INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

SAES Getters S.p.A., with registered office in Viale Italia 77, Lainate (MI), Italy, Tax Code and VAT no. 00774910152 (SAES or We), as the data controller, shall process your personal data to assess your professional profile in order to evaluate a potential collaboration and/or hiring by SAES (Data) in compliance with the applicable personal data protection regulations and the confidentiality obligations which inspire the activity of our company, as well as in strict compliance with labor law legislation (with particular reference to Italian Law no. 300/1970) and relevant collective agreements.

Please carefully read this information notice pursuant to the data protection law on processing personal data.

If you have any doubts on the characteristics of the processing of the Data, you may contact the HR Dept. or the Legal & Compliance Dept., as well as the subjects and contact details indicated at the bottom of this information notice.

1. Data Controller

The Data Controller is SAES Getters S.p.A., with registered office in Viale Italia 77, 20045 – Lainate (MI), Italy, Tax Code and VAT no. 00774910152.

2. Data source

The Data was communicated to SAES directly by you when you decided to send us your curriculum through the channels made available by SAES, including, for example, the “Careers” section of the website www.saesgetters.com.

SAES may collect other data from you during any job interviews.

3. Data collection

SAES collects and processes only data that is pertinent and does not go beyond the purposes of the processing and, therefore, only the data necessary to evaluate your profile and the opportunity of establishing a working relationship with SAES: we invite you not to communicate unnecessary data which will, in any event, be immediately deleted.

We also ask that you do not communicate to SAES personal data of third parties unless this is strictly necessary to achieve the purposes of the processing: in this case, we remind you to fulfil the legal obligations regarding the protection of personal data and, in particular, to inform the third parties of the communication of their data and obtain their consent, if necessary.
The Data includes personal data and “sensitive” data.

Personal Data
Personal data includes your personal and contact details, data relating to your education and work career, as well as the roles held.

“Sensitive” Data
We define “sensitive” as data that reveals racial or ethnic origin, 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 relating to a person’s health or sex life or sexual orientation. Sensitive data corresponds to data belonging to the “particular categories” referred to in the art. 9 of Reg. (EU) no. 679/2016 (so-called GDPR).

SAES processes sensitive data such as, for example: those relating to trade union membership for the purposes of making withholdings and paying the contribution to the indicated trade union; data relating to the state of health (certificates relating to absences due to illness, maternity, accident, data relating to suitability for certain jobs and compulsory start-ups) for the purposes of verifying aptitude for certain jobs, justifying absences, insurance treatments and mandatory or contractual social security measures for accidents at work; data relating to membership of religious organizations for the purposes of permits for religious holidays.

We may collect sensitive data only to the extent that it is necessary to fulfill your obligations and exercise your and SAES’ specific rights in matters of labor law and social security and social protection, as well as for occupational health purposes and assessment of your work capacity and, in the latter case, under the responsibility of a professional subject to professional secrecy (i.e. the competent occupational doctor appointed pursuant to Italian Legislative Decree no. 81/2008, as well as by the nurse at the SAES’s infirmary, who act as data controllers upon written assignment received from SAES). The processing will take place in strict compliance with the general authorization n°1/2016 of the Garante Privacy, as subsequently extended, renewed and/or modified, as well as with the further ethical rules and guarantee measures adopted by the Garante Privacy pursuant to the articles 2-quater and 2-septies of Italian Legislative Decree no. 196/2003 and subsequent amendments.

4. Purpose of processing and related legal basis

Evaluation of your professional profile for the purposes of possible collaboration and/or hiring by SAES

Data will be processed to evaluate your professional profile for the purposes of possible collaboration and/or hiring by SAES.

This processing finds its legal basis in the need to carry out pre-contractual measures adopted at your request.

In relation to these purposes, the communication of your Data, although optional, is necessary: failure to provide it will not allow us to evaluate your profile or even contact you again to arrange a possible interview.

5. Communication and transfer abroad of the Data

With your prior consent, Data shall also be disclosed to subsidiaries and associates of the SAES Group (acting, unless otherwise provided, as independent data controllers) for the same purposes, i.e. for the purpose of evaluating whether your profile may be of interest to one of our affiliates.

This processing finds its legal basis in your express consent: in the absence of your consent, we will not be able to transmit your data to the other companies of the SAES Group and, consequently, you will be able to participate in any selection processes initiated by affiliates only by directly transmitting the Your Data to the company of your interest. Any failure to consent is optional and will not have any consequences on your relationship with SAES. Consent, where given, may be revoked at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.

Please note that some SAES Group companies are also based in countries based outside the European Union (e.g. USA), which do not benefit from an adequacy decision by the European Commission. In order to transfer your Data to our affiliates based in a third country, we ask you to express a specific consent: in the absence of your consent, we will not be able to transmit your Data to SAES Group companies established outside the European Union and, consequently, you will be able to participate in any selection processes initiated by these companies only by forwarding a specific applications and transmitting your data separately. Any failure to give us the consent will have no consequence on your relationship with SAES. We advise you to give consent only if you are interested in a job opportunity abroad.

6. Processing methods

In relation to the purposes indicated, the Data shall be processed using manual and automated means that ensure the protection of the Data by design and by default, appropriate to guarantee its security and confidentiality, with logics strictly linked to the specific purposes, by staff to which SAES has provided suitable operating instructions, with specific regard to the purposes of processing and processing methods, as well as to the security measures adopted.

7. Data storage periods

Data will be stored and processed for 12 months from receipt on the basis of the legitimate interest of the data controller in the conservation of the candidates’ curricula for the purpose of a possible re-contact within the period of the following year from the conferral of the same: this interest was assessed as prevailing in relation to the data subject’s interest to delete his/her curriculum immediately after the end of the recruitment process (it is reasonable to believe that you have an interest in being contacted again for further professional opportunities).

Data may be stored for further periods of 12 months subject to your express consent, acquired in writing (also via e-mail) before the expiry of the retention period indicated above.

If your profile is not in line with our needs, your Data will be deleted immediately.

Data may be stored for a longer period, if a contractual relationship is established with SAES: in that case, the Data will be processed according to the information notice that will be provided to you when establishing the relationship.

8. Your rights

At any time, you may exercise the other rights granted to you pursuant to the regulations on the protection of personal data in force and, in particular, the right to ask the data controller where appropriate for confirmation as to whether or not personal data concerning you is being processed, access to data and the rectification or erasure of said data or restriction of processing the Data; the right to object to such processing; the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal, the right to portability of the Data; the right to bring action before the legal authorities, or to lodge a complaint with the competent supervisory authority for protection of personal data.

You may also request the complete list of recipients of the Data, at any time.

You may exercise these rights by contacting us at privacy@saes-group.com or contacting SAES’ Legal & Compliance Dept. by writing to it, at the address in Viale Italia 77, Lainate (MI), Italy.

For information or clarifications on your rights, you may contact us at the same addresses.

9. Data Protection Officer

SAES has appointed its own Data Protection Officer, who can be contacted at the addresses below for information on data processing and the rights of data subjects: LCA Servizi S.r.l., Mr. Gianluca De Cristofaro (e-mail: dpo@saes-group.com; Tel. +39 02 7788751).

10. Additions

If substantial changes are made, SAES shall send you an e-mail to notify you of the changes and to ensure receipt of any request to exercise rights over personal data, as described above.