This privacy policy has been drawn up and issued pursuant to art. 13 of European Regulation 2016/679 (hereinafter also referred to more simply as the European Regulation), which introduced significant legislative developments.

This privacy policy, therefore, updates and replaces any previous versions issued before now.

Having stated the above, it should be noted that:

1) by effect of the establishment of a business relationship and during the course of such relationship, our company will need to collect and process your personal data;

2) the following definitions given by the aforementioned European Legislation are herewith provided for the purpose of clarity:

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pursuant to article 13 of European Regulation 2016/679, therefore,

we hereby inform you

that the collection and processing of your personal data shall be carried out by the undersigned company in compliance with the following:

1. purpose: the data will be processed for the correct fulfilment of accounting, tax, commercial and technical obligations and for all business activities in general related to the business relationship in force;
2. advertising purposes: the data may be used, subject to specific and explicit consent, also for the sending of advertising/communication material by post, e-mail, telephone, fax, text message and similar; after having giving consent, it is, however, your right to oppose the processing of your data for this purpose at any time and without expense;
3. procedures: the data will be processed with both paper and electronic/computerised/telematic instruments/forms, in full compliance with the law, according to principles of lawfulness and fairness and so as to safeguard your privacy;
4. optional provision of data: the provision of data is optional and not compulsory;
5. consequences of refusal: the refusal to provide data or the opposition to their processing, may imply the impossibility of continuing any business relationship or relationship of any other nature with our company; denial of the use of the data for the sending of advertising material/communication shall not have any consequence on present or future relations;
6. persons or legal entities or categories of persons or legal entities (addressees) to which the data may be communicated or disseminated: personal data may be communicated to third parties only for the fulfilment of legal or contractual obligations. The data shall, in no event, be disseminated;
7. persons tasked with processing: the data shall be processed exclusively by suitably authorized company staff working in the administrative and commercial sector;
8. automated decision-making processes (e.g. profiling): automated decision-making processes are not applied in any way;
9. rights of the data subject: you have all the rights provided for by the European Regulation, including the right to request access to personal data and their modification, their cancellation, limitation of the processing, the right to oppose their processing, besides the right to the portability of the data. You also have the right to submit a complaint to the Control Authority;
10. transfers to third party countries: any transfers of personal data to a third party country outside the European Union or to an international organisation shall occur on the basis of an adequacy decision by the Commission or, in the case of transfers as per articles 46, 47 or 49, second paragraph, of the European Regulation, on the basis of appropriate and suitable guarantees;
11. data storage period: the data shall be stored for a period which is strictly necessary to deal with the data subject’s requests or on the basis of what is provided for by current regulations or by any contractual clauses;
12. data controller: the data controller is Comet S.p.A., having headquarters in Reggio Emilia (RE), Via G. Dorso n. 4, in the person of its temporary legal representative;
13. data protection officer (DPO): The company has designated a DPO pursuant to  art 37 GDPR, who can be contacted for information request or clarifications at the following address: dpo@comet-spa.com

This privacy policy may be integrated, verbally or in writing, with further elements and indications, to best meet your information requirements regarding “Privacy” and to comply with the regulatory developments.

Reggio Emilia, 05/10/2018

The data controller Comet S.p.A.

Whereas:

1) Following your visits to this website, the completion of forms, the receipt of your requests or enquiries, preliminary contacts, market surveys and research, and the possible establishment of commercial relationships, our Company will collect and process your personal data, including through tracking tools embedded in email communications (so-called tracking pixels), as described below;

2) For the sake of clarity, we hereby set out the following definitions provided by Regulation (EU) 2016/679:

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity;

Processing: any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

In light of the foregoing, pursuant to Article 13 of Regulation (EU) 2016/679,

we hereby inform you

that the collection and processing of personal data will be carried out by our Company in accordance with the following provisions:

Purposes and legal basis:

1. Data will be processed to respond to your requests or enquiries, to fulfil administrative, accounting, tax, commercial and technical obligations, and to carry out business activities required by law or otherwise strictly connected with existing relationships (Article 6(1)(b) GDPR);
2. Your data may also be used to send advertising materials or communications by post, email, telephone, fax, SMS, MMS and similar means, solely with your freely given, optional, specific and explicit consent, which may be withdrawn at any time. Even after giving consent, you have the right to object to the processing of your data for this purpose at any time and free of charge (Article 6(1)(a) GDPR);
3. When individual marketing emails are received, the Data Controller will track users’ interactions and behaviour through tracking pixels to assess the effectiveness of communications and adjust their frequency and content (Article 6(1)(a) GDPR). In particular, information may be collected about whether an email has been opened, as well as any further information that may be inferred from the recipient’s IP address, such as language, device type and similar details. Further information about the interactions being tracked may be requested by contacting the Data Controller.

As authorised by the Italian Data Protection Authority in its provision of 17 April 2026, consent to marketing and tracking activities is a single consent. Users may withdraw their consent at any time on a granular basis, choosing whether to disable tracking only or to stop marketing activities entirely.

Methods: Data will be processed using both paper-based and electronic, computerised and telematic tools or media, in full compliance with the law, in accordance with the principles of lawfulness and fairness and in a manner that protects your confidentiality.

In any event, you may prevent tracking pixels from operating by disabling the automatic download of images in your email application’s settings.

Provision of data: With regard to the purpose referred to in point 1, the provision of data is mandatory and necessary to manage the commercial relationship between the parties. Providing your data for the purposes referred to in points 2 and 3 is optional and not mandatory; refusal will not affect the activities referred to in point 1.

Withdrawal of consent: You may at any time withdraw, separately, your consent to receive the newsletter, thereby stopping all further mailings, or withdraw only your consent to individual tracking while continuing to receive the newsletter without individual tracking pixels. Consent may be withdrawn using the link at the bottom of each newsletter or via the preferences management page. Withdrawal does not affect the lawfulness of processing based on consent given before its withdrawal.

Persons or categories of persons (recipients) to whom data may be communicated or disclosed: Data may be communicated to third parties solely to fulfil legal or contractual obligations. The data will not be disseminated under any circumstances.

Persons authorised to process data: Data will be processed exclusively by a limited number of duly authorised Company employees in the administration, marketing, IT/data processing centre and sales departments.

Automated decision-making (e.g. profiling): No automated decision-making processes are carried out.

Data retention period: Data will be retained for the period strictly necessary to fulfil the data subject’s requests or as required by applicable legislation or contractual clauses. Data collected through individual tracking pixels will be retained for 24 months from the time of collection and will subsequently be deleted or anonymised.

Data subjects’ rights: You enjoy all the rights laid down in Regulation (EU) 2016/679, including the right to request access to your personal data, rectification, erasure, restriction of processing, to object to processing and to data portability. You also have the right to lodge a complaint with the supervisory authority.

Transfers to third countries: Any transfer of personal data to a third country outside the European Union or to an international organisation will take place on the basis of an adequacy decision by the European Commission or, in the case of transfers pursuant to Articles 46, 47 or 49(2) of the Regulation, on the basis of appropriate safeguards.

Data controller: The data controller is Comet S.p.A., with its registered office at Via G. Dorso No. 4, Reggio Emilia (RE), represented by its legal representative pro tempore.

The Company has appointed a Data Protection Officer (DPO) pursuant to Article 37 of the GDPR. The DPO may be contacted for information or clarification at dpo@comet-spa.com.

This privacy notice may be supplemented, orally or in writing, with further information and details in order to meet any questions you may have concerning privacy and to reflect regulatory developments.

Date: 26/10/2026

The Data Controller
Comet S.p.A.

Comet products and regulation (EC) No 1907/2006 (REACH)

In accordance with the art. 33 of the regulation (EC) n. 1907/2006 (REACH), Comet Spa announces that in products having components in steel alloys, aluminum alloys and brass alloys, it is lead content (very high risk substance – SVHC – with CAS number 7439-92-1) in higher concentrations at 0,1% w/w.
For these products, if used in accordance with their intended use, no special precautions for use are required.

Reggio Emilia, 27th June 2018

PEOPLE QUALITY

For Comet, the importance of the individual and his role in the creation of quality and in achieving aims, is a reason for continuous training activity and stimulus to growth.
Quality begins in Comet with the training and involvement of the personnel at all levels.

PROCESS QUALITY

Comet knows that achieving aims is the result of numerous activities strictly connected to one another. All the company’s processing chain, from administering orders to programming, from the supply of raw materials to after-sales services, is regulated by procedural systems and subjected to continuous re-examination.

PRODUCT QUALITY

For Comet, the company offer is formed by two indissoluble aspects: product and service.
Attention to market changes and the requests of Clients leads to the continuous development of new products that link the fruits of the most advanced technology to our usual reliability.

The good name of our company on the market is due in no small measure to the virtuous approach we adopt in our business dealings, and to relations with our stakeholders.

At Comet, we are convinced that a company can achieve great things only if it is inspired by strong and positive values like those which characterized our founders, and which we continue to keep alive today: probity, skill, team spirit and flair for innovation.

The Comet Code of Ethics gives a clear statement as to our principles of conduct, based on transparency and confidentiality, to areas of application, and to the company’s commitments regarding internal and external relations.

Download Code of Ethics

Whereas

1) as a result of your request to receive our periodic newsletter, the undersigned company will collect and process some of your personal data;

2) the following definitions given by the aforementioned European Legislation 2016/679 are herewith provided for the purpose of clarity:

Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Having stated the above, in compliance with article 13 of European Regulation 2016/679,

we hereby inform you

that the collection and processing of personal data shall be carried out by our company in compliance with the following:

1. general purposes: the data shall be processed to meet your requests/answer your queries, for the correct execution of bureaucratic, accounting, fiscal and technical procedures and for business activities which are compulsory by law and, in any case, strictly associated with the business relations in force;
2. “direct marketing” purposes”: your data may be used, only and exclusively subject to your free, optional, specific and explicit revocable consent at any moment, also for the sending of advertising material/communications by post, e-mail, telephone, fax, sms and mms messages and similar instruments; after having given your consent, it is, in any case, your right to object, at any time and without charge, the processing of your data for this purpose;
3. procedures: the data will be processed with both paper and electronic/computerised/telematic instruments/media, in full compliance with the law, according to principles of lawfulness and fairness and so as to safeguard your privacy;
4. optional provision of data: the provision of your data is optional and not compulsory;
5. consequences of refusal: the refusal to provide data or the opposition to their processing for the purposes as per point a), may imply the impossibility of satisfying some of your requests; denial of the use of the data for the purposes as per point b), shall not have any consequence on the recognition of benefits bound to promotions or outstanding relations;
6. persons or categories of persons (addressees) to which the data may be communicated or disseminated: personal data may be communicated to third parties only for the fulfilment of legal or contractual obligations. The data shall, in no event, be disseminated;
7. persons tasked with processing: the data shall be processed exclusively by suitably authorized company staff working in the administrative, marketing, IT and commercial sector;
8. automated decision-making processes (e.g. profiling): automated decision-making processes are not applied in any way;
9. rights of the data subject: you have all the rights provided for by the European Regulation 2016/679, including the right to request access to personal data and their modification, their cancellation, limitation of the processing, the right to oppose their processing, besides the right to the portability of the data. You also have the right to submit a complaint to the Control Authority;
10. transfers to third party countries: any transfers of personal data to a third party country outside the European Union or to an international organisation shall occur on the basis of an adequacy decision by the Commission or, in the case of transfers as per articles 46, 47 or 49, second paragraph, of the European Regulation, on the basis of appropriate and suitable guarantees;
11. data storage period: the data shall be stored for a period which is strictly necessary to deal with the data subject’s requests or on the basis of what is provided for by current regulations or by any contractual clauses;
12. data controller: the data controller is Comet S.p.A. having headquarters in Reggio Emilia (RE), Via G.Dorso n. 4, in the person of its temporary legal representative;
13. data protection officer (DPO): The company has designated a DPO pursuant to  art 37 GDPR, who can be contacted for information request or clarifications at the following address: dpo@comet-spa.com

This privacy policy may be integrated, verbally or in writing, with further elements and indications, to best meet your information requirements regarding “Privacy” and to comply with the regulatory developments.

Date: 05/10/2018

The data controller
Comet S.p.A.

With Legislative Decree No. 24/2023, Italy implemented Directive 2019/1937 concerning the protection of the authors of reports of crimes or irregularities that have come to their knowledge in the context of their employment relationship (so-called “Whistleblowing”), providing, under certain conditions, the obligation for private companies to activate internal reporting channels, which guarantee the confidentiality and identity of the whistleblower and protect him from any possible retaliatory action.

Comet S.p.A, already endowed with an Organisational Model pursuant to Legislative Decree 231/01, has coordinated and adapted the reporting system already in use with the recent legislation, by implementing a reporting channel called the Whistleblowing platform which can be accessed by clicking on the following link Comet Group Whistleblowing to send to the Whistleblowing Manager of Comet S.p.A your reports.
Comet S.p.A believes that an adequate whistleblowing system can enable employees, customers and suppliers to send reports in a systematic and confidential manner, and to establish a protected and constant interaction and dialogue with its Whistleblowing Manager.

Whistleblowing Regulations

Informative Ex art. 13 GDPR