Privacy

Last Update: 04-may-2021

This Privacy Policy describes how we collect, use, process and communicate data concerning you, including personal data, in relation to your access and use of the services offered by M.T.E. sas. in compliance with Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation). This regulation applies only to natural persons.

When this document mentions “MTE,” “we,” “us,” or “our,” it refers to the company M.T.E. sas which is responsible for user data under this Privacy Policy (the “Data Controller”).

The data controller is M.T.E. sas di Fermi Roberto & C. with registered office in Via Luigi Guanella, 5 – 20128 Milan (MI) – Italy

1) Types of data we collect

MTE collects the following categories of data:

1.1) Information you provide us directly

When you use the platforms of the MTE services, we ask and collect the following personal data. These information are necessary for the proper execution of the contract between us and the user and allows us to act in accordance with our legal obligations. Without this data, we may not be able to provide you all the required services.

Account data. When you register for an account, we ask you to provide certain data such as your name and surname and E-Mail address.
Profile data. To use certain features (for example product shipments, issuance of tax receipts, etc.), we ask you to provide us with additional data, including your address, your telephone number.
Other authentication information. To help create and maintain a trusted environment, we may collect identification data or other authentication information (such as your social security number).
Payment information. To use certain functions of the MTE services we may redirect you to external services for the management of the payment (for example PayPal). No personal data will be transferred from us to PayPal during the payment process.
Communications with MTE. When you communicate with MTE or use the customers assistance services of MTE services, we collect information about your communications and any data you choose to provide.

1.2) Information we collect automatically when using the MTE services

When you use MTE services, we automatically collect information, including your personal data, about the services used and how they are used. These information are necessary for the proper execution of the contract entered into between us and the user, to allow us to act in accordance with our legal obligations and on the basis of our legitimate interest in being able to improve and offer you the functionality of the MTE services

Usage information. We collect information regarding your interactions with MTE services, including, for example, the pages or other content you view, your searches and other actions you perform on MTE services.
Log data and device information. We automatically collect log data and device information when a user accesses and uses the MTE services, even if he has not created an MTE account or is not logged in. This information includes, among other things: information on how the user has used the MTE services, IP address, date and time of access, information on hardware and software, information on the device, information on events concerning the device, unique identifiers, crash data, cookies, pages viewed by the user.
Cookies and similar technologies. Currently MTE does not use cookies and similar technologies to track or monitor user behavior.

2) How we use the data we collect

MTE uses, stores and processes your data, including personal data, to provide, understand, improve and develop MTE services, creating and maintaining a reliable and secure environment and comply with its legal obligations.

2.1) To provide, improve and develop MTE services

Allow you to access and use MTE services
Manage, protect, improve and optimize MTE services and the experience of our users, including, for example, conducting analysis and research activities
Provide customer support
Send you service or support messages, such as, for example, updates, security alerts and account notifications
If you provide us with your contact details, we may process this information to: (i) detect and prevent fraud attempts and (ii) any purpose you authorized at the time of data collection.

We process the information provided on the basis of the legitimate interest in improving our MTE services and the use that users make of them, and where necessary to ensure the proper execution of the contract between us and the user.

2.2) To create and maintain a more reliable and secure environment

Detect and prevent fraud, spam, abuse, security incidents and other malicious activities
Conduct security investigations and risk assessments
Verify or authenticate the information or identification provided by you (for example, verify the shipping address or check the personal data for tax purposes)
Perform checks by cross-comparing databases and other sources of information, including background checks, to the extent permitted by applicable law and with your consent when required
Fulfill our legal obligations
Resolve any disputes and enforce our rights against third parties
Ensure that our Terms of Service and our other policies are enforced
In connection with the activities described above, we may perform profiling based on your interactions with MTE services, on your profile data, on other content that you send to MTE services and on information obtained from third parties. In special cases, automatic processes can limit or suspend access to MTE services if such processes detect a potentially risky activity for the security of MTE services, its customers or third parties

We process the information you provide on the basis of the legitimate interest in protecting MTE services, measuring the proper execution of the contract between us and the user and complying with applicable laws.

2.3) To provide, personalize, evaluate and improve our advertising and marketing

Send you promotional messages, marketing information, advertising and other information that may be of interest to you based on your preferences (including information about MTE or one of its partners’ campaigns and services)
Personalize, measure and improve our advertising / communication
Manage referral programs, awards, surveys, sweepstakes or other promotional activities or events sponsored or managed by MTE or our partners
Perform profiling based on your characteristics and preferences (based on the information you provide, your interactions with MTE services) to send you promotional, marketing, advertising and other information that we think may be of interest to you

We will process your personal data for the purposes listed in this section on the basis of the legitimate interest in carrying out marketing activities to offer you products or services of your potential interest or that can improve and increase your professionalism or interest in the matter. You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in the communications you receive.

3) Sharing and communication

3.1) Compliance with the law, response to requests from public authorities, prevention and protection of our rights

MTE may disclose your data, including personal data, to courts, public authorities, government authorities or authorized third parties if and to the extent that they are required or authorized to do so by law or if such disclosure is reasonably necessary: (i ) to perform our legal duties (ii) to comply with a legal procedure and to respond to claims made against MTE, (iii) to find verified requests relating to a criminal investigation or an alleged or suspected illegal activity or any other activity likely to expose MTE, yourself or any of our other users to legal liability, (iv) to manage and enforce our Terms of Service or other agreements, (v) to protect MTE’s rights, property or personal safety , its employees, its users or the general public.

Where appropriate, we may notify users of such legal requests, unless: (i) providing such information is prohibited by applicable legal procedure, based on an order received from a court or under the law, or (ii) we believe that the notice is useless or ineffective, creates a risk of injury or physical harm to an individual or group of individuals, or creates or increases a risk of fraud against the property of MTE, its users and MTE services. In cases where MTE complies with legal requests for data communication without giving notice to the user for the aforementioned reasons, MTE will try to inform the user concerned about the request as soon as it determines in good faith that this is no longer prohibited.

3.2) Service Providers

MTE uses a variety of third party providers to provide services related to MTE services. The providers of these services are located within the European Economic Area (“EEA”). Specifically, our service providers are based in Italy.

For example, service providers can help us: (i) verify your identity, (ii) provide technical assistance, maintenance and product development services, (iii) enable the provision of MTE services through third party platforms and software ( for example through integration with our API), (iv) provide customer support, advertising or payment services. These suppliers have limited access to your data to perform these operations on our behalf and are contractually bound to protect and use such data in accordance with the purposes for which they received them and with this privacy policy.

MTE will have to communicate your data, including your personal data, to third party suppliers to ensure the adequacy of the contract entered into with you.

3.3) Social network platforms

MTE does not currently use social network platforms

3.4) Business operations

If MTE undertakes or is involved in any merger, acquisition, reorganization, business transfer or bankruptcy or insolvency proceeding, it may sell, transfer or share some or all of its assets, including your data, in relation or as a result of such transaction. In such cases, you will be notified before your personal data is transferred and becomes subject to a different privacy policy.

3.5) Aggregated data

We may also share aggregate data (information about our users that we combine so that they do not identify a single user or are not related to it) and other anonymous information for regulatory compliance, sector and market analysis, demographic profiling, marketing and advertising and other commercial purposes

4) Other important information

4.1) Analysis of your communications

We may examine or scan your communications with MTE services for fraud prevention, risk assessment, regulatory compliance, investigation, research, product development and customer service purposes. For example, we could scan, review or analyze messages to carry out debugging operations, as well as improve and expand the range of services. We will use automated methods when reasonably possible. However, occasionally, we may have to manually check some communications, including, for example, for anti-fraud investigations and customer support or to evaluate and improve the functionality of these automated tools. We will not review, scan or analyze your communications to send you marketing messages and we will not sell reviews or analytics of such communications.

These activities are carried out on the basis of MTE’s legitimate interest to ensure full compliance with applicable laws and our Terms of Service, prevent fraud, promote security, improve and ensure the proper performance of our services.

5) Partner and Third Party Integration

MTE services may contain links to third party websites or services, such as, for example, third party integrations, co-branded services or third party branded services (“Third Party Partners”). MTE does not own or control such Third Party Partners and when you interact with them you may provide your data directly to the Third Party Partners, MTE or both. These third party Partners have their own rules regarding the collection, use and communication of data. We invite you to carefully read the privacy policies of the other sites you visit.

6) Your rights

You can exercise any right described in this section towards the Data Controller, by sending an email to info@mtesas.org. We remind you that we may ask you to verify your identity before taking further action based on your request.

6.1) Data management

You can access and update some of your data from your Account settings. You are responsible for updating your personal data.

6.2) Rectification of inaccurate or incomplete information

You have the right to ask us to correct inaccurate or incomplete personal data concerning you (and which you cannot update personally from your MTE account)

6.3) Portability and access to data

You can request copies of your personal information that we hold. Additionally, you may be entitled to request copies of personal data you have provided to us in a structured, commonly used and electronically readable format, and / or request us to transmit such information to another service provider (where technically feasible)

6.4) Data retention and deletion

In general, MTE keeps your data for the time necessary to execute the contract stipulated with you and to fulfill our legal obligations. If you no longer want MTE to use your data in order to provide you with access to MTE services, you can request us to delete your personal information. We remind you that if you decide to request the deletion of your personal data:

We may retain some of your personal data for as long as necessary to satisfy our legitimate business interests, such as fraud prevention and detection and promoting security
We may retain some of your personal data to the extent necessary to fulfill our legal obligations. For example, MTE may retain some of your data for tax obligations, reports and legal investigations
Since we protect MTE services from accidental loss or data theft, residual copies of your personal data may, for a limited period of time, not be removed from our backup systems

6.5) Withdrawal of consent and limitation of the processing of personal data

Where you have given consent to MTE for the processing of your personal data, you can revoke this consent at any time by sending us a communication in which you specify which consent you want to revoke. We remind you that the withdrawal of consent does not affect the legitimacy of any processing activity based on it before its withdrawal. Furthermore, the applicable law may give you the right to limit the methods of use of your personal data by MTE, specifically if (i) you contest the accuracy of your data; (ii) the data processing is not carried out lawfully and you object to the deletion of your personal data; (iii) MTE no longer needs it for processing purposes, but requests information to ascertain, exercise or defend your right in court; or (iv) you have opposed the processing pursuant to section 6.6 below, pending verification of the possible prevalence of MTE’s legitimate reasons over your

6.6) Opposition to the processing of personal data

In some countries, the law allows you to request MTE not to process your personal data for specific purposes (including profiling) where such processing is based on a legitimate interest. If you object to such processing, MTE will no longer process your personal information for these purposes, unless we can demonstrate compelling legitimate reasons to proceed with the processing or if such processing is necessary to establish the assessment, exercise or defense of a right in court.

Where your personal data are processed for marketing purposes, you can at any time ask MTE to stop processing such data for direct marketing purposes by sending us an email to info@mtesas.org

6.7) Presentation of complaints

You have the right to lodge complaints regarding the data processing activities carried out by MTE with the authorities in charge of data protection.

7) Safety

MTE constantly implements and updates security measures of an administrative, technical and organizational nature aimed at protecting your data from unauthorized access by third parties, from destruction or alteration. Some of the security measures we use to protect your information are firewalls, encryption, and information access controls. If you have reason to believe that your login credentials to your MTE account have been lost, stolen or otherwise compromised, or in the case of unauthorized use or suspected use of your MTE account, you can contact us as described in the Contact Us section

8) Changes to this privacy statement

MTE reserves the right to modify this privacy statement at any time in accordance with this section. In the event of changes to this privacy policy we will publish the updated version on MTE services and update the “Last Updated” date at the top of this document. We will also give you notice of changes made by email at least thirty (30) days prior to the effective date of the changes. If you do not agree with the modified privacy policy, you can ask us to delete your account or your data. If you do not ask to cancel your account or your data before the date of entry into force of the updated privacy policy, your access or continued use of the MTE services will be subject to the privacy policy as per the latest modification.

9) Contact us

If you have any questions or complaints regarding this privacy policy or MTE’s data processing practices, you can send us an email to info@mtesas.org or contact us at the following address:

M.T.E. sas di Fermi Roberto & C.
Via Luigi Guanella, 5
20128 – Milano (MI)
Italy