USERS OF SMEMORANDA GROUP WEBSITE
Contact us: Website section available to Users who, after entering their Personal Data as required for SG to contact them, wish to submit a Request to GE.
Cookies: text (letters and/or numbers) that contains information packages that are stored on the User’s own computer or mobile device whenever they visit a website through a browser. At each subsequent visit the browser sends cookies to the originating website. Cookies may only be stored for the duration of the session when a certain website is being used (session cookies), or for a longer period and irrespective of that session (persistent cookies).
Personal Data: any information relating to an identified or identifiable – whether directly or indirectly – natural person, by reference to their name, ID number, location data, online ID or elements characteristic of their physical, physiological, genetic, psychological, economic, cultural or social identity.
Newsletters: any email communication having commercial and informative content, sent by Smemoranda Group Companies in relation to their products or activities.
Smemoranda Group Companies: companies that are part of the corporate group of which SG is the holding company. These companies are: Zelig Media Company S.r.l.; C’Art Group S.r.l.; Crazy Bell S.r.l.; Digital GUT S.r.l.; Gut Distribution S.r.l.; Nava DesignS.r.l.
2. Data Controller
With respect to this Information, the Data Controller is Smemoranda Group, viale Ortles 52/54, 20139, Milan, tax code 10191940153 and VAT Number 10541990965, which is the holding company of Smemoranda Group Companies. Any User’s request in relation to the Processing performed by SG concerning their own Personal Data (including the exercise of the rights referred to in paragraph 7 below) shall be addressed to SG by mail at the registered office, or by email to: firstname.lastname@example.org
3. Purpose and legal basis of the Processing
SG collects and uses Users’ Personal Data for the following purposes:
- The collection of Personal Data for the purposes referred to in letter a) is subject to the Cookies information available at the following link https://en.smemorandagroup.com/cookie/, which SG recommends consulting.
b) To allow Users to submit a Request to SG
- The collection of Personal Data for the purposes referred to in letter b) is required to allow Users to use the Contact us section and thus submit their Request to SG and receive from SG the relevant response to their Request.
- Said Processing is based on freely given, specific, informed and unambiguous consent of the User, expressed as positive action on the Website (i.e., by completing the relevant sections of the Request, as present on the Contact us section, and sending the Request to SG by clicking on the button “send request”).
- The refusal of the User to the processing referred to in letter b), precludes them from sending the Request to SG.
c) To allow users to receive the Press Releases
- The Processing of the User’s Personal Data for the purposes referred to in this letter c) is optional and is based on the legitimate interest of SG, pursuant to Article 6 f) of the Regulation, to promote the image of the corporate group of which it is the holding company, and to notify Users of developments of the corporate group itself (e.g., extraordinary transactions resulting in the entry of a new company in the corporate group).
- Such legitimate interest, balanced with the User’s right to privacy, is deemed to prevail also based on the intermittent frequency of the Press Releases that are, in fact, sent in relation to extraordinary transactions involving SG andSmemoranda Group Companies.
- In any event, the User has the right to object at any time to the Processing, and the objection pursuant to Article 21 of the Regulation may be exercised following the indications referred to in paragraph 7 g) of this Information.
d) To allow users to receive the Newsletters
- The collection of Personal Data for the purposes referred to in this letter d) is optional.
- The refusal by the User to the Processing shall not preclude them from sending a Request to SG, but shall prevent them from receiving Newsletters from Smemoranda Group Companies.
- Said Processing is based on freely given, specific, informed and unambiguous consent of the User, expressed through positive declaration or action (e.g., flag) on the Website.
- Consent may be withdrawn at any time, following the indications referred to in paragraph 7 a) of this Information, on the understanding that the withdrawal of consent shall not affect the lawfulness of the Processing carried out prior to such withdrawal.
4. Modalities of data collection
SG collects Personal Data with the following modalities:
a) Personal Data entered by Users on the Website:
- Personal Data entered by the User on the Website in order to submit the Request to SG, as per paragraph 3 b) of the Information, or for the purpose of receiving the Newsletters, as per paragraph 3 c) of the Information.
b) Personal Data automatically collected by the Website:
- Personal Data automatically collected by the Website through, but not limited to, Cookies (for more information, we recommend consulting the Cookies information at the following link https://en.smemorandagroup.com/cookie/).
5. Categories of recipients of Personal Data (if any)
Personal Data are processed by SG and/or third parties, who have been screened for their reliability and competence, to whom such Personal Data may be disclosed insofar as it is necessary or advisable, provided that all this occurs within the EU. In particular, SG informs Users that their Personal Data may be processed by, and/or disclosed to:
SG employees and/or collaborators appointed to follow up on Requests received by SG through the Contact us section.
Smemroanda Group Companies, for the purposes indicated at paragraph 3 d) of the Information;
6. Duration of storage of Personal Data and criteria for the determination thereof
SG keeps Personal Data for the period of time strictly required to fulfil the purposes for which it collected them in the first place, as indicated in paragraph 3 of the Information. In particular, save for the exercise of the right of the User to withdraw their consent as per paragraph 7 a), SG keeps the User’s Personal Data for the following periods of time:
for the purposes of paragraph 3 a), it is hereby recommended to consult the Cookies information available at the following link https://en.smemorandagroup.com/cookie/;
For the Request submitted by the User to SG: in connection with the purposes referred to in paragraph 3 b) of this Information, SG keeps the User’s Personal Data for a period of 3 months from the date of the last contact between SG and the User, i.e., the date of the most recent Request submitted by the User to SG, or the date of the most recent response sent by SG to the User.
For sending the Press Releases: in connection with the purposes referred to in paragraph 3 c) of this Information, SG keeps the User’s personal data for a maximum period of 24 months from the date of the Request or the last User interaction with SG. To this end, “last user interaction with SG” means the most recent affirmative action that the User has implemented and serves to prove to SG an interest of the User in learning about the business of SG or of the corporate group of which it is the holding company, and – as a result – in receiving the Press Releases (e.g., click on the Press Releases; submitting a subsequent Request to SG).
In the absence of User interaction (e.g., failure to open the Press Releases) for an uninterrupted period of 24 months after such date, SG shall send the User a notice to give them the opportunity to consent to receiving Press Releases and, in the event of a negative response, SG shall permanently erase the User’s Personal Data or irreversibly render them anonymous.
Upon expiry of the terms indicated in this paragraph 6 of the Information, SG shall automatically erase the Personal Data collected or render them irreversibly anonymous, so that such data may no longer be associated with the User.
7. User’s rights
Pursuant to and for the purposes of the Regulation, for the period referred to in paragraph 6 of this Information, each User has the right to:
a) with reference to the Processing referred to in paragraph 3 d), withdraw their consent at any time without affecting the lawfulness of the Processing carried out prior to the withdrawal. The withdrawal of consent may be exercised by exercising the opt-out at the bottom of the Newsletter (see Article 7 (3) of the Regulation).
c) obtain from SG the rectification of Personal Data and the right to have incomplete Personal Data completed, without undue delay (see Article 16 of the Regulation);
d) for specific reasons (e.g., unlawful processing, withdrawal of consent, non-existence of the purposes of the Processing), obtain the erasure of Personal Data, without undue delay (see Article 17 of the Regulation);
f) in the event of authorised Processing, receive the Personal Data in a readable format, in order to transmit them to a third party, or, where technically feasible, request the transmission by SG of the Personal Data directly to said third party (right to data portability– see Article 20 of the Regulation)
g) object to the Processing of their Personal Data as made by SG for the purposes referred to in paragraph 3 c) of this Information, by sending an email to SG at email@example.com or by opting-out at the bottom of the Press Release;
h) be informed by SG without undue delay of any breaches or non-authorised access by third parties to its systems containing Personal Data (data breach – see Article 34 of the Regulation);
i) lodge a complaint with the supervisory authority of the EU Member State of their habitual residence, place of work or of the alleged infringement (see Article 77 of the Regulation);
For further information concerning the terms and conditions for the exercise of Users’ rights, see the text of the EU Regulation as available at this link http://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=EN, or contact GE in accordance with the modalities described in paragraph 2 of this Information.