This information notice (hereinafter, "Privacy Notice") relates to the processing of your personal data (hereinafter, the "Personal Data") carried out by OFMECO HEAT TRANSFER TECHNOLOGY S.R.L., with registered office in Milan (MI), Corso Magenta 43, VAT number 11278760969, e-mail info@ofmecohtt.com (hereinafter, "OFMECO" or the "Data Controller"), also in compliance with EU Regulation 2016/679 (hereinafter, "GDPR").
1. Identity and contact details of the data controller
The data controller is OFMECO. Since the Data Controller is established on the Italian territory, no representative has been appointed.
The Data Controller has appointed a Data Protection Officer ('DPO'). The DPO can be contacted at the Controller's addresses info@ofmecohtt.com.
2. Purpose of processing and legal basis for processing
Your Personal Data will be processed for the following purposes
a) to send you direct marketing communications, newsletters, advertising material, by means of traditional contact systems and automated computer systems, including commercial or promotional communications by e-mail or SMS, or for market research and analysis. The legal basis for the processing is consent, expressed in accordance with the Privacy Policy;
b) for activities to determine your habits and preferences through profiling, in order to provide you with a personalised service. The legal basis is your consent, expressed in accordance with the Privacy Policy. In relation to the Personal Data processed, the disclosure of Personal Data is not a contractual obligation. You are free to provide Personal Data. If you fail to provide such data, OFMECO will not be able to provide you with a personalised service;
c) for purposes related to related legal obligations. The legal basis for the processing is
OFMECO's legal obligation to process Personal Data in accordance with applicable legislation.
3. Modalities of expression of consent
You can express your consent by signing a computerised document via specific flagboxes.
4. Method of processing and logic
- In relation to the Personal Data processed for the purposes referred to in point a) number 3 of the Privacy Policy (marketing purposes), the processing will be carried out through software for sending commercial information;
- In relation to Personal Data processed for the purposes referred to in point b) number 3 (profiling), the processing will be carried out by means of CRM-type software that allows us to define tastes and preferences in order to offer you personalised services and communications. For further details, see the next point of the Privacy Policy;
- With regard to the Personal Data processed and stored for the purposes referred to in point c), number 3 (legal obligations), the processing will take place by means of paper-based instruments, automated logics and the use of CRM-type management software that will allow for the best possible management of the fulfilment of legal obligations.
5. Automated decision-making and profiling
If you consent to the processing of your Personal Data in order to benefit from personalised services through profiling, your Personal Data may be subject to an automated decision-making process, with a specific algorithm that will decide which communications are best suited to your profile or which may be of most interest to you. The processing carried out in this way has, by way of example, the expected consequences of sending highly profiled commercial communications, sending invitations to events considered to be of interest to you, etc.
In accordance with Article 22 GDPR, you have the right to:
- Obtain human intervention in the decision-making process by OFMECO;
- Express your opinion;
- Obtain an explanation of the decision reached by OFMECO;
- Challenge the decision itself.
6. Source of Personal Data
Only Personal Data provided in accordance with the Privacy Policy will be processed.
The Controller will not process Personal Data from publicly accessible sources.
7. Recipients and categories of recipients of Personal Data
The following may be recipients of the Personal Data
- Communications companies that carry out commercial communication and profiling activities on behalf of the Data Controller, where consent has been given, and which have the status of data controllers;
- Companies offering information society services, including, in particular, those offering hosting services;
- Companies carrying out statistical and market surveys, where the relevant consent has been given;
- Auditing companies;
- The Controller's partner companies.
8. Data categories
Personal Data will be processed. Under no circumstances may special Personal Data as defined in Article 9 of the GDPR be processed.
9. Data Transfer
The Controller intends to transfer Personal Data to entities established in a country outside the European Union or to an international organisation. Such entities could be, for example, represented by:
- Communication companies that perform communication activities on behalf of the Controller;
- Communications company service providers;
- Controlled and/or controlling organisations.
The transfer of Personal Data to such entities, where established in a third country or an international organisation, is carried out subject to an adequacy decision by the European Commission, which has verified that the third country, the territory or one or more specific sectors within the third country, or the international organisation in question ensure an adequate level of protection of your rights. In any event, if OFMECO deems it appropriate, it reserves the right to enter into specific separate agreements obliging such entities to adopt adequate security measures, including organisational measures, aimed at providing appropriate guarantees for your rights. Personal Data may thus be transferred to the following countries: United States of America. To obtain a copy of such Personal Data or the place where it has been made available, simply send your request to OFMECO, at the email address info@ofmecohtt.com.
10. Retention period of Personal Data
- The Personal Data processed for the purposes set out in point a) number 3 of this policy (marketing purposes) are processed and stored by OFMECO until you request their deletion and/or revocation, in your capacity as Data Subject;
- Individual Personal Data processed for the purposes of point b) number 3 (preference determination purposes), as acquired from time to time, shall be processed and stored by OFMECO for a period of time not exceeding twelve (12) months from the collection;
- The Personal Data processed and stored for the purposes set forth in point c), number 3 (fulfilment of legal obligations) shall be processed and stored by OFMECO in accordance with the provisions of the laws in force, in any case for a period of time not exceeding 10 (ten) years starting from the termination of the effects of the contract in case of conclusion of the same, unless otherwise required by law.
11. Optionality of consent and consequences of non-consent
- In relation to Personal Data processed for the purposes referred to in point a) number 3 of this notice (marketing purposes), the disclosure of Personal Data is not a contractual obligation. You are free to provide Personal Data. If you do not provide such Personal Data, OFMECO will not be able to carry out any marketing activities.
- In relation to Personal Data processed for the purposes set out in point b) number 3 of this notice (preference determination purposes), the disclosure of Personal Data is not a contractual obligation. You are entitled to provide Personal Data. If you do not provide such Personal Data, OFMECO will not be able to carry out any profiling activities.
- In relation to Personal Data processed for the purposes referred to in point c) number 3 of this notice (legal obligations), the disclosure of Personal Data is a legal obligation.
12. Your Rights
a) Right of opposition
As a Data Subject, you have the right to object in the following terms:
- The Right to object at any time, on grounds relating to your particular situation, to the processing of Personal Data relating to you pursuant to Article 6(1)(e) or (f) of the GDPR. The Controller shall refrain from further processing your Personal Data, unless the Controller demonstrates the existence of compelling legitimate grounds for processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;
- Where Personal Data is processed for direct marketing purposes, you have the right to object at any time to the processing of Personal Data relating to you carried out for such purposes, including profiling insofar as it is related to direct marketing;
- If you object to processing for direct marketing purposes, your Personal Data will no longer be processed for such purposes. You may object to the processing of your Personal Data for direct marketing purposes even partially, e.g. by objecting only to the sending of promotional communications by automated and/or digital means, or to the sending of paper communications and/or the receipt of telephone communications;
- Where your Personal Data is processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, you have the right to object to the processing of Personal Data on grounds relating to your particular situation, except where the processing is necessary for the performance of a task carried out in the public interest public interest.
b) Other Rights
OFMECO also wishes to inform you of the existence of your following rights:
- Right of access: you have the right to obtain from OFMECO confirmation as to whether or not personal data concerning you is being processed and to access your Personal Data and specific information, in accordance with article 15 of the GDPR;
- Right of rectification: you have the right to obtain from OFMECO the rectification of inaccurate Personal Data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration, in accordance with Article 16 of the GDPR;
- Right to data deletion, including the right to withdraw consent: you have the right to obtain from OFMECO the deletion of your Personal Data without undue delay or to withdraw your consent to the processing, if the grounds defined in Article 17 of the GDPR exist. You have the right to revoke your consent at any time, without affecting the lawfulness of the processing based on the consent you gave before revocation;
- Right to restriction of processing: you have the right to obtain from OFMECO the restriction of processing, when the hypotheses defined in Article 18 of the GDPR apply;
- Right to data portability: you have the right to receive, in a structured, commonly used and machine-readable format, your Personal Data provided to the Data Controller and you have the right to transmit it to another Data Controller without hindrance from OFMECO, as provided for in article 20 of the GDPR
- Contractor's right to object to commercial communications: as a contracting party, you have the right to object at any time, free of charge, to receiving commercial communications from OFMECO;
- Right to lodge a complaint with the Data Protection Authority: you have the right to lodge a complaint with the Data Protection Authority, in order to complain about a breach of data protection regulations, in accordance with Article 77 of the GDPR.
13. How to exercise your rights
You may exercise the rights indicated in the Cookie Policy by addressing your requests directly to OFMECO at the e-mail address info@ofmecohtt.com, or by sending the relative communication by registered letter with return receipt to the address Piazza Franco Marenghi 2, zona Boma - Tower B1, 46100 Mantova (MN). You may lodge a complaint with the Authority for the Protection of Personal Data according to the procedures provided for by the official website, addressing it to the contact details available at https://www.garanteprivacy.it/home/footer/contatti.
14. Accessibility of Privacy Policy
The Privacy Policy is available at the URL www.ofmeco.com/privacy-policy.
15. Modifications
OFMECO may amend the Privacy Policy, also to adapt to changes in national and/or European Union legislation, or to technological innovations. Any new versions of the Privacy Policy will be posted on www.ofmeco.com (hereinafter, the "Site"). We encourage you to periodically check the Privacy Policy. Any changes will be communicated to you through a pop-up on the Site or by other means and/or computer tools. If OFMECO substantially modifies the Privacy Policy, providing for new processing purposes and/or categories of Personal Data processed, OFMECO shall inform you, requesting the necessary consents, by means of a pop-up on the Site or by different methods and/or IT tools.
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