REGULATION (EU) 2016/679 (“GDPR”)

Pursuant to art. 13 of Regulation (EU) 2016/679 and relative to the data that we will enter into possession of, for the protection of natural persons and other subjects relative to the processing of personal data, the following shall apply:

1. Controller
Via della Tecnica, 50 – 41122 Modena (MO) – IT

2. Purposes of the Processing
The data that you supply will be used for the following purposes:

  1. To establish and fulfil the contractual relationship;
  2. For administrative – accounting requirements (accounts, invoicing, finance department) in compliance with the regulations in force;
  3. To send, even by e-mail, informative messages (Newsletter) and marketing material (advertising);
  4. To obtain anonymous statistical information about website use, even in order to check its correct operation and to prevent cybercrime.

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

3. Processing Methods
The personal data will be processed in hard copy, using computers and telematics and will be placed in the relevant databases to which the persons in charge of the processing will have access.
The processing may even be performed by third parties which supply specific processing, administrative or instrumental services necessary for achieving the above-mentioned purposes.
All data processing operations are carried out in such a way as to guarantee the integrity, confidentiality and availability of the personal data.

4. Period for which the personal data are stored
For points 2.a) and 2.b) the data will be stored for the duration of the contractual relationship and for the subsequent years envisaged by the regulations in force for compliance with legal obligations and protection of data for use in court proceedings.
For points 2.c) and 2.d) the data will be stored until a request to unsubscribe from the Newsletter is received.

5. Provision of data
The data must be provided for the purposes in points 2.a) and 2.b) in order to allow the contract to be entered into and fulfilled. Therefore, refusal to provide the data prevents establishment of the contractual relationship and/or fulfilment of the consequent obligations.
Provision of the data for the purposes in points 2.c) and 2.d) is optional, but refusal to provide it makes fulfilment of the requests impossible.

6. Communication and disclosure of the data
The data may be communicated to:

  1. All subjects whose right to access such data is recognised and envisaged in accordance with regulatory measures. For example: Authorities, Supervisory and Oversight Bodies,
  2. External Subjects appointed as processors, which carry out specific activities on behalf of the controller (accounting, tax and insurance requirements, management of takings and payments, etc.). For example collaborators, banks, tax consultants, solicitors, etc.;
  3. Employees of the company departments who have been expressly authorised to carry out processing and have received suitable operating instructions.

7. Transfer of data
The personal data are stored at the Company registered office in Modena and on Servers located within the European Union. In any case, it shall be understood that, if necessary, the Controller will have the right to move the servers even outside of the European Union. The Controller as of now guarantees that in such cases the transfer of the data outside of the European Union will be performed in compliance with applicable legal provisions, subject to stipulation of the standard contractual clauses required by the European Commission.

8. Rights of the data subject
Pursuant to articles 15 to 22 of Regulation (EU) 2016/679, at any time you may exercise the right to:

  1. obtain from the controller confirmation as to whether or not personal data concerning you are being processed;
  2. access information about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed and, where possible, the envisaged period for which the personal data will be stored;
  3. obtain the rectification and erasure of the data;
  4. obtain restriction of processing;
  5. obtain data portability, that is to say, receive the data concerning you which you provided to the controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided;
  6. object to the processing at any time and even where the personal data are processed for direct marketing purposes;
  7. object to a decision-making process based solely on automated processing relative to a natural person, including profiling.
  8. request from the controller access to and rectification or erasure of the personal data or restriction of the processing concerning you, or to object to the processing, as well as the right to data portability;
  9. withdraw consent at any time, the withdrawal of consent not affecting the lawfulness of processing based on consent before its withdrawal;
  10. lodge a complaint with a supervisory authority.

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

  • A recorded delivery letter to the Controller (indicated in Point 1):
    C.M. Surface Treatment S.p.A. – Via della Tecnica, 50 – 41122 Modena (MO) – ITALY;
  • An e-mail to the address

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