PRIVACY policy

1. How the website works

By means of the website (the “Site”), managed by Italtractor ITM S.p.A. - a Titan International Inc. Company (the “Company”), the User accesses and may look through the Company’s products (such as undercarriage components, complete undercarriage, etc.) and services (i.e. product support, inspection, after sale service, training distribution network). In addition, by registering to the Site, the User may also receive further services offered by the Site (e.g. Catalogue, TrackAdvice).

2. Privacy Policy

This Privacy Policy describes the modalities and purposes through which the Company carries out the processing of its Users’ personal data (the “data”), and it principles also apply to the modalities and purposes related to the processing of Users’ personal data carried out by the other companies of the ITM Group, when Users autonomously choose to provide them with their personal data, by directly contacting them through the Site, by sending them requests of information or their CV for job applications.
This Privacy Policy is provided to Users pursuant to and in compliance with Art. 13 of Legislative Decree 196/03 – Personal Data Protection Code (the “Privacy Code”) and with the Provisions issued by the Data Protection Authority, as well as with the Recommendations by the EU Authorities for the protection of personal data, assembled in the Art. 29 Working Party pursuant to Directive 95/46/EC.
This Privacy Policy refers only to the processing of personal data carried out through the Company’s Site and sites managed by the Company, without any extension to the data processing operations carried out by other websites visited by the User by links and not managed by the Company, in relation to which the Company does not take on any responsibility.

3. Data Controller

The Data Controller is the Company, located in Via Confortino, 23/28 - 40053 Valsamoggia - Loc. Crespellano (BO) – Italy.
The data is mainly processed at the Data Controller’s premises, within the European Union and, with respect to services provided by third parties, also outside the European Union. In case of transfer of the data in countries which do not ensure standard of protection equivalent to Italy, the Company undertakes to adopt all the necessary measures to legitimize said transfer.
Furthermore, when Users autonomously choose to provide their personal data to other companies of the ITM Group, by directly contacting them through the Site, by sending them requests of information or their CV for job applications, the relevant ITM company will act as Data Controller as well, pursuant to the principles set out in this Privacy Policy.

4. Modalities of data processing

The data is processed mainly with electronic, computerized and automated means, for the period of time which is strictly necessary to seek the purposes for which it was collected.
The Company processes the data in compliance with the law, adopting adequate security measures able to prevent non-authorized accesses, dissemination, non-authorized alteration or destruction of the data.

5. Purposes of data processing

Users’ data will be processed exclusively for the following purposes:

a. Activation and operative management of the services offered by the Site (e.g. Users’ registration, login, contacts, customer service, etc.), as well as for the carrying out and management of the respective administrative and/or accounting purposes. In this respect, the providing of the data by the User is voluntary but the refusal to provide the same data will cause the impossibility to obtain the service requested (e.g. registration to the Site);

b. With the previous consent from the User, marketing activities, such as the sending of newsletters, invitations to participate in surveys and market researches, commercial and promotional communications concerning products and/or services by the Company. The purposes above will be carried out with automated and non-automated means (e.g. email, , etc.) In order to carry out such activities it is necessary to acquire the consent from the User: the consent will be required at the newsletter registration by the User and may be always revoked, also partially; for example, the communications sent by email will give the User the possibility to refuse further sending. The consent is voluntary, and the refusal to provide the same will only prevent the User from receiving communications, promotions and offers, of course not affecting the possibility of using the services and functionalities of the Site;

c. Purposes connected to the execution of obligations provided by law, regulations, EU and national provisions, orders imposed by competent authorities.

6. Personal data undergoing processing

The Company receives and collects, through the Site, information related to the Users visiting its pages and using the services offered by the Site. In particular, the Company will collect and process the following information.

6.1 Web-browsing data

When the User browses through the Site, the latter collects certain information such as the pages visited, the links and/or buttons clicked by the User, the date and hour of the access, the User’s IP address, the browser used the operative system used (so called “web-browsing data”). Said data, for its nature, in certain cases could allow to identify the User, also by means of elaborations and connections with third party data. However, the Company uses said data exclusively to obtain statistical and anonymous information about the use of the Site, for purposes strictly related to the control of its correct running. The data may also be used for the ascertainment of liabilities in case of IT crimes in damage of the Site.

6.2 Data voluntarily provided by the User

The Company does not collect User’s data by external sources and limits to the minimum the collection of User’s personal data, exclusively in relation to the purposes illustrated in previous par. 5, meaning:

a. Registration to the Site: when registering to the Site for the subscription to specific services (such as the Catalogue, TrackAdvice, etc.), the User will be asked to provide an email address and create a password for accessing the Site, as well as the User’s name, surname, company, address and telephone numbers. The providing of said data is entirely voluntary, however, the refusal to provide all the mandatory information will impede the possibility for the User to registering to the Site.

b. Sending of the newsletters: when the User registers to certain service of the Site (e.g. newsletter registration), the User may freely express (by selecting the specific tick-boxes) the consent for the use of the personal and contact data (e.g. email address) for the sending of newsletters from the Company as illustrated in previous par. 5, lett. b. The providing of the consent by the User is entirely free and it will not affect the possibility of registering to the Site the use of the other services offered by the Site.

c. Other data voluntarily provided by the User - Contacts: during the use of the services offered by the Site, the User may also provide the Company, or the other company of the ITM Group which the User autonomously chooses to contact, with personal data in order to receive additional information and/or services (e.g. by requesting information, reporting disservices or dysfunctions on the Site, etc.). Said data will be processed by the Company and the relevant company of the ITM Group exclusively for the purpose strictly related to the User’s request. The refusal to provide said data may affect the possibility, for the User, of receiving the service or information requested.

d. Careers – work with us: the Company gives the opportunity to apply on-line as a candidate to work in the Company or in other companies of the ITM Group by the page “Careers”. To this end, the Company, or the other company of the ITM Group which the User autonomously chooses to send the application, will get and use the information provided and the CV sent only for the purposes of the selection. In this respect, Users are strongly recommended not to insert any sensitive data (e.g. health conditions, sexual life, political opinions, etc.) except for those inserted in their CV only as strictly necessary for the purpose of the application selection and evaluation in compliance with legal obligation (e.g. minority group membership, etc.): in such cases, this data may be collected and processed also without express consent. Subsequently a written consent may be required at the time of first contact for the selection (e.g. first interview). The information of the CV sent to the Company will be processed only for staff recruitment and will be kept for the strictly necessary time.

7. Cookies

A cookie is a little file which a website sends to the browser and saves on the User’s computer when visiting a website. Cookies are used in order to allow or enhance the running of the website, but also to gain information on the Site or on the User’s web-browsing activities.
Generally speaking, the Site uses cookies both for technical purposes and for additional purposes: while technical cookies are used as strictly necessary to the correct running of the Site and to provide the User with the services expressly requested (e.g. authentication, language selection, etc.), as illustrated below, the cookies used for additional purposes (e.g. targeting and profiling cookies, analytics cookies) are used in order to carry out analysis of the User’s behaviour on the Site, in order to develop the content of the Site and send marketing messages in line with the preferences showed by the User during the web-browsing of the Site.

7.1 Technical cookies

These cookies are essential to allow the User to browse on the Site and use its functionalities, such as the access to the reserved area of the Site (cookie of authentication). The strictly necessary cookies are used to record a univocal identifier in order to manage and identify the User with respect to other Users visiting the Site in the same moment, providing the User with a consistent and precise service (e.g. the shopping cart). These cookies are necessary to the correct working of the Site and to record the choices expressed by the User (e.g. username, language, etc.), to distribute requests on different servers, to record when the User gives his/her authorization or expresses the consent to specific options (e.g. newsletters), to allow the User to visualize contents and video through Adobe Flash Player.

7.2 Performance and Analytics Cookies

These cookies may come from the Company or third parties such as Google Analytics session or persistent cookies, and their use is limited to the performance and enhancement of the Site. They collect information concerning how a User uses the Site, such as the pages visited. In addition, analytics cookies may recognize, measure and track the visitors of the Site, allowing us to improve and enhance the Site, by way of an example by ascertaining if the User easily finds the searched information, or by identifying the aspects of the Site are more interesting. Said cookies are used by the Company to elaborate statistical analysis on the ways Users browse through the Site, on the number of pages visited or of clicks made on a page during the browsing.
For information on how to manage the performance and analytics cookies installed by Google, as well as to refuse them, please visit the Privacy Policy of Google and the options on cookies at the following link:

7.3 Third party targeting and profiling technologies

These technologies are used by the Company in the form of pixel tracking in our emails in order to verify the clicks on the links or images contained there and the opening of the emails of newsletters. Such information are collected in order to calculate the number of Users which have visited the pages of the Site or clicked the content of the newsletters, allowing us not only to obtain statistical information, but also to identify the features and contents preferred by each User, in order to send personalized information.

7.4 How to disable cookies on the browser

Apart from the choice to accept or refuse the cookies used by the Site for additional purposes by means of the mechanism illustrated in this Privacy Policy, in the future the User may disable from the browser the cookies installed by the Site also by means of the setting of the same browser. The majority of web browsers are set to accept cookies. However, if so wishes, the User may set his/her browser to limit the number of cookies accepted or to block all cookies, by changing the browser’s settings with the following procedures:
• Microsoft Internet Explorer: Click “Tools” in the top right corner and select “Internet settings”. In the pop-up select “Privacy”: here the User may change the cookies settings.
• Google Chrome: Click the “wrench” in the top right corner and select “Settings”. Then select “Show advanced settings” and change the “Privacy” settings.
• Mozilla Firefox: In the top left menu select “Settings”. In the pop-up window select “Privacy”: here the User may change the cookies settings.
• Safari: In the top right menu select “Preferences”. Then select “Security” and change the cookies settings.
In order to carry out such operation in the mobile telephone, please consult the handbook of the device.

Please be aware that by disabling all the cookies on the Site, certain functionalities of the Site may not be available (e.g. authentication).

7.6 Further information on cookies

The website contains the instructions for the management of cookies of the most used browsers; alternatively, it is possible to consult the documentation related to the software used on the device.

8. Communication of data to third parties

The data provided by the User and those collected by the Site in the providing of the services (e.g. IP address) won’t be disseminated and may be communicated, also abroad in Countries outside the EU, exclusively for the purposes and with the modalities above, to the following categories of entities:

• collaborators, consultants, professionals, companies of the Group providing to the Company technical or organizational services (e.g. IT service providers), or collaborating with the Company, for the correct providing and execution of its services or for marketing activities;
• persons, companies, professionals, companies of the Group providing assistance and advice to the Company, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;
• subjects and entities legitimated to access the data by law provisions or authorities’ order.
The subjects and entities indicated above will process the data in their quality as autonomous Data Controllers pursuant to applicable law or as Data Processors. The list of names of the subjects to which the data are or may be communicated is available by contacting the Company at the address indicated in par. “Contacts and Users’ rights”.

9. Data retention

To ensure the continuous update of the data, the Company will deactivate the User’s account and the services requested after a period of 12 months of inactivity by the same User. The User will always have the possibility of registering again.

10. Contacts and Users’ rights

Section 7 of the Privacy Code grants the User, in its quality as data subject (i.e. the natural person whose data is processed), the exercise of specific rights.
In particular, the User has the right to obtain:
(i) the confirmation as to the existence of data concerning the User, even if not recorded yet, and the communication of the same data in intelligible form;
(ii) the indication of the origin of the data, purposes and modalities of the processing, subjects and categories of subjects to which the data may be communicated or which may know the data in their quality as representatives in the State’s territory, as data processors, or persons in charge of the processing;
(iii) the updating, rectification or, in case of interest, integration of the data;
(iv) the erasure, anonymization or the blocking of the data unlawfully processed.
The User has the right to oppose, also partially for the single channels of communication, on legitimate grounds, the processing of the data and to oppose the processing for commercial information, marketing, profiling and market research purposes.
The rights listed above may be exercised by means of the specific functions available on the Site, or of the links inserted in the emails.

11. Amendments to the Privacy Policy

The Company may amend, from time to time, this Privacy Policy, by publishing the amendments on the Site. We invite Users to check periodically such updates.
In case the amendments are particularly meaningful, the Company may communicate them to the User by means of a different channel (e.g. by sending an email).