Italtractor ITM S.p.A is primarily responsible to you for any questions, concerns or complaints you may have about this Policy or our handling of your information. If you have questions, please contact the Data Privacy Leader at:
Post: Via Confortino, 30 - 40056 Valsamoggia - Loc. Crespellano (BO) – Italy
Telephone: +44 (0)1562.850561
This privacy notice also covers our group of companies ("ITM Group") and we've listed them below:
Titan Intertractor GmbH
VAT DE 815 517 982
Hagener Strasse 325
D - 58285 Gevelsberg
Pyrsa - Piezas Y Rodajes S.A.
Poligono Industrial El Tollo
Km174,2 - Apartado de Correos 18
E - 44300 Monreal Del Campo
Intertractor America Corporation
960 Proctor Drive
Elkhorn, Wisconsin 53121
ITM Latin America Ltda
Rodovia Edgard Máximo Zambotto,
Km 79 Bairro Ponte Alta - Atibaia
São Paulo - CEP 12952-901
Titan ITM (Tianjin) Co. Ltd
n. 6 Hechang Road
Wuqing Development Area
People's Republic of China
If you would like to access previous versions of this Policy please click here. Alternately you can email TeamGDPR@group-itm.com
2. information we collect
2.1 Information you give us. You may give us information, including information that can identify you ("personal information"), when you use our Website, correspond with us, enquire about or purchase our goods or services. Where we request information from you, we will collect the information set out in the relevant forms or pages. You may choose to provide additional information to us when you contact us or otherwise interact with us.
We collect your personal information when you communicate with us whether in person, through our Website, email, over the phone, or via any other medium. For example, we collect your contact details and the details of our messages to you and from you (including when you sent it, when we received it and where you sent it from).
If you are a regular user of our Website (such as the Catalogue, TrackAdvice,) or wish to subscribe to specific services, you may wish to create a Client Account ("Account") with us. The information that you provide when setting up your Account may include your name, email address, company name, your ITM contact and telephone numbers. If you register to hold an Account with us, you will also have a unique password which enables you to access your Account.
You may also provide us with personal data (such as the content and circumstances of your communication with us and your contact details) in order to receive additional information and/or services. The data will be processed by us exclusively for the purpose strictly related to your request. The refusal to provide that data may affect the possibility of you receiving the service or information requested.
2.2 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 interaction. We collect information automatically through the use of various technologies, including through "cookies" (please see section 8 of this Policy below)
2.3 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 are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, 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:
(a) providing and improving our products and services to you or your company: we use your information in order to provide you with, and improve, the products and services you or your company have requested, including when making purchases, sending you confirmation emails or contacting you regarding your Account. This also includes using your information to make payment to you or your company or take payment from you or your company. We use your information to improve our products and services to better suit the technical capabilities of our customers;
(b) 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;
(c) administering the Website: we use your information in order to administer our Website for internal operations, including troubleshooting purposes and to understand any errors you may encounter when using our Website;
(d) safety and security: we use information collected on our Website as part of our efforts to keep our Website safe and secure and to help manage and administer our IT systems;
(e) marketing: we use your information in order to communicate with you and keep you up to date with our activities and those of ITM Group companies that you may be interested in and to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them. We will provide you with this information via email, text or telephone. For more details on how we will market to you, please see section 6 of this Policy below;
(f) online advertising: we use your information in order to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. For more details please see section 7 of this Policy below. We also use your information when communicating with you through social media in order to build and maintain our social media brand;
(g) investigating any complaints and providing customer service: we may use your information in order to investigate any complaints on your behalf and to provide you with a 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;
(h) recruitment: We accept online applications to work in our company or in 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 curriculum vitae and covering letter). We will use your personal information only for the purposes of progressing 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; and
(i) to make necessary disclosures: we may use your information in order to make necessary disclosures in response to requests which we are legally required to comply with, to law enforcement or regulatory authority, body or agency or in the defence of a legal claims.
4. Why we use your information
Our processing of your personal information will be based on a variety of legal grounds, including:
(a) where the processing is necessary for the purposes of our legitimate interests: this includes, for example, to: (1) provide our products and services to you; (2) 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; (3) better understand how you use our products, services and Website and to make improvements; (4) research and analyse the products and services you want; (5) tailor our content and offers to those more relevant to you; (6) provide security over our business and who we partner with; and (7) develop and maintain relationships with vendors, partners and other companies and dealing with individuals who work for them;
(b) where we need to comply with a legal obligation: for example, we may need to disclose your data to a law enforcement agency or to your or our representatives acting in a legal dispute;
(c) where you have provided your consent: for example, we may require your consent when using technologies such as cookies.
If you would like to have more information about our legitimate interests to process your personal data, please contact us as set out below.
If you are unable or do not want to provide the personal information we need in order to perform a contract with you or comply with a legal obligation, this may result in us not being able to facilitate your request. For example, if you do not provide us with your delivery address, we will not be able to process your order or send products to you.
5. how we share and disclose your information
We may share your information with members of Titan/ITM Group for the purposes outlined at section 3 of this Policy and with the third parties identified in this Policy. We may also share your information with third parties when:
(1) it is 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) in connection with the sale, transfer or reorganisation of a business;
(5) 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) to ensure the safety and security of our users, customers, consumers and third parties; and
(7) to protect our rights and property and the rights and property of our guests and third parties.
These third parties include organisations providing a service to us or acting as our agents, including, but not limited to, sub-contractors (including their agents), consultants and professional advisers, IT suppliers, database providers, backup and disaster recovery specialists, email providers and other service providers necessary for improving our products and services.
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your personal information, will only be provided in connection with the performance of their function. They will not be permitted to use your personal data for any purposes other than those outlined in this Policy.
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. In any event, we will offer you the option to unsubscribe in every communication sent.
You may object to receiving direct marketing from us at any time by contacting us by email at TeamGDPR@group-itm.com or selecting the unsubscribe option in our email communications.
7. Cookies and other technologies
For information about the specific cookies used on this Website, please refer to our Cookies Policy.
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.
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
• 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 www.allaboutcookies.org 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.
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).