Personal Data Processing

General Data Protection Regulation (GDPR), Regulation (EU) 2016/679

“Sace Sistemi Srl” hereby informs you, pursuant to the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, that the personal data provided by you, or otherwise acquired in the course of our business activities, may be processed in compliance with the above-mentioned legislation and with the confidentiality obligations that govern our company’s activities.

In general, as required by the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, we undertake to:

  • Process personal data lawfully, fairly and transparently.
  • Collect personal data for specified, explicit and legitimate purposes.
  • Collect only the data necessary for such purposes.
  • Take appropriate measures to ensure that data is accurate and kept up to date.
  • Retain data in an identifiable form only for as long as necessary for the stated purposes.
  • Use appropriate technical and organisational measures to ensure data security.
  • Be able to demonstrate compliance with the principles of the GDPR.

Such “personal data” may be processed not only to comply with obligations established by law, regulations or European Union legislation, but also to obtain preliminary information prior to the possible conclusion of a contract to which you may be a party; to fulfil contractual obligations arising from a contract entered into with you; to provide one or more services or carry out operations contractually agreed with you; and to establish, exercise or defend a legal right, including through authorised representatives, whether in out-of-court, administrative or judicial proceedings.

Personal data may also be processed for purposes connected with and instrumental to our company’s activities, including: carrying out checks and assessments regarding the results and progress of ongoing business relationships and the associated risks; responding to requests for information or clarification from customers or third parties, within the limits permitted by law; developing new business relationships; carrying out marketing and promotional activities; conducting statistical and market studies and research; sending advertising material; carrying out direct sales or promotional activities relating to our products or services; and meeting operational, management and debt recovery requirements.

Processing activities, including consultation, analysis, comparison, interconnection, communication, dissemination and any other appropriate processing operation, may be carried out using paper-based or electronic systems, including online systems, and may involve automated tools capable of connecting the data concerned with data relating to other parties, according to qualitative, quantitative and time-based criteria, whether recurring or determined on a case-by-case basis.

Data processing will be carried out using appropriate tools designed to ensure security and confidentiality and may also involve automated systems for storing, managing and transmitting such data.

We also inform you that the processing of personal data relating to you may be carried out on behalf of our company — for the purposes and according to the methods described above, and in compliance with appropriate confidentiality and security standards — by companies, organisations or consortia that provide us with specific data-processing services or otherwise perform related, instrumental or support activities necessary for the execution of operations, services or any other activities requested by you or that we may provide to you in the future.

We further inform you that the data provided to us may be communicated and/or disclosed, in addition to all parties legally entitled to access such data pursuant to applicable laws or regulations, to companies controlled by or affiliated with us pursuant to Article 2359 of the Italian Civil Code; to economic operators; and to any other categories of parties to whom such data must be provided for the performance of the requested service or activity, for the management of information and IT systems, accounting and banking activities, personnel administration, debt recovery and litigation, insurance activities, factoring and financial intermediation, marketing and market research activities, and activities related to professional firms in general.

In relation to the above processing activities, you may exercise the rights granted under the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679, with regard to the personal data provided by you.

Finally, please note that, without prejudice to the optional nature of providing the data covered by this notice, any refusal to provide your personal data and to authorise its processing and communication to the parties and categories of parties referred to above — where such consent is required by law — may make it impossible for us to carry out the operations, services or activities requested by you or to establish or continue a business relationship with our company.

DATA CONTROLLER

With reference to data processed directly by our company, we hereby inform you that the Data Controller is Sace Sistemi Srl, with registered office at Viale Luca Gaurico 283, 00143 Rome, Italy.

For any request relating to the rights referred to in Article 7, you may contact our Privacy Office by email at info@sacesistemi.it, or write directly to the company at the address indicated above.

We also inform you that no Data Processor has been appointed in relation to the personal data covered by this notice.

CODE OF ETHICS AND CONDUCT

Introduction

This Code of Ethics and Conduct (hereinafter, the “Code”) sets out the values and principles shared by the Company and expresses the ethical and behavioural commitments and responsibilities that “Sace Sistemi Srl” adopts and implements in carrying out its business activities.

More specifically, this Code is intended to provide guidance on the minimum standards of business practice with which the Company and its employees/consultants are required to comply.

It also forms an integral part of the Organisation, Management and Control Model adopted by “Sace Sistemi Srl”.

All persons working within and on behalf of “Sace Sistemi Srl”, without distinction or exception, shall conduct themselves in accordance with the principles and provisions of the Code within the scope of their respective duties and responsibilities.

Under no circumstances may the belief that one is acting for the benefit or in the interest of the Company justify conduct that is contrary to the principles and provisions of this Code.

Values

  • Professional Ethics
    We conduct our relationships with fairness, consistency and a strong sense of responsibility towards those who engage with us, ensuring the utmost confidentiality of all information acquired.
  • Expertise and Professionalism
    Our professionalism, in-depth knowledge of the markets and the expertise acquired through years of business experience make us a reliable partner for both clients and candidates.
  • Customer Focus
    Our clients are at the heart of our activities, and we devote particular attention to understanding and meeting their needs.
  • Results-Oriented Approach
    We manage every assignment with determination and perseverance until we achieve a result that is accepted and shared by the Client.
  • Commitment to Continuous Improvement
    We are constantly committed to identifying and implementing the most effective working methods in order to respond to our Clients’ needs and continuously improve the quality of our services.
  • Reliability
    Our commitment is to complete every assignment with the utmost transparency and in full compliance with the commitments we have undertaken.

Conduct

In carrying out our work, we adhere to principles of fairness and transparency, which are reflected in the following conduct:

  • we accept only assignments that we realistically believe we can successfully complete, always informing the Client of any potential difficulties and risks;
  • we guarantee absolute confidentiality regarding all information that comes into our possession;
  • we agree with our Clients, in advance and in detail, on the specifications and scope of the services requested;
  • we pay particular attention to providing our services promptly and efficiently;
  • we provide objective evidence of the qualifications and expertise of the consultants involved and of the results achieved.