Circular in accordance with Article 13 of Regulation (EU) 2016/679

Dear customer,

Mattia Maffei, whose registered office is in Corso Einaudi, 53, Turin (TO), as data Controller, is hereby informing you how your data will be used by the Company in respect of the activities defined in the contract and related to request for information through our contacts (email, mobile phone, etc…) in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and its implementing legislation (jointly below, the Regulation).

1. Personal data that concern you are:

  • a) Collected during telephone/computer communications
  • b) Provided following a contract stated with our Company

2. Your data may be processed for the following purposes:

  • c) The sending of commercial or promotional communications, also related to services other than those purchased before (in case of your express acceptance of this service);

The legal basis for the processing of your personal data is the performance of a contract for the purposes referred to in point b) and your consent for the purposes referred to in point a) and c).

3. Providing your data is optional. Nevertheless, the possible denial to provide your data for the purposes referred to in point 2c) will not have any consequences, except the impossibility of being informed about possible marketing initiatives and advertisement promos from the Company, as well as of receiving personalized commercial communications.

4. With respect to the purposes set out in point 2), the processing of data operated by the Company shall be done by computer/telephone means, following reasons closely connected to the same purposes and so as to guarantee our clients’ safety anyway, always in full compliance with the legislation in force with regard to personal data protection.

5. In order to implement the contract, your data will be processed by Mattia Maffei, who may communicate them to third parties in respect of data strictly necessary to ensure the provision of services.

The Company may communicate your own personal data (ii) in respect of data strictly necessary to ensure the provision of services.

These third parties will have access to the personal data necessary to perform their functions (and they will not be entitled to use them for other objectives), they will be required to process the data in accordance with the applicable law and will be responsible for the processing commissioned by Mattia Maffei.

Notwithstanding the foregoing, your personal data will not be communicated to other parties, or otherwise disseminated. Your personal data will be stored in servers available to companies within EU and will not be transferred to non-European countries in any way.

6. Any data that have been collected and processed with your consent for the purposes referred to in point c) will be stored until you withdraw your consent to receive commercial communications from Mattia Maffei or request the removal of your own data, except the extraordinary need to store the data to protect Mattia Maffei’s rights, in respect of outstanding notifications at the time of the request, or on public authorities’ indication.

7. In accordance with Articles 15 to 22 of Regulation, you have the right to: a) bring about the cessation of the processing in the event that your personal data were processed for direct marketing purposes, including in relation to services identical to the ones already provided by our Company (the so-called right to object); b) obtain information on the purposes for which your personal data are processed, on the time necessary to process your data and on the entities to whom your data have been communicated (the so-called right to access); c) obtain the correction or the supplement of inaccurate personal data concerning you (the so-called right to rectification); d) obtain the erasure of your personal data in the following circumstances: (i) data are no longer required for the purposes for which they were collected; (ii) you withdrew your consent to the processing of your data having been previously processed on the basis of your consent; (iii) you objected to processing your personal data if they are processed to pursue one of our legitimate interests; or (iv) the processing of your personal data do not comply with the law. Nevertheless, Mattia Maffei’s data retention is permitted when it is necessary to allow the fulfilling of a legal obligation or to establish, exercise or defend a legal claim in court (the so-called right to erasure); e) obtain that your personal data are retained only, without being used in other ways in the following circumstances: (i) you contest your personal data’s inaccuracy, for a period enabling us to verify the accuracy of your personal data; (ii) you oppose the erasure of your personal data, even though the processing is unlawful; (iii) your personal data are required for the establishment, exercise or defense of legal claims; (iv) you opposed to processing and the verification whenever our legitimate grounds override yours is still pending (the so-called right to restriction of processing); f) receive, in a commonly used machine-readable interoperable format, your personal data, whether they are processed under contract or on the basis of your consent (the so-called right to data portability).

You finally have the right to call on the Personal Data Protection Authority (Monte Citorio Square, 121, 00186, Rome) to assert your rights with regard to the processing of personal data.

You will be entitled to revoke the given consent for the processing of your personal data for the purposes referred to in point 2c) at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You will be entitled to revoke your consent sending a written communication at [email protected]

8. The Controller of the processing of your personal data is Mattia Maffei, whose registered office is in Corso Einaudi, 53, Turin (TO). You can address your requests and warnings to the processing Controller at [email protected]

Your rights specified in paragraph 7 of this circular can be exercised writing at the same email address.

9. Mattia Maffei uses technical and profiling cookies in order to collect and access the information stored on his device. More information can be found on the available comprehensive circular about the application of cookies.

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