Dear Sir/Madam,

In compliance with the EU Regulation 2016/679 regarding the protection of individuals with regard to the processing of personal data and the free movement of such data, the Data Controller, indicated below, is required to provide Customers (hereinafter referred to as “data subjects”) with certain information regarding the use of personal data.

Please note that the data processed by the Data Controller are solely those provided by the data subjects at the time of assignment, for purposes strictly related to contractual obligations, and do not originate from third parties. Therefore, the processing of such data does not require specific consent from the data subject.

Explicit consent will be requested if the Data Controller needs to process the data for purposes other than those listed below. This specific consent may be requested at any time during the existing contractual relationship, both prior to and after it, for marketing purposes or subscription to our newsletter. It will be requested through a dedicated form that must be duly completed and signed by the data subject.

According to the applicable regulations, this processing will adhere to the principles of fairness, lawfulness, transparency, and protection of your privacy and your right to the protection of personal data.

In accordance with Article 13 of the European Regulation 2016/679, we provide you with the following information:

  1. Purpose of the data processing

Personal data are processed within the normal professional activity of the Data Controller indicated below for the following purposes:

  • Purposes strictly related and instrumental to the management of the professional relationship, such as all activities necessary for the correct management and execution of tax and accounting obligations, the management and execution of contracts, administration and payment management.

  • Communication of the data of the data subject to any consultants of the Data Controller, natural or legal persons acting as Data Processors or Joint Data Controllers, such as accountants, lawyers, and collaborators of the Data Controller necessary for the assigned task.

  • Functional activities of the Data Controller, such as data processing for promotional, commercial, administrative purposes, and/or legal obligations, information about initiatives promoted by the Data Controller, and promotions of services and/or products offered by the Controller.

c) Gomedianet acts as the Data Processor in the following activities, as agreed upon with the Data Controller through a nomination agreement:

  • Management of websites and company social media pages.
  • Video/photographic shooting, editing of images, and publication on websites or social media pages.
  • Management of customer contacts for sending newsletters, invitations, commercial advertisements, etc.
  1. Data processing methods

The processing is carried out through operations or a combination of operations such as collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, blocking, communication, erasure, and destruction of data.

The data will be processed in written form and/or on magnetic, electronic, or telematic media, even when the data is communicated to the subjects indicated in this information, who are also committed to processing them using only the methods and procedures strictly necessary for the specific purposes listed in point 1. The processing is carried out by authorized persons and collaborators within their respective functions and in compliance with the instructions received, exclusively for the achievement of specific purposes while strictly adhering to the principles of confidentiality and security required by the aforementioned law.

 

  1. Provision and refusal of data provision

The provision of common personal data and identification data for the purposes listed in point 1a) is strictly necessary for the performance of the professional assignment.

Any refusal by the data subject would make it impossible to fulfill these purposes.

The activities listed in point 1b) are subject to the data subject’s consent. Any refusal will not compromise the processing described in the previous point.

All processing activities listed in point 1c) are subject to an additional nomination agreement by the Client, who remains the Data Controller of the personal data eventually provided and processed by Gomedianet.

 

  1. Data disclosure

Without prejudice to communications made in compliance with legal obligations, the data may be disclosed, exclusively for the purposes indicated in point 1, in Italy or abroad, to the following categories of collaborators or external parties:

  • Consultants or companies identified by the Data Controller for the performance of the assignment entrusted by the data subject.
  • Banks and/or credit and financial institutions and/or other agents operating in the credit field.
  • Independent collaborators of our company.
  • Professionals and consultants.
  • Any legitimate recipient of communication for the aforementioned purposes listed in point 1.

Any other purpose of processing will require specific consent from you and will be treated accordingly.

 

  1. Data retention period

The data will be processed for the entire duration of the established contractual relationships and even afterwards for the fulfillment of all legal obligations.

Images and videos collected during the provision of services commissioned by the client will be kept for the entire duration of the service and for 6 months thereafter.

Images and videos collected for social and media management services, newsletter management, and website management will be stored in our archives throughout the service period and for 10 years thereafter to address any potential disputes.

 

  1. Data transfer abroad

    Personal data may be transferred to countries within the European Union or to countries outside the European Union, subject to the verification of adequacy decisions by the Commission or based on standard contractual clauses as provided by Article 46 of the Regulation. Personal data or media published on social networks located outside the European community are subject to the privacy policies of those platforms and will be verified by Gomedianet di Simula Valerio Antonello for the security of transfers.

 

7. Rights of Data Subjects

 

Data subjects have the rights provided by Articles 15 to 22 of the Regulation. These rights include the right to access personal data, request their deletion or correction, revoke consent, limit processing, and request data portability.

Data subjects can obtain confirmation of the existence of their personal data, request access to the data in an intelligible form, and inquire about the data’s origin, logic, and purpose. They can also request data deletion, anonymization, or blocking if the data is unlawfully processed, as well as updates, corrections, or integration of the data. Data subjects have the right to object to the processing of their data for legitimate reasons.

 

The Data Controller for personal data is Gomedianet di Simula Valerio Antonello, with registered office in – 20161 Milan, Italy.