to dataprivacy@sirman.com oppure al seguente indirizzo:Privacy contact form
Our organisation adheres to the EU-US Data Privacy Framework and transfers personal data to the US in accordance with the agreement.
Sirman S.p.A.
Last update 31/10/2022