PRIVACY POLICY

Information pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”)

Dear Sirs,
we would like to inform you that the Regulation (EU) 2016/679 (the GDPR) provides for the protection of persons regarding the processing of personal data.

In accordance with the law, this treatment will be based on principles of correctness, lawfulness and transparency, protecting your privacy and your rights.

Under Article 13 of that Regulation, we therefore provide the following information.

1. Personal data processed, source of data, purpose of data processing, legal basis of processing and storage period

“Data” means those relating to natural persons treated by Comat srl for the stipulation and execution of the contractual / commercial relationship with its customers / suppliers, such as for example those of the legal representative of the customer / supplier who signs the contract in name and on behalf of the employees / consultants of the customer / supplier, involved in the activities referred to in the contract, the data of the group companies of the customer / supplier for which the latter signs the contract with the necessary powers of representation, any other information necessary for the execution of the contract and / or the provision of the service (s) (also indicated below); those supplied by subjects not belonging to the customer / supplier group through the sending of curricula and assessment interviews, direct contacts during exhibitions, fairs, and third party reporting.

The source from which the Data come is customer / supplier / other subjects.

In particular, said data will be processed for the following purposes.

A. MANAGEMENT OF THE CONTRACTUAL / COMMERCIAL REPORT such as: satisfaction of specific requests of the interested party before the conclusion of the contract; conclusion, modifications, execution of the contract; provision and management of related services (installation, activation and / or commissioning, maintenance and / or assistance, etc.); claims management.

The legal basis of the treatment is:

• Execution of the contract for the data of the legal representative of the supplier / customer
• Legitimate interest in the data of the employees / consultants of the supplier / customer involved in the activities referred to in the contract.

Data retention period: contract term and, after termination, for 10 more years. In case of judicial contentious, for the entire duration of the same, until the terms of practicability of the appeals are exhausted.

B. ADMINISTRATIVE – ACCOUNTING PURPOSE, such as: invoicing; management of payments, delays and missed payments; communication of the same Data between group companies, for organizational, administrative, financial and internal accounting purposes functional to the predicted activities.

The legal basis of the processing is the need to fulfil a legal obligation to which Comat srl is subject.

C. FULFILLMENT OF OBLIGATIONS OR RIGHTS EXERCISE under national or European Union law or collective agreements in accordance with national law, such as: fulfilment of obligations provided for by EU and national laws, in particular by laws, regulations, including contingent and urgent measures for the protection of public order, verification and prosecution of crimes.

The legal basis of the processing is the need to fulfil a legal obligation to which the data controller is subject.

Data retention period: contract term and, after termination, for 10 more years. In case of judicial contentious, for the entire duration of the same, until the terms of practicability of the appeals are exhausted.

D. judicial recovery of debts (IN CASE OF CUSTOMERS), such as: protection and possible credit recovery, either directly or through third parties (agencies / credit recovery companies) to which they will only be communicated for this purpose.

The legal basis of the processing is the legitimate interest.

Data retention period: contract term and, after termination, for 10 more years. In case of judicial contentious, for the entire duration of the same, until the terms of practicability of the appeals are exhausted.

E. IF NECESSARY, TO VERIFY, EXERCISE AND / OR DEFEND RIGHTS IN JUDICIAL PLACE.

The legal basis of the processing is the legitimate interest.

Data retention period: contract term and, after termination, for 10 more years. In case of judicial contentious, for the entire duration of the same, until the terms of practicability of the appeals are exhausted.

F. Resume filling and sending through the website www.comatfilters.com, the information contained in the curricula spontaneously sent through the company domain www.comatfilters.com are processed for purposes related to evaluation and selection, or to propose any other job offers consistent with the concerned person’s professional profile.

The legal basis of the processing is the interested party’s consent (optional and revocable at any time) and the legitimate interest.

Data retention period: the needed time to fulfil the purposes indicated. In particular, all the data referred to above will be kept for a period of no more than thirty months from receipt.

G. Information and promotional / marketing actions: such as, for example, sending of commercial/promotional communications, through automated methods of contact (such as e-mail) or traditional ones (such as phone calls with operator and traditional mailing) relating to services offered by Comat srl or reporting of company events, as well as the implementation of statistical analyses and the survey of satisfaction level.

The use of e-mail coordinates provided by the customer in the context of a product or service sale for the purpose of its products or similar services direct sale, is allowed only for purpose of newsletter and information sending. The interested party, at the time of collection and sending of each communication, is informed about the possibility to oppose at any time to the treatment, easily and for free. To unsubscribe from the mailing list, simply use the “unsubscribe” function at the bottom of each e-mail.

The legal basis of the processing is the interested party’s consent (optional and revocable at any time) and the legitimate interest.

Data retention period: until the interested party asks to unsubscribe from the promotional communication service / newsletter sending.

H. Security, pursuant to legislative Decree 81/2008. With reference to the identification data freely given by the host / visitor to our offices (name, surname, belonging institution or company), the treatment has the exclusive purpose of guaranteeing compliance with the corporate safety procedures formally applied, also in accordance with the current regulations (e.g. annotation in the register / visitor database, temporary badge identification, applications of legal obligations regarding job security).

The legal basis of the processing: need to fulfil legal obligations to which the holder is subject.

Data retention period: Data will be kept for the period required by law.

After the expiry of the retention periods indicated above, Data will be destroyed or made anonymous, consistent with the techniques of cancellation and backup procedures.

2. Communication area, parties authorized to process and transfer data to countries outside the European Union

Data may be disclosed to third parties operating as data controllers, by way of example, authorities and supervisory and control bodies and, in general, public or private entities, entitled to request data (e.g. banks and credit institutions; and other public authorities).

Data may be processed, on behalf of the owner, by external parties designated as data processors, who perform specific activities on behalf of the owner, for example, its distribution network, companies and agents carrying out the activity of debt collection for the owner, legal, tax and administrative consultants.

Data may be processed by employees of company departments responsible for the pursuit of the above-mentioned purposes, who have been expressly authorized to process and who have received adequate operating instructions.

Data may be transferred to countries outside the European Union, solely in relation to those in which the level of protection is deemed appropriate by the European Commission pursuant to art. 45 of the GDPR.

3. Data provision.

Data provision by the customer / supplier / other parties is optional, however any refusal to provide such Data could result in the non-performance or partial execution of the contract / service.

4. Data controller

The Data controller is the Managing Director and Legal Representative of Comat srl with registered office in via Po – Parabiago (MI) and operational headquarters in via Puccini 7 – Ossona (MI), telephone number: +39 02 90384121, fax number +39 02 90384017, mail privacy@comatfilters.com.

5. Interested party rights.

By contacting the Privacy Office by e-mail at privacy@comatfilters.com, the interested party can ask Comat srl for access to data concerning him / her, their deletion, the correction of inaccurate data, the integration of data incomplete, the deletion of data, the limitation of processing in the cases provided by art. 18 GDPR, and to oppose, for reasons connected with their situation, to the processing carried out by the legitimate interest of the owner.

Furthermore, if the treatment is based on consent or on the contract and is carried out using automated tools, the interested party shall have the right to receive the Data in a structured, commonly used and automatically readable form, as well as, if technically feasible, to transmit them to another holder without impediments.

The interested has the right to lodge a complaint with the competent Supervisory Authority in the Member State in which he is habitually resident or employed or of the State in which the alleged violation has occurred.

The interested party has the right to revoke the consent given at any time for the marketing purposes and to oppose the treatment of data processed for the same purposes. It is still possible for the person concerned who prefers to be contacted for the above purposes exclusively through traditional mode of manifesting its opposition only to receive communications through automated mode.

6. Changes to Privacy Policy

The Owner reserves the right to make changes, at any time, to this statement, giving appropriate notice to site users. In order to view any changes made, the user is invited to consult regularly this information, which in any case indicates the date of last update.