PRIVACY POLICY

With specific reference to personal data as defined by art. 4 paragraph 1 n. 1) of EU Regulation no. 679/2016 (hereinafter “Regulation”) concerning you as an “Interested”, the undersigned company TERMOMECCANICA GLSRL (hereinafter “TERMOMECCANICA”) (VAT number 01272990357), with registered office in Castelnovo Ne ‘ Monti (RE), 42035 – Via L. Giangolini, n.1 – Felina district, in the person of its pro tempore legal representative, as the “Owner” pursuant to art. 4 paragraph 1 n. 7) of the Regulations, provides you with the following information which will be valid and effective starting from 25.5.2018.

1. Nature and type of your data collected and processed.

1.1. Your data being processed fall exclusively into the category called “personal data” pursuant to art. 4 paragraph 1 n. 1) of the Regulations (“any information concerning an identified or identifiable natural person (” interested party “); the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number is considered identifiable , location data, an online identifier or one or more characteristic elements of its physical, physiological, genetic, psychic, economic, cultural or social identity “).

2. Information on “Owner”.

2.1. The “Owner” of the processing of your personal data pursuant to art. 4 paragraph 1 n. 7) of the Regulations is the company TERMOMECCANICA GLSRL (hereinafter “TERMOMECCANICA”) (VAT number 01272990357), with registered office in Castelnovo Ne ‘Monti (RE), 42035 – Via L. Giangolini, n.1 – fraction Felina, in the person of its pro tempore legal representative, who can be contacted by you at the following address privacy@termomeccanicagl.it

2.2. We inform you that any changes or updates regarding the data relating to the subject specified above will be suitably published in the appropriate “Privacy” section on the website of the undersigned owner.

3. Purpose of the processing.

3.1. In compliance with art. 5 paragraph 1 letter. b) of the Regulations, we inform you that your personal data will be collected and subsequently processed directly to fulfill the request for sending the newsletter and related registration in the mailing list, concerning information messages and commercial and promotional communications relating to the activity carried out by the Data Controller. , in full compliance with the principles of lawfulness and correctness and the provisions of the law.

4. Nature of consent to data processing

4.1 Your possible consent to the processing of the data better illustrated in art. 1.1. of this information for the execution of the purposes referred to in the previous art. 3.1. it is optional; therefore, we inform you that your refusal to consent to the processing in question will make it impossible for the Data Controller to process the requests for forwarding newsletters.

5. Recipients of the personal data collected and processed.

5.1. In compliance with art. 13 paragraph 1 letter. e) e f) of the Regulations, we inform you that, if you have granted the relative and optional consent with respect to the purposes referred to in the previous art. 3.1 of this information, your personal data may be disclosed to third parties, exclusively to fulfill the purposes better described in art. 3 above, such as, by way of example, IT assistance companies, based in the Italian territory or within the European Union or in a so-called country. third, with the express exception of those considered “inadequate” by the European Commission pursuant to art. 45 of the Regulation.

5.2 The data collected will not be disclosed and disseminated.

6. Retention period of personal data collected and processed.

6.1. In compliance with art. 13 paragraph 2 letter. a) of the Regulation, we inform you that the data will be kept until the request of the interested party for any opposition to the sending and the will of the latter to renounce receiving the newsletter through the methods made available for this purpose at each sending.

7. Processing methods.

7.1. We inform you that your data better indicated in the previous art. 1.1. of this information will be processed with paper, electronic, IT or telematic tools and / or supports, in full compliance with the law, according to the principles of lawfulness and correctness, and in order to protect its confidentiality.

8. Principles applied to the processing of your data.

8.1. In compliance with art. 5 of the Regulation, we inform you that your personal data will be:

• Processed in a lawful, correct and transparent manner towards the interested party (so-called principle of lawfulness, correctness and transparency);

• Collected for specific, explicit and legitimate purposes, and subsequently processed in a way that is not incompatible with those purposes (so-called purpose limitation principle);

• Adequate, relevant and limited to what is necessary with respect to the purposes for which they are processed (so-called data minimization principle);

• Exact and, if necessary, updated (so-called principle of accuracy);

• Kept in a form that allows the identification of the interested parties for a period of time not exceeding the achievement of the purposes for which they are processed (so-called principle of conservation limitation);

• Processed in such a way as to guarantee adequate security of personal data, including the protection, by means of adequate technical and organizational measures, from unauthorized or illegal processing and from loss, destruction or accidental damage (so-called principle of integrity and confidentiality) .

9. Rights of the interested party.

9.1. In relation to your personal data being processed by the Data Controller, we inform you that you have the right to exercise the following rights, reproduced in full below:

Right of access by the interested party (Article 15 of the Regulation)

“1. The interested party has the right to obtain from the data controller confirmation as to whether or not personal data concerning him is being processed and, in this case, to obtain access to personal data and the following information: a) the purposes of the processing; b) the categories of personal data in question; c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if they are recipients of third countries or international organizations; d) when possible, the retention period of personal data envisaged or, if not possible, the criteria used to determine this period; e) the existence of the right of the interested party to ask the data controller to rectify or delete personal data or limit the processing of personal data concerning him or to oppose their treatment; f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the data subject, all available information on their origin; h) the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the interested party. 2. If personal data are transferred to a third country or to an international organization, the interested party has the right to be informed of the existence of adequate guarantees pursuant to Article 46 relating to the transfer. 3. The data controller provides a copy of the personal data being processed. In case of further copies requested by the interested party, the data controller may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format. 4. The right to obtain a copy referred to in paragraph 3 must not affect the rights and freedoms of others “.

Right of rectification (Article 16 of the Regulation)

“The interested party has the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the interested party has the right to obtain the integration of incomplete personal data, including providing an additional declaration “.

Right to cancellation (Article 17 of the Regulation)

“1. The data subject has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay, if one of the following reasons exists: a) the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the interested party revokes the consent on which the processing is based in accordance with Article 6, paragraph 1, letter a), or Article 9 (2), letter a), and if there is no other legal basis for the processing; c) the interested party opposes the processing pursuant to Article 21, paragraph 1, and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21, paragraph 2; d) the personal data have been unlawfully processed; e) personal data must be deleted to fulfill a legal obligation under Union law or the law of the Member State to which the data controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1). 2. The data controller, if he has made personal data public and is obliged, pursuant to paragraph 1, to delete them, taking into account the available technology and implementation costs, he shall take reasonable measures, including technical ones, to inform the data controllers who are processing the personal data of the request of the interested party to delete any link, copy or reproduction of his personal data. 3. Paragraphs 1 and 2 do not apply to the extent that processing is necessary: a) to exercise the right to freedom of expression and information; b) for the fulfillment of a legal obligation that requires the processing provided for by the law of the Union or of the Member State to which the data controller is subject for the performance of a task carried out in the public interest or in the exercise of public powers of to which the data controller is invested; c) for reasons of public interest in the field of public health in accordance with Article 9, paragraph 2, letters h) and i), and Article 9, paragraph 3; d) for archiving purposes in the public interest, for scientific or historical research or for statistical purposes in accordance with Article 89 (1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously affect the achievement of the objectives of this treatment; or e) for the assessment, exercise or defense of a right in court “.

Right to limitation of processing (Article 18 of the Regulation)

“1. The interested party has the right to obtain from the data controller the limitation of the processing when one of the following hypotheses occurs: a) the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is unlawful and the interested party opposes the cancellation of personal data and requests instead that its use be limited; c) although the data controller no longer needs them for processing purposes, the personal data are necessary for the data subject to ascertain, exercise or defend a right in court; d) the interested party opposed the processing pursuant to Article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party. 2. If the processing is limited pursuant to paragraph 1, such personal data are processed, except for storage, only with the consent of the interested party or for the assessment, exercise or defense of a right in court or to protect the rights of another natural or legal person or for reasons of significant public interest of the Union or of a Member State. 3. The interested party who has obtained the processing limitation pursuant to paragraph 1 is informed by the data controller before said limitation is revoked “.

Right to data portability (Article 20 of the Regulation)

“1. The interested party has the right to receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to a data controller and has the right to transmit such data to another data controller without impediments from part of the data controller to whom he provided them if: a) the processing is based on consent pursuant to article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), or on a contract pursuant to Article 6, paragraph 1, letter b); is b) the processing is carried out by automated means. 2. In exercising their rights relating to data portability pursuant to paragraph 1, the interested party has the right to obtain the direct transmission of personal data from one data controller to another, if technically feasible. 3. The exercise of the right referred to in paragraph 1 of this article is without prejudice to article 17. This right does not apply to the processing necessary for the performance of a task of public interest or connected to the exercise of public authority to which the data controller is invested. 4. The right referred to in paragraph 1 must not affect the rights and freedoms of others “.

Right to object (Article 21 of the Regulation)

“1. The interested party has the right to object at any time, for reasons connected to his particular situation, to the processing of personal data concerning him pursuant to Article 6, paragraph 1, letters e) or f), including profiling based on these provisions. The data controller refrains from further processing personal data unless he demonstrates the existence of compelling legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the data subject or for the assessment, exercise or the defense of a right in court. 2. If personal data are processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data concerning him for these purposes, including profiling to the extent that it is connected to such marketing direct. 3. If the interested party objects to the processing for direct marketing purposes, the personal data are no longer processed for these purposes. 4. The right referred to in paragraphs 1 and 2 is explicitly brought to the attention of the interested party and is presented clearly and separately from any other information at the latest at the time of the first communication with the interested party. 5. In the context of the use of information society services and without prejudice to Directive 2002/58 / EC, the interested party may exercise his right to object by automated means using specific techniques. 6. If personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1, the interested party, for reasons connected to his particular situation, has the right to object to the processing of personal data that concerns him, except if the processing is necessary for the performance of a task of public interest “.

Right to lodge a complaint with the supervisory authority (Article 77 of the Regulation)

“1. Without prejudice to any other administrative or judicial appeal, the interested party who considers that the processing that concerns him or her violates this regulation has the right to lodge a complaint with a supervisory authority, particularly in the Member State in which he habitually resides, works or of the place where the alleged violation occurred. 2. The supervisory authority to which the complaint was lodged shall inform the complainant of the status or outcome of the complaint, including the possibility of a judicial remedy under Article 78 “.

Right to an effective judicial remedy against the supervisory authority (Article 78 of the Regulation)

“1. Without prejudice to any other administrative or extrajudicial appeal, every natural or legal person has the right to propose an effective judicial remedy against a legally binding decision of the supervisory authority that concerns him. 2. Without prejudice to any other administrative or extrajudicial appeal, each interested party has the right to lodge an effective judicial remedy if the supervisory authority which is competent pursuant to articles 55 and 56 does not deal with a complaint or does not inform it within three months of the state or the outcome of the complaint proposed pursuant to article 77. 3. Actions against the supervisory authority shall be brought before the courts of the Member State in which the supervisory authority is established. 4. Where actions are brought against a decision of a supervisory authority that was preceded by an opinion or a decision of the committee under the consistency mechanism, the supervisory authority shall transmit that opinion or decision to the court “.

9.2. In compliance with art. 12 paragraph 1 of the Regulations, TERMOMECCANICA undertakes to provide you with the communications referred to in articles 15 to 22 of the Regulations in a concise, transparent, intelligible, easily accessible form and in simple and clear language: such information will be provided in writing or with others any electronic means or, at the request of the interested party, will be provided orally, provided that the identity of the interested party is proven by other means.

9.3. In compliance with art. 12 paragraph 3 of the Regulation, the Data Controller informs you that he undertakes to provide you with information relating to the action taken regarding a request pursuant to articles 15 to 22 without undue delay and, in any case, at the latest within one month of receipt of the request itself; this deadline can be extended by two months, if necessary, taking into account the complexity and number of requests.

9.4. In order to be able to exercise the rights described above in this article, the interested party may use the contact details specified in art. 2 of this “Information”.

Castelnovo né Monti (RE), 25 May 2018

THERMOMECHANICS GLSRL

(in the person of its pro tempore legal representative)