Privacy and Cookie Policy

Information on the processing of personal data

Pursuant to Article 13 of the Privacy Code (Legislative Decree 196/03) and Article 13 EU Regulation No. 2016/679 (hereinafter, “GDPR”), we inform you that the company that owns the site indicated at the bottom of this site is the data controller (hereinafter, “Data Controller”). According to the indicated law, such processing will be based on the principles of fairness, lawfulness and transparency and protection of your privacy and rights.

1. Object of processing
The Data Controller processes the personal, identifying and non-sensitive data (in particular, name, surname, tax code, VAT number, email, telephone number - hereinafter, “personal data” or also “data”) communicated by You when registering to the Data Controller's website and/or when subscribing to the newsletter service offered by the Data Controller.

2. Purposes of the processing
Your personal data are processed:
A) without Your express consent (art. 24 lett. a, b, c Privacy Code and art. 6 lett. b, e GDPR), for the following Service Purposes:
- allow You to register on the website;
- operate and maintain the website;
- to allow You to subscribe to the newsletter service provided by the Owner and any additional Services that You may have requested;
- fulfill pre-contractual, contractual and tax obligations arising from existing relationships with You;
- Fulfill obligations required by law, regulation, EU legislation or an order of the Authority;
- prevent or detect fraudulent activity or abuse harmful to the Website;
- exercise the rights of the Data Controller, such as the right of defense in court.
B) Only with Your specific and distinct consent (Articles 23 and 130 Privacy Code and Art. 7 GDPR), for the following Marketing Purposes:
- To send You via email newsletters, commercial communications and/or advertising material on products or services offered by the Owner.
Please note that if you are already our customer, we may send you commercial communications relating to services and products of the Controller similar to those you have already enjoyed, unless you disagree (art. 130 c. 4 Privacy Code).

3. Method of processing
The processing of Your personal data is carried out by means of the operations indicated in art. 4 Privacy Code and art. 4 n. 2) GDPR and precisely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data is subject to both paper and electronic and/or automated processing.
The Data Controller will process your personal data for as long as necessary to fulfill the above purposes and in any case for no longer than 10 years after termination of the relationship for the Service Purposes and for no longer than 2 years after data collection for the Marketing Purposes.

4. Access to data
Your data may be made accessible for the purposes set out in Articles 2.A) and 2.B):
- to employees and collaborators of the Controller, in their capacity as persons in charge and/or internal data processors and/or system administrators;
- to the company of which the Data Controller is part (e.g., for support activities in the study of the feasibility of the client's project, for technical management activities of the project, for the storage of personal data, etc.) or to third parties (e.g., providers for the management and maintenance of the website, suppliers, credit institutions, professional firms, etc.) who perform outsourcing activities on behalf of the Data Controller, in their capacity as external data processors.

5. Communication of the data Without Your express consent (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Owner may communicate Your data for the purposes of art. 2.A) to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom the communication is compulsory by law for the fulfillment of the said purposes. Your data will not be disseminated.

6. Transfer of data
The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or third party companies appointed and duly appointed as Data Processors. Currently, the servers are located in the Netherlands. It is in any case understood that the Data Controller, should it become necessary, will have the right to move the location of the servers to Italy and/or the European Union and/or non-EU countries. In this case, the Data Controller assures as of now that the transfer of data outside the EU will take place in accordance with the applicable legal provisions by entering, if necessary, into agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission.

7. Nature of data provision and consequences of refusal to respond
The provision of data for the purposes set out in Article 2.A) is mandatory. Without them, we will not be able to guarantee you either registration to the site or the Services of art. 2.A). On the other hand, the provision of data for the purposes of art. 2.B) is optional. You can therefore decide not to provide any data or to deny later the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material related to the Services offered by the Owner. In any case, you will continue to be entitled to the Services referred to in Article 2.A).

8. Rights of the data subject
In Your capacity as a data subject, You have the rights under art. 7 Privacy Code and art. 15 GDPR and specifically the rights to:
i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in intelligible form;
ii. to obtain information on: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identity of the owner, managers and the representative appointed under Art. 5, paragraph 2 Privacy Code and Art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State, managers or agents;
iii. obtain: a) the updating, rectification or, when you are interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;
iv. to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if pertinent to the purpose of 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 calling systems without the intervention of an operator by email and/or through traditional marketing methods by telephone and/or paper mail. It should be noted that the data subject's right to object, set forth in point b) above, for direct marketing purposes through automated modalities extends to traditional ones and that, in any case, the possibility for the data subject to exercise the right to object even partially remains unaffected. Therefore, the data subject may decide to receive only communications by traditional means or only automated communications or neither type of communication.
Where applicable, you also have the rights under Articles 16-21 GDPR (Right to rectification, right to be forgotten, right to restrict processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority.

9. Methods of exercising rights
You may at any time exercise your rights by sending:
- a registered letter to the holder's address: Mino Di Vita, via De Sica 21 - 20153 Milano
- an e-mail to the address: mino@minodivita.com

10. Minors
This Site and the Owner's Services are not intended for minors under the age of 18, and the Owner does not intentionally collect personal information referring to minors. In the event that information about minors is unintentionally recorded, the Owner will delete it in a timely manner upon users' request.

11. Data controller, data processor and appointees
The Data Controller is indicated at the bottom of the site itself.
The updated list of data processors and data processors is kept at the Data Controller's office.

12. Changes to this Policy
This Policy is subject to change. You are therefore advised to check this Policy regularly and refer to the most up-to-date version.