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Privacy Policy

Date of last update: 30/03/2023

Compliance with data privacy and data protection legislation is essential to ensure that personal data remains secure, that our business operations are as efficient, secure and transparent, and that the rights of data subjects are respected.

This Privacy Policy (“Policy”) aims to provide all users with detailed information about the nature of personal data collected and the respective purposes of processing, and thus comply with the right to information and enhance the transparency of our activities.

The provision of personal data in the context of browsing the Site and using our Products implies knowledge and explicit acceptance of the conditions contained in this Privacy Policy and in the Cookies Policy.

1. Who is the Controller?

Evinrude due S.r.l. Evinrude due S.r.l is an innovative SME with REA (Company registration): MI - 2109554 and Share Capital of €750,000 with headquarters in Via Giosuè Carducci 8, 20123, Milan Italy and registered with the Register of Companies of Milan, Monza, Brianza.

Evinrude due S.r.l (hereafter referred to as “Coverflex”) is a company owned by Universal Cover S.A. and part of the Coverflex Group.

2. Does Coverflex have a Data Protection Officer?

To reinforce our commitment to the protection of personal data, Evinrude has appointed a Data Protection Officer who can be contacted at the following email address: [email protected].

3. Use of Coverflex Site

Accessing and browsing the Site does not necessarily imply the provision of personal data. However, certain features require it, such as submitting a contact form to ask questions about Coverflex products or registering for a webinar.

The remaining features available on the Site and associated with Coverflex products require prior registration on the Coverflex application in agreement with the subscription of the respective product, being the processing of personal data in this context subject to a separate Privacy and Cookies Policy.

For recruitment and selection purposes, you can consult the Privacy Policy - Careers, available here.

4. What categories of personal data are collected?

Personal data means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier. Coverflex collects and processes the following categories of personal data:

• Identification data, such as name;
• Contact data, such as e-mail address and phone number;
• Location data, such as the country of residence;
• Professional data, such as company name and job title;
• Navigation and usage data, such as IP address, cookies and similar tracking technologies. The collection and use of Cookies is regulated in our Cookie Policy.

5. On what basis and for what purposes is my personal data processed?

At Coverflex, we process your personal data in order to provide our Products, to execute the agreement concluded with you, and/or to comply with any established legal or pre-contractual obligations, as well as for Coverflex's legitimate interests or your consent, where applicable.

Additionally, through contact registration on the Site forms, we also use your information for contact management and direct marketing purposes to promote our Products, as well as sending emails with updates about the company, invitations to events, newsletters, and other information related to Coverflex.

It is also very important to us to keep our products and services visible, which is why we have this website. To do this, we maintain a secure database with the information we collect from you, with your consent, to share information about Coverflex.

Note: If you wish to unsubscribe at any time and stop receiving future e-mails, there are detailed instructions at the bottom of each e-mail.

Furthermore, your personal data will be collected and processed to answer the questions you may send through the Site.

6. For how long will my personal data be processed?

We only retain your personal data for the period strictly necessary to fulfill the abovementioned purposes within the legal limits. After the defined conservation period ends, Coverflex undertakes to delete, destroy or anonymize your personal data.

You can request additional information regarding the retention periods of your personal data by communicating to us at the e-mail address [email protected].

7. Who are the recipients of my personal data?

Your data may be communicated to third parties when the transmission is made in order to comply with a legal obligation, a resolution of the Supervisory Authority or other relevant control authority, or a court order; or when the communication is carried out to protect the vital interests of Users or any other legitimate purpose provided by law.

Additionally, it should be noted that Coverflex uses or may use third parties (processors) hired by it to, on behalf of Coverflex and in accordance with the instructions given by it, process the user's data in strict compliance with the law and this Privacy Policy. Coverflex undertakes the commitment to hire only processors who provide sufficient guarantees of implementation of appropriate technical and organizational measures to ensure the protection of the user's rights.

For the purpose of sharing personal data, these, where applicable and in the terms set out above, may be communicated to partners, other group companies, carriers, marketing campaign agencies, sales services, support, and customer support, among others.

8. Are there international data transfers?

By rule, Coverflex does not transfer data outside the European Economic Area ("EEA"). However, any information that may be shared with a third country outside the EEA, i.e. that is necessary to ensure full compliance with the purposes mentioned in this Privacy Policy, for example, in the context of using certain providers of computer systems support services, Coverflex undertakes to carry out such a transfer in full compliance with applicable legal provisions, including as to the determination of the adequacy of such country with respect to data protection or by providing adequate safeguards.

9. What are my data protection rights and how can I exercise them?

Under applicable law, you may request the following data protection rights at any time:

• Right of Access: right to obtain confirmation as to whether or not personal data concerning the User are being processed and, if so, the right to access his/her personal data and certain information.
• Right of Rectification: right to rectify inaccurate personal data concerning the User or to request that incomplete personal data be completed.
• Right to Erasure: right to obtain the erasure of your personal data, without undue delay as long as there are no valid reasons for its retention, such as cases where it has to be kept to comply with a legal obligation or because a judicial process is underway.
• Right to the Limitation of Processing: right to request limitation of the processing of your personal data, in the form of suspension of processing or limitation of the scope of processing to certain categories of data or purposes of processing, as set out in Article 18 of the GDPR.
• Right of Portability: the right to receive the personal data concerning you that you have provided in a structured, commonly used, and machine-readable format and/or the right to have such data transmitted to another controller.
• Right of Opposition: right of the User to object at any time to the processing of data concerning him/her, provided that there are no legitimate grounds for such processing which override the User's interests, rights and freedoms, or for the purposes of the establishment, exercise or defense of a right in a legal proceeding.

The User may also revoke his or her consent for processing dependent on obtaining consent, without such revocation invalidating the processing of the data while consent was in effect.

In addition, you may lodge a complaint with Supervisory Authority or another competent data protection authority (https://edpb.europa.eu/about-edpb/board/members_en).

You can exercise your rights at any time. To do so, send a communication to the following e-mail address: [email protected].

Additionally, for the purpose of verifying the User's identity as the owner of the personal data, the communication must contain, whenever possible, the following elements: name, e-mail address and the right(s) you wish to exercise.

Note that if an authorized representative exercises any rights on your behalf, proof of such authorization will be required.

Coverflex will reply through the means by which you exercised your right within a maximum period of one month from the receipt of the request, except in cases of special complexity, in which this period may be extended to two months upon due justification.

10. How is my personal data protected?

Coverflex employs the best means at its disposal to protect users' personal data against unauthorized access, disclosure, modification, or destruction of data. To ensure the security of user data and maximum confidentiality, Coverflex handles information in an absolutely confidential manner, in accordance with internal security and confidentiality policies and procedures, which are periodically updated as necessary, as well as in accordance with the terms and conditions provided by law. Depending on the nature, scope, context, and purposes of data processing, as well as the risks arising from the processing to the rights and freedoms of the User, Coverflex undertakes to implement, both when defining the means of processing and when processing itself, the necessary and appropriate technical and organizational measures for the protection of the User's data and compliance with legal requirements.

11. Final provisions

Cookies

Coverflex collects and uses cookies on its Site. If you wish to manage the cookies collected and stored you can do so via the following link. For more information, please consult our Cookies Policy.

Minors

In strict compliance with the GDPR, we do not collect any information from persons under the age of 13. Our Site, Products and/or services are all directed to persons 13 years of age or older.

Applicable law and jurisdiction

The Privacy Policy, as well as the processing of personal data by Coverflex, are governed by the provisions of Regulation (EU) 2016/679, of the European Parliament and of the Council, of 27 April 2016 ("RGPD") and by the laws and regulations applicable in Portugal.

To settle all questions and disputes that may arise, inherent to this Privacy Policy, the District Court of Coverflex headquarters has exclusive jurisdiction, without prejudice to the mandatory legal rules applicable.

Changes to the Privacy Policy

Coverflex may change this Privacy Policy at any time. These changes will be appropriately disclosed through the Site's pages, and if they involve a substantial modification in how data will be processed, Coverflex will notify such changes through the contact details it has made available.

Questions

Should you have any questions regarding the processing of your personal data and the exercise of your rights under applicable law and in particular under this Policy, please contact us at [email protected].