Privacy Policy

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IMEAS S.P.A.,
headquartered in Villa Cortese (20020 – MI), Via Antonio Pacinotti, 36, registered with the Register of Companies of Milan Monza Brianza Lodi, tax code 00215070129 and VAT number 13480470155, in the person of its legal representative and Chairman of the Board of Directors Mr. Franco Zenere (tax code ZNRFNC42S29B286Q), born in Bruscate (MI) on 29.11.1942, in his capacity as Data Controller (hereinafter referred to as “IMEAS” or “Data Controller”), pursuant to Articles 4 and 28 of Legislative Decree June 30, 2003, no. 196 – Privacy Code (hereinafter, “Privacy Code”) and Articles 4 No. 7 and 24 of EU Regulation 2016/679 of April 27, 2016, on the protection of individuals with regard to the processing of personal data (hereinafter, “Privacy Regulation”) informs you pursuant to Article 13 of the Privacy Code and Privacy Regulation that your personal data are collected and processed by IMEAS for purposes̀ directly related and instrumental to the provision and management of the services offered by this website and related services (hereinafter, “Site”). The provision of your personal data is necessary for the provision of the Services by IMEAS, therefore, failure to provide your personal data, even partially, will result̀ in IMEAS being unable to proceed with the provision of the Services. Processing of personal data means any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.

Therefore, we inform you that this data will be processed manually and/or with the support of computer or telematic means for the following purposes.

  1. Primary purposes of personal data processing.
    • First, the processing of the requested personal data that you are required to provide when registering on the Site pursues the purposes of making possible the provision of the Services by IMEAS, allowing you to access and navigate within the Site through its web pages. The processing of personal data may also pursue pre-contractual purposes, such as responding to specific requests from the data subject.
    • However, the above personal data are processed only for the purpose of allowing access to the Site, browsing and registration to the Site to obtain information or clarification in relation to IMEAS and/or its products.
    • Your personal (non-sensitive) data processed by IMEAS are those required for the above purpose, and in particular may be processed, common personal data such as: first name, last name, e-mail. The processing will not involve personal data that falls under “sensitive” or “special data.”

 

  1. Purposes of fulfilling obligations under the law, regulations or EU regulations.

2.1 Second, your personal data (both common and sensitive) will also be processed in order to fulfill obligations under the law, a regulation, or EU legislation.

 

  1. Mandatory or optional consent for the pursuit of the primary purposes of personal data processing.

3.1 According to the applicable regulations of the Privacy Code and the Privacy Regulations, the Data Controller for the purposes set out in points 1 and 2 of this Notice is not obliged to acquire the specific consent for the processing of the common personal data of the users who will register to the Site. In fact, the processing of such data illustrated above pursues primary purposes for which Article 24 of the Privacy Code and Article 6 of the Privacy Regulations exclude the need to acquire a specific consent of the user, either because the processing is necessary to fulfill an obligation required by law, regulation or EU legislation, or because the processing is necessary to perform obligations arising from a contract (in the case: the general conditions of access and navigation of the IMEAS website) to which the data subject is a party or to fulfill, prior to the conclusion of the contract, specific requests of the data subject or – finally – because the data processing pursues administrative-accounting purposes pursuant to Art. 34 i-ter of the Privacy Code.

3.2 Where the data subject does not wish to provide the personal data required and necessary according to the above anyway, the consequence would be the inability to access the website.

 

  1. Communication and dissemination of personal data in pursuit of the primary purposes of processing.

4.1. The data processed for the purposes mentioned in paragraph 1 may be disclosed to any other third party when disclosure is required by law, including the scope of prevention/repression of any illegal activity related to accessing the site.

4.2. With reference to art. 13, paragraph 1, letter (d) of the Privacy Code and art. 13, paragraph 1, letter (e) of the Privacy Regulations, we proceed to the indication of the subjects or categories of subjects who may become aware of the personal data (both common and sensitive) of the user, in their capacity as managers or appointees and we provide below appropriate list by categories:

  • IMEAS staff, appointed as data processors;
  • Third parties involved by IMEAS in the management of the Site and appointed as data processors.

4.3. Personal data will not be disseminated.

 

  1. Data retention times and other information.
    • The personal data of users who register on the Site will be kept for the time strictly necessary to fulfill the primary purposes outlined in Paragraph 1 and therefore to allow navigation within the Site and to respond to any requests from the Data Subject. Subsequently, the data will be stored in IMEAS’s database to respond to further requests from the Data Subject and for legal obligations. Should a user of the Site, following the conclusion of navigation, request the deletion of his or her data, exercising the rights set forth in Paragraph 7, the possibility of responding to any requests made by the Interested Party by IMEAS will be lost.
    • In addition, the five-year or ten-year retention periods of only documents and related data of a civil, accounting and tax nature as stipulated by applicable laws shall remain in effect.
    • Data collected are processed within the registered office and operational offices of the Data Processors.
    • Pursuant to Article 13, paragraph 1, letter (f) of the Privacy Regulation, we inform you that all data collected will not be transferred to a third country or international organization, either within or outside the European Union

 

  1. Data Controller and Data Processor..

The identification details of the Data Controller are as follows:

IMEAS S.P.A.,

Villa Cortese (20020 – MI), Via Antonio Pacinotti, 36,

tel. 0331 4630 11 and fax. +39 0331 4323 11

Address for the exercise of rights under Article 7 of the Privacy Code: email: privacy@imeas.it

The updated list of Data Processors – where appointed – can be found at the indicated location.

 

  1. Exercise of rights by the data subject.

7.1. Pursuant to Article 7 of the Privacy Code and pursuant to Articles 13(2)(b) and (d), 15, 18, 19 and 21 of the Privacy Regulations, we inform you that:

  1. (a) You have the right to request from the Data Controller access to, rectification or erasure of, or restriction of, personal data concerning you or to object to their processing, as well as the right to data portability;
  2. b) you have the right to file a complaint with the Garante per la protezione dei dati personali, following the procedures and directions published on the Authority’s official website at garanteprivacy.it.
  3. (c) any rectification or erasure or restriction of processing made at your request – unless this proves impossible or involves a disproportionate effort – will be communicated by the Data Controller to each of the recipients to whom the personal data have been transmitted. The Data Controller may notify you of such recipients if you so request.

7.2. The exercise of rights is not subject to any form requirement and is free of charge.

7.3. For utility, Article 7 Of the Privacy Code is reproduced in full below, while Articles 15 to 23 Of the Regulations can be found at this link:

http://eur-lex.europa.eu/legal-content/IT/TXT/HTML/?uri=CELEX:32016R0679&from=IT

TEXT ARTICLE 7 OF THE PRIVACY CODE

Art. 7

(Right of access to personal data and other rights)

  1. The data subject has the right to obtain confirmation of the existence or non-existence of personal data concerning him/her, even if not yet recorded, and its communication in an intelligible form.
  2. The data subject has the right to obtain the indication:
  3. (a) of the origin of personal data;
  4. (b) of the purposes and methods of processing;
  5. (c) of the logic applied in the case of processing carried out with the aid of electronic instruments;
  6. (d) of the identification details of the owner, managers and designated representative under Article 5(2);
  7. e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or appointees.
  8. The data subject has the right to obtain:
  9. (a) updating, rectification or, when interested, supplementation of data;
  10. (b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
  11. c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the protected right.
  12. The data subject has the right to object, in whole or in part:
  13. a) for legitimate reasons, to the processing of personal data concerning him/her, even if relevant to the purpose of collection;
  14. b) to the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.

 

To exercise your rights, you can download, fill out and send the appropriate form (downloadable here) to the address given in Section 6.