Policy pursuant to and for the purposes of Article 13 EU Regulation 2016/679 (GDPR)

In compliance with EU Regulation 2016/679 (European Data Protection Regulation) we provide you with the necessary information regarding the processing of the personal data you provide. The policy does not apply to other websites that may be consulted via links on the data controller’s domain websites and the data controller is in no way responsible for the websites of third parties. This policy is provided pursuant to Article 13 of EU Regulation 2016/679 (European Personal Data Protection Regulation) and is also inspired by the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, regarding Cookies as well as the provisions of the Order of the Italian Data Protection Authority of 08/05/2014 regarding cookies. Personal data that can be processed: “Personal data” refers to any information relating to an identified or identifiable individual (“data subject”); an identifiable person is one who can be identified, directly or indirectly, by specific reference to an identifier, such as a name, an identification number, location data, an online identifier or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity; (C26, C27, C30).

Data communicated by the data subject

The optional, explicit and voluntary sending of messages to the contact addresses, as well as the filling in and forwarding of the forms on the Data Controller’s website, entails the acquisition of the sender’s contact data, which are necessary in order to reply, as well as all the personal data included in the communications.


Cookies are small text files that sites visited by users send to their terminals, where they are stored in order to be retransmitted to the same websites on subsequent visits. Cookies are used for different purposes, have different characteristics and can be used either by the data controller of the website you are visiting or by third parties. This website uses technical cookies that are strictly necessary for the functioning of the website. For more information on cookies and their general functions, visit an informative website such as allaboutcookies.org.

Cookie names Type of cookie First or Third party Can be blocked Session or Persistent Expiry Time Purpose

1. Data controller

Data controller, pursuant to Articles 4 and 24 of EU Regulation 2016/679 is Samag Holding Logistics S.p.A., with registered office in Piazza di Pietra 26, 00186 Rome, represented by of its legal representative pro tempore. To contact the data controller: Tel. 02800281, email privacy@retestrategy.com.

2. Purpose of processing, legal basis, data retention period and nature of provision of data

A) Browsing the website – LEGAL BASIS : Legitimate interest Article 6(f) and Recital 47: processing is necessary for the purposes of pursuing the legitimate interests of the data controller or a third party, provided that the interests or the fundamental rights and freedoms of the data subject which require the protection of personal data are not overridden, regarding the reasonable expectations of the data subject based on his or her relationship with the data controller. Activities strictly necessary for the operation of the website and the provision of the navigation service on the platform. – DATA STORAGE PERIOD: until the duration of the browsing session. – NATURE OF PROVISION: With the exception of what is specified for navigation data (which are necessary in order to allow navigation of the website), the user is free to provide personal data. B) Possible compilation of data collection forms for contacts – LEGAL BASIS : execution of pre-contractual measures taken also at the request of the data subject. – DATA RETENTION PERIOD: 1 year – NATURE OF PROVISION: Provision of data is optional or necessary depending on the specific purpose for which the data is processed. Failure to provide the data marked with the symbol* will make it impossible to obtain what is requested or to use the services of the data controller.

3. Recipients of personal data collected

The personal data provided will be shared with parties who will process the data as data controllers (Article 28 of EU Regulation 2016/679) and/or as individuals acting under the authority of the Data Controller and the Data Processor (Article 29 of EU Regulation 2016/679), for the purposes listed above. Specifically, the data will be shared with: – subjects who provide services for the management of the information system used by Samag Holding Logistics S.p.A. and telecommunications networks; freelance professionals, studies or companies within the scope of assistance and consultancy relationships; – authorities responsible for fulfilling legal obligations and/or provisions of public bodies, upon request. The list of Data Processors is constantly updated and available by writing to privacy@retestrategy.com or at the registered office of Samag Holding Logistics S.p.A.

4. Data transfer to third countries

Personal data provided will not be transferred to countries outside of the EEA.

5. Possible automated process

We do not use decision-making processes based on automatic processing, including profiling.

6. Rights of the data subject

You may assert your rights as expressed in Articles 15, 16, 17, 18, 19, 20, 21 of EU Regulation 2016/679 by contacting the Data Controller at privacy@retestrategy.com. You have the right, at any time, to ask the data controller for access to your personal data, rectification, deletion, restriction of processing and portability of your data. Furthermore, you have the right to object, at any time, to the processing of your data based on consent and/or legitimate interest. Without prejudice to any other administrative or judicial remedy, if you consider that the processing of data concerning you violates the provisions of EU Regulation 2016/679, pursuant to Article 15 letter f) of the aforementioned EU Regulation 2016/679, you have the right to lodge a complaint with the Data Protection Authority (Supervisory Authority www.garanteprivacy.it).

7. Further information

The data controller reserves the right to change, update, add or remove parts of this privacy policy at its own discretion and at any time. In order to facilitate such verification, the disclosure will contain the date of update. Update date: 29 August 2022