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Privacy Policy

Omega Front, as the Data Controller, informs pursuant to Article 13 of EU Regulation No. 2016/679 (“GDPR”) that the data provided by users (the “Data Subject” or the “User”) through the website available at the link: https://cmtracker.net (the “Site”), regardless of the mode and tool used, will be processed in the manner and for the purposes described below.

1. Data Controller

1.1. The Data Controller is Omega Front. (hereinafter, the “Data Controller”).

1.2. The Data Controller makes the following email address available for any communication:contact@omegafront.com.

1.3. The Data Controller may designate one or more data processors pursuant to Article 28 of the GDPR, who, on behalf of the Data Controller, provide specific processing services or related, instrumental, or support activities, adopting all technical and organizational measures appropriate to protect the rights, freedoms, and legitimate interests recognized by law to Data Subjects.

2. Description of Processing

2.1. The processing will involve individual operations, or a set of operations, of the following personal data provided by the Data Subject during the use of the services provided by the Data Controller through the Site, as described in the following table (the “Personal Data” or the “Data”):

Processing of Personal Data

Type	Purpose of Processing	Legal Basis	Retention Period
Registration Data: email address	Register User's account Allow User to access the Site	Execution of a contract to which the Data Subject is a party or the execution of pre-contractual measures adopted at the request of the Data Subject (Article 6(1)(b) GDPR).	For the duration of the account.
Communications	Send communications related to the activity for which the Data Subject has provided their Data.	Legitimate interest of the Data Controller (Article 6(1)(f) GDPR).	-
Marketing and Profiling	Provide personalized proposals based on Site usage. Send commercial communications and newsletters. Profiling and statistics.	Explicit consent of the Data Subject for marketing purposes (Article 6(1)(a) GDPR). The Data Subject may withdraw consent at any time via the link in communications and/or the Site’s footer.	-
Identification Data	Allow the Data Subject to complete their account.	Execution of a contract to which the Data Subject is a party or the execution of pre-contractual measures adopted at the request of the Data Subject (Article 6(1)(b) GDPR).	For the duration of the account.
Security and Fraud Prevention	Ensure the security of processed Personal Data. Prevent or discover fraudulent activities or abuses harmful to the Site.	Comply with a legal obligation to which the Data Controller is subject (Article 6(1)(c) GDPR).	For the necessary period according to the law, up to a maximum of ten (10) years.
Exercise of Rights	Exercise the Data Controller's rights, e.g., in judicial proceedings.	Legitimate interest of the Data Controller (Article 6(1)(f) GDPR).	-
Profile Completion Data	Complete the profile.	Execution of a contract to which the Data Subject is a party or the execution of pre-contractual measures adopted at the request of the Data Subject (Article 6(1)(b) GDPR).	For the duration of the account.
Browsing Data	Obtain anonymous statistical information on the use of the Site and monitor its proper functioning.	Legitimate interest of the Data Controller (Article 6(1)(f) GDPR).	Browsing data will be retained for the necessary period for analysis and comparative statistical processing, not exceeding seven (7) days unless authorities need verification.
Cookies and other technologies	Refer to the “Cookie Policy” available at the following link:https://cmtracker.net/cookies.	N/A	N/A

2.2. It is noted that with reference to browsing data and geolocation data, the information collected, while not intended to be associated with identified subjects, could by nature, if associated with other Data held by third parties (e.g., internet service providers), allow the identification of Data Subjects (e.g., IP addresses, domain names of computers used, URLs of requested resources, request times, server response codes, Data Subject geolocation).

3. Processing Methods

The processing of Personal Data:

(a) is carried out using the operations indicated in Article 4(1)(2) of the GDPR, namely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion, and destruction of Data;
(b) is also performed with the aid of electronic or automated means;
(c) includes the use of email or other remote communication techniques.

4. Social Network

4.1 The User has the option to include certain social buttons in their profile on the Site, which are hyperlinks to the User's social network accounts (e.g., Facebook, Instagram, and Twitter). Using these hyperlinks does not install third-party cookies on the Site, and the Site will not share the User's Personal Data with social networks accessible via the hyperlink.

4.2 Users are advised to review the privacy policies of the social networks linked via the hyperlinks:

(a) Instagram: https://help.instagram.com/519522125107875
(b) Facebook: https://www.facebook.com/privacy/policy
(c) X/Twitter: https://x.com/en/privacy
(d) Discord: https://discord.com/privacy
(e) YouTube: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data
(f) TikTok: https://www.tiktok.com/legal/page/us/privacy-policy/en
(g) Reddit: https://www.reddit.com/policies/privacy-policy

5. Transfer of Personal Data

5.1 The management and storage of Data will primarily occur in Europe, on servers of third-party companies appointed and duly designated as data processors.

5.2 The Data Controller may provide access to the Site and the services indicated therein in other countries, in which case the transfer of Data to such countries is strictly limited to the actual need to know. The Data Controller will take necessary measures to protect the Users' Personal Data and prevent unauthorized access.

5.3 In cases where Personal Data is transferred to systems used by the Data Controller and/or third-party companies appointed and duly designated as Data Processors outside the European Union, the Data Controller ensures the application of the European Commission's standard contractual clauses to guarantee the safe international transfer of personal data, in accordance with Articles 44, 45, and 46 of the GDPR.

6. Security Measures

The Data Controller has adopted a variety of security measures to protect Data against the risk of loss, misuse, or alteration, consistent with the measures expressed in Article 32 of the GDPR.

7. Consequences of Non-Disclosure of Personal Data

7.1 While it is the Data Subject's discretion to provide Personal Data to the Data Controller, the provision of Personal Data may be:

(a) Mandatory for the provision of services accessible through the Site and for purposes related to the fulfillment of obligations required by applicable laws and/or regulations, as well as by orders issued by competent authorities/supervisory and control bodies;
(b) Optional with reference to data provided voluntarily by the Data Subject and for marketing and/or profiling purposes.

7.2 Refusal by the Data Subject to provide Personal Data to the Data Controller may result in the inability of the Data Controller to provide the requested services and make the Site accessible.

7.3 Furthermore, please consider that revoking one or more permissions and/or consents not granted by the User may affect the proper functioning and/or the ability to access and/or correctly use the Site and/or the services provided by the Data Controller.

8. Data Retention and Deletion

8.1 The retention period for Personal Data is indicated in the table in Section 2 above.

8.2 At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this term, the right of access, deletion, rectification, and the right to data portability cannot be exercised by the User.

8.3 Personal Data will be stored in cloud archives through the services of third parties, such as Amazon Web Service.

9. Data Subject Rights

The Data Subject may exercise the rights provided in Chapter III of the GDPR within the limits and conditions specified therein:

(a) Right of access (Art. 15): The Data Subject has the right to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access to the personal data in a commonly used electronic format and certain information about the processing (e.g., purposes, categories of data processed, recipients, transfers outside the EU, profiling activities, etc.).
(b) Right to rectification (Art. 16): The Data Subject has the right to obtain the rectification of inaccurate personal data concerning them without undue delay and/or the completion of incomplete personal data, including by providing a supplementary statement.
(c) Right to erasure or “right to be forgotten” (Art. 17): The Data Subject has the right to obtain from the Data Controller the erasure of personal data concerning them without undue delay, and the Data Controller has the obligation to erase personal data without undue delay.
(d) Right to restriction of processing (Art. 18): The Data Subject has the right to obtain from the Data Controller restriction of processing.
(e) Right to data portability (Art. 20): The Data Subject has the right to receive in a structured, commonly used, and machine-readable format the personal data concerning them provided to a Data Controller and has the right to transmit such data to another Data Controller without hindrance from the Data Controller to whom the personal data was provided.
(f) Right to object to processing (Art. 21): The Data Subject has the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them pursuant to Article 6(1)(e) or (f) of the GDPR, including profiling based on those provisions.

10. Exercise of Rights

10.1 The Data Subject may exercise their rights at any time by sending:

(a) An email to contact@cmtracker.net.

10.2 The Data Controller undertakes to provide the Data Subject with information on the action taken regarding a request to exercise their rights without undue delay and, in any case, at the latest within a period of 30 (thirty) days from receipt of the request, extendable up to 3 months only in cases of particular complexity.

10.3 Any corrections, deletions, or restrictions of processing carried out upon the explicit request of the Data Subject (unless this proves impossible or involves disproportionate effort) will be communicated by the Data Controller to each recipient to whom the personal data have been transmitted. The Data Controller may inform the Data Subject about those recipients if requested.

11. Right to Lodge a Complaint

Data Subjects who believe that the processing of personal data concerning them is carried out in violation of the GDPR have the right to lodge a complaint with the Italian Data Protection Authority (Garante Privacy) via email at garante@gpdp.it or urp@gpdp.it, by fax at 06.696773785, or by post to Garante Privacy, Piazza Venezia 11, 00187 Rome, or alternatively to bring a claim before the judicial authorities.

12. Data Processors and Authorized Persons

The updated list of data processors and persons authorized to process data is kept at the Data Controller's registered office.

13. Changes to this Notice

This notice may be subject to changes. Therefore, it is advisable to regularly check this notice and refer to the most updated version.

Last Updated Date: [17/03/2025]