The Innovation Group, with registered office in Milan, 20122, Corso Monforte 2, VAT No. 06750900968 (hereinafter “Holder“), as data controller, informs you pursuant to art. 13 EU Regulation n. 2016/679 (hereinafter, “GDPR“) that your data will be processed in the manner and for the following purposes.
1. Object of the Treatment
The Data Controller processes identification personal data (for example, name, surname, company name, address, telephone, e-mail, later “personal data” or even “data“) communicated by you when participating in events, to subscribe to newsletters, to download articles or reports from the The Innovation Group website.
2. Purpose of the processing
Your personal data are processed:
With your consent (at 7 GDPR), for the following Marketing Purposes:
- Send you via e-mail, mail and / or sms and / or telephone contacts, newsletters, reports, commercial communications and / or advertising material on products or services offered by the Owner or invitations to participate, if interested, to complete short questionnaires used by us anonymously for the preparation of the previously mentioned reports.
- send via e-mail, mail and / or sms and / or telephone contacts commercial and / or promotional communications of third parties (for example, business partner of the Data Controller).
Without your express consent (at 6 letter b), e) GDPR), for the following Service Purposes:
- fulfil the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);
- exercise the rights of the owner, for example the right to defence in court;
Please note that if you are already a customer, we may send you commercial communications relating to services and products of the Owner similar to those you have already used, except if you dissent.
3. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subjected to both paper and electronic and / or automated processing.
The Data Controller will process personal data for the time necessary to fulfil the aforementioned purposes and in any case for no more than 5 years from the collection of data for the Marketing Purposes previously illustrated.
4. Access to data
Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):
- to employees and collaborators of the Owner
- to third party companies or other subjects (as an indication, the owner’s partner) in their capacity as external data controllers.
5. Communication of data
Without the need for express consent (Article 6 letter b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies, as well as to those subjects to whom communication is mandatory by law. These subjects will process the data in their capacity as independent data controllers.
Your information will not be disclosed.
6. Data transfer
Personal data are stored on servers located in Italy, Milan, within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.
7. Nature of the provision of data and consequences of refusal to reply
The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we cannot guarantee the services of the art. 2.A).
The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).
8. Rights of the interested party
In your capacity as an interested party, you have the rights set forth in art. 15 GDPR and precisely the rights to:
- obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
- obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the holder, of the responsible and of the designated representative according to the 3, comma 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;
obtain:
- updating, correction or, when of your interest, integration of data;
- the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
- the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disclosed, except in the case in which this fulfilment proves impossible or involves a use of means manifestly disproportionate to the protected right;
- object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the interested party to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of correction, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.
9. How to exercise rights
You can exercise your rights at any time by sending:
- a registered letter a. at The Innovation Group, Via Ettore Romagnoli 6, 20146 Milan
- an e-mail address: unsubscribe@theinnovationgroup.it.
10. Holder, manager and agents
The Data Controller is The Innovation Group with registered office in Milan, 20122, Corso Monforte 2 and operational headquarters in Via Ettore Romagnoli 6, 20146 Milan.
The updated list of those responsible and appointed for data processing is kept at the registered office of the Data Controller.
11. Consent to the processing of personal data
The undersigned to whom this information is addressed, having acknowledged what has been communicated to me – in particular the rights granted to me by the EU Regulation n. 2016/679 – I consent to the processing and communication of my personal data, by the owner and / or the person in charge of the processing, limited to the purposes indicated by the aforementioned information and due to the fulfilment of the obligations related to the execution of the existing contract.