PRIVACY NOTICE UNDER REGULATION (EU) 2016/679 – ON THE PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND ON THE FREE MOVEMENT OF SUCH DATA
ANIMA Federazione delle Associazioni Nazionali dell’Industria Meccanica Varia ed Affine (fiscal code 80067530156) with registered office in Milan, via Angelo Scarsellini 13 (20161); telephone number: 02 4541 8500; e-mail address: email@example.com (hereinafter, also only “ANIMA” or “Federation” or the “Data Controller“), pursuant to Regulation (EU) 2016/679 – on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR“), as Data Controller, informs you on the following.
1- ANIMA, which is a member of Confindustria (Confederation of Italian Industry), has as its corporate purpose, among others, to “encourage and develop, by the most appropriate means, technical, scientific and economic cooperation for the purpose of improving production; to establish relations with other Federations or Industrial Associations, both domestic and foreign“. To this end, ANIMA controls, through the majority or the totality of the corporate shareholdings, some companies (namely: ASA Azienda Servizi Anima S.r.l., Icim Group Srl, Tifq Srl and Tifqlab Srl and collaborates with Easyfrontier Srl, a partner in the “Easy Customs service”) which, altogether, constitute the so-called ANIMA System, through which the Federation pursues and implements its statutory goals and provides services to the associated companies.
2 – ANIMA is aligned with the high standards of confidentiality of personal data introduced by the GDPR, based on the principles of fairness, lawfulness, transparency and protection of privacy and of the rights of the data subject.
3 – ANIMA collects and commonly utilizes, in the performance of its institutional activities, Personal Data referring to the associated companies, their respective directors, managers, employees, collaborators and consultants; such Personal Data – which have been collected because they have been transmitted by the associated companies in compliance with the obligations incumbent upon them or have been collected directly by the Federation (e.g., on the occasion of participation in meetings, events, courses, webinars or conventions, or through spontaneous contribution by the data subject) also through the companies of the ANIMA System – are utilized to communicate invitations to meetings, events, courses, conventions, webinars, as well as to send promotional material on ANIMA initiatives through newsletters, as well as, obviously, for the purposes indicated within its own statute.
4 – ANIMA guarantees to each data subjects the exercise of their rights as better specified in paragraph 8 below.
IN VIEW OF THE ABOVE, ANIMA HEREBY INFORMS YOU THAT
- Data controller and data processor
The Data Controller is ANIMA (as defined above), with registered office in Milan, via Angelo Scarsellini 13.
Moreover, the companies belonging to the ANIMA System, as defined above, which provide ANIMA with specific processing services or perform activities connected with, instrumental to or in support of those performed by ANIMA, have been appointed as Data Processors.
- Categories of Personal Data processed
Your Personal Data that will be processed by ANIMA are: name, surname, title, role/assignment, address, telephone number, e-mail address, tax code directly provided by you (hereinafter “Personal Data“). They are recorded in the database of ANIMA and of ANIMA System by virtue of the statutory purposes of the Federation as well as of the purposes better described in paragraph 3 below.
- Purpose of the processing of Personal Data and legal basis
Your Personal Data are processed for the following purposes:
(A) in relation to the associative relationship and, in any case, for the pursuit of the Federation’s institutional goals: the statutory, administrative and, in general, associative management.
For the pursuit of the purpose referred to in letter (A) above, the legal basis is the signing of the application to join ANIMA.
(B) to inform you – by means of automated tools (email, sms, mms and instant messages) or traditional tools (phone calls with an operator, paper mail) – about initiatives, activities and projects of the Federation (meetings, courses, conventions, competitions, webinars, etc.), to send you informative and promotional material and newsletters, and, in any case, for any other activity promoted by ANIMA that ensures the correct and lawful processing of the data, protecting their confidentiality and integrity.
For the pursuit of the purposes referred to in point (B) above, the legal basis is your prior specific consent.
(C) communication of your Personal Data to speakers and/or partners of webinars, conventions or courses in which you take part.
For the pursuit of the purpose referred to in letter (C) above, the legal basis is your prior specific consent.
- Processing methods and mandatory or optional nature of the supply of Personal Data – consequences of any refusal
The processing of your Personal Data, whose Data Controller is ANIMA, for the purposes better described in points (A), (B) and (C) of paragraph 3 above, may be carried out with or without the aid of electronic or automated means.
Said data processing will include – in compliance with the principles of fairness, lawfulness, transparency and protection of confidentiality – the operations strictly necessary for the purpose.
The provision of Personal Data for the pursuit of:
– the purposes referred to in letter (A) of paragraph 3 (management of the associative relationship) is necessary to join ANIMA and for the management of the associative relationship and any refusal to provide such information will make it consequently impossible to join ANIMA and to take part even partially to the activities envisaged by the statute of the Federation;
– the purposes referred to in letter (B) of paragraph 3 (marketing) is optional, however, failure to provide such Personal Data will have no effect on the possibility to join ANIMA but it will result in the impossibility to inform you about promotional and commercial initiatives and to send you invitations to events, courses, conferences, workshops, webinars and/or newsletters;
We would also like to inform you that if you have given your consent to authorise the Data Controller to pursue the purposes set out in paragraph 3(B) above, you will be free at any time to withdraw your consent and/or object to the processing of your data for the aforementioned purposes and/or methods, by sending in an informal way a clear written communication to this effect to the contact details better specified in paragraph 9 “Contacts to exercise the data subject’s rights and for further information“. With regard to receiving newsletters, you may also simply click on the unsubscribe link indicated at the footer of the email that you will receive.
– the purposes referred to in letter (C) of paragraph 3 (communication of Personal Data to speakers and/or partners of conferences/courses/webinars) is optional; however, failure to provide such data will have no effect on the possibility to join ANIMA but it will result in the impossibility to communicate your Personal Data to speakers and/or partners of webinars/courses.
- Storage of Personal Data
Your Personal Data processed for:
– the management of the association relationship with ANIMA will be processed for the entire duration of the association relationship and thereafter for 10 years, except in the case of any litigation, legal requirements or specific requests from the competent Authorities;
– for marketing purposes for two years from the obtainment of consent and in any case until such consent is withdrawn.
Your Personal Data will not be subject to disclosure or fully-automated processing.
- Personal Data Recipients
Your Personal Data may be communicated to the following entities:
(i) the subjects authorized to the processing by ANIMA to whom instructions have been provided in writing:
– ANIMA employees and collaborators who manage the personal data database, communications and invitations to courses, webinars, conventions and events organized by ANIMA, also with their own speakers and/or partners;
(ii) subjects who provide services for ANIMA and which have been appointed in writing by ANIMA as external data processors:
– companies providing the GoToWebinar (LogMeIn Inc.) and Mailup (MailUp S.p.A) platforms;
– companies belonging to the ANIMA system, as defined above, which provide ANIMA with specific processing services or perform activities connected with, instrumental to or in support of those carried out by ANIMA;
(iii) other third parties who process Personal Data as independent data controllers:
– Public Authorities that have access to Personal Data by virtue of regulatory or administrative measures;
– legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labour, etc., when the communication is necessary or functional to the correct fulfillment of the law obligations;
– speakers and/or partners of events/webinars/conferences/courses in which you participate in order to allow them to pursue their own purposes.
A complete and up-to-date list of all the recipients of your Personal Data may be accessed by making an express request to the e-mail address firstname.lastname@example.org.
- Transfer of Personal Data outside the EU
Your Personal Data will be transferred to countries outside the EU, in particular to the USA. In this regard, ANIMA hereby informs you that said data transfer outside the EU will always take place in accordance with the applicable privacy legislation, namely on the basis of an adequacy decision issued by the European Commission in relation to the extra-EU country to which the Personal Data will be transferred or, in absence, by collecting your consent, when necessary, or by taking any other necessary measures to ensure the security of the personal data being transferred. Such measures include, for example, contractual agreements based on so-called standard contractual clauses as developed by the European Commission.
- Rights of the data subject
The GDPR grants you the exercise of the following specific rights:
- the right to request access to your Personal Data together with indications relating to the purpose of the data processing, the category of the Personal Data processed, the subjects or categories of subjects to whom they have been or will be communicated (with indication on whether such persons are located in third countries or are international organisations), when possible, the retention period of Personal Data or the criteria used to determine such period, the existence of your rights to rectification and/or cancellation of Personal Data, limitation to the processing and objection to it, your right to lodge a complaint with a supervisory authority, the source of the data, the existence and the logic applied in case of an automated decision-making process. If you exercise this right, and unless you indicate otherwise, you will receive an electronic copy of your personal data that is being processed.
- the right to obtain:
- the rectification of your Personal Data, if they are inaccurate or incomplete;
- the erasure of your Personal Data, when one of the grounds set out in Article 17 of the GDPR applies (e.g., your Personal Data are no longer necessary in relation to the purposes for which they were collected, you decide to withdraw your consent to the processing – where this is the legal basis – and there is no other legal ground for the processing, you object to the processing and there are no overriding legitimate interests of the Data Controller, your Personal Data have been unlawfully processed);
- the restriction of processing of your Personal Data: 1) for a period enabling ANIMA to verify the accuracy of your Personal Data (if the accuracy of the personal data is contested by you ); or 2) if the processing of Personal Data is unlawful and you ask, instead of deleting your Personal Data, for the limitation of the related processing, or 3) when ANIMA no longer needs your Personal Data, but they are required by you for the ascertainment, exercise or defense of legal claims, or, finally, 4) for the time necessary to evaluate the possible prevalence of the legitimate reasons of the Data Controller with respect to yours, if you have objected to the processing of your personal data pursuant to point c) below;
- your Personal Data in a structured format, commonly used and readable by an automatic device, also to transmit them to another holder, if the processing is based on consent or on a contract and is done by automated means (so-called right to data portability). If you are interested, you can ask ANIMA to transmit your Personal Data directly to the other controller, if this is technically feasible.
- the right to object to the processing of your Personal Data, if such processing is carried out pursuant to Article 6.1 lett. (e) (i.e. to execute a task carried out in the public interest or in connection with the exercise of public powers vested in the Controller) or lett. (f) (i.e. to pursue a legitimate interest of the Data Controller) of the GDPR, unless there are compelling legitimate reasons for the Data Controller to proceed with the processing, pursuant to Article 21 of the GDPR.
- the right to withdraw your consent at any time, without affecting the lawfulness of the processing of your Personal Data based on consent and carried out before its withdrawal.
- If carried out, you also have the right not to be subject to a decision based solely on the automated processing, including profiling, which produces legal effects concerning you or, similarly, significantly affecting you, while also having the right to obtain human intervention on the part of the data controller, to express your point of view and to contest the decision.
- If you are not satisfied with the processing of your Personal Data carried out by ANIMA, you can lodge a complaint with the Italian Data Protection Authority, following the procedures and the indications published on the official website of this authority (garanteprivacy.it).
- Any corrections or deletions of your Personal Data or processing limitations on the processing performed upon your request – unless this proves impossible or involves a disproportionate effort – will be communicated by ANIMA to each of the recipients to whom your Personal Data may have been transmitted, in compliance with the present notice.
The exercise of the preceding rights is not subject to any form and is free of charge. ANIMA can only ask you to verify your identity before undertaking further actions following your request.
- Contacts to exercise the data subject’s rights and for further information
To exercise your rights and/or to obtain any information regarding this privacy notice, you can send a written communication to: ANIMA Federazione delle Associazioni Nazionali dell’Industria Meccanica Varia ed Affine with registered office in Milan, Via Scarsellini 13 (20161) or an e-mail to: email@example.com.