Please read this Policy carefully before using this Website because it explains how we will process personal data (the “Data”).
1. INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA
Your Data will be processed to administrate and fulfil your requests and for general administration purposes by Company as a controller under the applicable data protection legislation, as follows:
Data / Data Categories (mandatory data is marked with an *)
Legal basis and consequences of failure to provide data
A) Deal with your enquiries and requests (e.g. if you were to contact us to ask for more information about our Company, we would need to process your contact details
Name*, surname*, email address *, phone number*, company* (if applicable), address (optional)
This data processing is in our legitimate interests in responding to your enquiries and requests and we do not believe that your interests or fundamental rights override (or outbalance) our legitimate interests. Failure to provide such data will make it impossible to us to provide you with your reques. You are allowed to exercise your right to object within the limits provided by the law.
B) Send you our newsletter
Email address*, city of residency*, country of residency*
This data processing will take only with your prior consent. Failure to provide such data will make it impossible to us to send you our newsletter. This will not affect in any way the use of the Website.
C) Improving services
Aggregated data that will not identitfy you regarding the usage of the services
This data processing is in our legitimate interests in improving our products/services and we do not believe that your interests or fundamental rights override (or outbalance) our legitimate interests. Failure to provide such data will make it impossible to us to improve our services. You are allowed to exercise your right to object within the limits provided by the law.
D) Website maintenance and troubleshooting
Browsing data like e.g. IP address, location – country -, information on pages you visited within the Website, access time on the Website, navigation time on each page, clickstream analysis
This data processing is in our legitimate interests for the maintenance of the Website and when you report a problem with our Website and we do not believe that your interests or fundamental rights override (or outbalance) our legitimate interests. Failure to provide such data will make it impossible to us to solve your issue. You are allowed to exercise your right to object within the limits provided by the law.
H) Processing in the context of any corporate events (sale of the Company or going concerns), due diligence exercises
Data included in Company’s database
This data processing is in our legitimate interests in managing possible corporate events and we do not believe that your interests or fundamental rights override (or outbalance) our legitimate interests. Failure to provide such data will make it impossible to us to improve our services. You are allowed to exercise your right to object within the limits provided by the law.
The Data may be processed in hardcopy, by automated or electronic means.
2. HOW WE PROCESS PERSONAL DATA
The data processing carries out with information system and organizational and logical methods strictly related to indicated purposes and the Company implemented all technical and organizational security measures to ensure the confidentiality, integrity, availability and resilience of data processing, in compliance with the article 32 of GDPR.
3. DATA RETENTION
Your Data will be stored in compliance with the applicable laws, for a period of time not exceeding what is necessary to achieve the purposes for which they are processed. The criteria for determining the data retention period take into account the lawful processing period and applicable laws (for example, tax or anti-money laundering laws), the statute of limitation periods and the nature of legitimate interests where they are the legal basis of the processing. Your Data may be stored for a longer period than the one originally planned, in the event of any disputes or requests by the relevant authorities. The Data processed to provide the newsletter service as described above will be stored until you withdraw your consent.
Provided that your Data are only held for as long as necessary, they will be cancelled, aggregated or anonymized in a secure manner once they are no longer needed.
4. COMMUNICATION OF PERSONAL DATA
The Data will be disclosed to the persons authorized for the processing within the Company’s staff. The Data may be disclosed by the Company solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects:
· where required, the competent judicial authorities
· where required, public administrations and supervisory and control authorities.
Your Data will not be publicly disclosed.
Entities belonging to the categories listed above, may act, as the case may be, as data processors (and in this case they will receive appropriate instructions from the Company) or as autonomous data controllers. In the latter case, the Data will be communicated only with the express consent of the data subjects, except where the communication is mandatory or necessary pursuant to the applicable law or for the pursue of purposes for which the consent from the data subject is not required.
5. DATA TRANSFER OUTSIDE OF THE EEA
If this is instrumental to the pursuit of the purposes set out above, your Data may also be transferred abroad to companies located both within and outside the European Economic Area (EEA). Some of these jurisdictions may not guarantee the same level of data protection guaranteed by the European laws. In this case, the Company undertakes to ensure that the data is processed with the utmost confidentiality, stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided by the European Commission.
To receive information about our mentioned safeguards and to obtain a copy of respective safeguards please contact us via e-mail firstname.lastname@example.org.
6. DATA SUBJECTS RIGHTS
At any time you will be entitled to exercise the following rights and therefore:
· obtain confirmation as to whether your Data are being processed, and, where that is the case, access to the Data, under Article 15 of GDPR (Right of access);
· obtain the rectification of inaccurate Data concerning you or, taking into account the purpose of the processing, the integration of incomplete Data (Right to rectification);
· obtain the erasure of your Data where one of the grounds under Article 17 of GDPR applies (Right to be forgotten);
· obtain the restriction of processing your Data, when one or more of the cases under Article 18 of GDPR applies (Right to restriction);
· object to the processing of your Data on grounds relating to your particular position, where applicable (Right to object);
· receive your Data in a structured, commonly used and machine-readable format as well as to transmit those data to another controller in the cases and within the limits referred to in Article 20 of GDPR, where applicable (Right to data portability)
Moreover, where provided, you have the right to withdraw your consent to process your Data, at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.
According with the GDPR, the Company may not charge for complying with any of the requests mentioned in this paragraph, unless they are clearly unfounded or excessive and repetitive. Should you request more than one copy of your Data or in cases of excessive or unfounded requests, the Company may: (i) charge a reasonable expense, considering the administrative costs incurred to fulfil the request; or (ii) refuse to fulfil the request. In these cases the Company will inform you of the costs before fulfilling the request.
The Company may ask for further information before fulfilling the requests if it needs to verify the identity of the person who has made them.
To exercise your rights, you can send an email with the following subject “PRIVACY”, to email@example.com. Remember that you can also use the unsubcribe link included in our marketing emails.
Without prejudice to any administrative or legal remedy, you also have the right to lodge a complaint to the relevant supervisory Authority, if you believe that processing of your Data is in breach of the GDPR. More information is available on the website https://www.garanteprivacy.it/.
In any case, the Company is interested in knowing the reasons for the complaint and requests that you use the above contact methods before turning to the authorities, in order to prevent and resolve any disputes, amicably and promptly.
7. LINKS TO THIRD PARTY WEBSITES
Third party websites accessible from this Website are under the third party responsibility. Company declines all responsibility concerning requests and/or provision of Data to third party websites.
This Website can also contain iFrames with content of third parties. Company is not responsible for third-party content presented in iFrames. The information presented therein is the sole responsibility of those website owners.
Company has no control or responsibility for the content of independent websites and provides this external content to its visitors for their convenience. As a result, when you visit a page containing such content, you may be presented with cookies from these third party websites.
Company does not control the distribution of these cookies.
8. LINKS TO SOCIAL NETWORKS
Our website includes links to social networks.
In order to protect your Data while visiting our Website we do not use social plugins. Instead HTML-links are embedded onto the Website, enabling easy sharing onto social media platforms. Embedding the link prevents a direct connection with various social media network servers when opening a page from our Website. When clicking on one of the buttons, a browser window opens and directs the user to the respective service provider website on which (after having logged in) for example, the “Like” or “Share” button can be used.
For more information on the purpose and scope of data processing and further use of your Data by the provider and their websites as well as your rights and possible settings to protect your privacy, please refer to the data protection information of the respective service provider.
10. CONTACTING US
Atlante S.r.l. Piazzale Lodi, 3 – 20137 Milan (Italy).
You can contact the Company writing to the following email address firstname.lastname@example.org