Privacy Marketing

SAES Getters S.p.A., 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 & Compliance Dept. of SAES Getters by writing to it, at the address in Viale Italia 77, Lainate (MI), Italy.

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.

Data Protection Officer

SAES Getters has appointed its own Data Protection Officer, who can be contacted at the address below for information on data processing and the rights of data subjects: Mr. Sergio Amato (e-mail: dpo@saes-group.com).

Data collected and processed

SAES Getters collects and processes only data that is pertinent collected directly from the data subject at trade fairs, technical events, business meetings and networking activities, or through contact forms, digital forms or QR codes made available by the Company in such contexts, specifically: personal and contact data (including but not limited to: first name, last name, professional qualification, address, telephone number and/or e-mail address). SAES Getters therefore only collects 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 pre-contractual (e.g. 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.

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

Data will be processed, based on the data subject’s prior consent, to develop business relationships with a view to offering services and/or products similar to and/or better than those that could be purchased.
As part of this processing, it is envisaged, by way of example:

• 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 such marketing purposes, SAES Getters S.p.A. and the other companies of the SAES Group expressly identified in this notice act as joint controllers pursuant to Article 26 of Regulation (EU) 2016/679 (GDPR), having jointly determined the purposes and means of such processing. The Parties have entered into a joint controllership agreement governing their respective responsibilities under the GDPR. The essential content of that agreement is as follows:

Joint Controllers: SAES Getters S.p.A. (parent company), SAES Chemicals S.r.l., and the other SAES Group companies involved in marketing activities from time to time (the updated list is available upon request by writing to privacy@saes-group.com).

Single point of contact for data subjects: SAES Getters S.p.A., Viale Italia 77, 20020 Lainate (MI) – privacy@saes-group.com. Data subjects may exercise their rights (access, rectification, erasure, restriction, portability, objection, withdrawal of consent) against any joint controller, but SAES Getters S.p.A. is designated as the single point of contact for handling such requests.

Allocation of responsibilities: SAES Getters S.p.A. is responsible for managing the marketing automation platform (HubSpot), integrated with the Salesforce system, which constitutes the SAES Group’s single lead management and commercial communications system, preparing and updating this notice, collecting and managing marketing consent, handling data subject requests, and – in the event of a personal data breach – notifying the competent supervisory authority within 72 hours. Each joint controller is responsible for lead collection activities at its own touchpoints.

The full text of the joint controllership agreement is available upon request by writing to privacy@saes-group.com.

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 list of these data processors would be available by simply making a request to SAES Getters.

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 will also be communicated to subsidiaries and associates of the SAES Group which, with regard to marketing activities, act as joint controllers pursuant to Article 26 GDPR as described in this notice, and, for all other purposes, as independent data controllers, where necessary to implement pre-contractual measures at your request, to fulfil legal obligations and for administrative-accounting purposes (by virtue of the legitimate interest of SAES Getters).
Where consent to marketing activities has been given, the Data will also be transferred to HubSpot Inc. (25 First Street, Cambridge, MA 02141, USA) and Salesforce, Inc. (415 Mission Street, San Francisco, CA 94105, USA), data processors pursuant to Article 28 GDPR, as providers of the platform used by the Joint Controllers for lead management and commercial communications.
Transfers to third countries outside the European Economic Area are carried out on the basis of adequacy decisions currently in force, the Standard Contractual Clauses adopted by the European Commission pursuant to Article 46 GDPR, or another transfer mechanism compliant with applicable law.

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 Getters has provided suitable operating instructions, with specific regard to the purposes of processing and processing methods, as well as to the security measures adopted.

Data storage periods

The Data will be stored in a form that allows for your identification for a period of time not exceeding that necessary to achieve the processing purposes and, in particular:

• for Data collected at trade fairs, events or other commercial touchpoints that do not progress to a negotiation phase or a contractual relationship with the Controller, within 6 months of collection will be deleted from all the Company’s systems upon expiry of that period;
• where consent has been given, with regard to data processed for marketing purposes by the Joint Controllers, for up to 24 months from the consent given, extendable by further periods of 24 months where the data subject, following contacts made and continued interest shown in the products and services of the Joint Controllers – as inferred, for example, from the degree of interaction with communications received (including, by way of example: opening of e-mails, clicks on links, downloads of materials, participation in events or webinars, requests for information) – does not withdraw consent, in the manner indicated in this notice or at the foot of each communication sent.

The Data may be stored for a longer period, if a contractual relationship is created with your company: in that case, the Data will be processed according to what is described in the privacy policy that will be provided to you when establishing the contractual relationship.

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 exercise these rights by contacting us at privacy@saes-group.com or contacting the Legal & Compliance 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.

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.