Belluzzo & Partners, Stradone San Fermo, 14, 37121 – Verona.
Definition of personal data
For the purposes of this Privacy statement, “Personal data” – in accordance with article 4 of the Regulation – means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Data voluntarily provided by the user
Belluzzo collects some personal data (name, surname, email address, telephone number, address, etc.) voluntarily provided by the users of the site through special registration forms or emailed to Belluzzo.
The computer systems and the software procedures of the site obtain, during their normal activities, certain personal data whose transmission is implicit in the use of Internet communication protocols. These data are not associated with identified subjects, but because of their very nature could, through specific processing and associations with data held by third parties, allow to identify the users. In this category of data are included the IP addresses of the computers used by users who use the site, the addresses in the Uniform resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical Regulation indicating the status of the response given by the server (processed, abnormal end, error, etc.) and other parameters related to the user’s operating system. This data are used only for obtaining anonymous statistical information on the use of the site and for checking its correct functioning, and are deleted immediately after processing. The data could be used for the assessment of liability in case of any cyber offences against the site.
Purpose and method of processing
Belluzzo processes the above personal data, in accordance with article 6, Cmma 1, letter b) and f), exclusively for:
a) user registration for the access to the contents and information materials on the site;
b) request for information about Belluzzo or contact requests;
c) sending personal data for job vacancies or collaboration with Belluzzo;
d) sending newsletters, invitations to events, seminars, etc.;
-Subject to explicit consent of the subject, under art. 6, Comma 1, letter a) of the GDPR in relation to:
e) profiling in order to provide professional services tailored for the subject.
Belluzzo protects the personal data of users by taking the security measures provided for by the Regulation.
Data optionally provided
The user (except for the above navigation data), has the option to provide his/her personal data in the site’s registration form or by e-mail. Failure to give the data involves the following consequences:
1. Under sub-case (a) of the preceding paragraph, non providing personal data will entail the impossibility for Belluzzo to allow the user to access the contents of the site;
2. Under sub-cases (b) and (c) of the preceding paragraph, non providing personal data will not allow Belluzzo to send the requested information to the user and to examine the proposal of work or collaboration;
3. Under sub-case (d) of the preceding paragraph, non providing personal data will result in the impossibility for Belluzzo to send newsletters, invitations to events, seminars, etc.;
4. Under sub-case (d) of the preceding paragraph, non providing personal data will result in the impossibility for Belluzzo of profiling the user in order to provide a service more appropriate to the user’s needs.
Communication and dissemination of personal data
Users personal data will be accessible to Belluzzo’s employees and consultants formally designated as data controllers. The management and retention of personal data will take place on servers located within the European Union, owned by Belluzzo or third parties in charge and duly appointed as data controllers. Currently the servers are located in France and Germany, but it is understood that Belluzzo, if deemed necessary, will have the right to move the location of the servers in Italy and/or the European Union and/or non-EU countries. In this case, Belluzzo ensures that the transfer of data to extra-EU countries will take place in accordance with applicable legal provisions, stipulating, if necessary, agreements which guarantee an adequate level of protection, and/or by adopting the standards provided by the European Commission. Some data may be communicated in an anonymous and aggregated form to third parties for statistical purposes. In any case, users cannot be identified through these data. Except for the cases permitted by law, or provided for by this Privacy Information, personal data will not be communicated or disseminated without the user’s consent.
Data Retention period
The personal data will be processed by Belluzzo until the user unsubscribe from the site under the cases sub (a) and (d) above. The personal data will be processed by Belluzzo under case sub (e) until the user notice. Personal data under cases sub (b) and (c) will be treated for a maximum time of one year, unless a stable relationship is established, or an engagement is given to Belluzzo by the user.
Source of personal data
Personal data are directly collected from the user
Rights of users with respect to their personal data
Users have the rights as per art. 15 of the Regulation, and more precisely the right:
• To obtain confirmation of the existence of their personal data and their communication in an intelligible form;
• To obtain the indication: a) of the origin of the personal data; b) the purposes and modalities of processing; c) of the logic applied in the case of profiling; d) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients are in third countries or are international organisations, and the existence of adequate guarantees to the transfer; e) of the retention period; f) the existence of a profiling process and its applied logic and the importance and expected consequences of such a treatment;
• To obtain: a) the updating, the rectification or, if the case, the integration of the data; b) the deletion or limitation of the processing of the data;
• To oppose, in whole or in part: a) to the processing of personal data which are processed within the meaning of article 6, comma 1, letter e), f), including profiling; (b) the processing of personal data for the purposes of sending promotional and commercial material by e-mail and/or by means of traditional marketing via telephone and/or paper mail;
• To revoke the consent provided pursuant to article 6, comma 1, letter a) and article 9, comma 2, letter a) of the Regulationat any time without prejudice to the lawfulness of the treatment based on the consent before the withdrawal;
• The right to submit a complaint to the supervisory authority for the protection of personal data (based in Piazza di Monte Citorio , 121 00186 ROMA) with the modalities indicated at the Internet address: http://www.garanteprivacy.it/. The relevant communications will be sent to the Data Controller.
Existence of an automated decision-making process including profiling
Personal data could be processed to profile the user for the purpose of proposing specific advisory services. The use of the collected personal data will allow the sending of communications more tailor made to the needs of the user. The profiling process could result in the creation of additional data from the originals, with the consequence, in the case of erroneous profiling, of a conditioning in the user’s choices.
Exercise of rights and request for information
To exercise the rights and for any questions or requests relating to the processing of personal data by Belluzzo, users can contact us at the following e-mail address: Privacy@belluzzo.net
38, Craven Street
160 Robinson Road,
#20-08 SBF Center