OMAS S.R.L. (hereinafter "OMAS"), with headquarters at Via Fornace seconda strada, 1 Arsego – 35010 San Giorgio delle Pertiche, Padua (Italy), which can be contacted by e-mail at this address privacy@omasindustries.com, as data controller is in charge of processing any personal information which has been provided directly or indirectly, also through their co-workers, by customers, suppliers, contacts or prospects (hereinafter jointly referred to as "Clients") in accordance with this privacy data sheet.

1. Personal Data processed by OMAS

OMAS collects the following types of personal information:

• contact data of the Client or of Client’s employees, if the latter is a legal person;

• Client’s identification data and those functional to inspections required for the purpose of applicable standards, including regulations against money-laundering;

• information provided by the Client with regard to the assignment/contract awarded to OMAS.

(hereinafter jointly referred to as "Personal Data").

2. Purposes of Personal Data processing

OMAS processes personal Data for the following purposes:

a.             correct and comprehensive performance of assignments and contracts;

b.             administrative/accounting purposes;

c.              compliance with applicable standards (hereinafter also referred to, jointly with item “A”,  as "Contractual Purposes");

d.             in order to assert and safeguard its rights, possibly as part of credit collection procedures, also through third parties;

e.             for Client segmentation by type or area of interest

(hereinafter also referred to, jointly with item “D”,  as "Legitimate Interest Purposes")

f.               in the event that the Client has benefited from services by OMAS or requested any of them, in order to send by e-mail any business or promotional information, also including training events organised by OMAS; nevertheless, when the assignment is awarded and at any time thereafter, the Client may ask to stop receiving commercial materials with "Marketing Purposes".

3. Legal basis for personal data processing

Personal Data processing is necessary with regard to Contractual Purposes, given that it is essential in order to:

• perform the assignment or contract awarded;

• meet any requirements of applicable regulations;

Personal Data are processed for Legitimate Interest Purposes according to article 6, letter f), of Regulation  (EU) 679/2016 on personal data protection ("Privacy Regulation"), in the legitimate interest of OMAS which is equally balanced with the Client’s interest, to the extent that any personal data processing shall be strictly limited to what is necessary for performance of the said activities and segmentation is completed only within the limits referred to above. Processing for Legitimate interest Purposes is not mandatory; this means that the Client may object to such processing using the procedures mentioned in this data sheet, and in that case OMAS may not process Personal Data for such purposes, unless OMAS can prove that there are overriding legitimate reasons.

Finally, processing for Marketing purposes is optional.

If the Client, according to article 130 of Lgs. D. 196/2003, should ask to stop receiving commercial materials from OMAS, the said client may no longer receive communications about initiatives and services provided by OMAS.

4. Procedures for Personal Data processing

Personal Data may be processed with manual or computerised systems, through procedures suitable to ensure their safety, confidentiality and to prevent any authorised access, diffusion, change or thefts of the said data, using appropriate measures from a technical, physical and organisational perspective.

5. Scope for data communication and divulging

For the Contractual Purposes mentioned above, Personal Data may be transferred to the following groups of recipients, both within and, according to the limitations detailed in Section 8 below, outside the European Union:

(a) third-party service and consulting suppliers for OMAS, in respect (merely by means of example) of the technology, accounting, administrative, legal, insurance and IT sectors;

b) counterparts and their legal counsels;

 c) persons and authorities which are expressly given the right to access personal data by law, regulations or provisions issued by the authorities in charge;

d) OMAS affiliates or subsidiaries.

For Legitimate Interest Purposes, Personal Data may be transferred to the following groups of recipients, both within and, according to the limitations detailed in Section 8 below, outside the European Union:

(a) third-party service and consulting suppliers for OMAS with regard to credit collection and transfer;

(b) OMAS affiliates or subsidiaries;

 (c) authorities in charge.

For the Marketing Purposes mentioned above, Personal Data may be transferred to the following groups or recipients, both within and, according to the limitations detailed in Section 8 below, outside the European Union:

(a) third-party service and consulting suppliers for OMAS with regard to sending commercial materials;

(b) OMAS offices.

A complete list of data protection officers is available on request, using the procedures detailed in this data sheet.

6. Transfer of data abroad

Personal Data may be transferred outside the national borders to Member States of the European Union, but they may also be transferred outside the European Union. Having regard to transfers outside the European Union borders to countries not considered adequate by the European Commission, OMAS shall implement safety measures which are appropriate and suitable for Personal Data protection. As a consequence any transfer of Personal Data to countries outside the European Union needs to be compliant with all appropriate and suitable guarantees for the transfer in question, such as data protection contractual clauses, pursuant to the applicable standards and more specifically to articles 45 and 46 of the Privacy Regulation.

In any case the Client is entitled to refer to the appropriate or suitable guarantees used for Personal Data transfers and the means used to obtain a copy of the said Personal Data or the place where they have been made available.

7. Rights of the data subject

The Client may, at any time and free of charge, send a request to the following address privacy@omasindustries.com, exercise the following rights:

a. apply to OMAS for confirmation of the existence of data regarding the said client, for information about their content, to check their accuracy and ask for them to be integrated, updated or amended;

b. make sure that any data processed in violation of the applicable law are erased, converted into anonymous format or blocked;

c. object, totally or in part, to data processing for legitimate reasons;

d. revoke, at any time, consent to data processing (in respect of the processing for which such consent may be required), without this affecting in any way the lawfulness of processing based on consent given before revocation.

8. Terms for data storage

The Personal Data shall be stored for the period of time necessary to pursue the aims for which such data have been collected, as stated in this data sheet. In any case the following terms for storage shall apply with regard to Personal Data processing for the purposes listed below:

• with regard to “Contractual Purposes” and “Legitimate Interest” any Personal Data may be stored for a period of time equal to the assignment or contract duration  (which also includes any renewals) and for 10 years after their expiry date, termination or withdrawal, except for cases where storage for a longer period of time may be required in the event of disputes, requests from the authorities in charge or according to applicable regulations;

• for “Marketing Purposes” with regard to sending commercial materials any Personal Data may be stored for up to 24 months following the last contact with OMAS, that is to say the latest assignment awarded, participation in events or initiatives organised by OMAS or opening of commercial materials sent by OMAS; nevertheless the Client may request, at any time, to no longer receive commercial materials from OMAS.

9. Amendments and updates

This data sheet may be amended and integrated, also as a consequence of any updates in respect of any applicable personal data processing regulations. such amendments shall be notified in advance, and Clients may review the text of the constantly updated data sheet through this link https://steel.omasindustries.com/privacy-policy.