Privacy Policy

Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR). Effective as of January 1, 2023.

PREAMBLE

This information takes into account what is indicated by the GDPR and the Privacy Code (Legislative Decree of June 30, 2003, no. 196). The document has also been prepared in accordance with the guidelines of the Privacy Guarantor (especially the guidelines on anti-spam issued by the Privacy Guarantor on July 4, 2013).

Data Controller: ROSSO300 S.r.l.

Website to which this privacy policy refers: https://www.andreanannetti.com/ (Site).

The Data Controller has also appointed a Data Protection Officer (DPO), responsible for monitoring compliance with the GDPR by the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Site.

Below are described the main processes involving your personal data. In particular, the legal basis for processing is explained, whether the provision is mandatory, and the consequences of not providing personal data are detailed. To best describe your rights, when necessary, we have specified if and when a particular processing of personal data is not carried out. On the Site, you have the option to enter personal data of third parties. In this case, you guarantee that you have obtained consent from these individuals for the inclusion of their personal data. Therefore, you undertake to indemnify and hold the Data Controller harmless from any liability.

Registration on the Site

Il Sito non offre la possibilità di registrazione. Therefore, the Data Controller does not process your personal data for this purpose.

Purchases on the Site

It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose. The Data Controller does not process user data to send purchase “reminder” emails for products and/or services of the Data Controller.

Responding to Your Requests

Your data will be processed to respond to your requests for information. Providing this information is optional, but your refusal will make it impossible for the Data Controller to respond to your inquiries. The legal basis for processing is the legitimate interest of the Data Controller in responding to user requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller.

Generic Marketing

Subject to your consent, the Data Controller may process the personal data provided by you to send you advertising material and/or newsletters related to its own or third-party products. The legal basis for this processing is your consent. Providing personal data for this purpose is entirely optional. Failure to give consent to the processing of data for marketing purposes will result in the impossibility for you to receive advertising material related to products/services of the Data Controller and/or third parties, as well as the impossibility for the Data Controller to conduct market research, including assessing user satisfaction, and sending you newsletters.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e., for the analysis of your consumption choices through the identification of the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters related to its own or third-party products of specific interest to you. The legal basis for this processing is your consent. Providing data for this purpose is entirely optional. Failure to give consent to the processing of your personal data for profiling purposes will result in the impossibility for the Data Controller to create your commercial profile, by detecting your choices and purchasing habits, and sending you advertising material related to products of specific interest from the Data Controller and/or third parties.

Transfer of Data

For the sending of promotional communications, subject to your explicit consent, your personal data may be transferred to “third parties.” The legal basis for this processing is your consent. Providing personal data for this purpose is entirely optional. Failure to consent to the transfer will result in the impossibility of transferring your personal data to third parties for advertising purposes.

Geolocation

The Site does not implement tools for geolocating the user’s IP address.

Curriculum Vitae

Through the Site, you can submit your curriculum vitae. Your curriculum vitae will be reviewed by the Data Controller or its collaborators. The purpose of the processing is the legitimate interest of the Data Controller in reviewing the document to assess the possibility of establishing a working or collaborative relationship with you. This interest is equivalent to your interest in being contacted by the Data Controller for this purpose. The data will be kept until the end of the selection period and, in any case, for a period not exceeding 6 months from the submission of the curriculum vitae. Providing this information is optional, but the failure to provide it may prevent the Data Controller from contacting you.

Appointment Booking

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Communication of Personal Data

As part of its ordinary activities, the Data Controller may disclose your personal data to specific categories of subjects. In Article 2, you can find the list of subjects to whom the Data Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not communicated to third parties.

“The ‘communication’ to third parties of personal data is distinct from the ‘transfer’ (governed by the preceding section).” Indeed, in the communication, the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes an independent Data Controller of the personal data. Furthermore, your consent is always required to transfer your personal data to third parties.

Subject to the above, it is understood that the Data Controller may still use your personal data to fulfill the obligations required by the current laws.

SPECIFIC PRIVACY NOTICE

Article 1 Processing Methods

1.1 The processing of your personal data will primarily be carried out using electronic or automated means, in accordance with methods and tools suitable to ensure its security and confidentiality in compliance with the GDPR. If the automatic chatbot service is operational, your personal data will also be processed to enable the activation of this service, through which the user can contact and be contacted by the Data Controller, with prior consent. The legal basis is the legitimate interest of the Data Controller in responding to user requests through the chatbot service. This legitimate interest can be considered equivalent to the interest of the data subject in using the automatic chatbot service.

1.2 The information obtained and the processing methods will be relevant and not excessive in relation to the type of services provided. Your data will also be managed and protected in secure and suitable computer environments according to the circumstances.

1.3 The Website does not process “special categories of data.” Sensitive data are those that can reveal racial or ethnic origin, religious, philosophical, or other beliefs, political opinions, membership in parties, trade unions, associations, or organizations of a religious, philosophical, political, or trade union nature, as well as health and sex life.

1.4 The Site does not process judicial data.

Article 2 Communication of Personal Data

The Data Controller may communicate your personal data to specific categories of recipients. Below are the entities to whom the Data Controller reserves the right to communicate your data:

• The Data Controller may disclose your personal data to all those entities (including Public Authorities) who have access to personal data by virtue of legal or administrative measures.
• Your personal data may also be disclosed to all those public and/or private entities, natural and/or legal persons (legal, administrative, and tax consulting firms, judicial offices, Chambers of Commerce, Labor Offices, etc.), where such disclosure is necessary or functional for the proper fulfillment of obligations arising from the law.
• The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Website, the Data Controller may disclose your personal data to these employees and/or collaborators.
• In the ordinary course of managing the Website, the Data Controller engages companies, consultants, or professionals responsible for the installation, maintenance, updating, and, in general, the management of hardware and software used by the Data Controller for the provision of its services. Therefore, only with reference to these purposes, your data may also be processed by these entities.
• For the sending of communications, the Data Controller uses external companies entrusted with the sending of this type of communications (CRM platforms). Your personal data (particularly email) may therefore be disclosed to these companies.
• For customer support purposes, the Data Controller uses one or more companies tasked with providing customer care services. Only for this purpose, your personal data may be disclosed to these companies.

The Data Controller reserves the right to modify the above-mentioned list based on its ordinary operations. “Therefore, you are encouraged to regularly access this information to check which entities the Data Controller discloses your personal data to.”

Article 3 Data Retention

3.1 This article describes for how long the Data Controller reserves the right to retain your personal data.

• Your personal data will be retained for the sole duration necessary to ensure the proper provision of services offered through the Website.
• For marketing purposes, personal data will be retained until any withdrawal of consent. For inactive users, personal data will be deleted one year after the sending of the last email that may have been viewed.

3.2 Notwithstanding the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as may be modified from time to time.

Article 4 Transfer of Personal Data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is secure from a regulatory standpoint as it is governed by the GDPR (General Data Protection Regulation). If the transfer of your personal data takes place to a non-EU country for which the European Commission has issued an adequacy decision, the transfer is considered, in any case, secure from a regulatory standpoint. This Article 4.1 specifies, from time to time, the countries to which your personal data may be potentially transferred and where the European Commission has issued an adequacy decision.

• The Data Controller carries out a transfer of data to Argentina This is carried out in accordance with the decision of the European Commission dated June 30, 2003, No. 2003/490/EC (published in the Official Journal of the European Communities L 168/19 on July 5, 2003), whereby it was deemed that Argentina ensures an adequate level of protection for personal data transferred from the European Union.
• Your personal data may be transferred to Australia in accordance with the provisions established by the European Commission in its decision of June 30, 2008. With this decision, the European Commission has determined that Australia provides a level of data protection equivalent to that offered by the European Union.
• To enable the proper operation of the Website, your personal data may be transferred abroad. This is allowed based on the decision of the European Commission dated December 20, 2001, No. 2002/2/EC (published in the Official Journal of the European Communities L 2/13 on January 4, 2002), whereby it was found that Canada ensures an adequate level of protection for personal data transferred from the European Union to recipients subject to the Canadian Personal Information Protection and Electronic Documents Act (‘the Canadian Act’) of April 13, 2000.
• It may happen that, for certain services offered by the Website, your personal data needs to be transferred to Israel. This transfer is secure from a regulatory standpoint in light of the decision of the European Commission dated January 31, 2011.n. 2011/61/EU (published in the Official Journal of the European Communities L 27/39 on February 1, 2011). This decision has established that the State of Israel, as defined under international law, provides an adequate level of protection for personal data transferred from the European Union regarding international automated transfers of personal data from the European Union.
• The Data Controller may transfer your personal data to the United Kingdom. The European Commission has indeed ruled, with the decision of June 28, 2021, that the United Kingdom provides an adequate level of protection for personal data in accordance with the provisions of the GDPR.
• The transfer of your personal data may occur to Switzerland. The transfer is covered by the decision of the European Commission dated July 26, 2000, No. 2000/518/EC (published in the Official Journal of the European Communities L 215 on August 25, 2000, and L 115 on April 25, 2001), whereby it was found that Switzerland ensures an adequate level of protection for personal data transferred from the European Union.
• Therefore, the user is invited to regularly access this article to verify whether the transfer of their personal data takes place to a country with these characteristics.
• Your personal data may also be transferred to New Zealand. This can occur based on the decision of the European Commission dated December 19, 2012, No. 2013/65/EU (published in the Official Journal of the European Communities L 28/12 on January 30, 2013), whereby it was deemed that New Zealand ensures an adequate level of protection for personal data transferred from the European Union.

4.2 Notwithstanding the provisions of Article 4.1, your data may also be transferred to non-EU countries for which the European Commission has not expressed an adequacy decision. You are therefore invited to regularly review this Article 4.2 to determine in which of these countries your data may be transferred. To enable the proper functionality of the Website, your personal data may be transferred to the U.S.A.. In these cases, the Data Controller will take every contractual measure necessary to ensure an adequate level of protection for personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on June 4, 2021.

4.3 In this section, the Data Controller specifies the countries to which they may specifically direct their activities. This circumstance may involve the application of the legislation of the relevant country, in conjunction with that of the GDPR.

• Upon the user’s request, the Data Controller will apply, to the processing of personal data, the potentially more favorable regulations provided by the user’s national legislation.

Art. 5. Rights of the Data Subject

In accordance with Article. In accordance with Article 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

• request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of processing concerning you, or to object to their processing, as well as the right to data portability.
• withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
• lodge a complaint with a supervisory authority (e.g., the Italian Data Protection Authority).

The rights mentioned above can be exercised by making a request without any formalities to the contacts indicated in the preamble.

Art. 6. Modifications and miscellany

The Data Controller reserves the right to make changes to this information at any time, providing suitable notice to users of the website and ensuring, in any case, an adequate and equivalent protection of personal data. To review any changes, you are invited to regularly consult this information. In the event of substantial changes to this privacy policy, the Data Controller may also communicate them via email.