INFORMATION ON THE PROCESSING OF PERSONAL DATA
pursuant to Articles 12 and following of the European Regulation 2016/679

The European Regulation 2016/679 (General Data Protection Regulation, hereinafter ‘GDPR’) and the relevant Italian legislation govern the processing of ‘personal data’, i.e., any information relating to an identified or identifiable natural person. In compliance with these provisions, Sargom Srl provides this information notice to describe how personal data is collected and processed to carry out order and shipment services on behalf of the Client Companies.

1. IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER
The Data Controller of personal data is Sargom Srl, with registered office in Rodengo Saiano (BS), Via Gaetano Bertoli no. 15, Tax Code and VAT no. 00284350170, sargomsrl@interfreepec.it. The Data Protection Officer (DPO), appointed by the Controller pursuant to Articles 37 and following of the GDPR, is Ms. Marta Sartori, who can be contacted at the email address: ufficio@sargom.it.

2. PURPOSES OF PROCESSING, LEGAL BASIS, AND CATEGORIES OF DATA PROCESSED
Sargom collects personal data from Clients in accordance with the principles of lawfulness, fairness, and transparency, and in compliance with the principle of minimization, acquiring and processing data only to the extent necessary to perform order and shipment services on behalf of the Client Companies. The personal data processed includes data provided by the Client when submitting their request to Sargom, or during direct contacts. Personal data may also be provided by third parties, such as the Client’s employees.

3. CATEGORIES OF DATA RECIPIENTS
Where relevant to the purpose of the processing and in compliance with applicable laws, Sargom may transfer the processed personal data to the following categories of recipients, acting as Data Controllers:- potential shippers and/or carriers;- companies within the Sargom network that handle production and commercial activities;- authorities to which communication is mandatory by law.External IT service providers may also act as Data Processors.

4. METHODS OF PROCESSING AND DATA CIRCULATION
The processing of personal data is carried out through the operations indicated in Article 4, par. 1 no. 2) of the GDPR, namely through the collection, recording, storage, adaptation, retrieval, consultation, use, and deletion of the same. Processing operations are carried out using both paper and electronic means. The personal data collected is processed by authorized and trained personnel, who are required to maintain the confidentiality of the data as provided by Article 29 of the GDPR.Sargom adopts technical and organizational measures suitable for protecting the data to ensure a level of security appropriate to the risk of improper use, loss, or unauthorized access. There is no decision-making process based solely on automated processing that may significantly affect the Data Subject. The management and storage of personal data take place on servers located within the European Union owned by Sargom and/or third-party companies duly appointed as Data Processors.

5. DATA RETENTION PERIOD
Sargom retains the Client’s personal data until the Client requests its deletion. The Client can cancel their account at any time by making an express request. Upon completion of the cancellation process, a confirmation email will be sent.

6. DATA SUBJECT'S RIGHTS
Sargom is committed to ensuring that the Data Subject can exercise their rights at any time:- Right of access, i.e., the ability to obtain confirmation from the Controller as to whether or not personal data concerning them is being processed and to obtain the information contained in this document (Article 15 GDPR);- Right to rectification or supplementation of inaccurate or incomplete personal data (Article 16 GDPR);- Right to erasure, provided that the processing is not required by law or by contract or necessary for the Controller to exercise their legal rights (Article 17 GDPR);- Right to restriction of processing, i.e., the ability to request that the data be processed only for storage purposes, excluding any other processing (Article 18 GDPR);- Right to object to processing carried out for the pursuit of the Controller’s legitimate interest (Article 21 GDPR).The Data Subject can exercise the above rights by writing to the email address: ufficio@sargom.it; if the Data Subject believes that the processing of their data violates privacy regulations, they can write to the email address: ufficio@sargom.it or lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).