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PRIVACY POLICY
pursuant to article 13 of EU Regulation 2016/679 (hereinafter referred to as GDPR)

Combitech Italia S.r.L. protects your privacy for the processing of personal data acquired through this website http://www.combitechitalia.com/en/index.aspx .


1. GENERAL INFORMATION
Users of the site (hereinafter “data subjects” pursuant to article 4, paragraph 1 of the GDPR) are informed of the following general profiles, which are valid for all areas of processing:

  • The Data Controller is Combitech Italia S.r.L. in the person of its legal representative, with registered office in Via Achille Grandi, 9 Zona Industriale - 20020 Arconate (MI) - Italia, VAT no / TAX Code IT12913100157, which you can also contact at the email address privacy@combitech.it /and phone N.: (+39) (+39) 0331 46.26.87.
  • All user data related directly or indirectly to natural persons are processed lawfully, fairly and in a transparent manner in relation to the data subject, in compliance with the general provisions set forth in article 5 of the GDPR.
  • We have taken specific security measures to prevent loss, illegal or improper use and unauthorised access of data.
  • Data is collected through the site using computer or paper systems (see “Printing of computer documents), only “common” data or information that does not include “special categories of data” (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation) or “judicial data” (personal data relating to criminal convictions and offences or related security measures).

The web hosting of the site is held by Aruba Spa in Abruzzo San Giovanni Teatino (AQ) - Shared Hosting Windows – and is managed and maintained by Linkaround Srl Via Perin del Vaga, 12 20156 Milano – Italia Phone.: +39 02.30.85.464 VAT no / TAX Code and Fiscal Code 02758300129, which is appointed External Processor of Combitech Italia’s data. The data are located inside the European Economic Area; any transfer of data to sub-processors abroad will be covered by standard contractual clauses and/or by a relative adequacy decision in accordance with articles 45 and 46 of the GDPR.
The updated list of people authorised to process data on behalf of the Data Controller, as well as the external data processors appointed by Combitech Italia S.r.L.is available at the Data Controller’s registered office.
The privacy policy of Combitech Italia S.r.L. does not involve the processing of personal data of natural persons under 16 years of age. Therefore, this site is not intended to intentionally collect personal information relating to such minors. In the event that information on minors is unintentionally recorded, the Data Controller will delete it in a timely manner, directly and/or at the request of users.

2. YOUR PERSONAL DATA
This section describes the methods for managing the personal data acquired through the http://www.combitechitalia.com/en/index.aspx  website, which may involve interaction with the user:

  • (2.1) Navigation data
  • (2.2) Contact us
  • (2.3) Other data
  • (2.4) Cookies

2.1 Navigation data
The computer systems and software procedures used to run this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected to be associated with identified parties, but by its very nature, could allow identifying users, through processing and association with data held by third parties. This category includes IP addresses or domain names of computers used by Users who connect to the site, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the reply status given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.

Legal basis and purpose of the processing
(art.13, par. 1, lett. c of the GDPR)

This data is used only to obtain anonymous statistical information on site usage and to check its proper functioning. The data could be used to verify responsibility in case of hypothetical computer crimes against the site (legitimate interests of the Data Controller – Recital no. 49 of the GDPR).

Scope of communication
(art.13, par. 1, lett. e and f of the GDPR)

Data are processed by the Data Controller’s internal personnel, who are duly authorised and instructed on the processing (art. 29 of the GDPR) as well as external processors duly appointed (see point 1.5).

Data retention period
(art.13, par. 2, lett. a of the GDP)

Data are kept for very short periods of time or for the time strictly necessary to comply with the navigation request.

Dissemination and transfer of Data
(art.13, par. 1, lett. e and f of the GDPR)

Data processed by the Data Controller are not disseminated or transferred to a third country.

Provision
(art.13, par. 2, lett. f of the GDPR)

The data are not provided by the data subject, but acquired automatically by the technological systems of the website.


2.2 Contact us
The “ http://www.combitechitalia.com/en/Contatti.aspx ” section allows data subjects to submit their request for information by filling in the appropriate form, and including information on the products that they are interested in, together with identification data (name/surname/email/message).

Legal basis and purpose of the processing
(art.13, par. 1, lett. c of the GDPR)

Only information not belonging to the special category of data is requested in order to be able to respond quickly to spontaneous requests for information. The request is sent on the basis of a freely given, specific, informed and unambiguous indication of the data subject’s consent (art. 6, par. 1, lett. a of the GDPR, recital no. 32) by ticking the appropriate checkbox. In any case, the processing of data may be necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (art. 6, par.1, lett. b of the GDPR).

Scope of communication
(art. 13, par. 1, lett. e and f of the GDPR)

Data are processed by the Data Controller’s internal personnel, who are duly authorised and instructed on the processing (art. 29 of the GDPR) as well as external processors duly appointed (see point 1.5).

Data retention period
(art. 13, par. 2, lett. a of the GDPR)

The data are generally kept for the time compatible with the purpose of the collection, in order to respond to this request; for users who have become Customers, the retention period is equal to the duration of the contractual relationship and up to 2 months after its termination; for other categories of data subjects, the retention period may not exceed 24 months.

Dissemination and transfer of Data
(art.13, par. 1, lett. e and f of the GDPR)

Data processed by the Data Controller are not disseminated or transferred to a third country.

Provision
(art. 13, par. 2, lett. f of the GDPR)

The provision of data relating to mandatory fields (name, surname, email, message) is necessary to obtain a response, while the remaining field (select a product) is optional, as it aims to provide Combitech Italia staff with additional elements useful to facilitate the contact and/or the subject of the request sent by the data subject.

2.3 Other data provided voluntarily by the user
The optional, explicit and voluntary sending of an email and/or ordinary letter to the addresses indicated on this website, and to info@combitech.it, entails subsequent acquisition of the sender’s address, which is necessary to reply to requests, as well as any other personal details included in the message.
If the sender sends his/her curriculum vitae to submit his/her professional application, he/she shall be solely responsible for the relevance and accuracy of the data sent. On the first useful contact during the candidate’s interview, a suitable privacy statement will be given to the data subject, and the data will be processed for the purpose of selecting the candidate. The sender must in any case refrain from sending information falling within the “special categories of data” or “judicial data” (see point 1.4 – General Information); if received, this information will be deleted, as it will not be processed in any way by the Data Controller.

2.4 Cookies
You can view the cookies policy here: cookies policy.

 

3. YOUR RIGHTS

3.1 You may freely exercise the following rights in relation to the processing of data by Combitech Italia S.r.L.:

  • Obtain confirmation as to whether or not personal data concerning you are being processed and, where that is the case, to obtain access to data and information relating to the processing.
  • Ask for the rectification of inaccurate data;
  • Request cancellation of data in the event that, among other reasons, they are no longer necessary for the purposes for which they were requested; in this case, Combitech Italia S.r.L. will cease to process the data, except where said data are necessary to establish, exercise or defend a legal claim.
  • Request application to restrict the data processing, in which case said data may only be processed with the prior consent of the data subject; except for the retention of the data and use for establishing, exercising or defending a legal claim or for protecting the rights of other natural or legal persons or for reasons of significant public interest of the European Union or a Member State.
  • Oppose, in whole or in part, for legitimate reasons, the processing of data, in this case Combitech Italia S.r.L. shall cease to process the data, unless they are necessary to defend a legal claim.
  • Receive the data provided to Combitech Italia S.r.L. in a structured, commonly used and machine-readable format, or to request Combitech Italia S.r.L.to transfer those data to another controller when technically possible.
  • Withdraw the consent given, if relevant, for the purposes outlined in point 2 above, without this affecting the lawfulness of the processed based on consent given before its withdrawal.
  • The above rights of access, rectification, cancellation, restriction, opposition and portability of data may be exercised directly by the data subject or by his/her legal or voluntary representative by means of a request sent by registered letter with return receipt to Combitech Italia S.r.L. Via Achille Grandi, 9 Zona Industriale - 20020 Arconate (MI) - Italia, VAT no / TAX Code IT12913100157, Phone number (+39) 0331 46.26.87 , which you can also contact at the email address privacy@combitech.it , or to info@combitech.it. The data subject has the right to lodge a complaint with a Supervisory Authority.

4. UPDATING OF THE POLICY
It should be noted that this policy may be reviewed and updated periodically, also as required by applicable laws or regulations. Any significant changes will be notified by posting a prominent notice on the homepage of this website. In any case, the data subject should periodically check this policy for any updates. This policy is made available in accordance with article 13 of the GDPR and is valid for the website www.combitechitalia.com.

5. OTHER INFORMATION NOTICES
The general policy for Customers, Suppliers and Consultants is found here.


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