Pursuant to Section 13 of Italian Legislative Decree no. 196 of 30 June 2003
(D.Lgs. 196/03) (Italian Personal Data Protection Code)
SG Holding (SG Srl) informs those who read this notice that Italian Legislative Decree no. 196 of 30 June 2003 (“Personal Data Protection Code”, or more simply “Italian Privacy Law”) provides that the processing of personal data—both ordinary and sensitive—shall be carried out in respect for the fundamental freedoms, rights and dignity of the data subject, with special regard for personal identity and the right to protection of personal data. The Italian Privacy Law embodies the principle that, after being provided with the information contained in this form, the data subject be asked to consent to the processing of his/her personal data. SG Holding (SG Srl) will process personal data in a licit, appropriate and transparent manner, safeguarding the privacy and rights of the data subject. Thus, pursuant to the Italian Privacy Law and regarding the personal data that shall be processed, in asking you to consent to the processing of your personal data by approving the statement of consent presented below (i.e., by clicking on the appropriate box), to the extent that it may be necessary and except as provided by Section 24 of the Italian Privacy Law, we hereby fulfil the obligations to provide this notice. In the case of registration on the website by means of personal account bearing the commercial name “Newsletter SG Holding”, you will be asked to provide shared data for the exclusive purpose of confirming your identity.
1. Method and Purpose of Personal Data Processing
1.1.1. The acquired or requested personal data that we normally process, as well as any future variations of said personal data, is of a common sort. Said data is processed for the purpose of providing the content offered to users of the website and for pursuing the objectives stated in our statute: planning, management, promotion and commercialization of conventions, incentive programs, meetings, special events and trade fairs both in Italy and abroad. Said personal data will also be processed for the generation of statistics both in-house and outside of our company. 1.1.2) Personal data will be processed for commercial and advertising purposes, for purposes of participating in Sinergie initiatives, and for the transmission of information regarding commercial initiatives and events. 1.1.3) The personal data may also be processed for the purposes of planning company activities, for purposes relating to internal auditing, and for reporting to other companies within the SG Holding (SG Srl) regarding the analysis of results or the company’s financial situation, as well as for other purposes of an analogous nature to those listed above. 1.2) The provision of the personal data for purposes of the processing in question is compulsory or voluntary depending on the nature of the processing and/or the nature and use of the data; nevertheless, the failure to provide said data may prevent the execution, in whole or in part, of the agreement set forth here or affect the means of carrying out the relationship. Said data are thus obligatory for creating an account allowing access to the reserved sections of the Sinergie website (said account is strictly personal). 1.3) The data will be processed also via electronic means, which may consist of any operation or set of operations listed in Section 4 of the Italian Privacy Law. 1.4) The security measures provided for in the Italian Privacy Law shall be applied in processing personal data via electronic means. Said electronic processing shall also involve a private geographical computer network equipped with servers and PCs having updated antivirus and firewall protection. 1.5) Personal data will be stored in printed form or on electronic media by our company or by other companies within the SG Holding as described herein.
2. Navigation Data
During the course of their normal operations, the IT systems and software procedures underlying the operation of the website http://www.sg-holding.it acquire certain personal data, the transmission of which is implicit in the use of internet communication protocols. By virtue of their nature, these data could be used to identify you as a user by means of their processing and association with other data, although they are not acquired for the purpose of being associated with identified users. Included in this type of data are IP addresses and other information that could potentially be used to identify your IT environment. The data specified above are used exclusively for statistical purposes regarding navigation by users within the website and the proper function of the website. These data are used anonymously. The user associated with said data provides certain personal information. At this point a username and password are assigned to the user and corresponding uniquely to him/her. The username and password will be used exclusively by the website to allow user identification and to allow the completion and fulfilment of relations and operations, whether governed by contract or not, requested by the user.
3. Categories of Subjects to Whom or Which Personal Data May Be Communicated
3.1) Pursuant to Sections 24 and 25 of the Italian Privacy Law, without prejudice to the communication and dissemination performed as required by law, personal data may be communicated to third parties for the same purposes as stated above at Point 1) and exclusively for functional reasons and within the bounds of execution of this agreement, such as, for example, companies that provide or manage services that are auxiliary to the activities of our company, companies that manage computerized postal services, commercial information companies, and professionals and consultants whose services are used by Sinergie S.r.l. 3.2) The personal data may also be communicated to other companies in the SG Holding (parent company, subsidiary, associate company, via both direct and indirect relationships, pursuant to laws in force), to public administrations or public authorities pursuant to laws in force. 3.3) Within the company, the personal data will only be accessible by personnel who are specifically authorized and/or assigned to process personal data because of their roles or positions within the company. 3.4) Personal data may be disseminated for the same purposes as described in Point 1).
4. Rights of Data Subject
The Data Subject is endowed with the rights set forth in Section 7 of the Italian Privacy Law, which is herewith copied in full: 1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. 2. A data subject shall have the right to be informed: a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2); e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing. 3. A data subject shall have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. 4. A data subject shall have the right to object, in whole or in part, a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
5 Data Controller
5.1) The data controller is SG Srl, with legal headquarters and domicile in Milan, Piazzale Giulio Cesare no. 14 – 20145 VAT NO. 09005800967, whose identification information may be acquired from the company’s legal headquarters.
6 Data processor
The data processor is SG Srl, with legal headquarters and domicile in Milan, Piazzale Giulio Cesare no. 14 – 20145, VAT NO. 09005800967, which can be contacted regarding exercise of the rights provided in Section 7 of D.Lgs. 196/03 at the following email address: email@example.com.