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PRIVACY STATEMENT




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BY USING THIS WEBSITE YOU ARE DEEMED TO HAVE ACCEPTED THIS PRIVACY POLICY.

October 2018

PRIVACY AND PERSONAL DATA PROTECTION POLICY

Being consistent with our VALUES, inspired by our VISION and guided by our
MISSION, we are focused on the objective of acting responsibly in the community
where we in as well as in the relations with all our partners. To this extent,
ensuring the protection of privacy and personal data and the transparent and
fair treatment are essential for the entire MARTIFER Group.




The protection of privacy and personal data is a fundamental commitment of all
the companies part of MARTIFER Group, based on the following principles for its
treatment:

- The treatment of personal data is carried out in a lawful, faithful and
transparent manner;

- The respective data collection is performed only for properly specified,
explicit and legitimate purposes, in accordance with the applicable legislation;

- The collected data is limited to what is strictly necessary and for the time
necessary for the purposes for which it are treated;

- Only the employees, collaborators and partners of the Group whose duties so
require have access to treated personal data;

- Personal data is treated as confidential.




A. Personal Data




According to the General Data Protection Regulation, i.e. Regulation (EU)
2016/679 of the European Parliament and of the Council of 27 April 2016
(hereinafter referred to as “GDPR”) - personal data is any information of any
nature and in any medium concerning an identified or identifiable natural person
(“data subject”). A natural person is considered identifiable if he/she can be
identified, directly or indirectly, in particular by reference to an identifier,
such as a name, an identification number, location data, electronic identifiers
or one or more specific elements of physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.




B. Responsibility for the Treatment




The company part of Martifer Group to which the data subjects are related is
responsible for the personal data treatment.




C. Conditions for the Treatment




The companies part of Martifer Group will only treat personal data if one of the
conditions laid down in the abovementioned European regulation is met, namely:

- If the data subject has given his/her consent to the treatment of his/her
personal data;

- If the treatment of personal data is necessary for the execution of a contract
in which the data subject is a party or for pre-contractual proceedings
requested by the data subject;

- If the treatment is necessary for compliance with a legal obligation to which
Martifer Group is subject;

- If the treatment is necessary to guarantee the legitimate interests of
MARTIFER Group.




CONSENT

When his/her prior and express consent (either in writing, orally or through the
validation of an option) is obtained and if such consent is wilful, informed,
specific and unambiguous. Examples of this are the consent for Martifer Group to
examine job applications or to validate specific qualification and training
certificates;




EXECUTION OF A CONTRACT AND PRE-CONTRACTUAL ARRANGEMENTS

Whenever the treatment of personal data is necessary for the execution,
implementation and management of the contract executed with us, e.g. for the
preparation of proposals or quotes, for the management of contacts, information
and requests, for the management of invoicing, collection and payments;




COMPLIANCE WITH THE LEGAL OBLIGATION

Whenever the treatment of personal data is necessary to fulfil a legal
obligation to which Martifer Group is subject, e.g. the communication of
identification data to police, legal, fiscal or regulatory authorities;




LEGITIMATE INTEREST

Whenever the treatment of personal data is in the legitimate interest of
Martifer Group or third parties and whenever our reasons for its use should
prevail over the data protection rights;




D. Storage Period for Personal Data




In compliance with the abovementioned principles, the personal data processed by
Martifer Group shall be stored for as long as strictly necessary for the
purposes for which it was collected. The determination of these terms is based
on criteria for the retention of information that is defined and appropriate to
each treatment and respects the legal and regulatory obligations to which the
Group is subject.




E. Rights of the Holders of Personal Data




Martifer Group ensures that the data subject may exercise the rights conferred
to him/her by the GDPR on data protection, namely:




- RIGHT OF ACCESS TO PERSONAL DATA (the data subject may obtain confirmation on
whether his/her personal data is treated and access information on it);




- RIGHT TO CORRECT (the data subject may request its correction or completion);




- RIGHT TO ERASURE (the data subject may require that his/her personal data be
erased) in the following situations:




i. if the personal data is no longer necessary for the purpose for which it was
collected or treated;

ii. if the consent on which the data treatment is based is withdrawn and there
is no other legal basis for it;

iii. if the data subject objects to the processing and there are no overlapping
legitimate interests;

iv. if the personal data has been unlawfully treated;

v. if the personal data has to be erased as a result of a legal obligation;




- RIGHT TO THE LIMITATION OF TREATMENT (the data subject has the right to
request the limitation of treatment) when:

i. the data subject disputes its accuracy for a period which allows the
verification of its accuracy;

ii. the data subject considers that the treatment is unlawful;

iii. the data is no longer necessary for processing purposes, but such data is
necessary for a declaration, exercise or defence of a right in a judicial
proceeding;




- RIGHT TO DATA PORTABILITY (when the treatment is based on the consent or the
execution of a contract and is carried out by automated means, the data subject
may request the delivery in a structured format of current use and which may
allow automatic reading of personal data which concerns him/her and which he/she
has provided, and may also request that the personal data be transmitted to
another person responsible for the treatment, provided that this is technically
possible);




- RIGHT OF OPPOSITION (the data subject has the right to object to the
processing) at any time when:

i. there is no prevailing legitimate interest by the one responsible for the
treatment;

ii. the treatment is carried out for purposes other than those for which the
data was collected;




- RIGHT NOT TO BE SUBJECT TO EXCLUSIVELY AUTOMATED INDIVIDUAL DECISIONS (in
certain situations, the data subject has the right to request human intervention
when decisions are made based on exclusively automated treatment);




- RIGHT TO WITHDRAW HIS/HER CONSENT (the data subject has the right to withdraw
the consent he/she has given to the treatment of his/her personal data);




- RIGHT TO COMPLAIN TO THE NATIONAL DATA PROTECTION AUTHORITY (on any matters
relating to the treatment of his/her personal data).




If you intend to exercise any of the rights referred to above or to clarify any
issues relating the protection of privacy and your personal data by Martifer
Group, the contact may be made by letter addressed to the Group headquarters, to
the Permanent Committee on the GDPR or by e-mail sent to crgpd@martifer.com.




F. Safety Measures




Martifer Group companies have at their disposal safety, technical and
organisational measures that ensure the protection of personal data against
security breaches ('violation of personal data': violation of the safety that
causes, accidentally or unlawfully, non-unauthorised destruction, loss,
alteration, disclosure or access to personal data transmitted, stored or subject
to any other type of treatment), and against any other accidental or unlawful
treatment.




The commitment which was undertaken by Martifer Group on the protection of
personal data also implies that, whenever personal data is transmitted to other
entities, these are obliged to adopt technical and organisational measures to
ensure the same level of protection.




Martifer Group will carry out an impact assessment whenever data processing is
likely to jeopardise the fundamental rights and freedoms of natural persons.
Whenever we do this, we commit to comply with the European community and
national guidelines on this issue, such as GDPR (EU) 2016/679 and the National
Data Protection Commission guidelines.




G. Communication of Personal Data To Third Parties




In the exercise of their activities, the companies part of Martifer Group may
have to communicate or give access to treated personal data under their
responsibility to other entities, always ensuring that they present technical
and organisational measures that adequately protect personal data.




Personal data will only be accessed or shared with the following entities:

- Companies part of Martifer Group;

- Subcontracting entities that render services to the Group in matters such as
IT support, document management, legal support, human resources;

- Clients of companies part of Martifer Group or representatives designated by
them;

- Public authorities (e.g. the Tax and Customs Authority).




Martifer Group may have to transfer personal data to another country outside the
European Union which is not part of the list of countries that the EU has
already considered to have adequate levels of personal data protection. In such
cases, MARTIFER Group will ensure that data transfers are carried out in strict
compliance with the applicable legal regulations.




H. Additional Information




The data subject may request information or clarification on the treatment
carried out by any company part of Martifer Group to his/her personal data
sending it to the e-mail address crgpd@martifer.com.




This document can be changed at any time. In this case, the changes will be duly
announced and disclosed by the institutional communication media routinely used
by Martifer Group.


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