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INFORMATION PURSUANT TO THE DATA PROTECTION LAW ON PROCESSING PERSONAL DATA

INFORMATION PURSUANT TO THE DATA PROTECTION LAW ON PROCESSING PERSONAL DATA

SAES Getters SpA, with registered office in Viale Italia 77, Lainate (MI), Italy, Tax Code and VAT no. 00774910152 (SAES Getters), as the data controller, shall process your personal data, including the personal data of your employees, consultants and contractors and parties involved, in any event, collected for the purpose of evaluate the opportunity to establish a business relationship and enter into an agreement  to which this information pursuant to the Data Protection Law is attached (Data) in compliance with the applicable personal data protection regulations and the confidentiality obligations pertaining to our company’s business.

Please carefully read this information 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 us at privacy@saes-group.com or contact the Legal Dept. of SAES Getters by writing to it, at the address in Viale Italia 77, Lainate (MI), Italy.

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Data Controller
The Data Controller is SAES Getters SpA, with registered office in Viale Italia 77, 20020 - Lainate (MI), Italy, Tax Code and VAT no. 00774910152.
 

Data collected and processed
SAES Getters collects and processes only data that is pertinent and does not go beyond the purposes of the processing and, thus, only the data necessary to evaluate the opportunity to establish a business relationship: we ask that you do not provide unnecessary data, which will, in any event, be immediately deleted.
We also ask that you do not communicate to SAES Getters 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.
With regard to the personal data of your employees, consultants and contractors and parties that you involve, in any event, in the execution of the Contract, we remind you to provide the data subjects with a copy of this information pursuant to the Data Protection Law at the latest at the time that the data in question is communicated to SAES Getters.
Purposes of processing and legal basis
Negotiation of the Contract
The Data shall be processed to evaluate the opportunity to establish a business relationship and enter into an agreement, including the sending of information and service communications pertaining to the execution and management of orders and the shipping of products purchased, the execution of administrative-accounting activities, the fulfilment of tax obligations and the management of any disputes.
For the same purposes, the Data may be communicated to public authorities and to third party providers of services that are accessory and necessary to the execution of the Contract (e.g. shippers and couriers to manage shipments and deliveries, banks and credit institutes to manage payments, advisors and independent professionals assigned to oversee administrative-accounting obligations). Those parties shall process the Data, depending on the case, as autonomous data controllers, or data processors by virtue of a specific written assignment granted to them by SAES Getters.
The Data may also be disseminated in execution of legal obligations, above all the obligation of transparency and publicity deriving from the regulations on listed companies, including Consob Circulars and Regulations.

The legal basis for that processing lies in the need to reply to business requests and to adopt preparatory measures to perform the eventual Contract and to fulfil the related legal obligations.

Processing the Data described above is necessary, as it is connected with and instrumental to negotiating and establishing, of the eventual contractual relationship: therefore, any refusal to provide the Data may make it impossible to negotiate a contract.

Sending of gifts, commercial communications, invitations to events, surveys and market research
The Data shall also be processed for:
- sending gifts by post (e.g. branded pens and diaries);
- sending, via email, information communications with commercial or promotional content relating to the business of SAES Getters and the other companies in the SAES Group;
- sending, via email, invitations to events organised by SAES Getters and the other companies in the SAES Group;
- sending, via email, invitations to participate in surveys and market research, whose results will be managed in anonymous, aggregated form, for the sole purpose of improving the business of SAES Getters and the SAES Group, and the products and services offered.
For the same purposes, the Data may be communicated to third party providers of accessory services (e.g. communications agencies for the drafting and sending of commercial and promotional communications, communications agencies and travel agencies assigned to organise events and any travel, statistical analysis companies to conduct surveys and market research). Those parties shall process the Data, depending on the case, as autonomous data controllers, or data processors by virtue of a specific written assignment granted to them by SAES Getters.

The legal basis for that processing lies in the legitimate interest of SAES Getters to promote and improve its business and that of the SAES Group and to develop commercial relationships, and is compatible with your position, as it is reasonable to believe that you have the same interest in remaining informed on the developments of the business and on any additional activities of SAES Getters and the SAES Group and that, by communicating your data to us, you expect to receive those communications. You may always, at any time, object to the receipt of those communications or the use of one or more of the addresses provided by following the procedure at the bottom of the communications, or by contacting us at privacy@saes-group.com, or  contacting  the Legal Dept. of SAES Getters by writing to it, at the address in Viale Italia 77, Lainate (MI), Italy.
Processing the Data described above is not necessary to negotiate the eventual Contract, and your objection, if any, to the receipt of those communications shall not hinder the relationship whit Saes Getters in any way.

Communication and transfer abroad of the Data
The Data shall also be communicated to subsidiaries and associates of the SAES Group if necessary to perform the Contract and to fulfil legal obligations, in addition to administrative-accounting purposes (thus, by virtue of the legitimate interest of SAES Getters) and, in that context, may be transferred outside the European Union.
Any transfer shall be made to the extent that is necessary to perform the Contract.

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 parties to which SAES Getters has provided suitable operating instructions, with specific regard to the security measures adopted.

Data storage periods
The Data shall be stored in a form that allows for your identification for a period of time no longer than that necessary to achieve the purposes of the processing and, in particular:
- as regard the purposes of execution of the Contract, for the entire period of the duration of the relationship and for the subsequent period necessary to fulfil the related tax, accounting and labour law obligations, and to ensure the legal protection of the rights of SAES Getters;
- as regards the purposes of sending gifts, commercial communications, invitations to events, surveys and market research, up to 18 months following the expiry of the Contract, which may be extended by subsequent periods of 18 months where the data subject accepts this by responding positively to the request that we will send  with a month’s notice on that deadline.

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 for confirmation as to whether or not personal data concerning you is being processed, access to your data and the rectification or erasure of said data or restriction of processing the Data; the right to object to such processing for one or more of the related purposes and/or in relation to one or more of the addresses provided; 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 exercise these rights by contacting us at privacy@saes-group.com or contacting the Legal Dept. of SAES Getters by writing to it, at the address in Viale Italia 77, Lainate (MI), Italy.
You may also request the complete list of recipients of the Data, at any time.
For information or clarifications on your rights, you may contact us at the same addresses.
 

Data Protection Officer
SAES Getters 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: Angela Lomuscio, Esq. - B&V Studio Legale (e-mail: a.lomuscio@bvlex.it; Tel. +39 039-2304321).
 

Additions
In the event of substantial amendments to this information pursuant to the Data Protection Law, SAES Getters shall send you an email to notify you of the changes and obtain any request to exercise the rights described above.