TREATMENT OF PERSONAL DATA ON THE WEBSITES
www.sacmiindia.com - www.sacmi.in
of SACMI ENGINEERING (INDIA) PVT. LTD.
with legal address in Vashi - Navi Mumbai 400705 - 3, Ratnam Square 3rd Floor Tel: +91-22-27848072,022/27848073, Email: email@example.com (following, also "the COMPANY")
This page includes the descriptions of the management methods for the aforementioned Websites (hereafter referred to as “Sites” and/or individually as “Site”) with specific reference to the treatment of personal data by visitors who view the Websites (hereafter referred to as "Users" or "User" when referring to a single individual).
Personal data is “any information pertaining to a physical person that is or can be identified (“subject”); physical persons are identifiable if they can be identified directly or indirectly, with particular reference to identifying elements such as name, identification number, location data, online ID or one or more elements that are characteristics of their physical, physiological, genetic, psychological, economical, cultural or social identity”.
Treatment means “any operation or set of operations performed with or without the help of automated processes and applied to personal data or set of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by means of transmission, dissemination or any other type of distribution, comparison or interconnection, limitation, deletion and destruction”.
The sites of the COMPANY may contain links to websites of third parties, to be useful to the User: the COMPANY does not control nor is responsible in any way for these sites, their content and/or the treatment of Personal Data that these sites apply and/or perform.
The data treatment holder is the COMPANY as defined in the header above.
If the COMPANY has assigned a Data Protection Officer (DPO), contact data are found in the header.
The Data will be subject to treatment by the COMPANY, according to the limits set out by the applicable legislation, for the following purposes:
- allow performing operations that are strictly associated with and instrumental in managing our relationship with you, such as answering queries received via our contact modules; recording and processing your requests for technical support; recording and processing your applications as suppliers of the COMPANY; allowing access to reserved sections of the Site (such as those of the Customer Area or the Supplier Area) and provide support to recover login data for your account; ensuring the finalisation of sales agreements for goods and/or services, managing and fulfilling orders; ensuring delivery of purchased products and checking the trend of relationships (Supply of services);
- allow proper performance of contractual obligations taken by the COMPANY toward the User and vice versa (Contractual obligations);
- allowing fulfillment of the obligations set out by laws, regulations and European Union directives, or provisions required by authorities set out by the law and monitoring and control entities, as well as fulfilling accounting and taxation requirements (Legal obligations);
- finding information required to identify unusual activities, frauds and/or abuses when using the Site (Security);
- performing commercial information activities via e-mail, if you are using a service on the Site or are proceeding or have proceeded to purchase goods or services from the COMPANY, by means of emails about the same type of products and/or services (Soft Spam);
- providing information about our products and/or services as well as promotional and commercial activities, market research and marketing by means of automatic systems without the input of an operator (e.g. emails), as well as through traditional contact methods, such as by post; measuring your satisfaction by means of questionnaires, surveys or focus groups (Marketing).
Personal Data treated by means of the Site fall within the following categories.
- 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) particular categories of Personal Data, such as Data that disclose political opinions, religious or philosophical beliefs or membership of unions, as well as genetic Data, biometric Data to uniquely identify a physical 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 treatment of entered data belonging to the particular categories listed above, or to treat 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 treatment holder 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 treatment, 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 involved subjects (but from you indirectly), you ensure that this specific treatment is based on the authorisation of these subject or on another suitable legal basis that authorises treatment of this information.
- Searching and hiring personnel
- Navigation data and cookies
Information technology systems and software procedures used to operate the Site acquire some Personal Data during their normal operation, whose transmission is implicit in using Internet communication protocols. This information is not collected by the COMPANY to be associated with identified subjects, but it may, by its very nature, allow identifying users through processing or association with Data held by third parties.
This category of Data includes IP addresses or domain names of computers used by Users connecting with the Site, the URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to send the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply given by the server (successful, error, etc.) and other parameters about the operating system and software environment of the User.
This Data is used only for anonymous statistical information about use of the Site, to check its proper operation and to identify any unusual activity and/or abuses.
Data preceded by an asterisk (*) within the Site are considered by the COMPANY to be necessary and indispensable to fulfil the relevant purposes. The following are the legal bases used by the COMPANY to treat your Personal Data, according to the purposes listed under the previous Section (“Purpose of treatment and treated Personal Data”).
Provision of Personal Data and their treatment for the purposes associated with the Supply of Services and other Contractual obligations is strictly functional to perform the required service and to properly perform the contractual relationship signed with you, respectively; therefore they are a necessary condition to establish the contractual relationship. Consequently, failure to provide Personal Data required for this purpose, or the provision of wrong data, will make it impossible for the COMPANY to perform the Service and the contractual relationship and will entitle the COMPANY to refuse to perform them or to stop their performance.
The provision of Personal Data and their treatment for the purposes of the Legal Obligations is required by the COMPANY to meet the relevant legal obligations. When you provide Personal Data to the COMPANY, it needs to process it in compliance with applicable laws that may include storing them or communicating them to pertinent authorities for compliance with taxation, customs or other obligations.
Provision of Personal Data and their treatment for the purposes of Security, is based on the commitment of the COMPANY to identify and prevent illegal behaviours and to ascertain responsibility in the event of any cybercrime against the Site or third parties, therefore they are a necessary condition to navigate the Site. Consequently, failure to provide Personal Data required for this purpose will make it impossible for the COMPANY to provide access to the Site.
The provision of Personal Data and relevant treatment for the purposes of Soft Spam is based on the interest of the COMPANY to send you marketing communications via email pertaining to similar products and services to those you have already purchased and/or used by means of the Site. You can stop receiving these communications, without any consequence (other than no longer being able to receive similar communications by the COMPANY) by means of the specific link in the footer of each of the emails that you receive for this purpose.
Personal Data will be provided to personnel of the COMPANY employed to develop and manage the Site, who is authorised to treat them in order to fulfil the previously described purposes and who is committed to confidentiality or has received a suitable legal confidentiality obligation.
Personal Data treated for the previously described purposes can be shared, used and transferred among the companies of the SACMI Group for internal accounting and administrative purposes, having registered headquarters both within and outside countries of the European Union and/or the European Economic Area (given the international reach of Sacmi). In this case, the COMPANY ensures that Data will be treated by these subjects in compliance with applicable regulations. Therefore transfers are made by means of suitable guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other suitable guarantees. More information is available by writing to the email address: firstname.lastname@example.org.
Personal Data will be supplied to third parties, called Controllers of treatment, since they treat Data on behalf of the COMPANY (e.g. companies managing and fulfilling sales orders, companies with whom it is necessary to interact to provide Services, such as hosting providers, providers of emailing services or other companies tasked with technical maintenance, including maintenance of network equipment and electronic communication networks, software developers, companies providing the payment technological platform and gateway for product orders in the sector of e-payments, payment service providers and e-payment service providers). Personal Data that is strictly required to perform commercial operations or required Services may be shared with third parties with whom the COMPANIES has agreements for services that are functional to its operations (such as product delivery companies, auditing firms, people, firms or professional offices that provide support and consultancy services in the fields of administration, law, taxation, financial services and debt collection services, for the purpose of providing these Services).
Finally, Personal Data will be communicated, upon request, to the relevant authorities (e.g. in the event of frauds and/or abuses when using the Site), to financial offices or to other Public Institutions according to the provisions of current regulations.
The Data shall not be circulated ("circulation" meaning making unspecified subjects aware of the Data).
Personal Data treated for the purposes of Supply of Services and Contractual Obligations will be stored by the COMPANY for the time that is strictly required to perform the requested Service and to properly fulfill our contractual relationship with you. The COMPANY will keep active your authentication credentials for the Site Services until you decide to unsubscribe from those Services. In any case, since this Personal Data is treated to provide Services and to allow the contractual relationship to be fulfilled, the COMPANY may store them for a longer period, in particular as necessary in order to protect the interests of the COMPANY from any liability pertaining to the Services. Data will be deleted at the end of this period.
Your requests and the Data contained within them collected by means of the Contact Us area of the Site will be kept only for the time required to allow the COMPANY to identify proper fulfillment of the request. After this period, Data that allows identification, even if indirectly, of a physical person (such as name, surname, email) will be made anonymous and will be stored, in aggregate form, for statistical purposes.
Personal Data treated for the purpose of Legal Obligations will be stored by the COMPANY for the period set out by specific legal applications or by applicable regulations.
Personal data treated for the purpose of Security will not last more than 6 months, except when it is used to ascertain responsibility for any cybercrime against the Site or third parties (e.g. to protect from legal actions by providing this data to the relevant Authorities).
Personal Data treated for the purpose of Soft Spam will be stored by the COMPANY until you will request to stop their treatment by means of the link in the footer of each Soft Spam email sent.
Personal Data treated for the purpose of Marketing will be stored by the COMPANY until you withdraw your authorisation to do so. After withdrawing your authorisation, the COMPANY will no longer use your Personal Data for this purpose, but will still be able to store them, particularly when necessary to protect the interests of the COMPANY against any liability based on this treatment.
Since you are the concerned subjects of the Data treatment, you have the right, at any time, to:
- request access to your Personal Data (and/or a copy of this Personal Data) as well as to further information on the treatment in progress;
- ask to correct or update your Personal Data treated by the COMPANY, when incomplete or not up to date;
- request your Personal Data to be deleted from the COMPANY databases, when you believe treatment to be unnecessary or illegal;
- request that treatment of your Personal Data by the COMPANY is limited when you believe that your Personal Data are not correct, necessary or illegally treated or when you opposed their treatment.
- exercise your right to Data portability, i.e. obtaining a copy of Personal Data managed by the COMPANY and pertaining to you in a structured, commonly used and machine-readable format, or to request it to be transferred to a different Holder;
- oppose treatment of your Personal Data, using a legal basis for your particular situation which you believe would prevent the COMPANY from treating your Personal Data;
- withdraw your authorisation for Marketing purposes or oppose treatment for Soft Spam purposes. Remember that the authorisation given for Marketing communications covers not only communications sent by means of automatic systems without operator intervention (such as emails or SMS) but also traditional contact methods such as the phone or postal service. You can always withdraw authorisation to treatment also separately, for example deciding to receive these communications only by means of automatic systems such as email or SMS but not through the postal service or phone and vice versa.
The COMPANY wishes to inform you that Personal Data you supply can be modified at any moment, by means of the relevant sections within the Site or by writing to the email address: email@example.com.
Other rights can be exercised by writing to the email address: firstname.lastname@example.org.
For Marketing purposes, you can ask to withdraw or cease sending the relevant commercial communications at any moment by writing to the email address: email@example.com; when communications are received by means of computer tools, follow the procedure described in the footer of the communications (by means of the “Delete” button).
You can also stop receiving Soft Spam by means of the relevant link in the footer of every received email (by means of the “Delete” button).
The COMPANY wishes to inform you that you always have the right to complain to the relevant Control Authority (e.g. the Authority of the Country of your usual residence, in Italy being the Ombudsman for Personal Data Protection), if you believe that treatment of your Data is contrary to actually applicable regulations pertaining to the protection of personal data.
What are cookies?
For further information on cookies and their general functions, visit the information Website, allaboutcookies.org
Why do we use them?
Cookies have several functions. They help website managers understand how users use the actual website, they allow the user to navigate the various website pages more efficiently, and they help to remember expressed preferences, etc. Cookies also provide information of a commercial nature and, for example, this information helps the website manager to understand which products interest the User the most, as well as which of these products is the most important.
What type of cookies do we use?
Cookies that may be used on our Website fall within the categories illustrated as follows.
Temporary and permanent cookies
Cookies may expire at the end of a navigation session that is established as the time period between the user opening a window and closing it, or they may be kept for a longer period of time.
Temporary cookies – They are deleted and disappear from the device when the User leaves the website and closes the program used for navigation; they expire when the browser session ends and so they are not kept for a long period of time.
Permanent cookies – They remain on the device, even after the User has left the website, until they are deleted or until they reach their potential expiry date set by the website manager.
First party and third party cookies
There are "first party" and "third party" cookies based on the Website or the domain/webserver.
First party cookies are cookies that are directly set by the Websites visited by the User or the Website when the address is typed in by the User (displayed in the URL window).
Third party cookies are cookies set by a website that is different to the one visited by the User. 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 cookie using said website, i.e. cookies of sites or web servers other than the Site, belonging to third parties.
With regards to these cookies, these third parties generally are holders of data treatment independent of the COMPANY (and use the data they collect for their purposes and according to their own terms) or can operate as treatment controllers for the COMPANY (i.e. they treat Personal Data on behalf of the COMPANY).
Cookie Technology for performance and functionality
Based on the purposes pursued, cookies used on Websites can differ and fall within three further categories, illustrated as follows.
Strictly necessary cookies, so called “technical” cookies, are essential to navigate the Sites you are visiting and to use some functions. Some online services required by the User (e.g. accessing reserved areas) may not be supplied without these cookies. This type of cookie on our Websites does not collect any personal information from the User that may identify the User in any way simply through the cookies.
Performance cookies collect anonymous information and this allows us to understand how Users interact with our Websites. For example, they tell us which websites are visited more often, the time spent on the website, potential error messages, etc. The performance cookies that we use only collect information anonymously and on an aggregate basis. They are used to improve the running of the websites and User navigation experience. For information on how to cancel or manage performance cookies, please refer to the relevant section on this page.
Functionality cookies: they allow our Websites to record User choices (such as the size of the text viewed, language preference, country location, etc.) and provide functionality based on User choices. In some cases, cookies may also be used to provide online service (e.g. offering a live chat service) or to avoid offering services or messages that the User has already refused in the past. Our Websites set this type of cookie on the navigation device used by the User in a fully anonymous manner and you shall not be able to identify it. For information on how to cancel or manage performance cookies, please refer to the relevant section on this page. Please be reminded that, if the User deletes this type of cookie then selected preferences and/or settings shall not be memorised for future visits.
Third party statistical/analytics cookies without identification purposes: use of Google Analytics with IP masking and no cross-checking with other data held by the third party.
The COMPANY uses the services of Google Analytics provided by Google Inc. to manage Sites with IP masking and no cross-checking with other data held by the third party, i.e. Google Inc.).Google Analytics issues cookies that generate information about the use of the Site by the User. These cookies can be likened, in compliance with the current regulation, to technical cookies, since they meet the following conditions: measures taken to decrease their identification power by masking parts of the IP (as described in this link: https://support.google.com/analytics/answer/2763052?hl=i); the third party is committed to use these cookies only to provide the service, to store them separately and not to “enhance” them or “cross-check” them with other information it has. In this regards, the COMPANY has not linked Google Analytics to any other additional service by Google and no marketing or data sharing option has been activated with Google. Furthermore, an add-on can be installed on the browser to disable Google Analytics (https://tools.google.com/dlpage/gaoptout).
For comprehensive information, we have provided a table below that indicates the name, treatment holder, purpose, duration and method for each cookie where their use may be disabled:
Social buttons 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.
YouTube and Google Plus
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
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.