This Privacy Policy describes the purposes and methods by which DQM S.r.l., as Data Controller (the “Company” or the “Controller”), collects and processes the personal data of users (the “User”) who interact with the website www.dqm.it (the “Website”) and the various services offered through it.

The information contained in this Privacy Policy is provided pursuant to Article 13 of EU Regulation No. 679 of 27 April 2016 (the “Regulation”), as well as applicable national legislation, measures issued by the Italian Data Protection Authority, and guidelines issued by European authorities.

The information concerning the processing of personal data applies exclusively to the Website and to processing carried out by the Company. It does not extend to processing carried out by third parties through other websites that Users may access via links. The Company accepts no responsibility for such processing, and Users should refer to the individual Privacy Policies of those third-party websites.

1. Data Controller and place of processing

The Data Controller is DQM S.r.l., with its registered office at Via Ribes, 27 – 10010 – Samone d’Ivrea (Turin), Italy.

Data are primarily processed at the Data Controller’s premises by the Company’s technical personnel, who are appointed and authorised to process personal data. Processing takes place within the European Union and, in relation to services outsourced to or provided by third parties, may also take place outside Italy and/or outside the European Union. If data are transferred to countries that do not provide a level of protection equivalent to that afforded in Italy, the Company undertakes to adopt the necessary safeguards for such transfers.

2. Methods of data processing

The Company processes Users’ data by adopting all appropriate security measures to prevent unauthorised access, disclosure, alteration or destruction of data.

Processing is carried out using manual, computerised and/or electronic tools, according to organisational procedures and methods strictly related to and limited to the purposes specified.

3. Purposes and legal bases for processing

Through the Website, the Company may process Users’ data for the following purposes:

• Contacting the Company. The Company allows Users to send communications, questions and requests for information concerning its activities, initiatives and services. The personal data provided by Users (e.g. email address, telephone number, where applicable, and/or other information voluntarily supplied) will be processed by the Company in order to receive, manage and respond appropriately to their communications. The legal basis for processing is the provision of the service expressly requested by the User. Refusal to provide the personal data required will make it impossible for the Company to manage and respond to the communication or request for information.
• Sending newsletters and communications, including promotional communications. The Company may send emails to the address provided by the User concerning services similar to those already supplied to that User. In these cases, the User’s consent is not required, but the User may object to the processing at any time. To make it easy for Users to opt out, each communication concerning these services will provide the option to refuse further similar communications. The legal basis for processing personal data for these purposes is the Company’s legitimate interest in sending Users information and updates concerning services similar to those they already use and that may be of interest to them, pursuant to Recital 47 of the Regulation.
• Disclosure of data to the Company’s distributors for marketing purposes. When contacting the Company, Users may voluntarily consent, by selecting the relevant checkbox, to the use of the personal and contact data they provide (e.g. email address) for disclosure to the Company’s distributors. These distributors may send Users their own marketing communications, such as newsletters, invitations to events, and informational and promotional materials concerning services and/or offers, through automated means (e.g. email and SMS) or traditional means (e.g. postal mail and telephone calls made by an operator). The legal basis for processing in this case is the User’s explicit consent. Users may freely decide whether or not to consent to such disclosure. Providing consent is entirely optional and does not in any way prevent Users from accessing the Company’s services or Website. Users may object to communications and withdraw their consent, including partially for individual communication channels, by contacting the relevant distributors.
• Pursuing the legitimate interests of the Company and/or third parties. Users’ data may also be used to exercise the rights and legitimate interests of the Company and/or third parties, for example, the right to defend legal claims, manage complaints and disputes, recover outstanding debts, and prevent fraud and/or unlawful activities. Although providing personal data is not mandatory in these cases, such data may nevertheless be necessary because they are closely connected with and instrumental to pursuing these legitimate interests, which do not override Users’ fundamental rights and freedoms. Refusal to provide the data may make it impossible to deliver the requested services (e.g. responding to a request for information).
• Compliance with legal and other applicable obligations. The Company may also use personal data provided by Users, or otherwise obtained during their interaction with the Website, for purposes connected with compliance with legal obligations, regulations, national and EU legislation, and orders issued by authorities legally entitled to do so. These obligations constitute the legal basis for processing, and prior consent from the User is not required.
• Conducting aggregated statistical analyses on an anonymous basis in order to improve the performance and services offered by the Company through the Website.

4. Categories of data processed

Through the Website, the Company receives and collects information about Users who visit its pages and use the web services available on the Website. In particular, the Company collects and processes the following information.

4.1 Data collected through browsing and cookies

When Users visit the Website, certain data are collected, including the pages viewed, links or buttons clicked, date and time of access, browser and operating system used (the so-called “browsing data”). The IP address is fully anonymised; browsing data therefore cannot identify or profile Users in any way. The Company uses these data solely to obtain anonymous statistical information about the use of the Website for purposes strictly related to its operation.

For information about the collection of User data through cookies and similar technologies, please refer to the Cookie Policy.

4.2 Data voluntarily provided by Users

The Company limits the collection of information voluntarily provided by Users to what is necessary to achieve the purposes described in Section 3 and to provide the services expressly requested.

The Company may also collect and process additional personal data if Users voluntarily provide them while using the services offered through the Website, for example, when contacting the Company to report service interruptions or malfunctions, exercise their rights concerning the processing of personal data, or for other related purposes.

Such data will be processed solely for purposes strictly related to the User’s request. Failure to provide the data may make it impossible to obtain the requested service.

5. Disclosure of data to third parties

The data provided by Users, as well as those collected by the Website in connection with its services, will not be disseminated publicly. They may, however, be disclosed, for the purposes and by the methods described in this Privacy Policy, to the following categories of recipients:

• Companies belonging to the Group, for administrative and accounting purposes, to pursue the legitimate interests of the Company and/or third parties, and to provide services expressly requested by Users.
• Companies, employees, collaborators, consultants and self-employed professionals engaged by the Company to perform technical or organisational tasks (such as IT service providers), or with whom the Company collaborates, including other companies belonging to the Group, for the provision and operation of its services or for possible communication activities.
• The Company’s distributors, subject to consent and for the purposes specified in Section 3, under the heading concerning disclosure of data to distributors for marketing purposes.
• Individuals, companies or professional firms providing assistance and consultancy to the Company, particularly, but not exclusively, in accounting, administrative, legal, tax and financial matters.
• Parties legally entitled to access the data under applicable laws or orders issued by the competent authorities.

The parties belonging to the above categories will process the data either as independent Data Controllers, as provided by law, or as Data Processors formally appointed by the Company.

These parties may be established in EU or non-EU countries. Where they are established outside the EU, the Company adopts the safeguards required by the Regulation to legitimise the transfer of personal data, including the execution of specific Data Transfer Agreements incorporating the standard data protection clauses approved by the European Commission.

A list of the parties to whom data are or may be disclosed, together with information about the safeguards adopted for transfers outside the EU, may be requested from the Company using the contact details provided in the section “Users’ Rights and Contact Details”.

6. Data retention

Data are processed for as long as necessary to carry out the activities described in Section 3. They are deleted when the purposes for which they were collected and processed have been fulfilled.

In particular, the Company will delete the personal data of Users who have requested information or sent communications by contacting the Company through the Website 12 months after the data were provided.

The Company will also delete the personal data of Users who have submitted applications for positions at the Company 24 months after the data were provided, if the applicant does not enter into an employment or collaboration relationship with the Company.

Finally, data collected for the Company’s marketing purposes are retained until the User unsubscribes or objects to processing. Thereafter, they may be retained in anonymous form for analysis and statistical purposes.

7. Users’ rights and contact details

Where expressly provided for by law and applicable, Users may exercise the rights granted under the Regulation. In particular, Users have the right to:

• Request confirmation as to whether their personal data are being processed and, if so, request access to information concerning that processing (e.g. purposes, categories of data processed, recipients or categories of recipients, and the retention period).
• Request the rectification of inaccurate or incomplete data.
• Request the erasure of their personal data (e.g. when the data are no longer necessary for the purposes for which they were collected or when consent on which processing is based has been withdrawn).
• Request restriction of processing (e.g. when the User contests the accuracy of the data; when processing is unlawful and the User opposes erasure; when the data are necessary for the establishment, exercise or defence of legal claims, even if the Data Controller no longer needs them; or when the User has objected to processing, pending verification of the existence of legitimate grounds).
• Receive their personal data in a commonly used, machine-readable format (e.g. PDF) and transmit those data to another Data Controller, or obtain direct transmission from one Data Controller to another where technically feasible (the so-called right to data portability).

Users also have the right to object, in whole or in part and on legitimate grounds, to the processing of their personal data, including processing for marketing purposes and through individual communication channels.

These rights may be exercised by sending a communication to the following email address: web@dqm.it.

Finally, if Users believe that the processing of their personal data violates applicable data protection legislation, they have the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).

8. Collection of data through cookies

A cookie is a small text file sent by websites to the User’s computer browser. It is stored when the User visits a website and may be sent back to the same website during a subsequent visit.

The Company uses cookies to make the Website function and/or improve its performance.

The Website uses the following types of cookies:

• Necessary cookies: These cookies are essential for the proper functioning of the Website. They provide basic functionality and security features anonymously.
  • cookielawinfo-checkbox-advertisement: Set by the GDPR Cookie Consent plugin. This cookie records the User’s consent for cookies in the “Advertisement” category. Duration: 1 year.
  • cookielawinfo-checkbox-analytics: Set by the GDPR Cookie Consent plugin. This cookie stores consent for cookies in the “Analytics” category. Duration: 11 months.
  • cookielawinfo-checkbox-functional: Set by the GDPR Cookie Consent plugin to record consent for cookies in the “Functional” category. Duration: 11 months.
  • cookielawinfo-checkbox-necessary: Set by the GDPR Cookie Consent plugin. This cookie stores consent for cookies in the “Necessary” category. Duration: 11 months.
  • cookielawinfo-checkbox-others: Set by the GDPR Cookie Consent plugin. This cookie stores consent for cookies in the “Other” category. Duration: 11 months.
  • cookielawinfo-checkbox-performance: Set by the GDPR Cookie Consent plugin. This cookie stores consent for cookies in the “Performance” category. Duration: 11 months.
  • CookieLawInfoConsent: Records the state of the default category button and the CCPA status. It works only in conjunction with the primary cookie. Duration: 11 months.
  • viewed_cookie_policy: Set by the GDPR Cookie Consent plugin to record whether the User has consented to the use of cookies. It does not store any personal data. Duration: 11 months.
  • _GRECAPTCHA: Set by Google’s reCAPTCHA service to identify bots and protect the Website against malicious spam attacks. Duration: 5 months and 27 days.
• Functional cookies: These cookies help provide certain features, such as sharing Website content on social media platforms, collecting feedback and enabling other third-party features.
  • pll_language: Used by Polylang to remember the language selected by the User when returning to the Website, and to retrieve language information when it is not available through other means. Duration: 1 year.
• Analytics cookies: These cookies help the Company understand how visitors interact with the Website. They provide information about visitor numbers, bounce rates, traffic sources and other metrics.
  • _pk_id.1.6e1b and _pk_ses.1.6e1b: Used by the Matomo plugin to collect browsing data in a completely anonymous and non-profileable manner. Their respective durations are 1 year and 27 days, and 30 minutes.

8.1 Disabling cookies through the browser

Users may delete cookies placed by the Website through their browser settings.

Most browsers are configured to accept cookies. However, Users may configure their browsers to limit the number of accepted cookies or block all cookies by changing the relevant settings as follows:

• Microsoft Internet Explorer: Click the “Tools” icon in the upper-right corner and select “Internet Options”. In the pop-up window, select “Privacy”, where cookie settings can be changed.
• Google Chrome: Click the wrench icon in the upper-right corner and select “Settings”. Then select “Show advanced settings” and change the “Privacy” settings.
• Mozilla Firefox: Open the drop-down menu in the upper-left corner and select “Options”. In the pop-up window, select “Privacy”, where cookie settings can be adjusted.
• Safari: Open the settings menu in the upper-right corner and select “Preferences”. Then select “Security”, where cookie settings can be adjusted.

Please note that disabling all cookies on the Website, including technical cookies, may impair certain functionalities.

8.2 Further information about cookies

The website www.allaboutcookie.org provides instructions for managing cookies in the most commonly used browsers. Alternatively, Users may consult the documentation supplied with the software installed on their devices.

9. Changes to the Privacy and Cookie Policy

The Company reserves the right to amend this Privacy Policy at any time by publishing the changes on the Website. Users are invited to check the Website for updates.

If changes are particularly significant and/or have a substantial impact on Users’ rights, the Company may also notify Users through other means, such as email.

Privacy and Cookie Policy last updated on 20 September 2022.

If you wish to have any data you have provided to DQM S.r.l. through this website deleted, please enter below the email address you used when submitting your request. We will delete all information relating to you from our computer systems.

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.