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PRIVACY DISCLAIMER

Last update on 25.5.2018

PRIVACY POLICY ACCORDING to ART. 13 GDPR

This privacy policy, according to GDPR art. 4 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, informs you on how IVM Chemicals srl will treat your personal information and how you can exercise your privacy rights

Definitions

“Personal data” (ex art. 4 no. 1 of GDPR) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Processing” (ex art. 4 no. 2 of GDPR) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Who’s the Data Controller? How can you contact him?

Business Name: IVM Chemicals srl Headquarter address: Via T. Tasso, n. 10, 20123 Milano (MI) Field office address: Viale della Stazione, n. 3, 27020 Parona (PV) Phone: 0384 25441 Email: ad es privacy@ivmchemicals.com

Data processing in relation to customers and contact page

Personal Data collected Personal Data collected regard:

Identification Data (business name, or name or surname for natural persons, headquarter address, phone, fax, e-mail, tax data, ecc.);
Data related to existing legal relationships, provided directly by the Data Subjects (in its broadest sense);

Purposes of the processing Purposes of the processing are the following:

Fulfillment of legal obligations, regulations, italian and european law or instructions received by supervisory and authority bodies related to or anyway connected to the contractual or legal relationship (existing or future).
Execution and management of agreed contracts or legal agreements reached and the related commiments (for example about execution and management of the received orders);
Assert and defend Data Subject rights, even in connection with fraud or debt collection;
Possible external professional collaborations for the fulfillment of legal obligations;
Internal statistical analysis in an aggregated form;
With reference to data collected through contact page, in relation to customers, but also not customers, IVM Chemicals srl treats Data Subject data through electronic means, and if necessary also paper-based means, in order to answer your questions and requests and receive advices useful to improve our offer.

The table below shows, for each above identified purpose, legal basis, categories of personal data, categories of data subjects and conservation period:

Purposes of the processing of personal data:	Legal basis	Types of personal data	Storage Period	Categories of recipients
Purpose 1	Legal obligation	Identification data Biographical data	Until the ending of the contractual relationships and for the following 10 years	*
Purpose 2	Contract	Identification data Biographical data	Until the ending of the contractual relationships and for the following 10 years	*
Purpose 3	Legitimate interests C. 47: Business relationship between Data controller and data subject	Identification data Biographical data	Prescription terms required by law	*
Purpose 4	Legitimate interests C. 47: Business relationship between Data controller and data subject	Identification data Biographical data	Until the ending of the contractual relationships and for the following 10 years	*
Purpose 5	Legitimate interests C. 47: Business relationship between Data controller and data subject	Identification data Biographical data	Until the ending of the contractual relationships and for the following 10 years	*
Purpose 6	Consent	Identification Data	Until 10 years after request accomplishment	*

*Categories of recipients In relation to the mentioned purposes, personal data could be communicated to the following companies and/or persons, located in UE countries, which provide services, also external, on behalf of the Data Controller. Among which**, in order to clarify, we just give as an example, not as an exhaustive list:

Accounting management consultants;
IT services company;
Control and supervisory bodies.

(**)Recipients/ external DPO list with additional data useful for the purpose of identification, is available at the Data Controller. Data transfer to a third country outside of the EU territory IVM Chemicals srl does not transfer personal data to non-EU territory. Conservation period Please refer to Table 1 column 4.

Rights of the Data Subject

Data subject can exercise the following rights, in relation to personal data object of the hereby policy, as provided by GDPR:

Right of access by the Data Subject [art. 15 of the EU Regulation];
Right to rectification[art. 16 of the EU Regulation];
Right to erasure without unjustified delay ("right to be forgotten") [art. 17 of the EU Regulation];
Right to restriction of processing[art. 18 of the EU Regulation];
Right to data portability [art. 20 of the EU Regulation];
Right to object [art. 21 of the EU Regulation];
Right not to be subjected to automated decision-making processes, [art. 22 of the EU Regulation].

The aforementioned rights may be exercised according to the provisions of the Regulations by sending an email to privacy@ivmchemicals.com IVM Chemicals srl in compliance with the art. 19 of the EU Regulation, proceeds to inform recipients to whom the personal data have been communicated, about any corrections, cancellations or limitations of the treatment requested, where this is possible. If the purpose of processing pursued by IVM Chemicals srl has as its legal basis the consent, the interested party has the right to proceed, at any time, to the revocation by sending an email to privacy@ivmchemicals.com. Pursuant to art. 7 of the EU Regulation, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. If the interested party considers that his rights have been compromised, he has the right to lodge a complaint with the Guarantor. For more information on the rights and their exercise, please refer to Rights of the data Subjec

Mandatory provision of personal data

Please note that if the processing purposes have a legal or contractual (or even pre-contractual) obligation as a lawfulness of processing, the data subject must necessarily provide the requested data. Otherwise, it will be impossible for the Data Controller to proceed with the pursuit of specific processing purposes. The Company does not make use of any automated decision-making process. Modalities of the processing

data will be processed in paper, digital and telematic form and inserted in the applicable data banks (clients, potential clients, ecc.), which can be consulted and processed by the operators and processors designated by the Data Controller who will be able to carry out the consultation, use, handling, comparison and any other appropriate operation, direct or automatic, respecting the legal requirements necessary to guarantee the confidentiality and the security of the data, as well as their accuracy, updating, and their relevancy to the declared aims.

Handling of data useful for navigation purposes

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. Among the information that can be collected we have the IP addresses, the type of browser or the operating system used, the addresses in notation URI (uniform resource identifier), the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request was made to the server, the method used and information on the response obtained, further information on the user's navigation on the site (see also the related section to cookies) and other parameters relating to the operating system and the user's computer environment. These same data could also be used to identify and ascertain responsibilities in case of any computer crimes against the site.

Advise regarding children under 16 years

Children under 16 cannot provide personal data. IVM Chemicals srl will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, if IVM Chemicals srl will notice its use, it will facilitate the right of access and cancellation forwarded by the legal guardian or by those who exercise parental authority. Exercise of the rights of the interested party: The interested party, in relation to the personal data subject of this information, has the right to exercise the rights provided for by the EU Regulation below:

Right of access by the data subject [art. 15 of the EU Regulation]:The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information, including, as an exemplary and non-exhaustive list, the purpose of the processing, the categories of data and recipients, the conservation period, the existence of the right to erasure, correction or limitation, the right to propose a complaint, all the available information on the origin of the data, the existence of an automated decision-making process pursuant to art. 22 of the Regulations, as well as a copy of their personal data;
Right of rectification [art. 16 of the EU Regulation]:the data subject has the right to obtain from the data controller the correction and / or integration of the incorrect personal data concerning him, without unjustified delay;
Right to erasure ("right to be forgotten") [art. 17 of the EU Regulation]:data subject has the right to cancel his / her personal data without unjustified delay, if one of the reasons expressly provided by the aforementioned article occurs, including as an example and not exhaustive list, the case in which the processing of personal data is no longer necessary with respect to the purpose, the revocation of the consent on which the treatment is based, the opposition to the treatment in case it is based on non-prevailing legitimate interest, the unlawful data processing, the deletion due to legal obligations, the use of minors data in absence of the conditions of applicability expected by art. 8 of the Regulations;
Right of restriction of processing [art. 18 of the EU Regulation]:in the cases provided for by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the data subject and the loss of the necessity of the data processing by the Data Controller, the Data Subject must be processed only for storage reasons, unless the consent of the Data Subject occurs and in the other cases expressly provided for by the aforementioned article;
Right to data portability [art. 20 of the EU Regulation]:the data subject, in cases where the processing is based on consent and contract and is performed by automated means, may request to receive personal data in a structured format, commonly used and readable by automatic device, and has the right to transmit them to another holder;
Right to object [art. 21 of the EU Regulation]:the data subject has the right to object to the processing of his / her personal data, in the event that the processing is based on a non-prevailing legitimate interest or is carried out for direct marketing purposes;
Right to not be subject to automated decision-making processes [art. 22 of the EU Regulation]: the interested party has the right not to be subject to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).

The description given above does not replace the text of the articles cited here to which is made reference and whose full text can be found at this article15-22

Right to lodge a complaint

If the interested party considers that his / her rights have been compromised, he / she has the right to lodge a complaint with the Guarantor for the protection of personal data, according to the methods indicated by the same Authority at the following Internet address: http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524. For more information on the rights of the interested parties provided for by the Guarantor, please refer to theLegal references on the rights of the data subjects

Changes and updates

This informative report shows the date of its last update in its heading. IVM Chemicals srl may also make changes and/or additions to this privacy policy also as a consequence of any subsequent amendments and/or regulatory amendments.

Legal references on the rights of the data subjects:

Article 15 Right of access by the data subject

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
1. the purposes of the processing;
2. the categories of personal data concerned;
3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
6. the right to lodge a complaint with a supervisory authority;
7. where the personal data are not collected from the data subject, any available information as to their source;
8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46relating to the transfer.
1The controller shall provide a copy of the personal data undergoing processing. 2For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. 3Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16 Right to rectification The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. 2Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Article 17 Right to erasure ("right to be forgotten")

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
3. the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
4. the personal data have been unlawfully processed;
5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
6. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
1. for exercising the right of freedom of expression and information;
2. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. for the establishment, exercise or defence of legal claims.

Article 18 Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
4. the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

Article 19 Notification obligation regarding rectification or erasure of personal data or restriction of processing The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. 2The controller shall inform the data subject about those recipients if the data subject requests it. Article 20 Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
1. the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
2. the processing is carried out by automated means.
In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
1The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. 2That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 Right to object

1The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. 2The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22 Automated individual decision-making, including profile

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
Paragraph 1 shall not apply if the decision:
1. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
3. is based on the data subject’s explicit consent.
In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(2)1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.

COOKIES INFORMATION

This website, managed by IVM Chemicals srl, with registered office in Milan, Via Torquato Tasso 10, which acquires, therefore, the capacity of Data Controller in accordance with Legislative Decree. No. 196/03 (Privacy Code), uses only technical cookies, defined as those used for the sole purpose of "performing the transmission of a communication over an electronic communication network, or as strictly necessary for the provider of a service of the information company explicitly requested by the subscriber or user to provide such service" (see Article 122 paragraph 1 of the Privacy Code) and Google analytical cookies, "similar to technical cookies where used directly by the website manager to collect information, in aggregate form, on the number of users and on how the latter visit the website".

In particular, the following:

Cookie	Function
_session_id	Session cookie
Google Analytics (GA) cookie	analytics cookie

It is possible to obtain a complete and up-to-date list of Google Analytics cookies at:

https://developers.google.com/analytics/legacy/universal-analytics

For installation and use of these cookies your prior consent is not required since these are cookies which are necessary and indispensable for the proper functioning of the applications.

This website allows you to select/deselect individual cookies, in the manner described below, but you are warned that, in the case of deactivation, full fruition of the same may not be guaranteed.

Unless they are disabled on our website, using the website the user accepts our cookie policy.

Cookies can be deactivated, removed or blocked using your browser settings, as indicated below:

Enabling / disabling cookies via the browser

There are several ways to manage cookies. By changing your browser settings, you can accept or reject cookies or decide to receive a warning message before accepting a cookie from websites visited. It is possible to delete all cookies installed in the cookie folder of your browser. Each browser has different procedures for managing settings. The links below show provide instructions for the most common browsers

Microsoft Windows Explorer

Google Chrome

Mozilla Firefox

Apple Safari

If you are not using any of the browsers listed above, select "cookies" in the help section of your browser to find out where your cookie folder is located.

For further information on the use of cookies, each data subject can directly contact to the Data Controller, by e-mail, at the following address: info@ivmchemicals.com, also in order to request the complete list of Data Processors.

WHISTLEBLOWING INFORMATION

Parona 14/07/2023

Gentili Collaboratori,

dal 15 Luglio 2023 entrerà in vigore D.Lgs del 24/2023 (Whistleblowing) - Segnalazioni di illecito - INFORMAZIONI AI SENSI DELL'ART. 13 DEL REGOLAMENTO (UE) 2016/679.

Questa comunicazione è per informarvi sulla sua applicazione nella nostra Azienda.

Cos’è la Segnalazioni di illecito – Whistleblowing?

Se un Collaboratore (Whistleblower, ovvero “Informatore”) viene a conoscenza di un illecito commesso da uno o più Collaboratori dell’Azienda relativo al diritto UE ( D.Lgs del 24/2023 REGOLAMENTO UE 2016/679) deve poterlo denunciare al Responsabile aziendale preposto, che sarà tenuto a promuovere le necessarie investigazioni e i successivi interventi, senza che questi possa divulgare in alcun caso la sua identità. Dovrà quindi ricevere riscontro delle azioni messe in atto dal Responsabile aziendale entro tre mesi dalla segnalazione.

Cosa si può segnalare?

Comportamenti, atti od omissioni che ledono l’interesse pubblico o l’integrità dell’Azienda come:

frode fiscale;
riciclaggio di denaro;
reato relativo ad appalti pubblici;
reato relativo alla sicurezza dei prodotti e dei trasporti;
reato relativo alla protezione dell’ambiente, alla salute pubblica e alla protezione dei consumatori;
reato relativo alla protezione dei dati, alla sicurezza delle reti e dei sistemi informativi;
reato relativo alla tutela della vita privata (rispetto della privacy, dell’ orientamento sessuale, reato di molestie);

Non sono ricomprese nell’ambito di applicazione del Whistleblowing, contestazioni, rivendicazioni o richieste legate ad un interesse di carattere personale del segnalante.

Chi è il Responsabile aziendale?

E’ la persona, o il gruppo di Persone, che l’Azienda ha valutato essere la più adatta a ricevere le segnalazioni e a gestirle con la massima riservatezza, indicata come Responsabile della prevenzione della corruzione e per la trasparenza.

IVM CHEMICALS ha nominato congiuntamente

Simone Grillo
Federico Omarini

Come fare la segnalazione?

Può essere fatta sia per tramite di posta elettronica sia telefonicamente, o chiedendo un colloquio.

Simone Grillo e Federico Omarini sono raggiungibili:

al seguente indirizzo mail: segnalazione-whistleblowing@ivmchemicals.com
Simone Grillo al numero telefonico diretto +39 02 430 22 254
Federico Omarini al numero telefonico diretto: +39 02 430 22 206

In caso la segnalazione non venga fatta in forma scritta, avrà valore solo una volta che il segnalante avrà firmato la sua trascrizione, fatta dal Responsabile, come previsto dalla normativa.

Nel caso in cui non venga dato seguito ad una segnalazione da parte dell’Azienda, la segnalazione può essere effettuata direttamente all’ANAC (Autorità nazionale anticorruzione)

Cosa utile indicare nella segnalazione?

Oltre al proprio nome e cognome, la qualifica ricoperta all’epoca del fatto segnalato, un recapito telefonico ed un indirizzo di posta elettronica, tutte le informazioni utili a comprendere e gestire le analisi sull’illecito segnalato (luogo, date, descrizione dei fatti, persone che hanno commesso la presunta violazione …)

A quali azioni da parte dell’Azienda si può andare incontro facendo una segnalazione di illecito falsa o infondata?

Se la segnalazione viene fatta al solo scopo di danneggiare o arrecare pregiudizio a Collaboratori o all’Azienda, verranno presi provvedimenti disciplinari e/o intraprese azioni legali.

Per il Consiglio di Amministrazione

Stefano Vasconi

Ilva s.r.l.