DATA CONTROLLER

The data controller of the processing activities carried out through the website is ICTLC S.p.A. with registered offices in Via Borgonuovo, 12 – 20121 Milan (Italy) (“We”, “us”, “our”, etc.).

DATA PROTECTION OFFICER

We have appointed a data protection officer (DPO) who can be contacted for any information relating to the processing of your personal data at the following address: dpo@ictlc.com.

PERSONAL DATA SUBJECT TO PROCESSING

“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person. By means of the website, we collect the following personal data:

a. Browsing Data
The computer systems and software procedures used to operate the website collect some personal data, the transmission of which is an integral part of Internet communication protocols. This information is not collected to be associated with you but, by its very nature, it may allow you to be identified by processing and associating it with data held by third parties. Among collected personal data there are IP addresses or domain names of the devices used by you to connect to the website, the URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as a reply, the numeric code indicating the status of the reply given by the server (successful, error, etc.) and other parameters regarding your operating system and device environment.
This data is used exclusively for the purposes of obtaining anonymous statistics on the use and proper functioning of the website to control its correct functioning, to enable us to correctly provide the various functionalities to you, as well as for security reasons. These personal data may also be used to ascertain any liability in cases of alleged computer crimes against the website or against third parties and they will be deleted after 7 days.

b. Data provided on a voluntary basis
By means of the website you may voluntarily provide personal data such as name, e-mail address for subscribing the on-demand newsletter service “ICT Insider”. We will process these data in accordance with the applicable law and on the assumption that they refer to you or to third parties who have authorised you to provide them pursuant to an appropriate legal basis which legitimise the processing at stake. In this case, you act as an independent data controller, assuming all relevant obligations and responsibilities according to the Applicable law. In this regard, you hence waive, in the full sense of the term, the right to all disputes, claims, claims for damages due to processing etc., which may be submitted to ICTLC of the said third party whose Personal Data have been processed through your use of the Website in breach of the Applicable Law.

c. Cookies and similar technologies
We collect personal data using cookies. You may find further information on the use of cookies and similar technologies here

• a. Purposes related to the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (e.g., to reply to a contact request).
  The legal basis for this processing of personal data is the provision of a service or the response to a request that does not require your prior consent under the applicable law.

• b. Purposes related to the compliance with a legal obligation to which we may be subjected.
  The processing of the data you provide may be necessary to comply with a legal obligation, a regulatory provision or an order of the competent authorities.

• c. Purposes related to research/statistical analyses on aggregated or anonymous data, without the possibility of identifying the data subject, aimed at measuring the functioning of the Website, traffic, usability, and interest.

• d. Purposes necessary for the establishment, exercise or defence of legal claim or whenever courts are acting in their judicial capacity.
  The processing of this data is based on our legitimate interest in ensuring judicial or extrajudicial protection whenever necessary.

• e. Purpose of sending e-mail newsletters and communications relating to professional content (including updates on matters within our competence), as well as promotional communications on our services and initiatives.
  The legal basis of the processing for this purpose is your consent.

VOLUNTARY OR OBLIGATORY NATURE OF PROVIDING THE DATA

Providing your Personal Data for the above-mentioned purposes is voluntary, however, any refusal to provide such data may not allow ICTLC to reply to your requests and to comply with legal obligations to which ICTLC is subject.

RECIPIENTS

Your personal data may be disclosed, in close relation to the purposes specified above, only to:
a. subjects necessary for order fulfilment of the services offered through the Website e.g., sending e-mails and/or analyzing data, which typically process Personal Data on our behalf as data processors;
b. persons authorised to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (e.g., our employees and lawyers);
c. law enforcement agencies and public authorities when so required by the applicable law.

TRANSFERS

Some of your Personal Data are transferred to Recipients who may be established outside the European Economic Area. ICTLC ensure that the processing of Personal Data by these Recipients is carried out pursuant to the Applicable Law. In fact, the transfer of Personal Data is based alternatively on an adequacy decision or the Standard Contractual Clauses issued by the European Commission. Further details and the signed agreements may be requested to the DPO.

DATA RETENTION

We will process your personal data only for the duration strictly necessary to achieve the purposes listed in the “Purposes and legal basis of the processing” section. For instance, we will process your personal data for the on-demand service “ICT Insider” until you will decide to unsubscribe and for sending the newsletter until you decide to revoke your consent. Apart from the above, we will process your personal data for as long as permitted by Italian law to protect our interests (Arts. 2946 and 2947(1)(3) c.c.). Further information regarding the period of retention of personal data and the criteria used to determine this period may be required by writing to the DPO.

YOUR RIGHTS

Pursuant to and to the extent allowed by the Applicable Law, you have the right, at any time, to request to ICTLC access to, rectification, erasure, restriction of the processing concerning your Personal Data or to object to relevant processing activity and to receive in a structured, commonly used and machine-readable format the Personal Data concerning you.
Requests to exercise your rights must be sent to the following address: dpo@ictlc.com.
In any case, pursuant to the Applicable Law, you have the right to lodge a complaint with the relevant supervisory authority (the Italian Garante) if you believe that the processing of your Personal Data is against the Applicable Law.

Please note that you may withdraw your consent at any time, without prejudice to the lawfulness of the processing carried out before the withdrawal, by clicking on the unsubscribe link contained in each communication or by writing at dpo@ictlc.com.

Pursuant to the Applicable Law, you have the right to lodge a complaint with the relevant supervisory authority (Garante per la Protezione dei Dati Personali) if you believe that the processing of your personal data is against the applicable law.

AMENDEMENTS

This Privacy Policy came into force on 23/05/2024. If you would like to see the previous versions of the Privacy Policy click here . We reserve ourselves the right to amend or simply update the content of the Privacy Policy, whether in part or in its entirety, also considering any changes in the applicable law. We therefore invite you to visit this section of the website regularly to become aware of the most recent and updated version of the Privacy Policy so that you are always updated on the processing activities that we carry out.