Privacy Policy – Personal Data Processing Information

Premise
Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) concerns the protection of natural persons with regard to the processing of personal data and the free movement of such data. According to this regulation, any processing of personal data relating to a subject—referred to as the “data subject”—must follow the principles of fairness, lawfulness, transparency, and respect for confidentiality and the rights of the data subject.

This notice is provided in compliance with the GDPR to inform you that, in relation to the relationship you have with our organization—as a Client, Supplier, or Candidate—we may collect and process personal data about you, either directly or through third parties, even verbally. Such data qualifies as “personal data” under the GDPR and is therefore subject to the protection it provides.

As the data subject, you are entitled to exercise the rights granted under this regulation. In accordance with Articles 13 and 14 of the GDPR, ACM S.p.A., as the Data Controller, will process the personal data you provide with the utmost care, applying effective management procedures to safeguard your data.

Data Controller
The Data Controller is ACM S.p.A., with registered office at Via Pradone 48/54, 26010 Cremosano (CR), Italy
Tel: +39 0373 71382
Email: privacy@acm-plastic.it

Data Processing Without the Data Subject’s Consent
Even without your explicit consent, we are authorized to process your data when it is:

• Required to comply with legal, regulatory, or EU obligations.
• Necessary for the performance of a contract or to fulfill specific requests prior to entering into a contract.

Consent is also not required in the following cases:

• When the data comes from public registers, lists, or documents accessible to anyone.
• When necessary to safeguard your life or physical safety or that of a third party.
• When processing is required for legal defense or to assert a right in court.
• When necessary to pursue a legitimate interest of the Data Controller or a third party, under conditions established by the Data Protection Authority.

Personal Data Collected
The following categories of data may be collected and processed:

• Identification and contact details (e.g., name, address, tax code, VAT number, legal/residential address).
• Contract-related data and relevant transactional information.
• Accounting and payment information.
• Data about your company or professional role.
• Data related to your employees or collaborators.

Voluntarily Provided Data
Data voluntarily submitted via forms or email on our website is considered necessary to fulfill your request or contact you. This may include:

• Contact data provided via web forms or direct communication.
• Marketing-related communications, only with prior consent.
• Job applications via our website or social media (e.g., name, CV details, photo, etc.).

Data Retention Period
Data will be retained for the duration of your relationship with us and for up to 10 years after it ends. For non-accounting data, we will retain it only as long as necessary to fulfill the purpose for which it was collected.

Mandatory or Optional Nature of Data Provision
Certain data is essential for contractual or legal obligations and must be provided. Refusal may reduce our ability to work effectively with you. Sensitive or high-risk data will only be processed with your explicit written consent.

Data Processing Methods
In accordance with Articles 12 and following of the GDPR, your data will be securely processed using both manual and electronic means, stored in secure systems, and managed in compliance with Article 32. Data may be included in legal documentation and records as required by law.

External Processing Activities
Some services may be delegated to third-party providers (e.g., administration, logistics, IT services). These parties will only be given the information necessary for their tasks and are required to maintain confidentiality. If not authorized internally, they will be formally appointed as Data Processors under Article 28 of the GDPR.

Transfer of Personal Data Abroad
Your data will only be processed in Italy and San Marino. Should it be processed outside the EU, you will be notified, and your GDPR rights will be guaranteed.

Legal Basis for Data Processing
Data processing is lawful under Article 6 of the GDPR when:

• Necessary for the performance of a contract.
• Based on legitimate interest.
• Required for compliance with legal obligations.
• Necessary to protect vital interests.
• Required for tasks carried out in the public interest.
• Based on consent (e.g., for cookies or marketing). Consent may be withdrawn at any time without affecting the legality of previous processing.

Purpose of Data Processing
Personal data is processed for:

• Administrative and accounting tasks (e.g., tax compliance).
• Customer and order management.
• Legal claims and dispute management.
• Internal controls (e.g., safety, service quality).
• Business and marketing activities.
• Promotional campaigns and customer satisfaction surveys.

Who Has Access to Your Data
Data may be accessed by:

• Internal staff (e.g., administration, marketing, customer service).
• Consultants and service providers.
• Executives, auditors, agents, and distributors.

Communication and Disclosure
Your data may be communicated to:

• Group companies.
• Public authorities and supervisory bodies.
• Banks and credit institutions.
  Data will not be disclosed to unauthorized parties or made publicly available. We do not sell, rent, or share your data with unrelated third parties.

Your Rights
As a data subject, you have the right to:

• Access your data.
• Request rectification or deletion.
• Limit processing.
• Request data portability.
• Withdraw consent at any time.
• Object to processing for legitimate reasons or for marketing purposes.
  To exercise your rights, contact:
  Email: privacy@acm-plastic.it
  Phone: +378 0549 876611

You may also lodge a complaint with the competent data protection authority (“Garante per la protezione dei dati personali”).

Need more information?
Contact us:
Email: info@acm-plastic.it