PRIVACY POLICY FOR THE PROCESSING OF PERSONAL DATA

(provided pursuant to Legislative Decree No. 196 of 30/06/2003 and subsequent amendments, known as the “Privacy Code,” and Regulation EU 2016/679, known as “GDPR”)

This document (“Privacy Policy”) provides information regarding the processing of personal data, as specified below, which you will provide to the Italian company “CLOVER ORTHOPEDICS S.r.l.,” a sole proprietorship, with its registered office at Via Gadames No. 57/7, 20151 Milan (MI), Italy, share capital of EUR 10,000.00 fully paid, tax code and registration number in the Business Register of Milan Monza Brianza Lodi 11137730963, R.E.A. MI-2582827 (hereinafter also referred to as “Clover Orthopedics”). This information is provided for the website www.cloverorthopedics.com, owned by Clover Orthopedics, and is issued pursuant to Legislative Decree No. 196 of 30/06/2003, as amended (the “Privacy Code”), and Regulation EU 2016/679 (the “GDPR”).

The Data Controller is Clover Orthopedics itself, represented by its pro-tempore legal representative (hereinafter referred to as the “Controller”). For any inquiries, you can contact Sintea Factory via the following email address: info@cloverorthopedics.com or via the certified email address (PEC): cloverorthopedics@pec.it.

Within the scope of the purposes and methods described in this Privacy Policy, the personal data you provide, which may fall under the following category, will be processed: “Personal Data,” which includes your personal information (e.g., name, surname, and tax code) and contact details (e.g., email address and mobile phone number). Such data will hereafter be referred to as “Personal Data.” Clover Orthopedics does not collect, request, or process sensitive data from users. Specifically, by entering your email address and requesting communications, you explicitly authorize Clover Orthopedics to process your Personal Data, which will be used for the following purposes:

1. Managing your requests: If you voluntarily submit requests (e.g., for information or to be contacted), you are free to provide your Personal Data; however, failure to do so will prevent any relationship with Clover Orthopedics and the fulfillment of your request. Please note that any Personal Data provided via email or through forms on the website www.cloverorthopedics.com will be acquired solely for purposes strictly related to fulfilling your requests and will not be disclosed to unauthorized third parties or disseminated in any way. Your mobile phone number and email address will be requested to respond to your inquiries or, more generally, to contact you. The legal basis for this processing is your explicit request to be contacted.
2. Marketing communications: To send promotional communications related to the activities of the Controller, newsletters, customer satisfaction surveys, or information on events organized by Clover Orthopedics or its commercial partners (e.g., healthcare-related informational events, professional congresses, or updates on innovations in the healthcare sector), mainly via email. The legal basis for this processing is your explicit consent.

By entering your email address and requesting communications or completing any forms available on the website www.cloverorthopedics.com, you automatically authorize the Controller to collect and process your Personal Data for the purposes outlined herein.

Your Personal Data will be processed using manual, computerized, or telematic tools designed to ensure security and confidentiality by appropriately trained personnel, in compliance with applicable regulations, to achieve the aforementioned purposes. The data is stored on servers located at our facilities and with Aruba. For disaster recovery and business continuity purposes, data may be hosted on servers (physical or virtual) in external facilities located within the EU, ensuring full compliance with Regulation 2016/679 (GDPR). If necessary, the Controller reserves the right to relocate server locations to other EU or non-EU countries, ensuring that any transfers outside the EU comply with applicable regulations.

The provision of your Personal Data for the purposes outlined above is optional; however, failure to provide this data will prevent Clover Orthopedics from utilizing it and fulfilling the activities described in this Privacy Policy. By providing your email address or completing forms on the website www.cloverorthopedics.com, you have explicitly consented to the processing of your Personal Data by Sintea Factory.

Your Personal Data will not be disclosed or disseminated unless required by law (e.g., requests from law enforcement, judicial authorities, or other public entities for defense or security purposes or the prevention, detection, or prosecution of crimes).

Personal Data provided via www.cloverorthopedics.com will be processed and stored for ten (10) years from the date of submission.

Your Personal Data may be shared with professionals and/or third-party companies, including those located outside the EU, provided they comply with GDPR requirements and provide services related to Clover Orthopedics’ activities through www.cloverorthopedics.com, especially for marketing purposes. For instance, your data may be shared with public or private entities, individuals or organizations (e.g., legal, commercial, tax, or labor consultants, couriers, IT companies) that assist the company in its operations. An updated list of data processors and authorized individuals is available for consultation at the Controller’s registered office.

Data Subject Rights
In compliance with GDPR, you have the right to:
(i) Confirm the existence of your Personal Data and access it in an intelligible format.
(ii) Request details on the source, purpose, methods, and retention period of data processing.
(iii) Request updates, corrections, or deletion of data processed unlawfully.
(iv) Object to processing for legitimate reasons or marketing purposes.
(v) Request processing restrictions or data portability.
(vi) Revoke your consent at any time, without affecting the legality of processing based on consent prior to revocation.

To exercise these rights, submit a written request to Clover Orthopedics S.r.l. at the provided contacts. For unsatisfactory responses, you may file a complaint with the Italian Data Protection Authority at www.garanteprivacy.it.