Privacy Policy

    Last updated on: 01.07.2026

    Information on the processing of personal data of users using the corporate website pursuant to Article 13 of the EU Regulation 679/2016 General Data Protection Regulation (GDPR)

    The information on this Website (https://sarom.eu/) are held in property by Berlin Packaging Romania S.R.L., a company duly registered in Romania, having its registered office in 24 Delea Veche Street, Office Building A, 9th Floor, Modul M4, Bucharest, District 2, Romania, Trade Registry no. J2016007539401, sole identification code RO36139167 (We or Berlin). Berlin is a limited liability company, part of Berlin Packaging Group (the Group).

    This Privacy Policy explains how We collect, use and otherwise process your personal data when you use our services and the Website.

    Simple navigation within the Website is free and does not require any registration, with the exception of some areas in which you may freely and expressly provide a series of data concerning you in order to access specifically identified services (e.g. to request information via the Contact page, the Careers page, etc.). Where, therefore, you intend to provide your personal data in order to access such further services, you will be expressly informed in accordance with GDPR with an indication (by way of example) of the purposes and modalities of use of your data by Berlin as well as of your right to request the deletion of your data or its update at any time.

    1. What data do we collect?

    1.1 In relation to the Careers page (Berlin Careers – Join Our Team of Packaging Experts) or the Contact page (Contact Berlin – Get in Touch with Our Packaging Experts)

    We collect the following personal data about you:

    1. surname;
    2. first name;
    3. location;
    4. telephone number;
    5. e-mail address.

    1.2 In relation to all Visitors and Users (as defined below)

    IP Addresses and Usage Data: We collect for IT security purposes and system diagnostics, your IP Addresses and Usage Data. Both IP Addresses and Usage Data are collected from Users (individuals that request additional information via the contact page or the career page) as well as Visitors (individuals that visit the Website without registering and/or giving any of their personal data).

    These types of data will also be used to analyze trends and the performance of the Website.

    For the purpose of this Privacy Policy the personal data listed under letters a-e above are hereinafter referred to as the Data.

    2. Legal basis for processing

    We collect only necessary data: This Website collects only the personal data required to meet your request. You will be notified of this at the moment of data collection. Your data will be processed in order to manage the use of the services (also post-sales) requested through the Website, to comply with the related legal obligations, to respond to your possible requests, as well as, on the basis of your consent, to carry out marketing activities and analysis of your preferences.

    Your data will be processed in full compliance with the GDPR.

    General applicable rule: The law allows Us to process personal data as long as We have a legal basis for doing so. The law also requires Us to inform you of the purposes of the processing.

    Our grounds of processing: As a result, when we process your personal data, we will rely on one of the following legal grounds for processing, for the purposes indicated:

    • Legitimate interest, in answering a request/application we will process information about you which you submit when you fill in the forms available on this Website, or the data you choose to send to us at your discretion directly to the contact addresses indicated on this Website.
    • Your consent, in some cases, we will ask you for specific permission to process some of your personal data, and We will process your personal data in this way, only if you agree to do so; for example, when you exercise your option to receive information from us, according to our registration section, available here Berlin Careers – Join Our Team of Packaging Experts and Contact Berlin – Get in Touch with Our Packaging Experts.

    Your consent may be withdrawn at any time following the steps available in the indicated section of this Privacy Policy. If at any point you opt-in for particular services or communications, such as newsletters, participation in our events etc., you will be able to unsubscribe at any time by following the instructions included in each communication.

    In any case, We will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of the Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

    3. Manner of processing the Data

    We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

    Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and methods strictly related to the purposes indicated.

    Data may be processed both electronically and on paper. Berlin guarantees the lawful and correct processing of the personal data provided through the Website, in full compliance with the legislation in force, as well as the maximum confidentiality of the data provided. The data shall not be disseminated and shall be processed by personnel expressly authorized to manage the Website and any linked CRM system. For purely organizational and functional reasons, Berlin has appointed a number of service providers functional to the management of the Website as external data processors for the processing of users’ personal data for purposes strictly connected and related to the provision of the services provided. A full list of external data processors can be obtained by contacting privacy.eu@berlinpackaging.com.

    The data may also be made available to the other companies in the Berlin Packaging group as well as to companies that provide us with services useful for the management of your purchases and related services.

    4. Place and usage of the Data. Personnel handling the Data

    Place: The Data is processed at Our operating offices, in the EU. Depending on your location, data transfers may involve transferring your Data to a country other than your own.

    Due to the organizational policy of the Group, to which Berlin belongs, Your personal data may be transferred to the United States of America where the servers hosting the group’s CRM (customer relationship management) applications are physically located, in particular to the company Berlin Packaging L.L.C., located at: 525 West Monroe Street – Chicago, IL 60661. The applicable legislation provides that your specific consent to the transfer to third countries is not required as the transfer is made on the basis of the adoption of adequate safeguards as per articles 46 and 47 of the GDPR, such as the adoption of standard contractual clauses approved by the EU Commission and on the basis of the Data Privacy Framework Program (“DPF”).

    We will transmit your data to relevant authorities when we have a legal obligation to do so; we can transmit your data to our partners that offer us services such as legal, billing, accounting, security, marketing, user interactions, hosting.

    Usage: Berlin collects Your data so that We can: (a) Present You this Website and improve it; (b) Email You any news and updates on Berlin and its offers; (c) Respond to Your email, if You contact Us via email; and (d) Manage Your participation to our events.

    Personnel: Personal data will be processed by authorized personnel, including in the marketing, purchasing, finance and legal departments, and may be shared with affiliated Group companies, business partners, and service providers as necessary to provide services and manage requests. Data will not be sold to third parties.

    In addition to Berlin, your data may also be processed by the European parent company Berlin Packaging Italy S.p.A. for specific marketing activities planned by the same company.

    5. Further relevant information for you

    5.1 Retention time

    Unless specified otherwise in this document, the Data shall be processed and stored for as long as required by the purpose it has been collected for and may be retained for longer due to applicable legal obligation or based on your consent.

    Therefore:

    • Data collected for purposes related to the performance of a contract between Us and you shall be retained until such contract has been fully performed.
    • Data collected for the purposes of Our legitimate interests shall be retained as long as needed to fulfill such purposes, and in any case no longer than 10 years after the date of the last business relationship with you. You may find specific information regarding the legitimate interests pursued by Us within the relevant sections of this document or by contacting Us.

    We may be allowed to retain Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

    Once the retention period expires, the Data shall be deleted.

    5.2 Your rights based on the GDPR

    You have the right to do the following, to the extent permitted by law:

    • Withdraw your consent at any time. You have the right to withdraw consent where you have previously given your consent to the processing of your Data.
    • Object to processing of your Data. You have the right to object to the processing of your Data if the processing is carried out on a legal basis other than your consent.
    • Access your Data. You have the right to learn if your Data is being processed by Us and to obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
    • Verify and seek rectification. You have the right to verify the accuracy of your Data and ask for the Data to be updated or corrected.
    • Restrict the processing of your Data. You have the right to restrict the processing of your Data. In this case, We will not process your Data for any purpose other than storing it.
    • Have your Data deleted or otherwise removed. You have the right to obtain the erasure of your Data.
    • Receive your Data and have it transferred to another controller. You have the right to receive your Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
    • Lodge a complaint. You have the right to bring a claim before your competent data protection authority.

    5.3 Exercise of your rights

    Any requests to exercise your rights can be directed to Us through the contact details provided in this document, i.e. email address: privacy.eu@berlinpackaging.com.

    Such requests are free of charge and will be answered by Us as early as possible and always within one month, providing you with the information required by law.

    Any rectification or erasure of Data or restriction of processing will be communicated by Us to each recipient, if any, to whom the Data has been disclosed unless this proves impossible or involves disproportionate effort. At your request, We will inform you about those recipients.

    5.4 Information not contained in this Privacy Policy

    More details concerning the collection or processing of Data may be requested from Us at any time, at email address: privacy.eu@berlinpackaging.com.

    5.5 Links to other websites

    This Privacy Policy is provided only for the Website and not for any other websites that may be consulted by the user through links. Berlin cannot be considered responsible for personal data provided by users to external parties or to any websites linked to this Website.

    5.6 Profiling and/or personalization tools

    Berlin does not carry out any promotional and/or advertising activities without the user’s prior express consent.

    The Website uses "cookies", both technical (i.e. to facilitate navigation and use of the Website) and profiling (i.e. to analyze users and their behavior and preferences, and to provide them with personalized advertising).

    For a detailed explanation of the cookies used by the Website and how to deactivate them, please refer our Cookies Policy.

    5.7 Changes to this Privacy Policy

    We reserve the right to make changes to this Privacy Policy at any time by notifying you on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the beginning of the document.

    Should the changes affect processing activities performed on the basis of your consent, We shall collect a new consent from you, where required.