INFORMATION ON THE PROCESSING OF PERSONAL DATA
(art. 13 of EU Regulation 2016/679 – General Data Protection Regulation – GDPR)
Comer Industries Spa, hereinafter “Data Controller”, recognizes the importance of protecting personal data and undertakes to respect the privacy of the interested parties, processing private data with caution and confidentiality, not using them for purposes other than those specified below.
To this end, this policy describes how to manage the website with reference to the processing of personal data of users who consult it. This information is provided, also pursuant to Article 13 of EU Regulation 2016/679 (hereinafter “GDPR”), to those who interact with the web services of Comer Industries Spa, accessible electronically on the pages of the website: https://www.comerindustries.com.
This Policy may be modified or updated at any time by the Data Controller. The information is provided only for this website and not for other websites that may be consulted by the user through links, except for those indicated above.
DATA CONTROLLER
The data controller is Comer Industries Spa, with registered office in Reggiolo (RE) Via Magellano, 27 with registration to the Company Register of Reggio Emilia n. 07210440157, Fiscal Code. 07210440157 and VAT IT 01399270352.
PURPOSE, DATA AND LEGAL BASIS OF THE PROCESSING
The Data concerning the User is collected to allow the Owner to provide the Service, comply with legal obligations, respond to enforcement requests or actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activity, as well as for the following purposes: Contacting the User, Registration and authentication provided directly from this Website, Displaying content from external platforms, Management of support and contact requests, Remarketing and behavioral targeting, Analytics, Infrastructure monitoring, Commercial affiliation, Collection of privacy preferences, User database management, Interaction with platforms data collection and other third parties, Registration and authentication, Contact management and sending messages, Data linking, Information collection, Advertising, Traffic optimization and distribution, Internal processing tools and Online sale of goods and services.
Legal basis
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data; the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
processing is necessary to fulfill a legal obligation to which the Data Controller is subject; the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
Navigation data
The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of computers and terminals used by users, addresses in URI / URL (Uniform Resource Identifier / Locator) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data, necessary for the use of web services, are also processed for the purpose of:
– obtain statistical information on the use of the services (most visited pages, number of visitors by time or day, geographical areas of origin, etc.);
– check the correct functioning of the services offered.
The navigation data do not persist for more than seven days (except for any need to ascertain crimes by the judicial authority).
Data provided voluntarily by the user
The optional, explicit and voluntary sending of e-mails to the addresses indicated on the site, involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data contained in the message. Any specific summary information is reported or displayed on the pages of the Site prepared for services on request, so as to draw the attention of the interested party to the processing of his personal data. The processing of your data has the following purposes:
purposes related to the use of the services offered by the site (site navigation); activities strictly connected and instrumental to the management of relations with customers and potential collaborators (contact requests); marketing activities, only and exclusively with the specific consent of the user, aimed at market research; economic and statistical analysis; sending advertising / informative / promotional material, sending newsletters, also in relation to programs and promotions, including online, communications, development and maintenanceof the commercial relationship
process data relating to curricula for the evaluation of job applications.
The provision of data for the purposes referred to in numbers 2) and 3) is optional and must be provided in the manner expressly provided for in Article 7 of the GDPR and 130 of Legislative Decree 196/03 (hereinafter “Privacy Code”), directly from the website.
Communications relating to marketing activities may take place through the use of traditional methods (e.g., paper mail, telephone calls with operator), automated (e.g., telephone calls without operator) and similar (e.g. fax, e-mail, sms, newsletter). Unless dissented, the Data Controller may continue to send its customers commercial communications relating to services similar to those they are already using.
CATEGORIES OF PERSONAL DATA PROCESSED FOR CONTRACTUAL PURPOSES AS WELL AS FOR LEGAL OBLIGATIONS
Personal data, contact details, administrative-accounting data.
CATEGORIES OF PERSONAL DATA PROCESSED FOR THE OPERATION OF THE SITE
The IP addresses or domain names of the computers used by users connecting to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), other parameters relating to the operating system and the user’s computer environment, information relating to user behavior on the Site, to the pages that have been visited or searched, in order to select and make specific ads to the user of the Site and data relating to browsing behavior held on the Site, for example, using cookies.
PROCESSING METHODS
The processing of data will be carried out, by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The data will be processed both on paper and electronically and / or automatically.
OBLIGATION TO PROVIDE DATA
The refusal to provide consent to the processing of data referred to in the paragraphs Purpose and Legal Basis does not allow you to use the services offered by the Data Controller.
Some personal data are strictly necessary for the operation of the Site, others are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, and are deleted immediately after processing. In the processing of personal data that can, directly or indirectly, identify the user, a principle of strict necessity is respected. For this reason, the Site has been configured in such a way that the use of personal data is reduced to a minimum and in such a way as to limit the processing of personal data that allow the identification of the user only in case of need or at the request of the authorities and police forces (such as, for example, for data relating to traffic and permanence on the website or IP address) or to ascertain responsibility in case of hypothetical computer crimes.
RECIPIENTS OF THE PROCESS
The data, object of the treatment, will not be disseminated; instead, for the purposes indicated and subject to consent if necessary, they may be communicated to the companies of the Comer Industries Group, and to third parties, including commercial partners, consultants and freelancers, of services, auditors, public bodies, auditing or supervisory bodies, to fulfill obligations deriving from the law, regulations, community regulations or for aspects concerning the management and execution of the legal relationship with the intercurrent or intervening subjects. Data will be processed by the following subjects:
Employees of the companies of the Comer Industries Group, in Italy and abroad, who operate as persons authorized to process data according to the tasks performed and adequately instructed Managers pursuant to Article 28 GDPR.The list of Data Processors is available at the registered office of the Data Controller.For all the purposes indicated in this statement, the data may also be communicated abroad, inside and outside the European Union, in compliance with the rights and guarantees provided for by current legislation, subject to verification that the country in question guarantees an “adequate” level of protection pursuant to the provisions of the GDPR.
DATA RETENTION PERIOD
The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore, Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be processed until the execution of this contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
RIGHTS OF THE INTERESTED PARTY
Each data subject may, at any time, request:
a) access to your personal data (Article 15 GDPR);
b) their correction in case of inaccuracy (art. 16 GDPR); c) the cancellation of data referable to the same (Article 17 GDPR); d) the limitation of processing (Article 18 GDPR); e) the right to object to the processing of data where the conditions are met (art. 21 GDPR); f) the right to data portability, i.e. to receive the personal data provided in a structured format of common use and readable by automatic device (Article 20 GDPR).
For anything not expressly provided for by the provisions referred to herein, please refer in full to the legislation in force on privacy.
It is also possible for the interested party to lodge a complaint with the Guarantor Authority of personal data based in Piazza di Montecitorio n.121, 00186 Rome.To exercise these rights, communications may be sent to the Data Controller at the addresses indicated below: privacy@comerindustries.com or infodpo@kncm.it.
WITHDRAWAL OF CONSENT
There are various ways to manage your Tracking Tools preferences and to give or withdraw consent where necessary.
Users can manage their Tracking Tools preferences directly through their device settings – for example, they can prevent the use or storage of Tracking Tools.
In addition, whenever the use of Tracking Tools depends on consent, the User can give or revoke such consent by setting their preferences within the cookie policy or by updating such preferences through the tracking settings widget, if any.
Thanks to special functions of the browser or device it is also possible to remove previously saved Tracking Tools.
Other Tracking Tools present in the local memory of the browser can be removed by clearing the browsing history.
With regard to third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the relevant opt out link (if available), using the tools described in the third party’s privacy policy or by contacting them directly.
DATA SECURITY
Your personal data will be processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected and in compliance with the principle of necessity and proportionality, avoiding the processing of personal data if the operations can be carried out through the use of anonymous data or by other means. We have adopted specific security measures to prevent the loss of personal data, illicit or incorrect use and unauthorized access but please do not forget that it is essential for the security of your data that your device is equipped with tools such as antivirus constantly updated and that the provider that provides you with the Internet connection guarantees the secure transmission of data through firewalls, spam filters and similar devices.
COMMUNICATIONS
Any communication regarding the processing of data may be forwarded to Comer Industries Spa with registered office in Reggiolo (RE) at Via Magellano n.27, cap 42046 or to the email address: privacy@comerindustries.com or infodpo@kncm.it.
(art. 13 of EU Regulation 2016/679 – General Data Protection Regulation – GDPR)
Comer Industries Spa, hereinafter “Data Controller”, recognizes the importance of protecting personal data and undertakes to respect the privacy of the interested parties, processing private data with caution and confidentiality, not using them for purposes other than those specified below.
To this end, this policy describes how to manage the website with reference to the processing of personal data of users who consult it. This information is provided, also pursuant to Article 13 of EU Regulation 2016/679 (hereinafter “GDPR”), to those who interact with the web services of Comer Industries Spa, accessible electronically on the pages of the website: https://www.comerindustries.com.
This Policy may be modified or updated at any time by the Data Controller. The information is provided only for this website and not for other websites that may be consulted by the user through links, except for those indicated above.
DATA CONTROLLER
The data controller is Comer Industries Spa, with registered office in Reggiolo (RE) Via Magellano, 27 with registration to the Company Register of Reggio Emilia n. 07210440157, Fiscal Code. 07210440157 and VAT IT 01399270352.
PURPOSE, DATA AND LEGAL BASIS OF THE PROCESSING
The Data concerning the User is collected to allow the Owner to provide the Service, comply with legal obligations, respond to enforcement requests or actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activity, as well as for the following purposes: Contacting the User, Registration and authentication provided directly from this Website, Displaying content from external platforms, Management of support and contact requests, Remarketing and behavioral targeting, Analytics, Infrastructure monitoring, Commercial affiliation, Collection of privacy preferences, User database management, Interaction with platforms data collection and other third parties, Registration and authentication, Contact management and sending messages, Data linking, Information collection, Advertising, Traffic optimization and distribution, Internal processing tools and Online sale of goods and services.
Legal basis
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data; the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
processing is necessary to fulfill a legal obligation to which the Data Controller is subject; the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller; the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
Navigation data
The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of computers and terminals used by users, addresses in URI / URL (Uniform Resource Identifier / Locator) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data, necessary for the use of web services, are also processed for the purpose of:
– obtain statistical information on the use of the services (most visited pages, number of visitors by time or day, geographical areas of origin, etc.);
– check the correct functioning of the services offered.
The navigation data do not persist for more than seven days (except for any need to ascertain crimes by the judicial authority).
Data provided voluntarily by the user
The optional, explicit and voluntary sending of e-mails to the addresses indicated on the site, involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data contained in the message. Any specific summary information is reported or displayed on the pages of the Site prepared for services on request, so as to draw the attention of the interested party to the processing of his personal data. The processing of your data has the following purposes:
purposes related to the use of the services offered by the site (site navigation); activities strictly connected and instrumental to the management of relations with customers and potential collaborators (contact requests); marketing activities, only and exclusively with the specific consent of the user, aimed at market research; economic and statistical analysis; sending advertising / informative / promotional material, sending newsletters, also in relation to programs and promotions, including online, communications, development and maintenanceof the commercial relationship
process data relating to curricula for the evaluation of job applications.
The provision of data for the purposes referred to in numbers 2) and 3) is optional and must be provided in the manner expressly provided for in Article 7 of the GDPR and 130 of Legislative Decree 196/03 (hereinafter “Privacy Code”), directly from the website.
Communications relating to marketing activities may take place through the use of traditional methods (e.g., paper mail, telephone calls with operator), automated (e.g., telephone calls without operator) and similar (e.g. fax, e-mail, sms, newsletter). Unless dissented, the Data Controller may continue to send its customers commercial communications relating to services similar to those they are already using.
CATEGORIES OF PERSONAL DATA PROCESSED FOR CONTRACTUAL PURPOSES AS WELL AS FOR LEGAL OBLIGATIONS
Personal data, contact details, administrative-accounting data.
CATEGORIES OF PERSONAL DATA PROCESSED FOR THE OPERATION OF THE SITE
The IP addresses or domain names of the computers used by users connecting to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), other parameters relating to the operating system and the user’s computer environment, information relating to user behavior on the Site, to the pages that have been visited or searched, in order to select and make specific ads to the user of the Site and data relating to browsing behavior held on the Site, for example, using cookies.
PROCESSING METHODS
The processing of data will be carried out, by means of the following operations: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The data will be processed both on paper and electronically and / or automatically.
OBLIGATION TO PROVIDE DATA
The refusal to provide consent to the processing of data referred to in the paragraphs Purpose and Legal Basis does not allow you to use the services offered by the Data Controller.
Some personal data are strictly necessary for the operation of the Site, others are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, and are deleted immediately after processing. In the processing of personal data that can, directly or indirectly, identify the user, a principle of strict necessity is respected. For this reason, the Site has been configured in such a way that the use of personal data is reduced to a minimum and in such a way as to limit the processing of personal data that allow the identification of the user only in case of need or at the request of the authorities and police forces (such as, for example, for data relating to traffic and permanence on the website or IP address) or to ascertain responsibility in case of hypothetical computer crimes.
RECIPIENTS OF THE PROCESS
The data, object of the treatment, will not be disseminated; instead, for the purposes indicated and subject to consent if necessary, they may be communicated to the companies of the Comer Industries Group, and to third parties, including commercial partners, consultants and freelancers, of services, auditors, public bodies, auditing or supervisory bodies, to fulfill obligations deriving from the law, regulations, community regulations or for aspects concerning the management and execution of the legal relationship with the intercurrent or intervening subjects. Data will be processed by the following subjects:
Employees of the companies of the Comer Industries Group, in Italy and abroad, who operate as persons authorized to process data according to the tasks performed and adequately instructed Managers pursuant to Article 28 GDPR.The list of Data Processors is available at the registered office of the Data Controller.For all the purposes indicated in this statement, the data may also be communicated abroad, inside and outside the European Union, in compliance with the rights and guarantees provided for by current legislation, subject to verification that the country in question guarantees an “adequate” level of protection pursuant to the provisions of the GDPR.
DATA RETENTION PERIOD
The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore, Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be processed until the execution of this contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Data Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
RIGHTS OF THE INTERESTED PARTY
Each data subject may, at any time, request:
a) access to your personal data (Article 15 GDPR);
b) their correction in case of inaccuracy (art. 16 GDPR); c) the cancellation of data referable to the same (Article 17 GDPR); d) the limitation of processing (Article 18 GDPR); e) the right to object to the processing of data where the conditions are met (art. 21 GDPR); f) the right to data portability, i.e. to receive the personal data provided in a structured format of common use and readable by automatic device (Article 20 GDPR).
For anything not expressly provided for by the provisions referred to herein, please refer in full to the legislation in force on privacy.
It is also possible for the interested party to lodge a complaint with the Guarantor Authority of personal data based in Piazza di Montecitorio n.121, 00186 Rome.To exercise these rights, communications may be sent to the Data Controller at the addresses indicated below: privacy@comerindustries.com or infodpo@kncm.it.
WITHDRAWAL OF CONSENT
There are various ways to manage your Tracking Tools preferences and to give or withdraw consent where necessary.
Users can manage their Tracking Tools preferences directly through their device settings – for example, they can prevent the use or storage of Tracking Tools.
In addition, whenever the use of Tracking Tools depends on consent, the User can give or revoke such consent by setting their preferences within the cookie policy or by updating such preferences through the tracking settings widget, if any.
Thanks to special functions of the browser or device it is also possible to remove previously saved Tracking Tools.
Other Tracking Tools present in the local memory of the browser can be removed by clearing the browsing history.
With regard to third-party Tracking Tools, Users can manage preferences and withdraw consent by visiting the relevant opt out link (if available), using the tools described in the third party’s privacy policy or by contacting them directly.
DATA SECURITY
Your personal data will be processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected and in compliance with the principle of necessity and proportionality, avoiding the processing of personal data if the operations can be carried out through the use of anonymous data or by other means. We have adopted specific security measures to prevent the loss of personal data, illicit or incorrect use and unauthorized access but please do not forget that it is essential for the security of your data that your device is equipped with tools such as antivirus constantly updated and that the provider that provides you with the Internet connection guarantees the secure transmission of data through firewalls, spam filters and similar devices.
COMMUNICATIONS
Any communication regarding the processing of data may be forwarded to Comer Industries Spa with registered office in Reggiolo (RE) at Via Magellano n.27, cap 42046 or to the email address: privacy@comerindustries.com or infodpo@kncm.it.
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