Micheletto Srl, with registered office in Via Curtatone 13 – 20122, Milano MI, Italy , is the Controller of the personal data collected on this site pursuant to and for the purposes of EU Regulation 679/2016 (hereinafter GDPR):
1. PERSONAL AND NAVIGATION DATA
PERSONAL DATA PROCESSED FOR CONTRACTUAL PURPOSES – LEGAL OBLIGATIONS – RIGHTS OF THE DATA CONTROLLER
Personal data, contact details.
PERSONAL DATA PROCESSED FOR GENERAL MARKETING PURPOSES BY THE JOINT CONTROLLERS
Personal data, contact details.
PERSONAL DATA PROCESSED FOR MARKETING AND PROFILING PURPOSES
Personal data, contact data, data collected by cookies installed by the Sites.
PERSONAL DATA PROCESSED FOR SENDING NEWSLETTERS
PERSONAL DATA PROCESSED FOR THE OPERATION OF THE SITES
IP addresses or domain names of computers used by users who connect to the Sites, the URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the file size obtained in response, the numeric code indicating the status of the response given by the server (successful, error, etc.), other parameters relating to the operating system and the computer environment of the user, information relating to the user’s behavior on the Sites, to the pages that have been visited or searched, in order to select and make specific ads to the user of the Sites and data relating to the browsing behavior held on the Sites, for example, using cookies. For Micheletto it is essential to guarantee the safety and privacy of children. It is not in our interest to knowingly collect and use personal data of anyone under the age of sixteen (16) or any age limit set by the legislation of their country of residence. By registering on the Site, you confirm that you have reached the age of majority in your country of residence.
2. PURPOSE AND LEGAL BASES OF PROCESSING
The data and cookies received by you will be processed by Micheletto exclusively with the methods and procedures necessary to provide you with the services requested and for the additional purposes for which you have given your consent.
– General marketing purposes of the Joint Controllers: by way of example sending – with automated contact methods (e-mail) – promotional and commercial communications relating to services/products similar to those you have already used offered by the Joint Data Controllers by way of example and not exhaustive reporting of corporate events, whitepaper or newsletter subscription.
– Marketing purposes of third parties (with data communication) that belong to the services sector (in particular ICT and digital) and consulting, manufacturing, commerce, Public Administration: sending – with automated contact methods (such as SMS, mms e-mail) and traditional (such as telephone calls with operator) – promotional and commercial communications, advertising material relating to services/products offered, reporting of company events, as well as carrying out market studies and statistical analysis by third parties specified above, compared to the Joint Controllers, to whom the data are communicated.
– Marketing purposes by the Joint Data Controllers in favor of third parties (without data communication) belonging to the service sector (in particular ICT and digital) and consulting, manufacturing, commerce, Public Administration: sending – with automated contact methods (such as SMS, mms e-mail) and traditional (such as telephone calls with operator) – promotional and commercial communications, advertising material relating to offers of services/products, reporting of company events, as well as carrying out market studies and statistical analysis by the Joint Controllers on behalf of third parties.
– – Profiling purposes: analysis of your preferences, habits, behaviors, interests derived, for example, from online clicks on articles/sections of Micheletto’s websites, in order to send personalized commercial communications/ to carry out targeted promotional actions, business intelligence. The processing of your personal data for profiling purposes will take place, in case of consent, with data processing tools that, following intersection, will create your personal commercial and behavioral profile on the web. This data processing tool relates the data collected during your navigation on the Sites through the use of first-party profiling cookies that you accept personally with the data collected through the registration with Micheletto through the form. In addition, such data and/ or information, will be associated with any and/ or additional data and/ or information already in our possession as a result of membership of our services.
– Legal obligations: To fulfil obligations under applicable regulations and national and international law.
– Sending newsletters: if explicitly requested with registration to this service.
– Rights of joint controllerss: where necessary, to establish, exercise or defend the rights of joint controllers in court.
– Operation of the Sites: the computer systems and software procedures responsible for the operation of the Sites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified data subjects, but which, by their very nature, could, through processing and association with data held by the Joint Controllers or third parties, allow to identify users of the Sites.
3. DISSEMINATION, COMMUNICATION AND SUBJECTS ACCESSING DATA
The data may be processed by external parties operating as data controllers such as, by way of example, Authorities and supervisory and control bodies and, in general, subjects, including private individuals, entitled to request data, Public Authorities who make an express request to the Joint Data Controllers for administrative or institutional purposes, in accordance with current national and European legislation, as well as persons, companies, professional associations or firms providing assistance and advice.
The data may also be processed, on behalf of the joint controllers, by external subjects designated as Data Processors pursuant to art. 28 of the GDPR, to whom appropriate operating instructions are given. These subjects are essentially included in the following categories:
– companies providing maintenance services for websites and information systems;
– companies providing support in carrying out market studies;
– companies operating and maintaining the Joint Data Controllers’ database;
– companies offering e-mail services;
– companies providing management services for the marketing automation platform;
– companies providing organisational support and event hosting services.
Your personal data may be processed, in case of release under explicit consent, by third parties to whom the data are disclosed.
Personal data will not be disclosed.
4. TRANSFER OF DATA ABROAD
Data may be transferred abroad to non-European countries, and in particular to the United States, only after verification of the Standard Contractual Clauses adopted/approved by the European Commission pursuant to art. 46, par. 2, lett. c) and d) of the GDPR or of the binding rules for the company referred to in art. 47 of the GDPR or, in the absence thereof, pursuant to one of the derogatory measures under art. 49 of the GDPR.
A copy of the guarantees referred to in art. 46, par. 2, lett. c) and d) of the GDPR, adopted by the Joint Controllers, can be obtained by writing an e-mail to the following address [email protected].
5. DURATION OF PROCESSING AND STORAGE OF PERSONAL DATA
As established in Art. 5.1 e) of the GDPR, Micheletto will process the data provided by you for the period necessary to pursue the purposes for which they were collected. Generally, we retain your personal data for one year from the end of our relationship or from the last contact, unless otherwise prescribed by local legislation. In some cases, it may be necessary for us to retain your personal data for a longer period, for example if we are required to do so for legal, tax and financial reasons:
– Contractual purposes, Legal obligations and Sending newsletters: for the duration of the contract and, after termination, for 10 years.
– General marketing purposes of the Joint Data Controllers: until the exercise of the right of opposition exercisable through the appropriate unsubscribe button (“Click here”) or by contacting the Joint Data Controllers directly.
– Marketing and profiling purposes: until the withdrawal of consent for this purpose.
– Rights of the owner: in the case of juridical litigation, for the duration of the
litigation, until the expiry of the time limits for the availability of appeals.
– Operation of the Sites: for the duration of the browsing session on the Sites.
– After the above retention periods, your personal data will be destroyed, erased or anonymised, in accordance with the technical procedures for deletion and backup.
At Micheletto, your personal data will be processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected and in compliance with the principle of necessity and proportionality, avoiding the processing of personal data where the operations can be carried out by the use of anonymous data or by other means.
We have taken specific security measures to prevent the loss of personal data, unlawful or incorrect use and unauthorized access, but please do not forget that it is essential, for the security of your personal data, that your device is equipped with tools such as constantly updated antivirus and that the provider, which provides the Internet connection, ensures the safe transmission of data through firewalls, spam filters and similar devices.
7. RIGHTS OF THE INTERESTED PARTY
By contacting the Joint Controllers by e-mail at [email protected], you can ask the Joint Controllers for access to the data concerning you, their deletion, correction of inaccurate data, integration of incomplete data, limitation of processing in accordance with art. 18 GDPR.
In addition, if the processing is based on consent or contract and is carried out with automated tools you may request the portability of your data and receive them in a structured format, commonly used and machine-readable, and, where technically feasible, to transmit them to another holder without hindrance.
You have the right to revoke the consent given at any time for marketing and/or profiling purposes, as well as to oppose the processing, for reasons related to your particular situation, data if exercising a public interest or legitimate interest of the Joint Controllers as well as for marketing purposes, including profiling related to direct marketing.
You have the possibility, if you prefer to be contacted for this purpose exclusively through traditional methods, to express your opposition only to receiving communications through automated methods. The Joint Controllers shall refrain from processing, except for legitimate reasons that override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of a right in court.
You have the right to lodge a complaint with the competent supervisory authority in the Member State where you habitually reside or work or in the State where the alleged infringement occurred.
8. DATA PROTECTION OFFICER
Your data may be processed by employees of the corporate functions of the Joint Data Controllers assigned to the pursuit of the purposes indicated above, who have been expressly authorised to process and have received appropriate operational instructions.
The personal data processed for the operation of the sites, collected during the navigation on the same will be processed by employees, collaborators of the Joint Controllers or external subjects, as data processors, duly instructed by the Joint Controllers, who perform on behalf of the Joint Controllers technical and organizational tasks of the Sites.