INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA PURSUANT TO REGULATION (EU) 2016/679 (“GDPR”)

Pursuant to Article 13 of EU Regulation 2016/679, and in relation to the information that will be obtained, for the protection of individuals and other subjects in relation to personal data processing, the following is provided:

1.Data Controller
C.M. SURFACE TREATMENT S.r.l
Via della Tecnica, 50 – 41122 Modena (MO) – IT
info@cmspa.com

2.Purpose of Data Processing
The data provided by you will be used for the following purposes:

• Establishment and execution of the contractual relationship;
• Administrative and accounting compliance (accounting, invoicing, treasury) in accordance with current regulations;
• Sending of informational communications (Newsletters) and marketing communications (advertising materials), also by email;
• Gathering anonymous statistical information regarding the use of the site, also to monitor its correct operation and prevent cybercrimes.

The legal basis for processing is the contract, as well as Legitimate Interest and the necessity to fulfill a legal obligation for points 2.a) and 2.b).
The legal basis for processing is Legitimate Interest, as well as explicit consent for points 2.c) and 2.d).

3.Processing Methods
Personal data will be processed in paper, computerized, and telematic form and inserted into the relevant databases that can be accessed by those authorized to process the data.
Processing may also be carried out by third parties providing specific processing, administrative, or instrumental services necessary to achieve the aforementioned purposes.
All data processing operations are carried out in a manner that ensures the integrity, confidentiality, and availability of personal data.

4.Data Retention
For points 2.a) and 2.b), data will be retained for the duration of the contractual relationship and for the subsequent years required by applicable regulations to comply with legal obligations and for judicial protection needs.
For points 2.c) and 2.d), data will be retained until a request for unsubscribing from the Newsletter service is made.

5.Provision of Data
Providing data for the purposes of points 2.a) and 2.b) is mandatory for the conclusion of the contract and its execution. Failure to provide the data, therefore, does not allow for the establishment of the contractual relationship and/or compliance with the resulting obligations.
Providing data for the purposes of points 2.c) and 2.d) is optional, but refusal to provide them makes it impossible to fulfill the requests.

6.Communication and Dissemination of Data
Data may be communicated to:

• All subjects whose access to such data is recognized and provided for by regulatory provisions. By way of example: Authorities, Supervisory and Control Bodies, etc.;
• External subjects designated as data processors, who carry out specific activities on behalf of the data controller (accounting, fiscal and insurance obligations, management of collections and payments, etc.). By way of example: collaborators, banking institutions, tax and legal consultants, etc.;
• Employees of company departments who have been expressly authorized to process data and who have received appropriate operational instructions.

7.Data Transfer
Personal data are stored at the Company’s headquarters in Modena and on servers located within the European Union. However, the Data Controller, where necessary, may transfer servers outside the EU. In such cases, the Data Controller ensures that the transfer of data outside the EU will be carried out in accordance with applicable legal provisions, following the signing of standard contractual clauses provided by the European Commission.

8.Data Subject’s Rights
At any time, you may exercise, pursuant to Articles 15 to 22 of EU Regulation No. 2016/679, the right to:

• Request confirmation of the existence of your personal data;
• Obtain information about the purposes of processing, categories of personal data, recipients or categories of recipients to whom the personal data have been or will be communicated, and, when possible, the retention period;
• Obtain rectification and deletion of data;
• Obtain restriction of processing;
• Obtain data portability, i.e., receive your data from a data controller in a structured, commonly used, and machine-readable format, and transmit it to another data controller without hindrance;
• Object to processing at any time, including in the case of processing for direct marketing purposes;
• Object to automated decision-making processes concerning individuals, including profiling;
• Request access to personal data and the rectification or deletion of such data, or the restriction of processing concerning you, or object to their processing, as well as the right to data portability;
• Withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;
• Lodge a complaint with a supervisory authority.

9.How to Exercise Your Rights
You can exercise your rights at any time by sending:

• A registered letter to the Data Controller (as per Point 1):
  C.M. Surface Treatment S.r.l. – Via della Tecnica, 50 – 41122 Modena (MO) – IT;
• An email to cmsurfacespa@legalmail.it.

10.Tracking and Analytics
The Company uses third-party tools, including LinkedIn, to collect information regarding visitors’ interactions with the website. The purposes of such processing are to measure the effectiveness of marketing activities, monitor website usage, and improve the services offered. The information collected may include anonymized data on pages visited, actions performed, and general professional information, such as job title, industry, and company size. The processing of such data is carried out in accordance with applicable data protection laws. You may manage or withdraw your consent for this tracking at any time via our cookie settings or by exercising your rights as described in Point 9.