Privacy & Cookie Policy

POLICY

In accordance with art. 13 of Regulation UE 679/2016 and (“GDPR”) and Italian and European Law that incorporate it with their amendments and additions (“Privacy Applicable Law”), and in relation to the personal data that concern you (“Data”), we inform you as follows:

1. DATA CONTROLLER AND DATA PROTECTION OFFICER
   The Data Controller is C.M.D. S.p.A., with its registered office in Atella (PZ), at Nucleo Industriale Valle of Vitalba, in the person of its legal representative pro-tempore.In view of the types of personal data processing, the Data Controller has considered to designate, in accordance with art. 37 of European Regulation, a Data Protection Officer whom you may contact to the following address: C.M.D. Data Protection Officer, Via A. Pacinotti, 2 81020 San Nicola La Strada (CE) – Italy, or sending an email message to dpo@cmdengine.com.
2. PURPOSE OF DATA PROCESSING
   Data Processing by C.M.D.:
   1. It aims at carrying out by holder activities put in place for strictly connected and/or necessary purposes to the satisfaction of the demands made, from time to time, by the customer through the website https://www.cmdengine.com (respectively, The “Requests” and the “Website”) and/or by mail and fax. About the access to the restricted pages of the Website, you may be required to enter your personal data for registration. These data will be collected and processed in a form allowing the safety and compliance with European Regulation. The personal data of those who enter or register, via Social Network services (as Facebook – Twitter – Instagram – Linkedin) will be used for purpose related and instrumental to the registration and may also be used by C.M.D. for promotional, advertising and marketing purposes, such as the mailing of advertising, promotional and informative material on products and services, as well as for statistical analyses appropriate to detect the degree of website customers satisfaction and services and products users of C.M.D.;
   2. It is aimed at the execution of the commercial information activity of services provided by the Controller and/or other companies associated with them;
   3. It can be used for related purposes connected to the obligation from laws or applicable regulations, as well as provisions issued by a Supervisor Authority/Monitoring Control Bodies.
3. PROCEDURES AND DURABILITY OF DATA PROCESSING
   Data Processing:
   1. It is processed by using methods and procedures necessary to meet the Needs and is made by means of the operations or sets of operations as indicated in Art. 4, paragraph 1, point 2 of GDPR;
   2. It is also carried out with the aid of electronic or automated means. In this regard, it should be noted that data is stored in paper files located in the Controller office and in electronic files located in the Controller headquarters and third-party servers in Italy;
   3. It is also carried out with the aid of fax, email or others distance communication techniques. The Data Controller also uses the same methods when it discloses the Data to third parties for these purposes, as detailed in paragraph 6 below.
   4. The Data Processing is carried out with the aid of computer systems and procedures provided for the function of website collect certain personal information during normal operation, the transmission of which is subject to the use of data exchange protocols on the Internet network.These data are not gathered for association with identified subjects, but by their very nature, when processed or associated with data held by third parties, they might allow users to be identified.

      This category includes the IP addresses or names with domains of computers used by persons logging onto the site, the URI (Uniform Resource Identifier) addresses of the resources required, the URL of the requested resources, the time of request, the method used of subjecting the request to the server, the size of the file obtained in response, numeric code indicating the response status provided by the server (success, error ecc.) and other parameters relating to the user's operating system and IT environment.

      The latter, are used by Data Controller solely for purpose anonymous statistical information about the website and checking its proper running. In case of hypothetical computer crimes against the site, the data could be also used to ascertain responsibility.

   5. The Data is also processed through the use of “cookies” (namely of information that the site sends the user’s computer while browsing and that are related to the site contents itself to collect and recall information, in order to improve the Site). As far as the simple navigation of the Website is concerned, the types of data processed and the related specific information for "cookies" are specified below and the right procedures eventually so you can easily select if or how your personal data will be processed by means of this kind of technology.
      
      Technical cookies
      This website uses so-called “technical cookies”, which are small text files containing a certain amount of information exchanged between your website and your terminal (or your terminal browser) which allow the correct operation and use of the latter.

      Analytical cookies

      This Website uses so-called "analytical cookies" that are realized and made available by third parties, or rather, Google Analytics and Adobe Analytics. This happens for mere internal statistical analysis to improve the Website and to ease of use, and monitor its proper running. The Data Controller has in any case adopted the most suitable tools to reduce the power of identification of this type of cookie to the maximum.

      Profiling cookies

      This website uses so-called “Profiling cookies”. These cookies are not strictly necessary, but they allow us to custom and enhance your experience within the website. For example, they allow us to track and remember your purchase preferences and show you personalized and relevant advertisements. In addition, those ads also enable us to limit the number of times you see each advertisement, to measure the effectiveness of the advertising campaign, to remember your visit and share data collected with third parties.

      The elimination of these cookies, therefore, even if it does not compromise the general usability of the Website, may result in a limitation of some features. Options regarding the use of cookie on the Website through browser settings.

      The delivery of all cookies, can be deactivated by intervening on the settings of your browser. It should be noted that any changes on these settings could make the Website unusable where the cookies that are essential for the provision of our services were to be blocked. However, each browser has different settings for deactivating cookies.

   6. Regarding the durability of Personal Data Processing, unable to accurately determine the retention period, the Data Controller is now committed to inspire your data processing with the principles of expediency, relevance and data minimization, as required European Regulation, and periodically verifying the necessity of their retention. Therefore, once the purposes for which they were collected and processed are achieved, we will remove them from our systems and records and/or take any appropriate measures to render them anonymous, preventing your identification unless that such data will be stored to comply with regulatory obligations, or to ascertain, exercise or defend our right in court.

4. PROVISION DATA AND LEGAL BASIS OF THE PROCESSING

   Without prejudice to the personal autonomy of the person concerned, the provision of personal data can be:

   (a) mandatory according to Legislation or Regulation with reference to the purposes indicated in paragraph 2, letter (a) and (c) above.

   (b) optional with reference to the purposes indicated in point 2, letter (b) above. In this case, the Data will be processed with the prior consent of the data subject, required through specific pages of the Website from time to time.

5. REFUSAL TO PROVIDE PERSONAL DATA

   Any refusal by the data subject to supply the personal data or give consent to the processing when required:

   In cases referred to point 4, letter (a) and (c), will make it impossible for the holder to process applications;

   In case referred to point 4 letter (b), will make it impossible to process you sales and information campaigns of services rendered by the holder or other related companies.

6. DATA COMMUNICATION

   (a) The data can be communicated – for purposes of which to the point 2, letter (a) and (c), namely under specific legal obligations – to other subjects and in particular to consultants that assist the Data Controller for satisfaction requirements (for example Law and tax offices);

   (b) in addition the data can be communicated for purposes of which to the point 2, let. (b), to related companies.

7. DATA DISSEMINATION

   The Data are not subject to dissemination.

8. TRANSFER OF DATA ABROAD

   With the reference to the purposes referred to in Article 2, the data may be transferred to extra EU countries. In this case, we commit to include the standard contractual of data protection clauses approved by EU Commission for personal data transfer outside the EU or European Economic Area (EEA) in our contracts with third parties (this is the contractual term approved in accordance with Article 46.2 of General Data Protection Regulation (“GDPR”) or making sure that the Country in which information will be managed was deemed appropriate by EU Commission in accordance with Article 45 of RGPD. For what concerns the Data Transfer to the People’s Republic of China, it should be noted that there’s no adequacy decision in relation to the data protection level guaranteed in China and there aren’t other appropriate safeguards. In absence of adequacy decision and appropriate safeguards the transfer is according to the condition referred to Art. 49.1 letter (c) of Regulation, because, if it is required, the data transfer will be for concluding or fulfilling the contract between Data Controller and another natural or legal person in favor of the interested party.

9.  DIRITTI DELL’INTERESSATO

   9.1 – We lastly inform you that, in relation to personal data in our possession, you may exercise the rights provided by the Privacy Applicable Law. In particular, you can:

   a) request the controller about confirmation concerning the existing of personal data, the origin of such data, reason and purpose of the processing, the categories of persons to whom the information may be disclosed, and identification details of Data Controllers and Managers;
   b) request the access to Personal Data, to the transformation into anonymous form, to block it, to rectify it, to integrate it, to cancel it or limit its processing;
   c) Oppose the processing of data in the cases provided by Privacy Applicable Law;
   d) exercise the right to the portability within the limits of Art. 20 of GDPR;
   e) withdraw your consent (if this is necessary legal basis of processing) everytime without prejudice to the legality of the data processing carried out prior to the withdrawal;
   f) propose a complaint to the Guarantor for the Protection of Personal Data, following the procedures and conditions published on the official website of the Authority www.garanteprivacy.it.

   9.2 – Any corrections, deletions or restrictions to the processing required - where this is impossible or involves a disproportionate effort - will be transmitted by the Data Controller to each of the recipients to whom the Data have been disclosed. The Data Controller can transmit you these recipients, if you request it.

   9.3 –In order to exercise these rights indicated to the point 9.1 above, as well as for receiving any information, requests or reports on data privacy, you can send a registered or an email to the Data Protection Officer to the addresses referred to the Art. 1 of this policy, applied by C.M.D. S.p.A, due to regulatory changes, it is appropriate that the user read this document consistently over time.