Privacy Notice

1. INTRODUCTION

Medical Microinstruments, Inc., a Delaware corporation, with a registered address at  1209 Orange Street, Wilmington, Delaware 19802, and an office at Via Egidio Giannessi 52/54/56 – 56121 Montacchiello (PI) Italy, along with its parents, subsidiaries, and agents (hereinafter also referred as “MMI” or “we” or “Data Controller”) respects your privacy of its customers, visitors, suppliers, business partners, employees and other individuals (hereinafter referred to as “you” or the “data subject” or “user”).  MMI is and is committed to protecting your privacy through our compliance with this privacy notice.

This notice describes the types of information/personal data, as indicated below, we may collect from you or that you may provide when you visit the website https://www.mmimicro.com  (hereinafter also referred as “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information/personal data.

Please read this notice carefully to understand our practices regarding your personal data and how we process it.

2. CONTACT INFORMATION

The Data Controller is MMI and can be contacted at the following e-mail address and physical mailing address:

Attn: Legal Department

Via Egidio Giannessi 52/54/56 – 56121

Montacchiello (PI) Italy

Legal.mmi@mmimicro.com

                                                                                                                              

3. DEFINITIONS

By “personal data” we mean any information relating to an identified or identifiable natural person with particular reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factor specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

By “processing” we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. PERSONAL DATA PROCESSED

For the pursuit of the purposes set out below, MMI will process personal data belonging to the following categories:

• Data provided voluntarily (common personal data)

Through the Website you have the opportunity to voluntarily provide personal data such as your first and last name and your e-mail address to subscribe to our newsletter service, to attend our webinars or to contact MMI through the “Contact Us” form or other similar services. Further details on the collected data are provided by specific information texts on the application forms.

MMI will process these data in compliance with applicable law.

• Navigation data (common personal data)

The data in this category are collected via cookies. For detailed information on the cookies used, please refer to the specific cookie policy.

5. PURPOSES OF PROCESSING, LEGAL BASIS, AND RETENTION PERIODS

The purpose of the processing are the follows:

1. Purposes based on your consent.
   1. Management of newsletter subscribers.

MMI may use the data provided by you to send you commercial and promotional communications relating to its activities and services.

Data retention period: two years from the collection of the consent.

1. To enable the working of Website functions requested by the user.

MMI may use the data collected through cookies in order to ensure your greater experience of the Website.

Data retention period: the data processed for the above purpose will be kept as set forth within the cookie policy.

1. Purposes for performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
2. Provision of requested services.

MMI collects supply requests, which can also be sent via the ‘Contact us – Technical Support’ or ‘Contact us – Customer Service’ section, in order to deal with all such requests and with any suggestion in an appropriate and timely manner.

Data retention period: ten years from (1) the latest pre-contractual request or (2) the end of the contractual relationship.

1. Purposes for the fulfillment of our legitimate interests.

• Ensure the proper functioning of the Website.

MMI collects and uses your information to technically administer the Website and to ensure that it functions properly. MMI may use the personal information you provide to respond to your reports or complaints regarding the proper functioning of the Website.

Data retention period: the data processed for the above purpose will be kept (1) as set forth within the cookie policy – with regard to cookies – and/or (2) until the resolution of your report / complaint regarding the proper functioning of the Website.

 

1. If necessary, to protect contractual and pre-contractual rights or, in any case, any right arising from existing relationships.

Data retention period: the data processed for the above purpose will be kept for the same retention periods as indicated above, depending on the specific reference purpose.

Note. Should it be necessary to ascertain, exercise or defend the MMI’s rights in court, the retention period may extend until the termination of the litigation.

6. NATURE OF PROCESSING

Related to the above purposes, we point out that:

1. Where the legal basis is your consent, the provision of your personal data is optional; if you do not give your consent, there will be no negative consequences for you, except for the non-performance of the relevant services;
2. In other cases, the provision of your personal data is necessary in order to execute the contract concluded with you or to take steps at your request prior to entering into a contract: in such cases, failure to provide your personal data may result in our inability to perform what you have requested (e.g., provide you with the services).

Note. What has just been stated does not apply to the use of technical (necessary) cookies, which, as indicated within the cookie policy, allow us to ensure the proper functioning of our Website. It should be noted that if the functionality of these cookies had been restricted through the settings of the browser used, depending on different situations it may be difficult or impossible to browse properly.

7. METHODS OF DATA PROCESSING

Processing shall be carried out by means of paper and/or electronic instruments, including by persons authorized to do so, operating under the direct authority and according to the instructions given by MMI, with logic strictly related to the purposes indicated and, in any event, in such a way as to guarantee the security and confidentiality of the data processed.

Processing operations are carried out in such a way as to guarantee the security of data and systems. Specific security measures are adopted in order to reduce to a minimum the risks of destruction or loss, even accidental, of the data themselves, of unauthorized access, of processing that is not permitted or does not conform to the purposes indicated in this privacy notice. The security measures taken, however, do not make it possible to absolutely exclude the risks of compromise of personal data transmitted electronically. For this reason, it is important that you are aware of the risks and act in a responsible manner in order to mitigate them.

8. THIRD PARTIES TO WHOM YOUR DATA MAY BE DISCLOSED

Your personal data may be disclosed, for the purposes specified in section 5, to:

1. Personnel authorized by the Data Controller to process personal data on its behalf (such as MMI’s employees) who have committed to confidentiality or have an appropriate legal obligation of confidentiality;
2. Suppliers who provide services to the Data Controller and, by processing personal data, have been appointed as data processors (such as, for example, IT service providers, communication providers, external consultants, etc.);
3. Administrative or judicial authorities in the exercise of their functions, where required by the legislation in force.

Your personal data will not be subject to dissemination and will not be disclosed to third parties who are not authorized to process it.

The complete and updated list of autonomous data controllers, data processors appointed by MMI and recipients of data in any capacity may be requested at our offices.

9. DATA TRANSFERS ABROAD

MMI may transfer personal data to third parties as autonomous data controllers or data processors in order to carry out the activities described in this notice. Your personal data may be transferred to countries where the local legislation provides a different level of protection for your personal data and rights. If that is the case, we use appropriate safeguards like standard contractual clauses to effectuate the transfer and will transfer the data only after having carried out an assessment of the level of protection of your rights on the territory of the third country where the recipient is established. The information that we collect about you will be stored in the EU (European Union) / EMEA (Europe, Middle East, Africa). We have implemented international data transfer agreements based on standard contractual clauses; more information about these clauses or the transfer of personal data can be obtained by contacting us at through the contact details given in section 2.

10. CHILDREN

We understand the need to protect children’s privacy online (we define “children” as persons who, according to the legislation applicable in the country of the data subjects, are considered minors). We do not knowingly collect or use any personal data from children as well as do not knowingly allow children to register with us, order our products, communicate with us, or to use any of our online services. If you are a parent or guardian of a child and you become aware that he or she has provided us with personal data without your consent, you should contact us at the e-mail address given in section 2. If we become aware that a child has provided us with personal data, we will delete those.

In any case, by using the service, the data subject declares that it is not a minor according to its legal system.

11. YOUR RIGHTS

Users may exercise following rights, with reference to the data processed by MMI:

1. a) Right to access.

You may obtain confirmation from MMI as to whether or not your personal data is being processed and, if so, obtain access to your personal data.

If your personal data are transferred to a third country or international organization, you have the right to be informed of the existence of adequate safeguards relating to the transfer.

If requested, MMI may provide you with a copy of the personal data being processed. For any additional copies, we may charge you a reasonable fee based on administrative costs. If the request in question is made by electronic means, and unless otherwise stated, the information will be provided to you in a commonly used electronic format.

1. b) Right to rectification.

You may obtain from MMI the rectification of your personal data that are inaccurate, as well as, taking into account the purposes of the processing, the integration of the same, if they are incomplete, by providing a supplementary declaration.

1. c) Right to erasure.

You have the right to obtain without undue delay the erasure of your personal data in one of the following cases:

• The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• You withdraw the consent on which the processing was based and there are no other legal grounds for the processing;
• You object to the processing, as provided in the “Right to object” section below;
• Your personal data has been unlawfully processed; or
• Your personal data has to be erased for compliance with a legal obligation.

We inform you that MMI may not delete your personal data if their processing is necessary, for example, for the fulfillment of a legal obligation, for reasons of public interest, for the establishment, exercise or defense of a legal claim.

1. d) Right to restriction.

You have the right to obtain restriction of processing in the following cases:

• Where you claim inaccuracy of your personal data processed by us (the restriction being provided for a period enabling MMI to verify the accuracy);
• Where the processing appears unlawful and you oppose the erasure and request the restriction of use of your personal data instead;
• Where MMI does not need your personal data for the purposes of processing, but the personal data is required by you for the establishment, exercise or defense of legal claims; and
• Where an objection is raised by you in relation to the processing, pending the verification whether the legitimate grounds of MMI override those of you.

When you have obtained a restriction of processing of your personal data, you will be informed prior to lifting of such restriction.

1. e) Right to object.

As a general rule, you have the right to object, at any time and on legitimate grounds relating to your particular situation, to the processing of your personal data based on our legitimate interests. Provided that such objection is justified, MMI will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests.

1. f) Right to data portability.

Where the processing of your personal data is based on consent or is necessary for the performance of a contract or of pre-contractual measures and the processing is carried out by automated means, you may:

• Request to receive your personal data in a structured, commonly used and machine-readable format (e.g., computer and/or tablet);
• Transmit your personal data received to another data controller without hindrance from the Data Controller.

You may also request that your personal data be transmitted by MMI directly to another data controller indicated by you, if this is technically feasible for the Data Controller. In this case, it will be your responsibility to provide us with the exact details of the new data controller to which you intend to transfer your personal data, and to provide us with written authorization to do so.

1. g) Right to withdraw consent.

Where the processing of your personal data is based on consent, you have the right to withdraw such consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Note: in addition, in relation to cookies you can always change your consent via the “cookie settings” button available at the bottom left of the interface.

1. h) Right to lodge a complaint.

If you believe that your rights have been compromised or violated, or that the processing of your data is contrary to the regulations in force, you also have the right to lodge a complaint with the competent supervisory authority.

To exercise your rights, you can make an explicit written request to the Data Controller using the contact details indicated in section 2. At the same contact details you may request, at any time, for further information on the processing of your personal data; please note that the exercise of your rights must not prejudice and/or infringe the rights and freedoms of others.

MMI undertakes to reply to requests within one month, except in the case of particularly complex requests, for which it may take up to three months. In any case, MMI will explain the reason for the wait within one month of the request.

The outcome of the request will be provided in writing (at your request) or in electronic format (and, in this case, free of charge). MMI specifies that a possible contribution may be requested from you if your requests are manifestly unfounded, excessive or repetitive: in this regard, we will track your requests.

MMI, in compliance with the applicable regulations, undertakes to report to the recipients to whom your personal data have been disclosed any rectification, erasure or restriction of processing requested by your, where this is possible.

14. CHANGES

This privacy notice is updated as of October 9, 2023.

MMI reserves the right to modify or simply update its content, in part or in full, including due to changes in applicable law. MMI will inform you of any such changes as soon as they are introduced and will be binding as soon as they are published on the Website, and invites you to regularly visit this section in order to be aware of the most recent and updated version of the privacy notice so that you are always updated on the data collected and the processing carried out.