newsletter Privacy Policy

Interested parties: subscribers to the newsletter (clients and potential clients)

In compliance with art. 13 of the Privacy Code, Leg. Dec. 196/2003, we are writing to inform you that COEM S.p.A., in its capacity as Data Controller, electronically processes your data in order to fulfil the request to forward the newsletter and relative registration in the mailing list for direct marketing purposes, for forwarding the newsletter and for the forwarding of promotional, commercial and advertising material or relating to events and initiatives of the Data Controller, in complete compliance with the principles of lawfulness, fairness and legal provisions.  This service is performed through the use of automated systems as referred to in art. 130 of the Code (e.g. e-mail, fax, mms, text messages, etc.). The provision of your personal data is always optional; however, in the absence of providing data marked as “obligatory” in the above form, it will not be possible to provide the service. Your personal data will be processed with manual, electronic and/or computerised means, through the use of cookies (as indicated in the web and cookie policy document available on the site), through automated systems as provided for in art. 130 of the Code and through the use of cookies (for more information reference should be made to the privacy and cookie policy available on the site) in compliance with the procedures as per arts. 11, 31 and following of the Privacy Code and through the adoption of the minimum security measures provided for by the Technical Regulations, Annex B. To analyse and possibly improve the results of communications, the Data Controller uses systems for the forwarding of newsletters and promotional communications with reports. Thanks to these reports, the Data Controller can obtain information, for example regarding: the number of readers, of openings, of single “clickers” and of clicks; the devices (iPhone, Blackberry, Nokia…) and operating systems (Windows, Apple, Linux, Android…) used to read the communication; details of the activity of single users; the number of users held in suspension who have not yet confirmed subscription; details of the e-mails sent by date/hour/minute; details of the e-mails received and not, and of those forwarded; the list of “un-subscribers” to the newsletter; those who have opened an e-mail or clicked on a single link; users with problems visualising the message; the tracking link (that is, the number of clicks made on the links of the message); the tracking click (links which have been clicked and by whom). All these data are used for the purpose of analysing, and possibly for improving, the results of communications.

The data will be stored at the data Controller’s premises, at the site of the external provider (appointed as Data Supervisor) and on the platform used for forwarding Mail UP commercial information, and will be processed only by categories of suitably authorised persons in charge of processing (contact the Data Controller for information regarding the categories) and will be communicated externally only and exclusively to perform the services necessary for the correct management of the commercial relationship, guaranteeing the protection of the rights of the interested party (contact the Data Controller for the list of external entities). Your data may, moreover, be visualised also by the companies that manage the website, limited to technical accesses for maintenance and management needs of the web server. Your data will not be disseminated. In your capacity as interested party, you have the rights as per art. 7 of the Code, including the right to access the data free of charge, to obtain without delay their updating or cancellation due to breach of law, and to oppose the processing of your data for commercial or advertising information purposes.

Data Controller: The Date Controller is COEM S.p.A. – Via Cameazzo 25 – 41042 Fiorano Modenese (Mo) e-mail:

You have the right to obtain from the Data Controller the cancellation, communication, updating, correction, and integration of the personal data that refer to you, as well as, in general, to exercise all the rights provided for by art. 7 of the Privacy Code, a copy of which is provided below, by writing to the company registered office or by sending an e-mail to

Legislative Decree no. 196/2003: Art. 7 – Right of access to personal data and other rights

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning them exist, regardless of their being already recorded, and communication of such data in intelligible form.

2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.