Pursuant to Article 13 of the GDPR (EU Regulation 2016/679), the following information is provided, in accordance with the principle of transparency, in order to make you, the data subject, aware of how we collect, use, share, store and transfer your data (hereinafter defined as “Personal Data”, “Data” or “Information”) after you visit the website https://group-itm.com/en, collected through the Site itself.

 1. Data controller and contact details

The Data Controller is Italtractor ITM S.p.A, with registered offices at Via Confortino 30 - 40056 Valsamoggia - Loc. Crespellano (BO) – Italy (hereinafter defined as "ITM", “we" or “Data Controller”).
Italtractor ITM S.p.A is primarily responsible for answering any questions, concerns or complaints you may have about this Privacy Policy or about our handling of your information. If you have questions, please contact ITM at: 

ITMGDPR@group-itm.com
Via Confortino 30 - 40056 Valsamoggia - Loc. Crespellano (BO) – Italy | +39 051-738482

This Privacy Policy Notice also covers our group of companies ("ITM Group") and we have listed them below:-

1. Titan Intertractor GmbH
   VAT DE 815 517 982
   Hagener Strasse 325
   D - 58285 Gevelsberg
   Germany
2. Pyrsa - Piezas Y Rodajes S.A.
   VAT A50225614
   Poligono Industrial El Tollo
   Carretera Sagunto-Burgos,
   Km174,2 - Apartado de Correos 18
   E - 44300 Monreal Del Campo
   (Teruel) Spain
3. Intertractor America Corporation
   DUNS 076136100
   960 Proctor Drive
   Elkhorn, Wisconsin 53121
   USA
4. ITM Latin America Ltda
   VAT
   Rodovia Edgard Máximo Zambotto,
   Km 79 Bairro Ponte Alta - Atibaia
   São Paulo - CEP 12952-817
   Brazil
5. Titan ITM (Tianjin) Co. Ltd
   no. 6 Hechang Road
   Wuqing Development Area
   301700 Tianjin
   People's Republic of China
6. ITM Mining Pty Ltd
   52 Railway Parade
   Welshpool WA
   6106 Australia

Para tratamento de dados em território brasileiro, aplicam-se as regras especificadas na seguinte Política de Proteção de Dados Pessoais

“Relatório de Transparência da portaria MTE nº 3.714/2023

O relatório de Transparência Salarial e de Critérios Remuneratório foi elaborado e publicado pelo Ministério do Trabalho e Emprego (MTE), que coletou e organizou os dados em tabelas. Esse relatório não compara salários e critérios remuneratórios entre homens e mulheres conforme parâmetros fixados pelo artigo 461 da CLT, e serve exclusivamente para cumprimento das obrigações previstas no Decreto nº 11.795/2023 e na Portaria MTE nº 3.714/2023”.

Relatório Transparência Salarial_2024

2. information we MAY collect

1. We collect Personal Data when you use our Website, correspond with us, inquire about or purchase our goods or services. This may include contact details, communication details, and preferences. You may also create an Account or subscribe to our newsletter, providing additional information such as an email address and product interests.
   You can give us your email address and product preferences to receive our newsletter or other communications.
   
   
2. Information we collect automatically. When you visit our Website, we may automatically collect the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit, including the URL clickstream to, through and from our Website, products you viewed or searched for, download errors, timing and length of visits to certain pages and page interactions. We collect information automatically through the use of various technologies, including through cookies (please see section 7 of this Privacy Policy below)
   
   
3. Information we receive from other sources. We may receive information about you from other sources if you use any of the other services we provide on this Website, or from other members of the Titan/ITM Group. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers and market research firms) and may receive information about you from them (including information that is publicly available).

3. HOW WE USE YOUR INFORMATION

We use the information we collect in order to provide you with the best possible experience when you access our Website and engage with us, including by buying or using our services and products. This includes using your information for the following purposes:

1. Creating and managing your Account
   We use your information in order to create your Account, create a profile of you on our systems and manage our relationship with you. We also use your information to communicate with you regarding your Account and our services. The Data Controller processes your Information on the basis of your explicit consent pursuant to Article 6(1)(a) GDPR.
   
   
2. Newsletter and Marketing
   We use the information you provide when subscribing to our newsletter exclusively to send you periodic advertising communications by post, e-mail, telephone, fax, SMS, MMS, WhatsApp and similar means. These communications will include information about our products, services, events and initiatives, as well as special offers and promotions. No further processing of data, other than the mere sending of the newsletter, is envisaged.
   However, with your explicit and separate consent to profiling, we may use your data to: personalise the content of the newsletter, send you targeted marketing communications, keep you up to date about our activities and those of ITM Group companies that you may be interested in, and make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them. We use Account Engagement, an advanced feature of Salesforce CRM, to send you automated and personalised communications. These communications will be based on behavioural criteria and will aim to provide relevant sales and marketing information.
   For more details on how we will market to you, please see section 6 of this Privacy Policy below.
   The processing is carried out with your consent as stated in Article 6(a) of the GDPR.

4. Online Advertising:

• Effectiveness measurement: we will use your information to understand how effective our advertising is. For more details please see section 7 of this Privacy policy below.
• Relevant advertising: we will use your information to deliver targeted ads that are relevant to your interests.
• Social media: we will use your information to build and maintain our social media brand by communicating with you through these channels.

We use Account Engagement, an advanced feature of Salesforce CRM, to create customised interactions based on your needs, interests and stage of the buying cycle. We analyse data to identify opportunities, personalise communications and measure the effectiveness of actions taken, using automated processes.

The processing is carried out with your explicit and separate consent as stated in Article 6(a) of the GDPR.

5. Assistance
   We may use your information in order to investigate any complaints on your behalf and to provide you with more efficient customer care service. We may also use your information to ensure the quality and effectiveness of our handling of complaints or customer service requests.
   The processing is carried out with your consent as stated in Article 6(a) of the GDPR.

6. Recruitment
   We accept online applications to work for our company or other companies of the Titan/ITM Group through the 'Careers' page of the Website. We, or such other company of the Titan/ITM Group to which you freely choose to send an application, will receive the information provided in the application and supporting documentation (which may include a CV and cover letter). We will use your Information only for the purposes of moving forward with the recruitment process, assessing and making a decision about your suitability for a role, communicating with you and carrying out reference checks. We will also use your information to comply with legal and regulatory requirements.
   The processing of Information is necessary for the processing of the application and for the possible establishment of an employment contract at our facility (Art. 6.1(b) of the GDPR). In addition, there is a legitimate interest in responding correctly to your requests or communications (Art. 6.1 (f) of the GDPR).
   
   
7. To make necessary disclosures
   We may process your Personal Data to comply with legal obligations, such as providing information to law enforcement or regulatory authorities in response to legally binding requests, or to defend legal claims. If necessary, the processing will be based on the lawfulness condition set out in Article 6(1)(c) of the GDPR.

4. WHY WE USE YOUR INFORMATION 

Our processing of your Personal Data will be based on a variety of legal grounds, including:

1. where the processing is necessary for the purposes of our legitimate interests: this includes, for example, to:
   • provide our products and services to you;
   • ensure your Account is adequately protected and to ensure that our Website, network and information technology are secure and are being used in an appropriate manner;
   • better understand how you use our products, services and Website and to make improvements;
   • research and analyse the products and services you want;
   • tailor our content and offers to those more relevant to you;
   • provide security for our business and who we partner with; and
   • develop and maintain relationships with vendors, partners and other companies and deal with individuals who work for them;
2. where we need to comply with a legal obligation: for example, we may need to disclose your Information to a law enforcement agency or to your representatives or our representatives acting in a legal dispute;
3. where you have provided your consent: for example, we may require your consent when using technologies such as cookies.

 5. How we share and disclose your information

The Data are processed within ITM by persons authorised to process the Data under the responsibility of the Data Controller for the above-mentioned purposes. We also may share your information with members of Titan/ITM Group for the purposes outlined in section 3 of this Policy and with the third parties identified in this Policy.

Personal Data will not be communicated to other companies without your explicit consent. However, only where strictly necessary, we may share your information with third parties when it is:

1. necessary to involve a third party service provider in order to facilitate or extend our services;
2. explicitly requested by you;
3. required by a court order or any legal or regulatory requirement;
4. carried out in connection with the sale, transfer or reorganisation of a business;
5. carried out to enforce our contracts, and if we are defending a legal claim, your information may be transferred as required in connection with defending such claim;
6. carried out to ensure the safety and security of our users, customers, consumers and third parties; and
7. carried out to protect our rights and property and the rights and property of our guests and third parties.

These recipients may act as autonomous data controllers or Data Processors. The Data Processors follow the instructions of the Data Controller.

 6. How to opt in or opt out of direct marketing

We, and other members of the Titan Group, may use the information you give us for direct marketing purposes, to provide updates, newsletters or other communications that we think may interest you.
Where required by law, your prior consent will be obtained before we send you direct marketing communications. In any event, we will offer you the option to unsubscribe in every communication sent.
You may object to receiving direct marketing communications from us at any time by contacting us by email at ITMGDR@group-itm.com  or selecting the unsubscribe option in our email communications.

7. Cookies and other technologies

We collect information automatically through the use of cookies. A cookie is a text file containing small amounts of information that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer but does not name you. Some of our Website pages use cookies to better serve you when you return to the Website. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies; however, if you do this, some parts of our Website may not work properly. We also use pixel tracking technologies in our emails in order to verify clicks on embedded links or images and the opening of the emails of newsletters. This information is collected in order to obtain statistical information on our Website and emails, and also to identify the features and content preferred by each user, in order to send personalised information.

We use Google Analytics, which uses cookies to track your interactions with the website. These small text files are stored on the user's device and enable Google Analytics to, for example, distinguish one user from another, allowing it to track your sessions and actions individually, tracking how you navigate around the site, which pages you visit and how much time you spend on the site, and keeping track of all the actions you take on the site, such as purchases or newsletter subscriptions.
For information about the specific cookies used on this Website, please refer to our Cookie Notice.

8. Links to other websites and social media

Where we provide links to other websites, we do so for information purposes only. The other websites are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their Privacy Policy, which may differ from ours.

9. Transfer to a third country

With your explicit consent, your Data may be transferred to external structures, individuals or companies (including consultants and service providers) that the Data controller uses to manage the Site and to carry out activities connected, instrumental or consequent to the execution of the services offered by the Site. These parties may be located in European or non-European countries.

Some of these may not provide adequate data protection guarantees (a complete list of countries that provide adequate data protection guarantees is available on the website of the Italian Data Protection Authority). In such cases, we will ensure that appropriate safeguards are in place to protect your Personal Data in those countries, in accordance with this Privacy policy. Some of the safeguards we may employ, where appropriate, include: using European Commission approved standard contractual clauses with our suppliers, intra-group transfer agreements (so that we can safely transfer your Personal Data between group companies around the world) and compliance with the EU-US Data Privacy Framework (DPF).

 10. Data retention

We will not retain your information for longer than is necessary for our business purposes or for legal or regulatory requirements.

We will retain your information for as long as you have an Account with us and for a period after you have closed your Account with us. For example, we do this if it is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete Personal Data if relevant to an investigation or a dispute. They will continue to be stored until those issues are fully resolved.

 11. Your rights

Subject to applicable law, you may have the rights set out below in relation to your Personal Data:

1. Right to access your Information: you have the right to confirm whether we process your Data and to access any information related to that processing.
2. Right to rectification. You have the right to obtain the rectification of your Personal Data held by us if it is incomplete or inaccurate.
3. Right to erasure. In certain circumstances, you have the right to obtain the erasure of your Personal Data that we hold when it is no longer necessary for the purposes for which it was collected or otherwise processed, when you have withdrawn your consent or objected to the processing, or when the processing is unlawful. You also have the right to erasure where your Personal Data must be erased to comply with a legal obligation.
4. Right to restriction of processing. Where certain conditions apply, you have the right to restrict the processing of your Information.
5. Right to withdraw consent. You have the right to withdraw consent to the processing of your Data at any time, without prejudice to the lawfulness of the processing based on the consent prior to the withdrawal.
6. Right to data You can ask us to help you move some of your information to other companies. To help with that, you have a right to ask that we provide your information in a machine-readable format to another company.
7. Right to object. At any time, for reasons related to the specific situation, you may object to the processing of Personal Data concerning you, as provided for by Art. 6 (1)(f) of the GDPR (data processing for the protection of a legitimate interest). This also applies to profiling that refers to this legal basis (Art. 4 (4) of the GDPR).
   If you object, we will no longer process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing that prevail over your interests, rights and freedoms, or the processing serves to ascertain, exercise or defend a right in court. If you object to the processing of Data for advertising purposes, on the basis of Art. 6(1)(f) of the GDPR, we will immediately stop the processing without further checks. This also applies to profiling that takes place in such contexts.

12. Complaint

 You have the right to lodge a complaint with the competent independent administrative authority in the Member State of the European Union where you habitually reside, where you work, or where an alleged violation of the law on the protection of Personal Data has occurred. In Italy, the interested party can lodge a complaint with the Italian Data Protection Authority (Tel: +39 06-696771, website: www.garanteprivacy.it, email: protocollo@gpdp.it).

 13. Providing Personal Data

The provision of Data for the purposes above is purely optional. However, since such processing is necessary for the achievement of the purposes above, failure to provide the Data or partial or inaccurate provision of the Data in question will make it impossible, depending on the case, to use the services provided online and, in general, to process and process your specific requests.

 14. Different purpose of processing

It is specified that if the Data Controller intends to further process Personal Data for a purpose other than that for which they were collected, prior to such further processing, the Data Controller will provide you with information regarding this different purpose and any other relevant information.

 15. Profiling

We process your Personal data for profiling purposes referred to in points b) and d) of section 3 of this Privacy Policy, in order to analyse your preferences and browsing behaviour, and send you personalised commercial communications. Profiling is based on the analysis of your browsing data, your interactions with our services and the information you have voluntarily provided to us. To do this, we also use Account Engagement, a dedicated marketing platform of the Salesforce CRM, which also uses automated processes and Google Analytics (GA4) to analyse user behaviour and optimise the performance of a website, collecting both cookies and a wide range of data, such as demographic data, behavioural data and conversion data.

Consent to the processing of Data for profiling purposes has been acquired explicitly, freely and in an informed manner, separately from the other purposes. You have the right to object at any time, in whole or in part, to the processing of your Personal Data for profiling purposes, by contacting us at ITMGDR@group-itm.com.