The Data Controller is the natural or legal person, public authority or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data relating to a given service offered. With this regard, the Data Controller is Comunicaffè International, a daily newspaper registered at the Court of Milan number 715/2004 (address: Via Dogana, 3 – 20123 Milan – I Italy).
The purpose of this Information Notice is to inform the user about the way in which his/her personal data will be processed. Comunicaffe International in line with Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (hereinafter “Privacy Code”) and Regulation (EU) 2016/679 (hereinafter “GDPR”), intends to guarantee the privacy and security of each visitor’s personal data consistently with what is prescribed in this Policy.
This Policy is intended as information pursuant to Articles 13 and 14 of the GDPR.
1. TYPE OF DATA PROCESSED
The website offers content of an informative and sometimes interactive nature. During navigation of the site Comunicaffe International may, therefore, acquire information about the visitor in the following ways:
- A) Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and the addresses of the websites from which access was made, information on the pages visited by users within the site, the time of access, the length of time spent on each page, internal path analysis and other parameters relating to the user’s operating system and computer environment.
- B) Additional categories of data
These are all the personal data provided by the visitor through the site for the use of the services offered; for example, by registering and/or accessing a reserved area and/or a service and/or participating in one of the initiatives launched by Comunicaffe International alone or in partnership with third parties, by writing to an e-mail address of Comunicaffe International to request information or calling our toll-free number to have direct contact with customer service.
2. PURPOSE OF PROCESSING & LEGAL BASIS
The data and cookies received from you will be processed by Comunicaffe International exclusively with the methods and procedures necessary to provide you with the services requested or subscribed to (Contractual purposes) and for the further purposes for which you have given your consent.
In particular, your data will be used by Comunicaffe International to allow your registration to the site and to take advantage of all the services offered through the site.
Following your first registration, which is a necessary condition for the provision of the service you requested, if you request to use further Comunicaffe services, you will be able to use the credentials (username/email/password) already used during your first registration.
The purposes of the processing of the User’s personal data carried out by Comunicaffe International, together with the relative legal basis, can be summarised as follows:
– Providing the good and/or service requested by the user, managing the contracts perfected by the user, carrying out the relative administrative, accounting, fiscal and legal fulfilments, as well as processing the requests forwarded by the user. The processing operations carried out for these purposes are necessary for the fulfilment of contractual obligations and do not require the specific consent of the person concerned.
– To measure your experience during the usage of our website and/or of our products and services, as well as to ensure the correct functioning of the web pages and their contents. The processing put in place for these purposes is based on a legitimate interest of the Data Controller.
– To associate the personal data that you provided to Comunicaffe International by registering on this site or its use. The processing carried out for this purpose is based on a legitimate interest of the Owner.
– To inform you about commercial initiatives, also by automated means, relating to promotions and/or offers for which you may be entitled to benefit, in the interest of the Owner. The processing carried out for these purposes is carried out with the specific consent provided by the user, except for commercial communications relating to products and/or services similar to those already purchased and/or subscribed to by the user, for which the processing is based on a legitimate interest of the Owner, with respect to which the user may, in any case, always exercise his/her right to object.
– Only with your express consent the personal data may be used for statistical analysis, market research, promotional activities through social media and sending commercial information on products and promotional initiatives of Comunicaffe. (Direct marketing purposes).
– Only with your express consent the data may be used for profiling purposes conducted automatically by collecting information on the navigation you do while accessing and using the site and, by means of statistical correlation algorithms, linking it to the same information stemming from other users in order to identify common traits and classes of interest. By assigning your browser to a class of interest, our systems will then be able to provide you with content that is closer to your tastes and present advertisements that better meet your needs and better target the interests of advertisers while reducing the level of disruption to your experience.
As of the date you read this Policy, Comunicaffe International uses profiling data to aggregate marketing profiles, to manage the relationship with advertisers and improve campaigns, to infer patterns of use of our products and services, and to assist sales management in developing digital strategies. (Profiling purposes)
– To communicate your data for commercial and/or promotional purposes to third party companies operating in the publishing sector and/or to companies operating in the following sectors with which Comunicaffe International may enter into partnership agreements: social networking and interactive platforms, consumer goods, distribution, financial, insurance, automotive, services and humanitarian and charitable organisations, as well as telecommunications. Processing for these purposes is carried out with the specific consent provided by the user.
3. SCOPE OF DATA CIRCULATION
Within the scope of the purposes indicated above, your data may be communicated to:
– Comunicaffe International and/or other companies/third parties that carry out part of the processing activities and/or activities connected and instrumental to the same on behalf of the Data Controller, and who will be appointed for this purpose as data processors pursuant to Article 28 of the GDPR;
– individuals, employees and/or collaborators of the Controller, who have been entrusted with specific and/or multiple processing activities on your personal data. These individuals have been given specific instructions on the security and proper use of personal data and are defined as the persons authorised to process personal data under the direct authority of the Data Controller or Processor.
4. TRANSFER OF DATA ABROAD
Comunicaffe International may transfer your personal data to third parties located in countries outside the European Union or the European Economic Area. In this circumstance, such third parties will be appointed as Data Processors pursuant to and for the purposes of Article 28 of the GDPR and the transfer of your personal data to such parties, limited to the performance of specific processing activities, will be regulated in accordance with the provisions of Chapter V of the GDPR. All necessary precautions will therefore be taken in order to ensure maximum and adeguate protection of your personal data by basing such transfer:
(a) on adequacy decisions of the receiving third countries expressed by the European Commission;
(b) on adequate safeguards expressed by the receiving third party pursuant to Article 46 of the GDPR;
(c) on the adoption of corporate binding rules.
Users may request information on these guarantees by sending a request to firstname.lastname@example.org.
Following the ruling of the Court of Justice of the European Union on 16 July 2020 in case C311/18, with reference to third countries that are not recipients of one of the adequacy decisions by the European Commission, Comunicaffè International, in the event of data transfer abroad, will make specific assessments regarding the additional guarantees to be adopted, in order to prevent interference by local public authorities that may undermine the level of essential equivalence of protection of the data transferred there, compared to the level enjoyed under European law.
5. REDIRECTS TO EXTERNAL SOCIAL NETWORK SITES
The website may use social plug-ins. Social plug-ins are special tools that make it possible to incorporate social network functions directly into the website (e.g. the Facebook “like” function).
All social plug-ins on the website are marked with the respective logo of the social network platform (e.g. Facebook, Google, Twitter, Linkedin).
When you visit a page on our website and interact with the plug-in (e.g. by clicking the “Like” button) or leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform and stored there.
6. LINKS TO THIRD PARTY SITES
From this website it is possible to link to other third-party websites.
The Owner declines any responsibility regarding the possible request and/or release of personal data to third party sites and regarding the management of authentication credentials provided by third parties.
7. DATA STORAGE
Data will be stored for the period of time necessary to pursue the purposes for which such data was collected, as stated in this policy. In any case, the following retention periods will apply with respect to the processing of Data for the purposes set out below:
For the Contractual and Legitimate Interest Purposes, the data is retained for a period equal to the duration of the provision of the services and/or products requested by the user and for 10 years after the termination of the provision, without prejudice to any renewals and cases where retention for a later period is required for any litigation, requests by the competent authorities or pursuant to applicable legislation;
8. RIGHTS OF THE INTERESTED PARTY
The subjects to whom the above-mentioned personal data refer (so-called “interested parties”), have the right to exercise their rights in the manner and within the limits provided by current privacy legislation.
Comunicaffè International guarantees that you can exercise your rights at any time as provided for by art. 12 of the GDPR. In particular you have the right:
– to know whether the Controller holds and/or processes personal data relating to you and to access them in full, including by obtaining a copy (art. 15, Right of access);
– to the rectification of inaccurate personal data or the integration of incomplete personal data (Art. 16 Right of Rectification);
– to the deletion of personal data held by the Controller if one of the reasons set out in the GDPR applies (Art. 17 Right to Deletion);
– to ask the Controller to restrict the processing to only some personal data, if one of the reasons provided for by the GDPR exists (Art. 18 Right to Restrict Processing);
– to request and receive all your personal data processed by the Controller, in a structured, commonly used and machine-readable format or to request transmission to another Controller without hindrance (Art. 20 Right to Portability);
– to object in whole or in part to the processing of your data for the purpose of sending advertising material and market research (so-called Consent) (Art. 21 Right to object)
– to object in whole or in part to the processing of data in automatic or semi-automatic mode for profiling purposes (so-called Consent).
In addition, pursuant to Art. 7(3) GDPR, we inform you that you may exercise your right to withdraw consent at any time, without affecting the lawfulness of the processing based on your prior consent.
The exercise of these rights may be exercised by notifying Comunicaffè by writing to email@example.com
Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.
Furthermore, you always have the right to lodge a complaint with the Guarantor Authority for the Protection of Personal Data, which can be contacted at firstname.lastname@example.org or through the website http://www.gpdp.it.
11. LAST UPDATE