Information For the Processing of Personal Data
(version updated on 31 July 2020)
Associazione Milano & Partners, in its quality of Data Controller (hereinafter, "Owner"), informs You pursuant to EU Regulation 2016/679 ("GDPR") and Legislative Decree no. 196/2003, as amended and supplemented by Legislative Decree no. 101/2018, that Your personal data will be processed in the following manner and for the following purposes.
- Object of the Data Processing
The Data Controller processes personal identification and non- sensitive personal data (hereinafter, "Personal Data" or just "Data") communicated by You when browsing the website www.yesmilano.it (hereinafter, "Site"), of the request for information or subscription to the newsletter. In particular:
• name, last name, e-mail address and any other information shared by you when requesting information through the contacts indicated on the Site;
• the e-mail address necessary for the purpose of subscribing to the "Guida alla città/ City Guide" newsletter;
- Purpose and Legal Bases of the Processing
The Data Controller will process your Personal Data for the following service purposes and on the following legal bases:
• the execution of the contract and/or the fulfillment of pre-contractual commitments, in order to allow you to browse the Site, as well as to manage contact and information requests;
• the fulfillment by the Owner of legal obligations, i.e. to comply with obligations under national laws and regulations and EU legislation and regulations, or imposed by the competent authorities;
The Data Controller will also process your data only with your prior expressed consent to send you the “City Guide” newsletter, i.e. to update You on news, events and curiosities to better enjoy Milano. In this case, consent is provided when registering for the newsletter, following which you will receive a confirmation email containing a link to complete the registration.
Lastly, the Data Controller, only with Your prior consent expressed by clicking on the appropriate icons, will communicate your data to social networks such as Instagram, Facebook, WhatsApp and LinkedIn to allow You the required interactions.
- Method of Treatment
The processing of Personal Data is carried out, with electronic and paper methods, by means of the operations of collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction. some data.
- Data Storage
With reference to the communication of data to social networks, the Data Controller will not keep any of your Personal Data.
- Provision of Data
The provision of data for service purposes is mandatory and failure to provide it will prevent You from browsing the site or requesting information. The provision of data for other purposes is optional and, in the absence, the Data Controller will not be able to process Your Personal Data to update You on news, events and curiosities to better enjoy Milano or to allow You to interact with social networks.
- Access to Data
Your data may be made accessible for the above purposes to:
• employees and/or collaborators of the Data Controller, in their capacity as Data Processors and or internal Data Processors and/or System Administrators;
• third parties (for example, the Municipality of Milano, Parcam S.r.l., IT providers, etc.) who carry out outsourcing activities on behalf of the Data Controller, in their capacity as Data Processors.
- Communication of Data
Except in cases where the communication takes place upon Your express request and consent, Your data may be disclosed, even without Your consent, to supervisory bodies, law enforcement agencies, judiciary and competent authorities, upon their express request which will treat them as independent data controllers for institutional purposes and/or by law in the course of investigations and controls. Your Data may also be disclosed to third parties (for example, Partners, independent professionals, companies that manage social networks if consent is given, etc.), as independent Data cCntrollers, for the performance of activities instrumental to the purposes referred to above.
In case of interaction with social networks such as Instagram, Facebook, WhatsApp and LinkedIn, we invite You to view the information on the processing of personal data for each one of them.
- Transfer Of Data
The Data are neither disclosed nor transferred to non-EU countries. However, your data may be transferred outside the EU by the social networks with which you interact: in this case the transfer takes place with the methods and guarantees indicated in their policies for the processing of Personal Data.
- Rights of the Interested Party
The Data Controller informs You that, as an interested party, if the limitations provided for by law do not apply, You have the right to:
• obtain from the Data Controller confirmation of the existence or not of Your personal data, even if not yet registered, and that such data be made available to You in an intelligible form;
• obtain from the Data Controller an indication and, if applicable, a copy of: a) the origin and category of Personal Data; b) the logic applied in case of processing carried out with the aid of electronic tools; c) the purposes and methods of the processing; d) the identity of the owner and handlers; e) the subjects or categories of subjects to whom the personal data are communicated or who can learn about them, in particular if they are recipients of third countries or international organizations; f) when possible, of the data retention period or the criteria used to determine this period; g) the existence of an automated decision-making process, and in this case the logic used, the importance and consequences envisaged for the interested party; h) the existence of adequate guarantees in the event of data transfer to a non-EU country or to an international organization;
• obtain from the Data Controller, without undue delay, the updating and correction of inaccurate data or, when interested, the integration of incomplete data;
• withdraw at any time, easily, without hindrance, the consents given, using, if possible, the same channels used to provide them;
• obtain from the Data Controller the cancellation, transformation into anonymous form or blocking of data that are: a) unlawfully processed; b) no longer necessary in relation to the purposes for which they were collected or subsequently processed; c) in case of revocation of the consent on which the treatment is based and in case there is no other legal basis; d) if you have opposed the processing and there is no legitimate overriding reason to continue it; e) in case of fulfillment of a legal obligation; f) in the case of data referring to minors. The Data Controller may refuse cancellation only in the case of: a) exercise of the right to freedom of expression and information; b) fulfillment of a legal obligation, performance of a task carried out in the public interest or exercise of public authority; c) reasons of public health interest; d) archiving in the public interest, for scientific or historical research or for statistical purposes; e) exercise of a right in court;
• obtain from the Data Controller the limitation of processing in the case of: a) disputation of the accuracy of Personal Data; b) unlawful processing by the Data Controller to prevent its cancellation; c) exercise of Your right in court; d) verification of the possible prevalence of the Data Controller's legitimate reasons with respect to those of the interested party;
• receive from the Data Controller, if the processing is carried out by automatic means, without impediments and in a structured, commonly used and legible format, the Personal Data concerning You, in order to transmit them to another Data Controller or - if technically feasible - to obtain direct transmission from part of the Owner to another owner;
• object, in whole or in part: a) for legitimate reasons, connected to Your particular situation, to the processing of personal data concerning You; b) to the processing of Personal Data concerning You for the purpose of sending communication material, by e-mail and/or by traditional methods such as telephone and/or paper mail;
• files a complaint to the Italian Authority for the Protection of Personal Data.
In the cases mentioned above, where necessary, the Data Controller will inform the third parties to whom Your Personal Data are communicated of the possible exercise of these rights by You, with the exception of specific cases (e.g. when this fulfillment proves impossible or involves the use of means that are manifestly disproportionate with respect to the protected right).
- Ways to Exercise these Rights
You can at any time exercise these rights vis-à-vis the Data Controller:
• by sending a registered letter to the legal address of the Owner;
• by sending an email to firstname.lastname@example.org.
Consent to the sending of the "City Guide" newsletter can also be revoked at any time through the appropriate unsubscribe function contained in each e-mail being sent.
- Owner and Controller of Data Processing
The Data Controller is Associazione Milano & Partners, with registered office in Piazza della Scala no. 2, 20121 - Milano (MI), Tax Code 97726610153; VAT number IT11016320969. The updated list of Data Processors is kept at the headquarters of the Data Controller.
The Data Controller has also appointed a Data Protection Officer (Data Protection Officer) who will monitor the measures taken to protect your data and who can be contacted by writing an e-mail to email@example.com.