PRIVACY POLICY for Newsletter subscription on www.itttai.com

Policy in accordance with and pursuant to Art. 13 EU Reg 2016/679 (European Regulation regarding the protection of personal data).

You are hereby informed that EU Reg. 2016/679 (European Regulation regarding the protection of personal data) foresees the protection of persons and other subjects of the law with respect to the processing of personal data. As per articles 13 and 14, therefore, you are hereby considered informed of the following information:

1. Joint Proprietorship

The following companies, HOLDING SANTI SRL, located at 3/A Via Trento, 31020 Castello di Godego (TV), TRAPUNTATURA BELPUNTO SRL, 2 Via Asiago, 31030 Castello di Godego (TV), ITTTAI SRL, 2 Via Asiago, 31030 Castello di Godego (TV), SAGIWA SRL, 1 Via Asiago, 31030 Castello di Godego (TV), and RENIER S.S., 2 Via Asiago, 31030 Castello di Godego (TV), operate jointly as joint proprietors of the processing policy (hereinafter referred to as “joint proprietors”).
The email address and contact info of the internal reference person to contact for matters relating to the processing of personal data is the following: giorgia@belpunto.it, telephone number +39.0423.46.98.71 ext. 233.

2. Purpose and Legal Foundation

The processing of your personal data, given by you to us, is for the sole purpose of sending periodic information on our products and events that we will organise or in which we will participate (for example the fairs in our sector). The legal foundation for the processing and for the above-mentioned ends is founded upon the consent given through the selection of the specific boxes present in the contact forms (Point & Click).

3. Nature of Data

The data collected are name and email address. All the collected data abide by the rules contained in the present policy. The Owner does not request and does not intend to process specific categories of personal data as per Art. 9 EU Reg 2016/679.

4. How we used collected data

Once inserted in the specific forms your data are sent and managed by Growens S.p.A Mailing List Mailup service, with legal headquarters at 9 Via Pola, 20124 Milan (Italy). We process your data and the lists to which you are subscribed through this platform. The said platform allows us to identify the date and time which emails are opened and the number of clicks on the links. This is useful in order to supply information that is specific and relevant to the related expectations.
The platform allows one to unsubscribe to the Newsletter or the Mailing List at any time (the link to unsubscribe shall be present at the end of every email sent).
The platform collects your personal data on our behalf and are used by us for sending periodic emails or sequences of emails pre-set by us. No emails are sent through a fully automized process.
We periodically guarantee that the platform runs correctly and that it adapts to and respects the European Regulation for the protection of personal data, in the capacity of our personal data Manager.
The Mailup platform is connected to email addresses provided by the providers with headquarters and servers in Italy.

5. Compulsory Data Provision

Provision of personal data is not compulsory but necessary in order to send emails and for the purpose of the above-mentioned data processing. Under no circumstances shall we use your personal data for purposes different from those indicated in the present policy.
By clicking the specific box you are thereby declaring to have read this policy and to consent to the processing of your personal data. Thus, with the act of Point & Click, you thereby express your consent for the processing of personal data, within the limits and for the purposes indicated in this policy, to all effects of the law.

6. Recipients of Data

Your personal data may be communicated to our internal collaborators (employees in charge of such) as well as external collaborators (system managers, social media managers, programmers, web marketing agencies) who assist us in the managing of requests and organisation of the back office, as well as online platforms and services such as Mailup. Some of these collaborators and platforms are managers for personal data processing and are held to abide by our specific instructions; the employees, those responsible for personal data processing, are bound by strict company policy, as well as confidentiality and secrecy obligations. Upon request, the list of our data processing managers is available.

7. Processing measures

Your data shall be kept and managed on the Mailing List (Mailup) platform, which keeps a database containing your data and the recording of the actions you carry out in the emails we send you (when you have seen them and how many times). This serves to understand if everything is running properly and to offer you better service.
The email addresses are supplied by Italian companies and on servers located in Italy.

8. Transfer of data abroad

Some of your Personal Data shall be shared with Recipients that may be located outside the European Economic Area. Our supplier of software for the management of email lists guarantees that the processing of your Personal Data on the part of these Recipients is carried out in compliance with the applicable law. Indeed, the transfers are carried out by appropriate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

9. The rights of involved persons and the exercise thereof

According to European regulation, you have the right to request:
• access to your personal data (therefore to know what personal data is in our possession);
• the rectification of imprecise data or the addition to that which is incomplete (in the case that some data have undergone modifications);
• the deletion of personal data (upon verification of one of the conditions indicated in Art. 17, para. 1 of the GDPR, while respecting the exceptions foreseen by para 3 in the same article);
• the limitation of the processing of personal data (for example you might request to no longer be subscribed to our Newsletter despite continuing to be our clients), referring to one of the hypotheses indicated in Art. 18, para. 1 of the GDPR;
• the opposition to processing;
• to receive your personal data in a structured and legible (on an automated device) format, even for the purposes of communicating such data to another policy owner (right to porting);
• to revoke consent in any moment, within the limits of the hypotheses in which the processing is based on the consent to one or more specific purposes and regards common personal data (for example the date and place or birth or place of residence), or specific data categories (for example data relevant to race, political opinions, religious beliefs, health status or sexual orientation). Processing based on consent and carried out prior to the revocation of the said however, preserves its lawfulness until the moment of revocation;
• the above-listed rights, when the data refer to deceased persons, those who have a personal interest therein, or who act on behalf of the deceased person as their legal representative, or for family reasons requiring protection, unless the interested person has not expressly denied the same through a written declaration presented to the joint proprietors of the policy or which has been communicated to the latter.
• to make a claim to the regulating authority (Authority Guarantor for the protection of personal data www.garanteprivacy.it).

10. Period of retainment

Your personal data shall be kept for the entire duration of the subscription to the Newsletter or to other lists which you have requested subscription. Once you have unsubscribed, your personal data shall be retained for a maximum duration of 6 months and, moreover, for the necessary time for the fulfilment of legal obligations or for the protection of the legitimate interests of the Data Controller, in accordance and compliance with Art. 6 EU Reg 2016/679.

11. Security Guarantee for Your Personal Data

No IT system can be deemed 100% safe. Nevertheless, we adopt the most appropriate measures to safeguard security and minimise the risk of Data Breach through careful observance of rigorous technical and organisational measures, which are periodically updated, in order to limit the risk as much as possible.

12. Further information

The services and information content of this website are all directed to people of legal age. We do not intend to collect personal data from minors and, in the event such should occur, we shall proceed to their immediate deletion. No responsibility is taken for data provided that is imprecise or false. This Privacy Policy may be subject to future modifications and/or integrations. We therefore encourage you to consult it periodically according to your necessities.

MODIFICATIONS REGISTER
01/02/2020: first upload of Website online
19/09/2022: last modification