Customer Survey Information

Information pursuant to Article 13 of European Regulation No. 679/2016

1. Identity and contact details of the data controller
   Pursuant to Article 13 of the European Regulation no. 679/2016 “General Data Protection Regulation” (“GDPR”), we inform you that the Data Controller (or “Controller”) is Comecer S.p. A. (or “Comecer”), based in Castel Bolognese, (RA), via Maestri del Lavoro, 90 and can be contacted by mail at the head office or by e-mail at the following address: [email protected].
2. Purpose, data processed, and lawfulness of processing
   The personal data (“Personal Data”) collected (first and last name, company e-mail, country, company, industry/business unit) are processed in order to allow Comecer to carry out surveys and statistical activities in relation to the products and services provided and the perception of the brand by customers after requesting the consent of the data subject pursuant to Art. 6(a) GDPR to carry out this activity.
3. Nature of conferment and method of processing
   Personal Data is provided on an optional basis; failure to provide it will make it impossible to carry out the activities for which consent is requested. We remind you that you may always revoke your consent by making a request to [email protected]. Following this request, Comecer will not proceed with sending any further surveys to you.
   Personal Data shall be processed through manual processing or computer or telematic tools, solely by Comecer’s staff expressly authorised and trained to do so, allowed to access to Personal Data to the extent and within the limits necessary to carry out the processing activities covered by this notice.
4. Disclosure and transfer of Personal Data
   For the purpose of sending the surveys, Personal Data may be communicated to people within the Company’s organisation who act as authorised processors and will in no way be disclosed to unauthorised external third parties.
   Moreover, the fact that the Company belongs to the multinational group ATS may imply a circulation of Personal Data outside the territory of the European Union and the European Economic Area (“EEA”), which qualifies under Article 44 of the GDPR as a transfer of Personal Data to third countries. In this context, Personal Data will always be processed in accordance with the provisions of Articles 45 et seq. of the GDPR. In particular, as regards the possible transfer of Personal Data to the company ATS Automation Tooling System Inc. as the Company’s ultimate indirect parent company, based in Cambridge – Ontario (Canada), it should be noted that such transfer will take place on the basis of the European Union Commission’s adequacy decision of 20 December 2001. Apart from the aforementioned cases, your Personal Data will not be disclosed or transferred to third parties outside the territory of the European Union.
5. Retention periods for Personal Data
   Your Personal Data are kept by Comecer for the period of time necessary for the purposes for which they are processed and, in any case, no longer than 24 months from the date on which you gave your consent and without prejudice to your right of revocation.
6. Rights of the data subjects
   With respect to the Data Controller, with reference to the processing of personal data carried out by the same, it is possible, at any time, to exercise the rights provided by the GDPR and in particular: the right to access personal data and to obtain a copy thereof (art. 15 GDPR); the right to rectification of personal data (art. 16 GDPR); the right to erasure of personal data (art. 17 GDPR); the right to restrict the processing of personal data (Art. 18 GDPR); the right to data portability (Art. 20 GDPR); the right to object to processing (Art. 21 GDPR); and (where applicable) the right to revoke freely given consent at any time without affecting the lawfulness of the processing based on the consent given before revocation (Art. 7 GDPR).

These rights may be exercised by sending an appropriate request to the Data Controller by e-mail to: [email protected].

Requests regarding the exercise of rights will be processed without undue delay and, in any case, within 30 days of receipt of the request.

In any case, it is always possible to lodge a complaint with the competent supervisory authority pursuant to Article 77 GDPR if it is considered that the processing of personal data is contrary to the relevant legislation in force. For Italy, the supervisory authority is the “Garante per la protezione dei dati personali”, which can be contacted in the manner indicated at the following link: https://www.garanteprivacy.it/web/garante-privacy-en/home_en