This document sets out the manner in which and the purpose for which personal data will be processed by Finer Srl, in its capacity as data controller (the “Data Controller” or “Finer” or “the Company”). It also sets out the other information required to be given by law, including information on the data subject’s rights and how to exercise them.
Regulation (EU) 2016/679 on the protection of personal data (the “Regulation”) lays down rules on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and safeguards individuals’ fundamental rights and freedoms, with particular regard to the data subjects’ right to have their personal data protected.
Under Article 4, No. 1 of the Regulation, “Personal Data” means any information relating to an identified or identifiable natural person (the “Data Subject”).
“Data Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (Article 4, No. 2 of the Regulation).
Pursuant to Articles 12 et seq. of the Regulation, the Data Subject must also be made aware of the appropriate information concerning: (i) the Data Processing conducted by the Data Controller; (ii) the rights of Data Subjects.
1. THE PURPOSES OF THE PROCESSING AND LEGAL BASIS
With the express consent of the data subject, Finer will process your personal data (name, surname, email address, telephone number etc.) for sending communications containing information about Finer and the activities organized by the Company (such as, for example, conferences etc..), including updates and / or informative material of a legal and / or professional nature.
2. METHODS FOR PROCESSING AND STORING DATA
In compliance with the provisions of Article 5 of the Regulation, Personal Data processed by the Firm is:
(i) processed lawfully, fairly and in a transparent manner in relation to the Data Subject;
(ii) collected and registered for specified, explicit and legitimate purposes, and further processed in a manner that is compatible with those purposes;
(iii) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
(iv) accurate and, where necessary, kept up to date;
(v) processed in a manner that ensures appropriate security;
(vi) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the Personal Data are processed.
Personal Data will be processed by the Data Controller by automated and non-automated means. The Personal Data will be stored electronically on secure servers located in restricted areas with limited access.
Specific security measures are adopted so as to prevent data being lost or used in an unlawful or improper manner, as well as to prevent unauthorised access thereto.
3. PROVISION OF PERSONAL DATA
The provision of Personal Data is optional and any refusal by the data subject implies the impossibility for Finer to send communications containing information related to Finer or relating to conferences and other activities, including updates and / or information material of legal and / or professional nature.
4. STORAGE OF PERSONAL DATA
Personal Data is stored for the time strictly necessary to achieve the purposes for which it has been collected and processed. Therefore, as a general rule, Personal Data will be stored for the entire term for which the relationship with Finer is ongoing.
It is understood, however, that, once the contractual relationship with Finer, and with it the purpose for which the Data has been processed, have come to an end, the Data Controller will, in any event, be required and/or entitled to continue to store Personal Data, in whole or in part, for certain purposes, as expressly required by specific provisions of the law (such as the obligation to keep accounting records for a period of 10 years provided for under Article 2220 of the Italian Civil Code) or to assert or defend a right in court (for example, in the event of possible disputes in respect of the activities conducted by Finer).
5. DISCLOSURE OF PERSONAL DATA
Personal Data will be accessible by the persons in charge of processing it, as well as by external contractors.
Furthermore, to ensure the correct performance of the professional duties in question and/or compliance with specific provisions of law, Personal Data will be disclosed to court and other legal process officials, the opposing parties and their lawyers, arbitration panels and, in general, to all those to whom disclosure is necessary precisely for the purpose of correctly fulfilling the engagement or obligations provided for under the law.
6. PUBLIC DISCLOSURE OF PERSONAL DATA
Personal Data is not subject to public disclosure.
7. TRANSFER OF PERSONAL DATA ABROAD
Personal Data may be transferred to European Union Member States and third countries that are not part of the European Union for the purposes indicated in paragraph 1 above. If Personal Data is transferred outside the European Union without any decision having been taken by the European Commission on the adequacy of the protections provided in relation thereto, the applicable legislation on the transfer of Personal Data to third countries who are not part of the EU will still be observed.
8. THE DATA SUBJECT’S RIGHTS
Data Subjects can access their Personal Data at any time for the purpose of rectifying, erasing and generally exercising any and every right to which they are expressly entitled under the applicable legislation that protects their Personal Data. More specifically, they can exercise the following rights: to obtain confirmation as to whether or not Personal Data concerning them exists and to have it disclosed in an intelligible form, to know the source, purpose and manner in which Personal Data are processed; to know the identity of the Data Controller, as well as the identity of the data processors and the parties or categories of parties to whom Personal Data can be disclosed; verify whether or not the Personal Data is accurate or request that it be completed or updated or rectified; to request that Personal Data processed in violation of the law be erased, anonymised or blocked, as well as request the restriction of processing in accordance with the law, and object, in any event, in whole or in part, for legitimate reasons, to the processing thereof; to data portability; to file a complaint, report or petition with the Data Protection Authority, in those situations in which the required conditions are met. The applicable legislation also recognises the Data Subjects’ right to object to their Personal Data being processed for the purposes stated in paragraph 1 of this policy, as well as the right to revoke their consent to Data Processing at any time, without prejudice, however, to the lawfulness of the manner in which the Personal Data has been processed by the Data Controller on the basis of such prior consent.
9. DATA CONTROLLER AND DATA PROCESSOR
The Data Controller is Finer Srl, with registered offices Piazza Cavour 1, Milan, Italy (E-mail: )
The internal Data Processor is Mr Giorgio Maria Introini.
10. NOTICES AND THE DATA SUBJECTS’ EXERCISE OF THEIR RIGHTS
For the purpose of exercising their rights provided for under paragraph 8, Data Subjects can contact at any time the internal Data Processor indicated in paragraph 9, by email to .
11. CONSENT TO THE PROCESSING OF PERSONAL DATA
I, the undersigned, having read and understood the above policy describing the processing of my personal data, give my consent to such personal data being processed for the purpose of fulfilling the objectives provided for under paragraph 1 of such policy, namely that of communicating information about Finer or about conferences and other activities organised by the Company.