ON THE SUBJECT OF THE PROTECTION OF PERSONAL DATA PURSUANT TO ART. 13 OF LEGISLATIVE DECREE No. 196 OF 30.06.2003
Please read this document in order to be aware of the criteria we use to safeguard your privacy. If you have any questions, please write to: firstname.lastname@example.org.
Collection and use of personal data
The ID and IT-related personal data that refer directly to the customer subscribing to the Ambrosetti Live service (hereinafter “AL”) or those utilising it, identified as its users, will be processed by the Data Controller in compliance with provisions on the subject of the processing and protection of personal data in order to enable the use of the service, and for purposes strictly connected with and instrumental to the correct management of the same.
In particular, the Data Controller draws attention to its need to be able to dispose of a series of personal data in order to be able to identify the participants registered (hereinafter the “users”) and/or to contact them.
The personal data collected directly from the Data Subject or through the customer, in the case of third party users, include: name and surname, company, corporate position, address, telephone number, email, and any secretarial service data. This information is used by The European House - Ambrosetti S.p.A. for the implementation and management of the service, also through the website www.ambrosettilive.com, as well as for the sending of important communications relating to changes in contractual terms, in privacy standards and in the terms and conditions for the use of the service.
At the express consent of the Data Subject, the identification data may be used for the sending of communications connected with other initiatives (e.g.: the promotion of other services and/or initiatives) regarding the services offered by the Data Controller. The communications will be sent using automatic means such as e-mail and SMS, as well as traditional means, such as a phone contact with operator, in total compliance with the principles of lawfulness and correctness and the provisions of law.
The supplying of the personal information is optional. However, failure to supply it will make it impossible to subscribe to or use the service.
The user may at any time exercise his/her rights vis-à-vis the Data Controller (by way of non-limiting example object to, delete, rectify, integrate etc. the data), as provided for in articles 7 and 8 of Legislative Decree no. 196/2003, by sending a request to The European House -Ambrosetti S.p.A., at the following e-mail address: email@example.com.
With particular reference to the sending of communications for marketing purposes, the Data Subject may object to the same at any moment by sending a request to the above-mentioned e-mail address.
Further data: navigation data
During normal operation, the computer systems and software procedures utilised in the operation of this website gather some personal information the transmission of which is implicit in the use of Internet communication protocols.
This information is not gathered for the purposes of association with the identified Data Subject, but these data, by their very nature, could be processed and associated with other data held by third parties, leading to the identification of the users.
This data category includes IP addresses and domain names of the computers used by users connecting to the website, addresses in URI (Uniform Resource Identifiers) notation, the resources requested, the time of the request, the method used to submit the request to the server, the size of the response file received, the numerical code indicating the status of the response given by the server (OK, error, etc.) and other parameters concerning the user's operating system and computer environment.
Dissemination and communication of the personal data
The data collected will not be divulged or disseminated. With regard to dissemination, we specify that the Company subscribing to the service could be included, for reference purposes, on the list drawn up by the Data Controller featuring its key customers. This list only includes the dissemination of Company data, so no personal data will be disclosed.
The user may decide to use some of the functions offered by the service through the website (e.g. chat or forum) which could lead to the dissemination of his/her data or data referring to third parties. In this case, however, the user him/herself will be the data controller of these data and will therefore be responsible for publishing only the information for which he/she has obtained authorisation.
Their communication to third parties, other than the Data Controller, by data processors internal, but also external, to the corporate structure, and by the authorised users selected and appointed to carry out the processing, pursuant to articles 29 and 30 respectively of Legislative Decree no. 196/2003 and subsequent amendments and additions, is permitted only when necessary to guarantee the provision of the service to computer companies supplying IT support, consultants and speakers, involved in the correct and lawful pursuit of the above-described purposes (e.g. the development of websites, the webinar live platform, ...). During training sessions the participants can see the names of the other participants, their positions in the various companies and they can chat with each other and also with the speaker. So in this case the transmission of your personal data (name and surname) to the participants of the course is envisaged. In any case, processing by third parties shall only take place in accordance with the principle of correctness and in full compliance with the legislation in force.
The European House - Ambrosetti S.p.A. might be obliged by law, due to legal proceedings or disputes and/or in response to requests by public or governmental authorities inside or outside of the user’s country of residence to transmit the personal data to third parties. It may also transmit the data to third parties if it deems it to be important or expedient to do so in order to comply with the law of for other matters of public importance. For example, in the case of a distance learning programme financed by an interprofessional fund, certain information (e.g. viewing of the videos) must be shared with the company appointed to certify the effective implementation of the training plan. Your image will only be processed if you have signed a specific release to this end.
Moreover, in the case of restructuring, merger or sale, The European House - Ambrosetti S.p.A. may transfer to the third parties responsible for such operations all the personal data gathered. In this event, you will receive a communication on the matter.
Protection of personal data and processing methods
The European House - Ambrosetti S.p.A. takes precautions including administrative, technical and physical measures to protect the personal data from loss, theft and abuse, as well as from unauthorised access, disclosure, tampering and destruction. The data are processed by specifically designated internal staff using automated systems, thanks to which they can be stored, managed and transmitted. The data are also kept in computerised form in full compliance with the minimum security measures provided for by the law.
Integrity and storage of the personal data
Rights of the Data Subject
The Data Subject may exercise his/her rights as expressed in articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30 June 2003 by contacting the Data Controller. In particular, in accordance with art. 7, he/she has the right to obtain confirmation of the existence or otherwise of personal data concerning him/her - even if not yet recorded - and the communication of the same in an intelligible form. The Data Subject has the right to obtain information regarding: a) the source of the personal data; b) the purposes and methods of the processing; c) the logic applied to the processing, if the latter is carried out with the help of electronic means; d) the identification data concerning the Data Controller, Data Processors and the representative designated pursuant to art. 5, paragraph 2; e) entities or categories of entity to whom or which the personal data may be communicated and who or which may become privy to said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing. The Data Subject has the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been 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. Finally, the Data Subject may exercise his/her right to object in the terms and manners foreseen by the cited provisions.
Access to the personal data
Users may ask to correct their data if inaccurate or to delete them - provided that The European House - Ambrosetti S.p.A. is not legally obliged to keep them - by writing to firstname.lastname@example.org.
We can refuse to fulfil requests that are unreasonably repetitive, that require disproportionate technical efforts, that damage the privacy of others or that are inordinately impractical.
Questions on privacy
The Data Controller is The European House - Ambrosetti S.p.A., with registered office in (20149) Milan (MI), via Francesco Albani, 21, acting through the CEO, Valerio De Molli.
Nature of data provision
Provision of the data is mandatory for obligations required and sanctioned by law, otherwise data provision is voluntary but necessary and any refusal by the Data Subject will make it impossible for the Data Controller to fulfil the relationship which is being established and its prompt execution.
Pursuant to art. 24, paragraph 1, letters A) and B) of Legislative Decree no. 196/2003 and subsequent amendments and additions, consent to the processing of the aforementioned data is not necessary since they are collected to fulfil legal obligations and/or to fulfil the obligations deriving from the contract already in existence, or so-called precontractual obligations.
Pursuant to art. 23 of Legislative Decree no. 196/2003 consent to the processing of the aforementioned data is, however, necessary with regard to the additional and specific purposes outside of those specified in the contract. In particular, consent is required for the use of the data for marketing purposes regarding the services offered by the Data Controller. The messages will be sent using traditional and automatic means pursuant to art. 130, paragraphs 1 and 2, of Legislative Decree no. 196/2003. The Data Subject may oppose the processing, and in particular may specifically and separately oppose the sending of messages using traditional means and/or the sending using automatic means, by sending an e-mail to the above mentioned address provided by the Data Controller.
Consent is considered to have been given on the signing of the contract and, in the case of third parties, through the tools used by the customer, who is responsible for obtaining it.
ON THE SUBJECT OF THE PROTECTION OF PERSONAL DATA PURSUANT TO ART. 13 OF LEGISLATIVE DECREE No. 196 OF 30.06.2003 and subsequent amendments and additions.
Pursuant to and for the effects of the terms laid down in art. 13 of Legislative Decree no. 196/ 2003, the company The European House - Ambrosetti S.p.A., with registered office located in (20149) Milan (MI), via Francesco Albani, 21, in its capacity as personal Data Controller, hereby informs Data Subjects wishing to subscribe to the newsletter service about their personal data processing and use, the scope of communication and dissemination and the nature of data providing.
PURPOSES OF DATA PROCESSING
The personal data, essentially pertaining to the identity of their owner, collected from the Data Subjects, through the completion of the form for subscribing to the service, are subject to processing and are used directly to fulfil the request to send the newsletter, the object of which is to provide information, business and promotional communications on the Data Controller’s services, according to the principles of lawfulness and correctness and the provisions of law.
The data are processed by specifically designated internal staff using automated systems, thanks to which they can be stored, managed and transmitted. The data are also kept in computerised form in full compliance with the minimum security measures provided for by the law.
TRANSMISSION AND DIVULGING OF THE DATA
The data collected will not be divulged or disseminated.
Their communication to third parties, other than the Data Controller, by data processors internal, but also external, to the corporate structure, and by the authorised users selected and appointed to carry out the processing, pursuant to articles 29 and 30 respectively of Legislative Decree no. 196/2003 and subsequent amendments and additions, is permitted when necessary for the conducting of the declared purposes to computer companies supplying IT support involved in the correct and lawful pursuit of the above-described purposes. In any case, processing by third parties shall only take place in accordance with the principle of correctness and in full compliance with the legislation in force.
RIGHTS OF THE DATA SUBJECT
The Data Subject may exercise his/her rights as expressed in articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30 June 2003, by contacting the Data Controller. In particular, in accordance with art. 7, the Data Subject has the right to obtain confirmation of the existence or otherwise of personal data concerning him/her - even if not yet recorded - and the communication of the same in an intelligible form. The Data Subject has the right to obtain details regarding: a) the origin of the personal data; b) the purposes and methods used for processing them; c) the logic applied if the data is processed using electronic systems; d) the identity of the Data Controller, the data processors and the designated representative pursuant to art. 5, paragraph 2; e) the parties or categories of parties to which the personal data may be communicated or who may gain knowledge of them in their capacity as designated representative for the State territory, data processors or authorised users. The Data Subject has the right to obtain details regarding: a) the updating, correction or when interested the integration of the data; b) the deletion, transformation into anonymous form or blocking of any data processed unlawfully, including any data which need no longer be kept for the purposes for which they were collected or subsequently processed; c) a statement that the operations mentioned under the letters a) and b) were notified, also with regard to their content, to those to whom the data were transmitted or disseminated, except for cases in which such a fulfilment is impossible or entails use of means that are clearly disproportionate to the right protected. The Data Subject has the right to object to the processing under the terms and conditions provided for by the aforementioned provisions.
DATA CONTROLLER, DATA PROCESSOR AND PRIVACY COMMUNICATIONS
The Data Controller is the company The European House - Ambrosetti S.p.A., with registered office located in (20149) Milan (MI), via Francesco Albani, 21. The data processor is the pro tempore manager of the Ambrosetti Live service, Mr. Gianluca Consonni. An updated list of the data processors, appointed by the Data Controller pursuant to art. 29 of Legislative Decree 196/2003, is available on the company’s web site and/or at the Data Controller’s registered office. For any communications pursuant to art. 7 et seq. of Legislative Decree no. 196/2003 and subsequent amendments and additions, it is possible to write to the Data Controller at the following address: email@example.com.
DATA RETENTION TIME
The data will be stored until the raising of an objection by the Data Subject and, in any case, for not more than two years from the date in which the said data were recorded.
NATURE OF DATA PROVIDING AND CONSENT
The supplying of the personal data is optional, but necessary because failure to do so will make it impossible to proceed with the subscription to the service requested.
Pursuant to Legislative Decree 196/2003 consent to the processing of personal data is necessary since they are collected outside of previous contractual agreements (cf. art. 23 and 24 of Legislative Decree 196/2003).
Please be informed that consent will be considered to have been freely given on clicking “Acknowledgement and acceptance”.