VINHOOD is the data controller responsible for processing your personal data (“Controller”), acting through its pro tempore legal representative, with business address in Milan, Piazza della Repubblica 32.
In performing its activities, VINHOOD, as “Controller”, processes personal data in compliance with prevailing legislative provisions (Article 13 of Regulation (EU) 2016/679, “Regulation”) and applicable Data Protection legislation, adopting principles based on fairness, legality, and transparency and protecting your privacy and your rights, in accordance with the principles specified in this document.
WHAT INFORMATION DO WE PROCESS?
Personal information: name and last name
Contact information: e-mail address
Information regarding the company you collaborate with: name of the company and any information related to the type of request made (for example, number of employees; [●])
Information contained in the request: any personal data contained in the request made via the Website
Images and/or Voice
WHAT WE USE YOUR DATA FOR
We collect your data for the following purposes:
Managing your contact requests: your personal data will be processed in order to manage the requests you send us. The legal basis for such processing is detailed in article 6 (1)(b) of the Regulation, performance of precontractual measures to which the data subject is a party.
Following up on your appointment request and participating in the appointment: your data will be drawn to allow you to participate in the virtual appointment that you have requested. The drawn data may include your image and voice. The legal basis for such processing is detailed in article 6 (1)(b) of the Regulation, execution of precontractual measures to which the data subject is a party.
Sending you the requested documents: your data may be processed in the event that you request receipt of certain documents/studies/research that we’ve published. The legal basis for such processing is detailed in article 6 (1)(b) of the Regulation, execution of precontractual measures to which the data subject is a party.
Sending you marketing/promotional messages and invitations to our events/workshops: your personal data will be used in the event that you have expressly consented to receiving invitations and being informed about our events, receiving promotional messages about our activities (including new studies and surveys, etc.), and receiving market research and statistical surveys. The legal basis for processing is detailed in article 6 (A) of the Regulation, or rather the data subject’s consent. You may revoke your consent at any time.
YOU DECIDE WHETHER TO PROVIDE US WITH YOUR PERSONAL DATA
Providing your personal data in order to take advantage of the services, manage contact requests, receive marketing/promotional communications, and receive information about studies/surveys is always optional, but is necessary in order to follow up on your request.
Providing your data in order to receive commercial/promotional communications and information about studies/surveys is always optional. You may revoke your consent regarding receipt of marketing/promotional messages at any time and without providing any reason. The simplest way to do this is to click on the “Unsubscribe” link that can be found in each newsletter or message received. Or, alternatively, you may send a message to: firstname.lastname@example.org. If you withdraw your consent to receiving sales/promotional communications, this will not affect the validity of the communications sent to you up to that time.
HOW WE PROCESS YOUR DATA
Your data is processes in both hardcopy form and with the use of data transmission technology, only by authorized personnel who have been expressly assigned to this task.
Processing will take place through rationales and organizational forms that are strictly linked to the obligations, tasks, or other purposes that we have explained in detail in the preceding points.
We use precise technical and organizational measures to protect your data from any tampering, loss, or destruction and to prevent unauthorized access. Security measures are constantly monitored and improved, also based on advancements in technology.
WITH WHOM AND IN WHICH CONTEXTS DO WE SHARE YOUR DATA
Your personal data will be processed by parties which have been duly appointed as processors or processing agents authorized to perform such tasks and which have adopted security measures specifically to ensure your privacy and to prevent unlawful access by third parties or unauthorized personnel. These include third-party payment service providers that we use to allow you to purchase our experiences.
Your personal data, whenever provided, and always with your consent, as well as the limits strictly linked to the obligations, the tasks, and the purposes outlined above, may be shared with companies, organizations, or individuals other than VINHOOD.
Your personal data may be shared with Competent Authorities for the purpose of preventing, investigating, or repressing crimes, in compliance with legal provisions governing such matters.
The updated list of all Processors is available at the VINHOOD offices and may be requested by writing to the following e-mail address: email@example.com. This list may be supplemented and/or updated as required.
FOR HOW LONG DO WE PROCESS AND RETAIN YOUR DATA
We commit to erasing the following from our systems:
the personal data that you have provided in relation to requests made via our Website (contact requests, requests for materials, appointment requests), after one year from the date it was given.
the personal data processed for the purpose of sending commercial and marketing information and invitations to our events/workshops, as well as for participating in surveys and market research, after two years from the date of collection, or until you withdraw consent or object, which you may do at any time.
We warrant that our data processing is based on principles of adequacy and minimization (we only process data which we actually need for the processing purposes specified previously), and that we annually verify the need to retain data for a period no longer than that necessary for satisfying the purposes for which the data was collected and processed.
We may retain your data for the purposes of legal compliance or for ascertaining, exercising or defending a right in court.
Once the purposes for which your personal data was collected and processed have been satisfied, we will take suitable measures to render it anonymous in order to prevent identification of the data subject, maintaining however the option of using the personal data in anonymous way.
THE TRANSFER OF PERSONAL DATA TO NON-EU COUNTRIES
All processing of your data is performed in Italy and in European Union Member States.
Whenever a need may arise to transfer your data to non-EU countries, we are committed to:
Ensuring that the country to which the data provided by you will be sent guarantees an adequate level of protection, as provided under article 45 of the Regulation;
Monitoring and making transfers only in the event that we, or the Processor, can provide appropriate safeguards for enforcing your rights and effective legal remedies (in accordance with article 46 of the Regulation).
YOUR RIGHTS: YOU CAN FIND OUT ABOUT AND MANAGE YOUR DATA AT ANY TIME
You are guaranteed the following rights under article 15 et seq. of the Regulation:
Right to information;
Right to access of the Data Subject;
Right to rectification;
Right to erasure (right to be forgotten);
Right to restriction of processing;
Right to data portability.
Right to object.
If you feel that your data has been processed in an unlawful manner, you may lodge a complaint with one of the supervisory authorities responsible for monitoring data protection compliance. In Italy, a complaint may be lodged with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority) (http://www.garanteprivacy.it/).
HOW YOU CAN EXERCISE YOUR RIGHTS
To exercise the aforementioned rights, you may send a message to: firstname.lastname@example.org, showing in the message header the wording “Privacy – exercising rights”.
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