PRIVACY POLICY – Registration to events 6 – 12 June 2022
Information document pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR)
According to the General Data Protection Regulation (GDPR), we provide you with the following information regarding the processing of the personal data that you will provide us in our event registration form. Please note that, for those who intend to register for the event through the website of one of the Joint Controllers, this policy is integrated also with the privacy policy for browsing on the website itself, as well as the relevant cookie policy. With specific reference to the purpose of direct marketing through electronic means, this information is also intended for legal persons, in accordance with the provisions of Directive 2002/58/EC (e-Privacy Directive) as transposed into Italian law within the Privacy Code.
1.JOINT DATA CONTROLLERS
When two or more data controllers jointly determine the purposes and means of processing, they are defined as joint data controllers under Article 26 GDPR. The joint controllers of the processing of personal data, covered by this notice (hereinafter also only “Joint Controllers”), are:
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Molteni&C S.p.A., with registered office in Via Rossini 50 - Giussano (MB), duly represented by the person with the necessary powers. The data controller can be contacted via e-mail at: privacy@molteni.it
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Unifor S.p.A., with registered office in Via Isonzo, 1 – 22078 Turate (CO), duly represented by the person with the necessary powers. The data controller can be contacted via e-mail at: privacy@unifor.it
The essential terms of the joint controllership agreement are available by written request to the email addresses of the Joint Controllers, as indicated above.
Without prejudice to the data subject’s right to exercise his or her rights towards each Joint Data Controller, the point of contact for data subjects, has been identified in the address privacy@molteni.it
2. CATEGORIES OF PERSONAL DATA PROCESSED
Personal Data: any information concerning an identified or identifiable natural person (“data subject”); An identifiable natural person is one who “can directly or indirectly be identified, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier or to one or more specific factors to the physical, physiological, genetic, mental, economic, cultural or social identity” (article 4 par. 1.1 GDPR).
In particular, we will process your following personal data: Data indicated in the registration form on the site (e.g. name, surname, e-mail address). The data necessary for registration will be indicated as “required”.
3. HOW WE USE YOUR PERSONAL INFORMATION: PURPOSES OF PROCESSING | LEGAL BASIS | DATA RETENTION PERIOD | PROVISION OF PERSONAL DATA
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PURPOSE OF THE TREATMENT |
LEGAL BASIS FOR THE PROCESSING |
DATA RETENTION PERIOD |
NATURE OF THE PROVISION |
|---|---|---|---|
|
A) Registration to the event through the dedicated form. |
Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Art. 6 par. 1, lett. b) GDPR |
Until 12 months after the event |
Necessary to allow registration and participation in the event. Failure to provide Your data will prevent you from registering for the event and therefore not to participate in. |
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B) Direct marketing, i.e. direct sale of products and services, market research, sending of communications and promotional, commercial and advertising material or relating to initiatives and events through automated means (e-mail / newsletter, SMS messages or through social networks and sponsorships) and traditional means (paper mail). Communications may contain third parties’ promotional activities and/or third parties’ logo(s) (our partners belong to the following sectors: no profit; agriculture, forestry and fishing; manufacturing; suppliers of electricity, gas, steam and air conditioning; construction; wholesale and retail; repair of motor vehicle and warehousing; accommodation and food services; information and communication activities; financial and insurance activities; real estate activities; professional, scientific and technical activities; rental, travel agencies, support services to businesses; public administration; instruction; artistic, sports, entertainment activities; other service activies). For the complete list of the abovementioned third parties, please contact the Joint Controllers. We will not share any personal data with third parties for this purpose of processing. The Data Controller, in order to compare and eventually implement the results of communications, uses systems to send newsletters and promotional communications with reports. Through these reports, the Data Controller may eventually know, for instance: number of readers, openings, unique “clickers” and clicks; the devices and operating system used to read the communication; details concerning the activity of single users; details of emails sent, received and forwarded; All these Data are used in order to compare and eventually implement the results of communications. |
You will be subject to the aforesaid direct marketing activities only with your prior consent. (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR).
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Until consent withdrawal | opt-out (by contacting us as described in par. 7 of this Privacy Policy) |
Optional and free. Failing this, you can still register and therefore participate to the event. |
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C) Profiling: your personal data will be stored in our CRM/platforms for internal analysis. We will also cluster personal data in homogeneous groups according to your data and preferences in order to ensure a better organization of our services and for sending you tailored promotional communications. |
We will proceed with profiling activities if you allow us to do so by giving your express consent. (art. 6, par 1 letter a GDPR – Recitals 42 and 43 GDPR). |
Until consent withdrawal | opt-out (by contacting us as described in par. 7 of this Privacy Policy) |
Optional and free. Failing this, you can still register and therefore participate to the event. |
4. RECIPIENTS OF PERSONAL DATA
We share your personal information with employees and/or staff acting under the Data Controller’s authority (duly instructed for the former purposes, also according to article 29 GDPR), as well as third parties contractually linked to Molteni, in order to fulfill contractual obligations and achieve one or more of the aforesaid purposes of processing. In particular, we disclose personal information to the following categories of recipients: - subjects providing services concerning information system management and communication networks management (including e-mail, web platforms, cloud and software); - offices or companies in the context of assistance and consultancy relationships; - social networks; - relevant authorities in order to comply with legal obligations and/or provisions of public bodies, upon request. The abovementioned recipients could act as Data Processor (appointed pursuant to art. 28 GDPR) or as independent Data Controller(s). The complete list of the recipients is regularly updated and available upon request at the contact details indicated paragraph 1. of this Privacy Policy.
5. TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES
Personal data provided will not transferred outside the European Economic Area (EEA).
6. AUTOMATED PROCESS
Personal data will be subjected to paper, traditional manual, electronic and automated processing. It should be noted that, with reference to the profiling activity, it will be carried out through the intervention of an operator who, with the consent of the data subject, will process his/her data for the purpose of internal analysis and to divide them into homogeneous groups for specific characteristics (e.g. profession and origin), for better management of services and for sending tailored promotional communications.
We do not take any decision based solely on automated processing, including profiling since our profiling activity will take place - upon data subject’s consent - with the intervention of a human operator.
7. RIGHTS OF THE DATA SUBJECT
You have the right, at any time, to obtain from Molteni the access to your personal data (article 15 GDPR), request their rectification (article 16 GDPR), their erasure (article 17 GDPR) or restriction of their processing (article 18 GDPR). Furthermore, you have the right to object anytime to your personal data processing (article 21 GDPR), as well as the right not to be subject to automated processing, including profiling, without your prior consent (article 22 GDPR) voluntarily provided. Finally, you have the right to data portability, if applicable (article 20 GDPR). Furthermore, you have the right to lodge a complaint with the Italian Data Protection Authority (https://www.garanteprivacy.it/ ), or to take legal action according to art. 78 and 79 GDPR.
To withdraw consent to non-automated profiling, it will be sufficient to write an e-mail at any time to the address privacy@molteni.it with the subject “no profiling”.
To stop receiving automated direct marketing (e.g. by e-mail) you can write an e-mail at any time to the address privacy@molteni.it. with the subject "unsubscribe from automated direct marketing" or use our automatic unsubscribe systems (only for email) and you will no longer be disturbed. To stop receiving traditional direct marketing (e.g. paper mail) you can write an e-mail at any time to the address privacy@molteni.it. with the subject "unsubscribe from traditional direct marketing".
8. CHANGES TO THE PRIVACY POLICY
The Joint-controllers may revise this privacy policy from time to time. To facilitate this verification, the notice will contain the date of update.
Effective date: June 6, 2022