Privacy Policy

Privacy notice for Customers and Suppliers and for their respective contacts pursuant to Articles 13/14 and Article 21 of the General Data Protection Regulation (hereinafter GDPR) of Target Metalli S.r.l. (hereinafter referred to as “SIGLA” or “we”)

Who is the Data Controller? Whom can I contact?

Name and address of the Data Controller:

Target Metalli S.r.l., Via Vallarsa 13 – 20121 Milan

E-Mail: [email protected]

Website: targetmetalli.com

What categories of data are processed by COMPANY NAME and for what purposes?

We process the following categories of data of customers and suppliers: company name, legal form, registered office, legal representatives and contact persons (first name, last name, email address, and telephone/fax numbers), and billing data.

These data are stored and processed where necessary

• for the preparation and execution of a contract (including customer relationship management);
• for billing purposes;

for marketing, promotional, commercial, and advertising purposes, such as sending material and advertisements related to the products and/or services marketed by COMPANY NAME, sending promotional emails and SMS, and sending newsletters or ebooks, provided that you have not objected to the use of your data for commercial purposes.

On what legal basis do we process data?

The legal basis for the processing of personal data is the General Data Protection Regulation (GDPR) and, in particular:

• Article 6 (1) (b) of the GDPR, which allows processing for the purposes of entering into and executing contracts;
• Article 6 (1) (f) of the GDPR, which allows processing for the protection of our legitimate interests, provided that there is no overriding interest of the data subject that would prevent such processing.

We also process personal data based on the consent provided by the data subjects. Data subjects may withdraw their consent at any time. This action will not have retroactive effect. However, withdrawal of consent will prevent us from further processing the data subject’s personal data. Other regulations that allow data processing (Art. 6 (1) (b) and Art. 6 (1) (f) of the GDPR) will remain unchanged.

With whom do we share the provided data? Where are personal data stored?

We share personally identifiable information with recipients within the TARGET METALLI S.R.L. group who need to know such information in the performance of their duties and obligations, and with third parties appointed to process data on our behalf, as service providers, who are themselves bound by contracts required by data protection law, or to whom TARGET METALLI S.R.L. must provide information to fulfill its legal obligations. We also share personally identifiable information with TARGET METALLI S.R.L.’s business partners who provide products and services sold by TARGET METALLI S.R.L.

Personal data are stored on TARGET METALLI S.R.L. servers within the European Union.

Are data transferred to recipients outside the European Union or the European Economic Area (i.e., so-called third countries) or to international organizations?

The personal data of customers/suppliers will be transferred to third countries only if necessary for the execution of the contract.

How long are the data provided to TARGET METALLI S.R.L. kept?

We retain personal data only for the time necessary to achieve the purposes described above and then delete them; in any case, they will be deleted in accordance with the retention periods required by law.

What are the rights of the Data Subject? Where can I file a complaint?

Article 15 of the GDPR provides the right to be informed about the data we hold regarding the subject.

If any information is incorrect or outdated, the subject has the right to request its correction at any time, pursuant to Article 16 of the GDPR.

Additionally, under Article 17 of the GDPR, the subject may have the right to request the deletion of their personal data, unless we have overriding rights or powers to continue the processing.

Finally, under Article 18 of the GDPR, the subject has the right to restrict/limit the processing of their personal data.

To obtain information regarding the data we hold, for their correction, deletion, or to restrict/limit processing, contact the address provided in point 1.

You may request to receive the information you provided to us in a structured, commonly used, and machine-readable format, or request the transmission of such information to third parties.

Additionally, the data subject has the right to object to processing under Article 21 of the GDPR. See the information box below.

To contact the competent supervisory authority,

The Italian Data Protection Authority, write to:

Garante Privacy

Piazza di Monte Citorio n. 121 00186 ROME

Tel.: (+39) 06.696771

Email: [email protected]

Is sharing or updating data mandatory?

Providing your data is a free choice. However, we are authorized to process the personal data of subjects with whom we have contractual or pre-contractual relationships, in order to prepare and execute contracts and for billing purposes.

Are the personal data provided used for automated decision-making processes?

In principle, we do not use customer/supplier data for automated decision-making processes as described in Article 22 of the GDPR.

Are the data used for profiling/score assignment?

No

Right to object pursuant to Article 21 GDPR:

1. Right to object based on a particular situation:

Pursuant to Article 21 (1) of the GDPR, the data subject has the right to object at any time to the processing of their personal data on grounds relating to their particular situation. In case of objection, we will stop processing the personal data, provided that there are no compelling and legitimate legal grounds for us to continue processing which override the interests of the subject (e.g., to assert our rights or defend ourselves in legal proceedings).

1. Right to object to processing for commercial purposes:

Pursuant to Article 21 (2) of the GDPR, the subject also has the right to object to processing for direct commercial purposes. In this case, we will stop using the received personal information for promotional purposes.

An objection can be sent in any form to the contact details indicated in paragraph 1.

Privacy Policy – Online privacy

The protection of personal information is of primary importance to us. We will use the identifying data that the user chooses to provide us, or that has been collected during the use of the website, only as described in this Online Privacy Policy and in accordance with the applicable data protection regulations.

This Online Privacy Notice specifies the type, purpose, and scope of the collection, processing, and use of personal information that users choose to provide us while browsing and/or that may be transmitted through the TARGET METALLI S.R.L. website (targetmetalli.com) (hereinafter referred to as "our site"). Please note that it is not mandatory to provide any personal information in order to use our site.

Users who provide personal information for collection, storage, or use by TARGET METALLI S.R.L. have the right to be informed about the methods of storage, use, and transfer of information, and have the right to access the information and control its use, pursuant to Legislative Decree No. 196 of June 30, 2003 (Personal Data Protection Code) and (from May 25, 2018) the GDPR (General Data Protection Regulation), hereinafter “the Law.” The term Personal Data means any information relating to identifiable individuals, even indirectly, by reference to any other information, including a personal identification number, such as name, email address, telephone number, and similar data. For more information about the right of access, rectification, and deletion of any personal data we hold, the exercise of such rights, and our contact details, please refer to section 6 and section 7.

As required by the Law, the Data Controller is the Legal Representative of TARGET METALLI S.R.L., Via Vallarsa 13 – 20121 Milan (hereinafter “SIGLA”). For more information about TARGET METALLI S.R.L., see section 7.

The competent data protection authority is the Italian Data Protection Authority www.garanteprivacy.it. If the user believes that the processing of their data by us does not comply with this Online Privacy Policy or with current laws and regulations, they may file a complaint with the Italian Data Protection Authority. For completeness, in certain circumstances, as provided by Article 157 of Legislative Decree No. 196/2003 (not subject to the normal management of the site), TARGET METALLI S.R.L. will be required to transmit information and updates to the competent authorities for the verification of personal data processing. In such cases, the response is mandatory under penalty of administrative sanction.

Section 1

Information collected during the use of our site and use of such information

1. a) Contact forms

Our site offers the opportunity to provide us with personal information by filling out a contact form, for example, to request a quote or information about our products, or to express interest in a job offer from TARGET METALLI S.R.L. The information provided may include name, address, email address and telephone number, age, and date of birth.

We use the information to:

provide the user with the information, products, and services requested; personalize the user’s experience on our site and ensure that the site is displayed in the best possible way for the user and their device.

Data transferred via the Internet (e.g., through the transmission of emails) are subject to security risks. Therefore, it is not possible to guarantee complete protection against third-party access to transferred data.

1. b) Log information

While browsing the site, standard log information and details of user behavior patterns are collected, such as:

date and time of visit; browser type and version; operating system; Internet Protocol (IP) address; full clickstream and related URLs to and from our site, e.g., websites visited and products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks, and mouse-overs), and methods used to leave the page; types of plug-ins and version for system administration.

We have a legitimate interest in processing this data in anonymous form, as it allows us to improve and develop our site. We are in no way interested in identifying users who visit our site. The data collected in this way will not be associated in any way with any identifying information of the user from any other source.

1. c) Newsletter and commercial offers

Our site offers users the possibility to download and/or subscribe to receive commercial offers sent by us or our newsletter (hereinafter “newsletter”). To subscribe, the user must enter a valid email address. At the time of registration for commercial offers or the newsletter, the IP address, date, and time will be stored in our records. This is to protect us in case a third party misuses and registers the user’s email address for commercial offers/newsletters without their consent. No other data will be collected. The data collected in this way are used solely to send the user commercial offers or newsletters. The data are not transferred to third parties and are not in any way combined with other information possibly collected on our site. In case of downloading commercial offers or newsletters, we use the tracking system offered by Google Analytics (see below). You can unsubscribe from commercial offers/newsletters at any time. Further details are included in the confirmation email and in each commercial offer/newsletter.

For email communication, we use services and software provided by third parties and track user activities to ensure the content sent is targeted and to improve user experience.

1. e) Cookies

Our site uses Cookies, Pixel Tags, Local Shared Objects (also known as “Flash Cookies”), and similar technologies while browsing to enable certain specific functionalities of our site and to facilitate the analysis of user behavior on the site to improve user experience.

For more information about the cookies used and how they work, please visit our cookie policy.

To avoid the installation of cookies, adjust your browser settings accordingly. However, doing so may prevent you from fully using all the functions of the site.

1. f) Use of the IP Anonymization Function of Google Analytics

Our site uses Google Analytics, a web analysis service offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter “Google”). Google Analytics uses so-called “cookies”, text files stored on the user’s computer, to help analyze how users use the site. The information generated by these cookies, such as the time, place, and frequency of visits to our site, including IP addresses, are transmitted to and stored by Google in the United States.

Google declares that IP addresses sent by the user’s browser will never be associated with other data held by Google.

On our site, we use Google Analytics with the IP anonymization function. For this reason, Google shortens and then anonymizes IP addresses before transferring them from member states of the European Union or states that are signatories to the Agreement on the European Economic Area.

Google will use this information on our behalf to evaluate the use of our site by users, to compile reports on website activity for us, and to provide us with other services relating to website and Internet usage. This information is used by us for statistical purposes. Google may also transfer this information to third parties where required by law or when such data are processed by third parties on Google’s behalf.

We use Google Analytics including the Universal Analytics function. Universal Analytics allows us to analyze activities on our site across different devices (e.g., if the user accesses our site via a laptop and later through a tablet). The process consists of assigning a pseudonymous username to each user. This assignment is made at the time of registration or login with a username and password. Google will not receive any personal information. The addition of further functionalities to Google Analytics through Universal Analytics does not reduce or invalidate the security measures adopted for the protection of personal data, such as IP masking or additional browser applications.

Users can prevent the installation of cookies by adjusting their browser settings accordingly. However, doing so may prevent users from fully using all the functions of the site.

Google offers a deactivation function for the most common browsers, thus giving users more control over the data collected and processed by Google. By activating this option, no information regarding the visit to our site will be transmitted to Google Analytics. However, activation will not prevent the transmission of information to us or our web analytics service providers. For more information on the opt-out option provided by Google and on how to activate it, visit https://tools.google.com/dlpage/gaoptout.

Marketing services can be disabled at the following link: https://support.google.com/ads/answer/2662922?hl=en&ref_topic=7048998

For more information on Google’s terms of use and data protection, visit http://www.google.com/analytics/terms.

1. g) Use of Google Remarketing

This site uses the Google Inc. remarketing function (see Google Inc. address listed in the previous point f). This function is designed to display commercial messages based on the user's interests through the Google advertising network. The user's browser will store Cookies that allow that user to be recognized on sites belonging to the Google advertising network. These pages may show users promotional messages related to content previously visited by them on sites using the Google Remarketing function. Google states that it does not collect any personal data in this process. Users can disable the Google Remarketing function from the page http://www.google.com/settings/ads. Alternatively, they can disable the use of cookies for interest-based promotional messages through the Advertising Network Initiative by following the instructions on http://www.networkadvertising.org/managing/opt_out.asp

1. h) Use of Hotjar

To improve the browsing experience on our websites, we use Hotjar Ltd. services and software (Level 2, St Julian’s Business Center, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, http://www.hotjar.com). Hotjar allows us to measure and evaluate user behavior on our site. The purpose is to improve the user's browsing experience, remember preferences, solve technical issues, analyze trends, and generally improve our website. For these purposes, Hotjar sets cookies on visitors' devices to collect non-personal information about the device and browser (such as the device’s anonymized IP address, screen resolution, device type, operating system and browser type, country of access, language settings), about user interactions (such as mouse movements, keystrokes, scrolling, etc.), and log data (such as pages visited, time spent on a page, referring URL and domain, access date and time, etc.). Hotjar may store this data collected from users in anonymous form. For more information about Hotjar's privacy policies, see https://www.hotjar.com/privacy.

To prevent data processing by Hotjar, the user can disable cookies in their browser settings and delete any active cookies. The user can also object to Hotjar’s data collection and processing on the page https://www.hotjar.com/opt-out.

Section 2

Storage and transfer of information to third parties

The information will be stored on our secure servers and may be shared with our service providers who assist us with targeted communication to a specific audience, personalized advertising, and optimization of our website.

Personal information may be transferred outside of Italy and, in some cases, outside the European Economic Area (EEA) when necessary for the purposes described above (including the transfer of confidential information to third parties). In such cases, staff operating outside the EEA, whether employed by us or by one of our suppliers, may process the personal information. By submitting your personal information, you consent to such transfer, storage, and processing.

In cases where your personal information is transmitted outside the EEA, we ensure that appropriate measures are in place to protect your personal information and to ensure that it is always processed as required by the Law.

Section 3

Retention period

Personal data are retained only for the period necessary to achieve the purposes described above. Personal data will be deleted when they are no longer needed for the described purposes or upon the expiration of the retention periods required by law.

Section 4

Links to other websites

This Privacy Policy does not cover links on our site that lead to other websites. We recommend that you review the privacy policies of any other sites you visit.

Section 5

Changes to our online privacy policy

TARGET METALLI S.R.L. may modify the online privacy policy from time to time. Changes will be communicated through updates on the website. We recommend visiting the site regularly to review and accept any changes.

Section 6

Access to personal information / right to rectification and erasure

According to Article 15 of the GDPR (Right of Access by the Data Subject), the user has the right to know exactly what personal information is held in our records.

If the information we hold is outdated or incorrect, the user has the right to request correction and updating of the data. Under Article 16 of the GDPR (right to rectification), the user may also request the deletion of their data, provided there is no legal obligation or overriding legitimate interest to retain such data.

Right to object under the GDPR:

Right to object based on a particular situation:

According to Article 21 (1) of the GDPR, the data subject has the right, based on their particular situation, to object to the processing of their personal data at any time.

In the event of an objection, we will no longer process the personal data unless we can demonstrate compelling legal grounds for the processing that override the interests, rights, and freedoms of the data subject (e.g., to initiate or defend a legal claim).

Right to object for commercial purposes:

Additionally, under Article 21 (2) of the GDPR, the data subject has the right to object to the use of their data for direct marketing purposes. In such cases, we will no longer use the data subject's data for commercial purposes.

An objection can be sent in any form to the contact details provided in Section 7 below.

The Italian Data Protection Authority can be contacted at the following:

Address: Piazza di Monte Citorio n. 121 00186 ROME

Fax: (+39) 06.69677.3785

Phone: (+39) 06.696771

Email: [email protected]

If the processing of data is based on consent, the data subject may withdraw such consent at any time, regardless of whether it was given before or after the entry into force of the GDPR. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal date.

Section 7

Contact address

For questions and comments regarding this Online Privacy Policy, the use of personal information, or for any requests, please contact:

TARGET METALLI S.R.L.

Via Vallarsa 13

20121 Milan (MI)

E-Mail: [email protected]

Website: targetmetalli.com

Privacy Policy – Cookie Management

No personal data is intentionally collected through cookies.

Cookies are not used to transmit personal information; we do not use persistent cookies or other user tracking systems.

The use of so-called session cookies (which are not stored on the user's computer and are deleted when the browser is closed) is limited to the transmission of session identifiers (random numbers generated by the server) that facilitate safe and efficient browsing.

So-called session cookies are used instead of other techniques that could compromise the user’s privacy and do not collect any personal data or other personal information.