Privacy Policy

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Comecer Commitment to Data Privacy Compliance

Comecer S.p.A., a member of the ATS Corporation Group of Companies, is committed to compliance with all applicable country-specific data privacy laws, including but not limited to, the EU General Data Protection Regulation (GDPR). Protecting the privacy and security of your Personal Data is of the highest importance to Comecer; therefore, we conduct our business by abiding by applicable laws on data privacy and data security in every country in which we operate.

This Global Data Privacy Policy (the ‘Privacy Policy” or the ‘Policy”) tells you about Comecer’s policies and practices for the collection, use, processing, storage, hosting, transfer, and disclosure of information that we may collect about you through our sites and services, including, but not limited to the website or subdomains of www.comecer.com, lp.comecer.com, lbc.comecer.com, and www.centroditaratura.it (e.g. our public facing sites and support site) and other websites (including mobile websites and apps) owned and controlled by Comecer S.p.A. (the “Sites”). Before using our Sites and services, you will be asked to provide your authorization and consent, agreeing to the terms of this Privacy Policy and consenting to the processing of information about you as described here and in compliance with relevant data protection laws, including the GDPR. The collection, use, storage, transfer and disclosure of your Personal Data will be strictly limited to the terms for which you provide your authorization. For the purpose of this Policy, the reference to Personal Data includes the term “personally identifiable information” and “personal information”.

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. For any further information concerning the processing of Personal Data and the Data Processors, please contact [email protected] or the ATS/Comecer Global Data Protection Officer, Sheila FitzPatrick, at [email protected].

Personal data

Through our Sites, Comecer will not collect any Personal Data about you (e.g., your name, address, telephone number or e-mail address), unless you voluntarily choose to provide us with it (e.g., by registration, survey, contest participation), provide your explicit consent, or unless otherwise permitted by applicable laws and regulations for the protection of your Personal Data.

Purpose of Use

When you do voluntarily provide us with Personal Data, we will use it only for the purpose for which you have provided it, for example, to respond to your inquiry, process your orders, register you for an event, provide information related to Comecer products, services and events, manage your support accounts, offer you the opportunity to participate in surveys and contests, register for Comecer training courses, or provide you access to additional information or offers. Also, to support our relationship with you:

  • we may store and process Personal Data and share it with our worldwide affiliates to better understand your business needs and how we can improve our products and services; or
  • we (or a third party on our behalf) may use Personal Data to contact you about a Comecer offer in support of your business needs or to conduct online surveys to understand better your needs.

If you choose not to have your Personal Data used to support our relationship (especially direct marketing or market research), we will respect your choice. We do not sell or otherwise market your Personal Data to third parties. At this link you might find the detailed purposes according to which your Personal Data are processed and the legal basis for such personal data processing.

Information That We Collect and Use

We collect Personal Data needed to address your specific interests and requests identified through our Sites. Examples of personal information are name, address, telephone number, e-mail address, company name, position and any other contact details you willingly provide to us. For a complete list of all data elements that we collect and the use of those data elements, contact us at [email protected].

We collect Personal Data about those who communicate with us such as e-mail address, user-specific information on what pages visitors access or visit, and information volunteered by the visitor, such as survey information and site registrations. This information is used to personalize our communications with you about products that are specific to your needs and interests. Rather than burden you with information that is not relevant or of interest to you, we try to target information that is specifically important to you. No Personal Data is collected, used, accessed, stored, transferred, or distributed without your explicit authorization unless absolutely required to manage this website or respond to a request you have made unless allowed under local law. At any time, even after you have given authorization, you can opt out of receiving these communications by selecting “unsubscribe”.

We use the information that we collect to improve the content of our webpages by incorporating information that is relevant to our clients, to notify customers about updates to our Sites, to contact customers for marketing and sales purposes (including notifications related to product enhancements, warranties, and renewals) that are related specifically to their needs and interests, to track applicants for career opportunities, and to communicate with our partners. This information is not shared with other organizations for any reason, commercial or business, without your prior explicit consent.

If you browse and/or apply for jobs in the Careers portion of our Sites, your application and any additional information that you provide may be used to assess your skills and interests against career opportunities at ATS Corporation and for reporting purposes as may be required by Italian law or country-specific laws. This Careers portion of our site is directly hosted and managed by ATS Corporation. This usage is covered in the initial authorization that you provide to ATS Corporation, including Comecer. When you access our Recruitment System, you are asked to provide your authorization for us to collect, use, process, store, transfer and distribute your Personal Data before you enter any Personal Data. We use your information to communicate with you and to inform you of career opportunities.

Comecer uses third-party entities to provide valuable services on our behalf. We will only share your Personal Data with them in a legally compliant manner. Third parties with which we share your information are bound by all relevant data privacy laws, including the GDPR, terms of confidentiality, contractual agreements, including data processing agreements, and this Privacy Policy. All of our approved third-party providers go through an extensive data protection compliance vetting process before being selected as a third party provider. Please contact [email protected] with any questions related to our third-party providers.

Comecer may supplement the data it collects with additional data received from third-party sources, by using data append services or data brokers. The additional supplemental data consists of contact, company, and industry data, as well as title, department, address, phone number, and updated e-mail addresses. When using the information provided through these services, we will contact you via email to obtain either your explicit opt-in to continue marketing to you, or your explicit opt-out to remove you from our contact database, depending on the applicable data privacy regulation. For additional information about supplemental data and the third-party sources, contact us at [email protected].

The company does not sell, rent, or trade your Personal Data with third parties for any purpose. If you do not want to receive e-mails from us in the future, you may unsubscribe at any time or you may contact [email protected]. Comecer follows the country-specific requirements, including the GDPR, to implement the opt-out within the legally allowed time period.

If you supply us with your postal address online, as well as your consent, you may receive periodic mailings from us with information about new products and services or upcoming events. If you do not want to receive such mailings at any point after your consent has been given, contact us at [email protected] or write to us at the postal address provided under the Controller information. Send us your name and address and we will remove your name from all lists that we use internally and/or share with other noncommercial organizations. Comecer follows the country-specific requirements, including the GDPR, to implement the opt-out within the legally allowed time periods.

If you give us your telephone number online, and provide consent, you may receive telephone calls from us with information about new products and services or upcoming events. If you do not want to receive such telephone calls at any point after giving your consent, contact us at [email protected] or write to us at the postal address provided under the Controller information. Send us your name and phone number and we will remove your name from all lists that we use internally and/or share with other noncommercial organizations. Comecer follows the country-specific requirements, including the GDPR, to implement the opt-out within the legally allowed time periods.

Customers and applicants can prevent their information from being used for purposes other than those for which it was originally collected and for which consent was given by contacting us at [email protected].

Upon request, Comecer offers visitors the ability to have their information deleted or corrected for inaccuracies. To have your information deleted or corrected, contact us at [email protected] or write to us at the address provided under Controller information. We will respond to your request within the country-specific time frames.

If you use communities, blogs, or chat rooms on Comecer sites, to the extent they are available, you should be aware that any Personal Data you submit there can be read, collected, and used by other users of these forums, and could be used to send you unsolicited messages. Comecer is not responsible for the Personal Data that you choose to submit in these public forums.

For each visitor to our Web page, our Web server automatically recognizes only the visitor’s domain name, but not the e-mail address.

Data Retention

Comecer will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy and/or in accordance with applicable federal, regional, country, state, provincial or local data retention regulations, including the GDPR. At the above link you might find the applicable data retention time.

Purpose Limitation

Comecer will collect, use or disclose Personal Data supplied by you online only for the purposes disclosed to you, unless the disclosure:

  • is a use of the Personal Data for any additional purpose that is directly related to the original purpose for which the Personal Data was collected
  • is necessary to prepare, negotiate and perform a contract with you
  • is required by law or the competent governmental or judicial authorities
  • is necessary to establish or preserve a legal claim or defense
  • is necessary to prevent fraud or other illegal activities, such as willful attacks on Comecer information technology systems.

Communications or Utilization Data

Through your use of telecommunications services to access our Sites, your communications data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to Personal Data. To the extent that there is a compelling necessity, the collection, processing and use of your communications or utilization data will occur and will be performed in accordance with the applicable data protection legal framework.

Non-Personal Data Collected Automatically

When you access our Sites, we may automatically (i.e., not by registration) collect non-Personal Data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed). We may use this data and share it with our worldwide affiliates to monitor the relevancy of our Sites and improve their performance or content.

“Cookies” – Information Stored Automatically on Your Computer

Propensity management is the management of an individual’s inclination or natural tendency toward certain interests, products, needs, and so on. In order to tailor our communications with you to make sure that we are addressing your specific needs and not overwhelming you with unwanted information, we use cookies to handle propensity management. A cookie is a piece of information that is stored on your computer’s hard drive by your Web browser. When you revisit ATS Sites, our server recognizes the cookie, giving us information about your last visit. Most browsers accept cookies automatically, but you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you can still use most of the features of our Sites.

This privacy statement covers the use of propensity management by this site only and does not cover the use of propensity management by any advertisers. We work with companies that use third-party cookies and web beacons to collect anonymous information that helps us measure and improve our content and advertising effectiveness. These companies collect and analyze anonymous usage and volume statistical information from our users. This data is collected only in aggregate form.

Comecer complies with all applicable global regulations regarding the use of cookies, including the EU Cookie Directive and e-Privacy Regulation. Visitors to our Sites are asked to provide their consent before we place any cookies on your device. At this link you might find detailed information regarding Comecer’s use of cookies.

Clear Gifs (Web Beacons, Web Bugs)

We may employ software technology called clear gifs (also known as web beacons or web bugs) along with other technologies such as e-tags, javascript, and/or other capabilities that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies that are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs, which are about the size of a period, are embedded invisibly on Web pages. We do not tie the information gathered by clear gifs, e-tags, or java scripts to anyone’s personally identifiable information. For detailed information regarding Comecer’s use of clear gifs and other technologies, please refer to the Comecer Cookie Policy.

Children

Comecer will not knowingly collect Personal Data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose Personal Data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of “child” or “children” should take into account applicable laws as well as national and regional cultural customs.

Security

To protect your Personal Data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access, Comecer uses industry standard technical and organizational security measures.

Links to Other Websites

Comecer Sites contain links to other websites. Comecer is not responsible for the privacy practices or the content of other websites.

Data Security Breaches

To protect your Personal Data from unauthorized access and use, or accidental loss and destruction, Comecer has implemented strict security controls and intrusion detection software to notify us in the case of any potential or actual invasion of our systems. We have implemented a Data Breach Notification Policy and have established an Incident Response Team that has been trained to react immediately to any unauthorized access of our databases and systems. Should any data security breach occur that materially and negatively impacts your Personal Data, you will be notified as soon as possible once the breach has been determined.

Rights of the Data Subject

With respect to its role as a Data Controller, Comecer will take all reasonable steps to honor the following rights of data subjects:

  • Right to access and obtain a copy of your personal data
  • Right to rectification of personal data
  • Right to erasure of personal data
  • Right to limitation of the processing of personal data
  • Right to data portability
  • Right to object to processing
  • Right to revoke freely given consent

For additional information about your rights, Comecer’s obligations under each right, and how to exercise your rights, please contact [email protected].

If at any time you feel Comecer has not addressed your request to exercise your rights, you may lodge a complaint with the competent supervisory authority. In 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/home/footer/contatti

Do Not Track

Comecer may receive data lists containing your contact details from third parties. In countries, states, provinces or regions where Do Not Track laws are in place, Comecer will take every reasonable action to validate the lists we have received with the Do Not Track lists available through government agencies before communicating with you. Comecer abides by all Do Not Track regulations.

Questions and Comments

Comecer will respond to reasonable requests to review your Personal Data and to correct, amend or delete any inaccuracies. If you have any questions or comments about the Comecer Global Privacy Policy (e.g. to review and update your Personal Data), please send us your questions and feedback. You can contact us by sending an email to [email protected].

As the Internet, technology and our systems mature, so will our Data Privacy Policy. We will post changes to our Data Privacy Policy on this page. Please check this page regularly to keep up to date.

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