Privacy Policy

Information relating to the process of personal data

1. General information (applicable to all the Data Subjects) relating to the processing of personal data

The competence center “Competence Industry Manufacturing 4.0” (hereinafter “CIM 4.0”) needs to collect and process personal data in order to carry out its activities.

In addition, CIM 4.0 is required to process certain categories of personal data in order to comply with legal and/or regulatory requirements, in accordance with the Regulation (EU) 2016/679 (hereinafter “GDPR”) and with current Italian legislation on the processing of personal data.

According to the transparency and accountability principles, CIM 4.0 has developed a set of policies and procedures to ensure the application of appropriate security measures for each operational activity in order to protect the rights and freedoms of natural persons (Data Subjects).

In accordance with the provisions of art. 12, 13 and 14 of the GDPR, the following text describes how CIM 4.0 collects, uses and protects Data Subjects’ personal data, their legal rights, and the ways in which it is possible to get in touch with CIM 4.0.

1.1 Data Controller

The data controller is Competence Industry Manufacturing 4.0, with registered legal office in Turin, Via Nizza 230, 10126 and operation office in Turin, Corso Luigi Settembrini 178, 10135. CIM 4.0 is a limited liability cooperative company which aims to provide goods, services and business opportunities to the members of the organization at more advantageous conditions than they would get on the market.

1.2 Regulatory framework

Without pretention of exhaustion, the personal data protection regulatory framework is summarized below:

Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 on the Protection of Physical Persons with regard to the processing of personal data, as well as the free movement of such data (GDPR)

D.lgs. 196/2003, the Italian “Codice in materia di protezione dei dati personali” as well as adapted by the D.lgs. 101/2018 (below “the Privacy Code”);
D.lgs. 101/2018, the adaptation of national legislation to the provisions of the GDPR.

1.3 Scope of communication

Data Controller communicates personal data that are legitimately processed only to:

people authorized to access them by virtue of legal provisions, national laws, EU regulations;
people who operate under the authority of Data Controller;
service providers of Data Controller and therefore designated as Data Processors.

1.4 Transfers of Personal Data with Third Parties

CIM 4.0 does not transfer personal data to third countries or international organizations. However, the Controller could use cloud services: in this case the suppliers will be selected only if they had provided appropriate safeguards (art. 46 of the GDPR)

1.5 Data Subject rights

In accordance with the GDPR, Data subjects can exercise the following rights:

right of access (art. 15): right to obtain from CIM 4.0 whether Data Subject’s Data are being processed and, where applicable, have access to them;
right of rectification (art. 16): right to ask CIM 4.0 to rectify information considered inaccurate or to complete information Data Subject thinks it’s incomplete;
right of erasure (art. 17): right to ask CIM 4.0 to erase Data Subject’s personal information;
right of restriction of processing personal data (art. 18): right to ask CIM 4.0 to restrict the processing of Data Subject ’s information in certain circumstances;
right of portability of data (art. 20): right to obtain Data Subject’s Data in a structured format, ordinary used and readable, as well as the right to transfer Data to other controllers;
right to object to the decision-making process (art. 22): the data subject has the right not to be subject to a decision based solely on automated processing, such as profiling.

In addition, the Data Subject can exercise the right to object at any time to processing of personal data concerning him or (art. 22)

Data subjects can exercise the above mentioned rights by writing to CIM 4.0 by e-mail: privacy@cim40.com.

In order to allow the correct handling of request, the Data Subject has to specify wich is the right he/she intends to exercise and the treatment to which he/she refers, attaching a copy of a valid identity document that CIM 4.0 will use only to identify the sender.

1.6 Withdrawal of consent

With reference to Art. 7 of the GDPR, the Data Subject can revoke the consent given at any time. In the absence of a different legal basis, the withdrawal of consent implies the cessation of processing activities, including storage. The revocation does not affect the lawfulness of the processing previously carried out.

1.7 Right to lodge a complain

Data Subjects have the right to lodge a complaint with the supervisory authorities (art. 77 of the Law) in the event that they feel that the processing of the data by those in charge does not comply.

1.8 Personal Data Retention

CIM 4.0 will store and process personal data for the amount of time necessary for the fulfilment of the purpose of processing.

The following privacy statement shows the times and/or conditions that determine the duration of the retention period.

1.9 Automated decision making process

In relation to the following treatments, in no case CIM 4.0 carries out treatments that consist of automated decision-making processes on the data on natural persons.

2. Specific privacy notices

In the next paragraphs, supplementing the general information above, we provide details of the individual treatments carried out by CIM 4.0 in line with the requirements of Articles 12, 13, 14 of GDPR.

Privacy Notice for site visitors	Leggi qui
Privacy Notice for those who request the course catalogue online	Leggi qui
Privacy Notice for those who complete the pre-registration form for courses	Leggi qui
Privacy Notice for those who register for courses	Leggi qui
Privacy Notice for those who sign up for the newsletter	Leggi qui
Privacy Notice for those who send their Curriculum Vitae	Leggi qui

2.1 Information for website visitors

In addition to the general information, the following information is made available to people who access and consult the CIM 4.0’s website (https://cim40.com) according to art. 13 of the GDPR. In particular, CIM 4.0 notes that:

The site you are visiting belongs to CIM 4.0, which guarantees the security, confidentiality and protection of the data it possesses and those it will possess at any stage of the treatment process in compliance with the rules set by the legal framework of reference and in compliance with business secrecy
The site offers links or references to other third-party websites over which CIM 4.0 has no control. These links are provided for the convenience of users of this site and the Data Controller assumes no responsibility in relation to these sites, whose referents are to be considered independent Data Controllers and to which you have to ask for any further information
The site uses the use of cookies in compliance with the policy that can be consulted online (Cookie Policy).

2.1.1 Purpose of the personal data processing

The site uses cookies that allow CIM 4.0 to present its content on the web in an effective way according to the visitor’s expectations. Information relating to performance, pages visited and relevant technical errors are also used in order to guarantee continual improvement of the CIM 4.0’s online presence.

2.1.2 Legal basis of the personal data processing

The use of technical cookies and information used to support visit of the website is carried out in the legitimate interest of the Data Controller, who intends to present his offer on the internet in an efficacy way according to the visitor’s expectation.

The use of any other information to evaluate and optimize performance or to present advertisements managed by third party sites is based on the consent expressed by the user

2.1.3 Recipients of the personal data

CIM 4.0 invite users to consider that this website shares browsing data with WordPress (www.wordpress.com) and Google Analytics (https://analytics.google.com) for the preparation of performance reports of website. Besides information is share with YouTube (www.youtube.com) and Vimeo (https://vimeo.com) for the presentation of video content on the pages of the CIM 4.0 site. For more information, please refer to the respective cookie policy available on the reference sites.

2.1.4 Personal data retention

Browsing data are kept for six months.

2.1.5 Withdrawal of consent

The consent to the use of non-technical cookies can be withdrawn at any time by using the cookie settings. The withdrawal of consent will not affect the processing of data previously made and will lead to the interruption of the use of cookies

2.1.6 Refusal to provide personal data

The Data Subject may refuse to provide their personal data by deactivating the use of cookies as specified in the cookie policy available online. However, it should be noted that the operation could make the provision of the service less performing and inhibit the use of some of the contents of the site.

2.2 Privacy Notice for Data Subjects who request the online catalogue of courses

In addition to the general information, the following information is made pursuant to art. 13 of the GDPR to Data Subjects who fill in the online form to obtain the catalogue of courses promoted by CIM 4.0.

2.2.1 Personal data sources

The personal data processed are those provided by Data Subjects

by filling in the online form to obtain the catalogue of courses promoted by CIM 4.0;
Possible forwarding of e-mail communications;
Subsequent interactions and insights.

2.2.2 Purpose of personal data processing

The Data Controller processes personal data in order to:

follow up on requests made by the Data Subject by making the course list available
forward promotional information by email

2.2.3 Legal basis of the processing

The legal basis of the processing for both purposes is the consent expressed:

by filling in the catalogue request form by entering one’s personal data (Purpose a)
by ticking the item available on the online form page (Purpose b)

2.2.4 Recipients of personal data

The data of Data Subject are accessible only to authorized personnel, appropriately trained for processing. The data may be also communicated to external suppliers whose services are essential to give timely feedback to the expectations of the users.

In particular, the data necessary for the forwarding of promotional communications are communicated to MailChimp (https://mailchimp.com).

2.2.5 Personal data retention

In this case, the data of the Data Subjects are kept until the end of the interaction with the Data Subject.

2.2.6 Withdrawal of consent

With reference to purpose (b) , the Data subject can withdraw his/her consent at any time, using the link available in the periodical e-mails.

2.2.7 Refusal to provide personal data

The form specifies wich data are considered necessary to obtain what is requested: failure to provide such information could prevent the Data Controller from following up on the Data Subject’s request. Other data are to be considered optional and therefore not necessary although useful to facilitate communications between the parties: their absence does not compromise the satisfaction of the request.

In addition to the general information, the following information is made according to art. 13 of the GDPR to those who provide their personal data to receive newsletters from CIM 4.0.

2.3.1 Personal data sources

The personal data processed are provided by the Data Subjects, by filling in the online form prepared for subscription to the newsletter.

2.3.2 Purpose of personal data processing

CIM 4.0 processes personal data to periodically forward information about its initiatives and training proposals to the data subject by email.

2.3.3 Legal basis of the processing

The legal basis of the processing is the consent of the Data Subjects expressed by providing his / her email address in the appropriate section of the site.

2.3.4 Recipients of personal data

In particular, the data necessary for the forwarding of promotional communications are communicated to MailChimp (https://mailchimp.com).

2.3.5 Personal data retention

In this case, he data of the Data Subject are kept until the end of the interaction with the Data Subject.

2.3.6 Withdrawal of consent

At any time, the Data subject can withdraw the consent expressed by using the link contained in the periodically forwarded emails.

2.3.7 Refusal to provide personal data

The requested data (the e-mail address) are necessary for the execution of the treatment: failure to provide this information would not allow the Data Controller to follow up on the forwarding of periodic communications.

2.4 Information for those who complete the pre-registration form for courses

In addition to the general information, the following information is made pursuant to art. 13 of the GDPR to those who fill out the online form to pre-enroll in the courses promoted by CIM 4.0.

2.4.1 Personal data sources

The personal data processed are those provided by the data subject:

By filling in the online form prepared to obtain the catalogue of courses promoted by CIM 4.0
Possible forwarding of e-mail communications
Subsequent interactions and insights

2.4.2 Purpose of personal data processing

CIM 4.0 processes personal data in order to:

Contact the interested party regarding the planning of the course of interest to allow the eventual formalization of the registration
Send the catalogue of training courses promoted by CIM 4.0
forward promotional information by email to those who say they are interested

2.4.3 Legal basis of the processing

The legal basis of the processing for the purposes indicated is the consent expressed by the Data Subject:

by filling in the pre-registration form by entering one’s personal data (mandatory data and optional fields are specified, useful for facilitating) – for the purpose [1]
by ticking the items available on the form page – for the purpose [2] and [3]

2.4.4 Recipients of personal data

In particular, the data necessary for the forwarding of promotional communications are communicated to MailChimp (https://mailchimp.com).

2.4.5 Personal data retention

In this case, he data of the Data Subject are kept until the end of the interaction with the Data Subject.

2.4.6 Withdrawal of consent

With particular reference to the purpose [3], at any time the data subject can revoke the consent expressed by using the link contained in the periodically forwarded emails.

2.4.7 Refusal to provide personal data

The form specifies wich data are considered necessary to obtain what is requested: failure to provide such information could prevent CIM 4.0 from following up on the data subject’s request. The other data are to be considered optional and therefore not necessary although useful to facilitate communications between the parties: failure to provide them would not compromise the satisfaction of the request.

2.5 Privacy Notice for those who register for courses

The following privacy statement is made according to the art 13 of GDPR and regards who fill out the online form to enroll in the courses programmed by CIM 4.0

2.5.1 Personal data source

The personal data processed are those provided by the data subject:

By filling out the online form prepared for enrollment in the courses programmed by CIM 4.0
Possible forwarding of e-mail communications
Subsequent interactions and insights

2.5.2 Purpose of the processing

The Data Controller processes personal data in order to:

Provide the course requested by the interested party
Send the catalogue of training courses promoted by CIM 4.0
forward promotional information by email

2.5.3 Legal basis of the processing

The legal basis of the processing for the purpose [1] is the request of the interested party to be understood as a pre-contractual measure functional to the organization and to delivery of the course. For the purposes [2] and [3] the legal basis is constituted by the express consent by ticking the items available on the form page

2.5.4 Recipients of the personal data

The data of data Subject are made available to staff trained and authorized in order to carry out their duties and to external suppliers whose services are essential to give timely feedback to the expectations of the users. In particular, the data necessary for the forwarding of promotional communications are communicated to MailChimp (https://mailchimp.com).

2.5.5 Personal Data retention

In this case, the Data Subjects’s data are kept:

until the end of the course delivery except for legal obligations for the owner for the data processed (for the purpose [1])
until the end of the provision of the requested service (for the purposes [2] and [3])

2.5.6 Withdrawal of consent

With particular reference to the purpose [3], at any time the data subject can revoke the consent expressed by using the link contained in the periodically forwarded emails.

2.5.7 Refusal to provide personal data

The form specifies the data to be considered necessary to obtain what is requested: failure to provide it would not allow to follow up the request of the data subject. The other data are to be considered optional and therefore unnecessary although useful to facilitate communications between the parties: their failure to provide in any case would not compromise the provision of the requested service.

The form specifies the data to be considered necessary to obtain what is requested: failure to provide such information could prevent the Data Controller from following up on the data subject’s request. The other data are to be considered optional and therefore not necessary although useful to facilitate communications between the parties: failure to provide them would not compromise the satisfaction of the request.

2.6 Information for those submitting their curriculum vitae

In addition to the general information, the following information is provided according to articles 13 and 14 of the GDPR to the subjects of which CIM 4.0 acquires the curriculum vitae and job interview information.

2.6.1 Purpose of the processing

The personal data of those who, spontaneously or following a search for personnel or through another channel (e.g. portals and specialized social networks, recruitment companies), submit their curriculum to the attention of the Data Controller and / or decide to take an interview information from the Data Controller, are processed for

Identify the most suitable candidates for possible collaboration,
the proposal of job offers and possible consequent start of a collaboration relationship

2.6.2 Personal Data source

The personal data processed are provided by the Data Subject:

sending the curriculum to the Data Controller, spontaneously (via e-mail or by filling in the specially prepared online form) or in response to an announcement
interviews, specific interviews and selections
reporting by third parties, including recruitment companies
searches carried out on public databases, made available by specialized sites (e.g. LinkedIn)

2.6.3 Categories of personal data

: The personal data processed belong to the following categories:

personal data: name, surname, contact details, training and professional path
particular data: health data possibly provided by the interested party to ensure adequate identification of the job

2.6.4 Legal basis of the processing

CIM 4.0 processes the data of the interested parties on the basis of the free expressed consent with the sending of their Curriculum Vitae or the publication of their data on sites and portals aimed at finding new job opportunities. Similarly, the particular data provided to the Data Controller are processed on the basis of the consent of the Data subject, explicitly expressed when sending the curricular data or at the time of the first fact-finding interview.

2.6.5 Scope of communication and diffusion

The personal data of the Data Subjects may be communicated to the workers who work for the Data Controller (e.g. to schedule the interviews or any further in-depth meetings). They are appropriately trained and authorized.

2.6.6 Personal Data Retention

In this case, in the event that we do not proceed closely with the start of a collaborative relationship between the parties, the personal data are kept for a period of 36 months at the end of which the data will be deleted in the absence of renewal of consent. In the event of a collaboration relationship being initiated, the Data Controller will retain and update the curricular data on the basis of the data subject’s indications until the end of the relationship between the parties.

2.6.7 Refusal to provide personal data

The curricular data are to be considered necessary for the purposes indicated by the Data Controller. Failure to do so may result in the impossibility for CIM 4.0 to do each treatment activities and thus to carry out the activities enabling the eventual working relationship with the person concerned.