The Code of Ethics expresses the commitment and the ethical responsibilities in the conduct of the business affairs and activities by all those who have relations of all kinds with the companies of the SMI Group. The goals behind it are the wish to improve internal relations and form an external, unique and clear image, to motivate all recipients to pursue positive goals and have an established organization from an ethical and moral point of view.
Compliance with laws, transparency, good governance, good faith, trust and cooperation with the stakeholders are the ethical principles that inspire SMI to effectively and loyally compete on the marketplace, improve customers' satisfaction and develop skills and growth.
Honesty, professionalism, reliability, technical preparation and commitment are determining conditions to achieve corporate objectives and represent the values required to employees, collaborators and all those who have relations with the company.
In order to promote the respect for these values, the SMI Group's companies are committed to creating a working environment that ensures all recipients conditions which respect health, safety and personal dignity and in which individual characteristics do not give rise to discrimination or conditioning.
Lawfulness of processing All activities relating to personal data processing shall be lawful (consent, contract obligations, vital interests of the data subject or of third parties, compliance with legal obligations to which the controller is subject, public interest or exercise of official authority, legitimate interest pursued by the controller or by third parties).
Information statement The information statement has been improved and updated to the new regulations (art. 13 and 14 GDPR).
Rights of the data subjects (right of access, right to erasure-right to be forgotten, right to restriction of processing, right to object, right to data portability) Technical and organization measures have been adopted to ensure the data subject's exercise of his rights and to meet the data subject requirements.
Controllers, processors Based on the new principle of “accountability”, SMI Group organization was re-defined, in order to proactively ensure integral compliance with the Regulation. Redefinition of the role of data processors and service suppliers whose activity implies personal data processing.
Risk of data processing; accountability measures taken by controllers and processors (Impact assessment, record of processing activities, security of processing, data breach) The “Conformity document”, including records of data processing activity, plans, adopts and demonstrates all technical and organizational measures taken to adequately perform the data processing activities and specifies the necessary procedures to be adopted to notify data breach.
Transfer of personal data to international organizations Enoberg adheres to the general principles and guarantees concerning the transfer of personal data to third Countries.
The Controller is: ENOBERG S.r.l. Sede amministrativa: Via del Lavoro, 14 - 24060 Telgate (BG) - ITALIA VAT nr: 01490080163 - R.E.A. For further information, write to: firstname.lastname@example.org
According to the European Regulation 679/2016, the data subject is entitled to exercise the rights set forth in the Regulation. The integral version of art. 15; 16; 17; 18; 20; 21; 77 of the European Regulation is attached to this document.