Nuestra Política de Privacidad

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ver. 3 of 17/02/2022

Dear User,
We care about your Personal Data and we are committed to protecting and processing them with the utmost attention and diligence.

We would like to provide you with clear information about the means of the processing regarding Personal Data collected through the web sites www.comecer.com, lp.comecer.com, and ibc.comecer.com (Web Sites), directly given by you, or anyway generated by the use of the website, in compliance with the provision of Art. 13 of the Regulation (EU) no. 679/2016 “General Data Protection Regulation” (“GDPR”).

In order to ensure quick analysis of the Information, we have decided to divide the text in specific sections which can be directly read by clicking on the relevant title in the index below:

INDEX

Terms and Definitions

Data Controller

Personal Data Processed and Purposes of the Processing

Means of Data Processing

Who Process your Personal Data and the Categories of Recipients

Personal Data Storage Period

Rights of the Data Subject

How to contact the Data Controller

Cookie Policy

Terms and Definitions

Terms	Definitions
Supervisory Authority	The Supervisory Authority responsible for monitoring the application of the GDPR provisions in Italy is the Data Protection Authority with registered office in Piazza Venezia, 11 Rome.
Personal Data	Any information relating to an identified or identifiable natural person that may reveals his/her physical appearence, habits, lifestyle, health, political opinions, economic situation, etc.
Rights of the Data Subject	Rights exercisable by the Data Subject pursuant to the GDPR.
Data Subject	Natural person to whom the Personal Data are referred.
Processor	Natural or legal person, public authority, agency or other body which process personal data on behalf of the controller.
GDPR	Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of Personal Data.
Privacy Officer	The Company department appointed by the Data Controller to monitor the implementation of GDPR provisions.
Data Controller	Natural or legal person, public authority, agency or other body, which determines the purposes and means of the processing of personal data; in this case Comecer S.p.A.
User	Natural person who visits and interacts with the website.

Data Controller

The Data Controller is Comecer S.p.a. (“Comecer” or the “Company”), with registered office in Castel Bolognese (RA), Via Maestri del Lavoro n. 90.

The management of the Web Sites takes place also with the support of specialized suppliers, appointed by Comecer as Data Processor pursuant to Art. 28 of GDPR.

For any further information concerning the processing of Personal Data and the Data Processors, it is possible to contact directly the Data Controller by sending an email to the address of the Privacy Officer: [email protected].

Personal Data Processed and Purposes of the Processing

The simple navigation on the Web Sites shall not imply the collection of any Personal Data by Comecer
The IT systems of our Web Sites shall collect only some Personal Data, the transmission of which is implicit in the use of internet communication protocols. These information are not collected to be associated with you; however, by their own nature, they could, through processing and association with data held by third parties, allow users to be identified only in the event that it is necessary in relation to infringements.
The above data are used to obtain anonymous statistical information on the use of the Web Sites and to check its correct functioning; in order to allow – given the architecture of the systems used – the proper delivery of the various functions you requested, for reasons of security and assessment of liability in the event of computer crimes against the Web Sites or third parties and they shall be stored for the period of time strictly necessary for the purposes for which they were collected, except if it is necessary to store them for a longer period for the defence or exercise of rights.
Using the Web Sites, you can voluntarily provide us your Personal Data – such as your name, surname, date of birth, contact details (phone number, email, employer) country and other data – used to contact the Controller through the forms to be completed in the website or to ask information about Comecer products/services and activities. Comecer shall process these Personal Data in compliance with applicable law, assuming that they refer to you or to third parties that expressly authorized you to communicate their Personal Data on the ground on an appropriate legal basis that makes the processing legitimate.
In order to allow Comecer to provide a prompt answer to your information request, the IT systems of the Web Sites shall collect the following categories of personal data: identification data (such as IP address or domain names of devices used by users to navigate the website); data concerning provenance indications (such as referrer or the source from which you find the website); address of the webpage and data provided through the forms on the website.
After you completed the forms, you will receive an email by Comecer Marketing Office, confirming that your request has been taken in charge and it will be sent to the competent department in order to provide you the information/assistance requested.
Using the Web Sites, you can also have the chance to register to freely access to the contents (information and commercial materials) published by Comecer in the reserved section of the Web Sites.
With regard to Personal Data voluntarily provided through the registration form on the Web Sites and to Personal Data collected by the computer system of the Web Sites in order to manage your registration request, please refer to paragraph B above.
In addition, once you completed the registration procedure in the reserved section of the Web Sites, in order to provide you the requested services, the IT systems of the Web Sites shall collect also the following categories of personal data: event date login/logout/password recovery; download pdf; personal data you included in the forms available also in other pages of the Web Sites.
Finally, we inform you that in order to complete your registration request in the reserved section of the Web Sites, we ask you to give your consent to the processing of your Personal Data also in relation to the following further purposes: i) newsletter service subscription in order to receive promotional communications and updates on Comecer activities; ii) collection of information about behaviours and commercial habits of the users in the sector in which the Company operates, in order to improve the services offered on the basis of client needs and check the effectiveness of the promotional and marketing strategies used.
After obtaining your consent regarding the aforementioned purposes, through the IT systems of the Web Sites, the following categories of Personal Data shall be collected: identification data (such as IP address); data concerning provenance indications (such as source of the data); information about the level of interest related to the communications sent (such as newsletter read, consulted).
At any time, you shall manage your Personal Data concerning the registration in the reserved section of the Web Sites as well as the related expressions of consent, by entering your profile area in the reserved section of the Web Sites. You can also exercise you rights pursuant to GDPR, including the right to rectification or erasure of your personal data, with the modalities indicated in the section “Contact the data Controller” of this Privacy Policy.

In the event you decide to apply for a job position offered by Comecer using the section “work with us” on the website, we shall process your personal data in accordance to what is described in the specific Privacy Information: https://www.comecer.com/jobs/

Information related to the use of cookies are available in the Cookie Policy, which you can find later on in this webpage (it is possible to find the direct link to the Cookie Policy by clicking on the corresponding title in the index).

Users’ Personal Data shall be processed for the following purposes and using the following means:

PURPOSES OF PROCESSING	Legal basis
To allow the users to navigate the Web Sites	Processing is necessary in order to take steps at the request of the data subject prior to entering into a contract (Art. 6, par. 1, lett. b GDPR)
To be compliant with the obligations provided by national and/or European law and regulations (such as tax liabilities)	Processing is necessary for compliance with a legal obligation to which the controller is subject (Art. 6. par. 1 lett. c GDPR)
To obtain the necessary information to find anomalies, fraudulent activities and/or abuses in the use of the website or to exercise Company rights	Legitimate interest of the data controller to the correct functioning of the website, to the prevention of illicit conducts and to exercise its rights (Art. 6, par. 1, lett. f GDPR)
To manage requests for information and/or quotation on our products/services, or to manage the candidacy for the job positions offered by the Company	Processing is necessary for compliance with a legal obligation to which the controller is subject (Art. 6. par. 1 lett. c GDPR)
To manage requests for qualification and access to the section of the Web Sites reserved for professionals in the sector in which the Company operates and the use of the related functions	Processing is necessary for compliance with a legal obligation to which the controller is subject (Art. 6. par. 1 lett. c GDPR)
To manage newsletter registration applications in order to receive marketing communications and updates on the Company’s activities	Processing is based on the data subject’s consent (Art. 6, par. 1, lett. a GDPR)
To collect information about behaviours and commercial habits of the users in the sector in which the Company operates, in order to improve the services offered on the basis of client needs and check the effectiveness of the promotional and marketing strategies used (profiling)	Processing is based on the data subject’s consent (Art. 6, par. 1, lett. a GDPR)

How we process your Personal Data

Your Personal Data can be freely provided or, in the event of web navigation data, automatically collected during the use of the Web Sites. Where it is specified in the form on the Web Sites (Personal Data marked by an asterisk), the provision of Personal Data is necessary to provide you the service requested: if you refuse to communicate these Data, it may be impossible for the Data Controller to fulfil your request. On the contrary, with reference to Personal Data not marked as mandatory, you can refuse to communicate them and this refusal shall not have any consequence on the service availability or on the functioning of the Web Sites.

The provision of your Personal Data for the registration to the newsletter service, the sending of promotional communications or profiling implemented by the Data Controller is optional, consequently you can freely decide whether or not give your consent, or withdraw it at any time. Therefore, if you decide not to give your consent, Comecer will not be able to carry out the aforementioned activities.

Some sections of the Web Sites contain free spaces in which you can include special categories of Personal Data and communicate them to the Company (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation – Art. 9 of GDPR). Comecer asks you expressly to avoid providing these categories of Data. In the event in which you voluntarily choose to give us these Data, the Company may decide not to process them or to process them only with your specific consent or, in any event, in compliance with the applicable law.

The accidental processing of third party Personal Data that you communicated to Comecer may also occur. In this event, you become an autonomous Data Controller and assume all the related obligations and responsibilities provided by the law. In this regard, as of now, you exempt the Company from any liability arising from any claims or requests made by third parties, whose Data have been processed by us because of your spontaneous communication of them to us, in violation of the law on the protection of Personal Data. In any event, if you provide or process third party Personal Data, you must guarantee as of now, assuming any related responsibility, that this particular hypothesis of processing is based on a legal basis pursuant to Art. 6 of GDPR.

Who processes your Personal Data and the categories of Data Recipients

Your Personal Data given to us through our Web Sites shall be processed by Company employees, authorized by Comecer and adequately trained on the correct means of the processing for the purposes indicated in the section “Data Processed and Purposes of Processing”.

Your Personal Data cannot be transferred to other Countries, but they can be communicated to third parties in charge of implementing the necessary activities to provide the services offered by the Company, such as: subjects delegated to carry out technical maintenance, including maintenance of network equipment and electronic communications networks and providers of platforms for sending e-mails. Comecer appointed them as Data Processors pursuant to Art. 28 of GDPR and gave them specific instructions for the proper processing of personal data. Finally, Personal Data may be disclosed to private parties or public authorities that have access to them according to law provisions or other measures issued by competent authorities.

Personal Data Storage Period

Personal data provided for information/quotation requests on our products/services or assistance requests shall be stored for the period of time strictly necessary to answer the request and to implement the related assistance or supply.

Personal Data registered in the reserved section of the Web Sites shall be stored until the User decides to unsubscribe from the service.

Personal Data provided for newsletter registrations and the sending of marketing communications shall be stored for 24 months from the day of the last contact, except in the event of consent withdrawal or renewal of the consent before this deadline.

Personal Data processed for profiling shall be stored for 12 months from the day of the last contact, except in the event of consent withdrawal or renewal of the consent before this deadline.

At the end of the aforementioned periods Personal Data shall be erased or anonymized, except in the event in which the Company must store these Data for longer period according to the law, or if it is necessary for the resolution of judiciary/pre-judiciary disputes.

Rights of the Data Subject

As a Data Subject, you can exercise the following rights:

Right of Access	obtain from the controller confirmation as to whether or not personal data concerning you are being processed, more information on the processing and copy of the personal data processed
Right to Rectification	obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning you and the right to have incomplete personal data competed
Right to Erasure	obtain from the controller, without undue delay, the erasure of personal data concerning you
Right to Restriction of Processing	obtain the restriction of the processing in the event you assume that your data are incorrect, the processing is illegal or if these data are necessary for the establishment of legal claims
Right to Data Portability	receive the personal data concerning you, which you has provided to a controller, in a structured, commonly used and machine-readable format, in order to transfer these data to another Controller
Right to Object	Object, on grounds relating to your particular situation, to the processing of personal data concerning you, unless the controller demonstrates compelling legitimate grounds for the processing. You can also object to processing your data where them are processed for direct marketing purposes
Right to withdraw the Consent	withdraw the consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal

Contact the Data Controller

You may exercise your above listed rights or ask information to the Controller sending an email to Comecer Privacy Officer at the following address: [email protected] or sending a letter in a sealed envelope to the Company headquarters, located in Castel Bolognese (RA), Via Maestri del Lavoro 90, to the attention of Comecer Privacy Officer.

We remind you that you also have the right to lodge a complaint to the competent supervisory authority, which is the Italian Data Protection Authority. To have more information about this right you can visit this website: https://goo.gl/GLbTN9

What is a cookie?

A cookie is a small file that a site sends to the browser and saves on your computer when you visit a website. Cookies are used to make the site work or to improve its performance, but also to provide information to site owners.

Depending on the function and purpose of use, cookies can be divided into technical cookies, profiling cookies, and third-party cookies.

Technical cookies

Technical cookies are those whose use does not require the user’s consent. These cookies are essential in enabling you to browse a website and use all its features. Without these cookies, which are absolutely necessary, a website could not provide some services or features and navigation would not be as easy as it should be. A cookie of this type is also used to store the decision of a user on the use of cookies on the website itself.

This category also includes performance cookies, which are sometimes also called analytics cookies. These are cookies that collect information about the use that a user makes of a website and that allow for its operation to be improved. For example, performance cookies show which pages are most frequently visited, allow you to check what are the recurrent patterns of use of a website, help in understanding every difficulty that the user encounters in use and show the effectiveness of advertising which is published on the site.

Technical cookies are essential and cannot be disabled using the functions of this website. In general, cookies can be deactivated completely in your browser at any time.

Technical cookies used on the website

Name: _ga
Description: Allows for collecting statistical information in anonymous and aggregated mode (first-party cookies generated by Google Analytics).
Further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Duration: 2 years

Name: _gid
Description: Allows for collecting statistical information in anonymous and aggregated mode (first-party cookies generated by Google Analytics).
Further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Duration: 24 hours

Name: __utma
Description: Allows for collecting statistical information in anonymous and aggregated mode (first-party cookies generated by Google Analytics).
Further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Duration: 2 years

Name: __utmc
Description: Allows for collecting statistical information in anonymous and aggregated mode (first-party cookies generated by Google Analytics).
Further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Duration: session

Name __utmz
Description: Allows for collecting statistical information in anonymous and aggregated mode (first-party cookies generated by Google Analytics).
Further information: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
Duration: 6 months

Name: wordpress_logged_in_[hash] and wordpress_sec_[hash]
Description: Sessions management cookies. Required for managing authenticated Users.
Further information: https://codex.wordpress.org
Duration: for the time of the session

Name: wordpress_sec
Description: protects against hackers, stores account details.
Duration: 15 days

Name: wp-settings-1 and wp-settings-time-1
Description: WordPress management cookies maintain User settings and preferences and enable the main site functionality.
Further information: https://codex.wordpress.org
Duration: 1 year

Name: PHPSESSID
Description: Technical session cookie establishes a User session and communicates status data through a temporary cookie, commonly called session cookies. Since the PHPSESSID cookie has no expiration time, it disappears when the browser is closed. It does not contain any personal information.
Duration: for the time of the session.

Name: gdprCookieConsent
Description: Technical cookie that stores preferences for the use of cookies.
Duration: 1 year

Name: _icl_current_language
Description: Cookie that stores language settings
Duration: 1 day

Stastistical Cookie

Name: __hssrc
Description: Performance third-party cookie. Whenever HubSpot changes the session cookie, this cookie is also set to determine whether the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
Duration: time of the session

Name: __hstc
Description: This cookie is linked to websites that use the HubSpot platform. They report this name as being used for website analysis.
Duration: one year

Name: __hssc
Description: This cookie is linked to websites that use the HubSpot platform. They report this name as being used for website analysis.
Duration: 30 minutes

Targeting / Tracking /Advertising cookies

Name: hubspotutk
Description: This cookie name is associated with websites that use the HubSpot platform. This cookie is used to keep track of a visitor’s identity. This cookie is passed to HubSpot when the form is submitted and used during contact deduplication.
Duration: 1 year

Name: _gcl_au
Description: This cookie is set by Google Analytics to take information in advert clicks and store it in a 1st party cookie so that conversions can be attributed outside of the landing page
Duration: 3 months

Name: _fbp
Description: Facebook Pixel advertising first-party cookie. Used by Facebook to track visits across websites to deliver a series of advertisement products such as real-time bidding from third-party advertisers.
Duration: 90 days

Third-party cookies

A web page can also contain cookies from other sites and content in various elements hosted on the page itself, such as banner ads, images, videos, etc. In these cases, we are speaking of so-called third-party cookies, which are usually used for profiling purposes.

This website uses third-party cookies.

Third-party cookies and targeting cookies used on the site

Third-Party: Hubspot
Description: HubSpot è marketing automation software
Useful links: https://knowledge.hubspot.com/reports/what-cookies-does-hubspot-set-in-a-visitor-s-browser

Third-Party: Google
Description: Google services on this site include Google Maps to display maps, Google reCaptcha to avoid the compilation of forms by bots and Youtube for viewing videos on www.youtube.com.
Useful links: https://policies.google.com/technologies/types

Third-Party: Google .doubleclick.net
Description: These cookies set by a third party (DoubleClick) and are used for serving targeted advertisements that are relevant to you across the web. Targeted advertisements may be displayed to you based on your previous visits to this website. For example, advertisements about a topic you have expressed an interest in while browsing our site may be displayed t you across the web. In addition, these cookies measure the conversion rate of ads presented to the User.
Useful links: https://www.google.com/policies/privacy/partners/

Third-Party: AddThis
Description: widgets for sharing content to numerous social networks (including Facebook, Twitter, Google+, Linkedin, YouTube, etc.).
Useful links: http://www.addthis.com/privacy/privacy-policy/

Third-Party: LinkedIn – SlideShare
LinkedIn SlideShare service for sharing and using slides (for example, produced with Microsoft PowerPoint). Some pages of this site could contain slides, in so-called embedding, made available to the User with this system.
Useful links: https://www.linkedin.com/legal/privacy-policy

Third-Party: LinkedIn – Ads
Third-party tracking for measuring and verifying LinkedIn’s ad performance.
Useful links: https://www.linkedin.com/legal/privacy-policy

How to disable cookies?

Most browsers (Internet Explorer, Firefox, etc.) are configured to accept cookies. However, most browsers allow you to control and even disable cookies through browser settings. We remind you, however, that disabling technical cookies can cause the site to malfunction and/or can limit the service we offer.

How to change the settings for:

Google Chrome
Mozilla Firefox
Internet Explorer
Safari

Refer to their technical documentation for other browsers.

To disable analytical cookies and to prevent Google Analytics from collecting data on your browsing, you can download the browser add-on to disable Google Analytics: tools.google.com/dlpage/gaoptout.

Comecer reserves the right to modify or update this information also in order to comply with new obligations imposed by laws or for technical reasons.