Privacy policy

Privacy Policy pursuant to Articles 13 and 14 of Regulation (EU) 2016/679

Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the “Regulation”), CIRCO12 SRL hereby provides its customers, including potential customers, as well as third parties in general (e.g., delegates, legal representatives, etc.) who come into contact with the company on behalf of or under the mandate of customers, including potential customers (the “Data Subjects”), with the information required by applicable regulations regarding the processing of their personal data (“Personal Data”).

1. Data Controller and Data Protection Officer

CIRCO12 SRL (Tax Code - VAT No. 13050630964), with registered office at Via Francesco Melzi d'Eril, 44, 20154 Milan (MI), represented by its legal representative pro tempore, is the entity responsible for processing the Data Subjects’ data and, under the law, is considered the Data Controller of Personal Data. In this capacity, it is responsible for ensuring the implementation of appropriate organizational and technical measures for data protection in compliance with applicable regulations.

CIRCO12 SRL has appointed a Data Protection Officer (DPO), responsible for ensuring compliance with privacy regulations. The DPO can be contacted for any matters related to the processing of Personal Data at the following email address: amministrazione@audant.it.

2. Methods of Collecting Personal Data

The Personal Data processed by the Data Controller may be collected directly from the Data Subject, including through remote communication technologies used by the Data Controller (e.g., websites, smartphone and tablet apps, call centers, etc.).

3. Categories of Processed Personal Data

The Personal Data processed by the Data Controller include, but are not limited to:

i. Browsing data (e.g., IP addresses or domain names of computers used by users connecting to the website, request timestamps, method used to submit requests to the server, numerical codes indicating the response status from the server, and other parameters related to the user’s operating system and browser, logs);
ii. Personal identification data (e.g., name, surname, tax code, address, date and place of birth, nationality);
iii. Contact details (e.g., phone numbers, both landline and mobile, email address);
iv. Profiling and marketing data (e.g., interests and preferences);
v. Other data falling within the above-mentioned categories.

4. Purpose and Legal Basis of Processing

Personal Data, under the specified conditions, will be processed for the following purposes:

Website Registration and Management of Contact Requests and/or Informational Materials

The processing of the Data Subject’s personal data is carried out to facilitate preliminary and subsequent activities related to a website registration request, if applicable, as well as to manage requests for information, contact, and/or the provision of informational materials, and to fulfill any other related obligations.

The legal basis for this processing is the fulfillment of services related to the registration request, information requests, contact requests, and/or the provision of informational materials, as well as compliance with legal obligations.

The provision of data is optional; however, refusal to provide the required data will prevent the Data Controller from fulfilling the requested service.

Contract Execution

Personal Data will be processed for managing the contractual relationship (e.g., invoicing of fees, handling payments or complaints submitted to us) and for providing the requested services available through the website.

The legal basis for this processing is the performance of obligations related to the contractual relationship and compliance with legal obligations.

The provision of data is optional; however, refusal to provide the required data will prevent the Data Controller from fulfilling the requested service.

Compliance with Legal Obligations, Defense of Rights in Judicial or Extrajudicial Proceedings, and Fraud Prevention

Personal Data will be processed to comply with legal obligations, as well as to establish, exercise, or defend the Data Controller’s rights and/or protect itself from third-party claims in judicial or extrajudicial proceedings. Specifically, the Data Controller may process Personal Data to fulfill accounting and tax obligations and comply with judicial authority measures aimed at preventing and prosecuting crimes.

The legal basis for this processing is the pursuit of the Data Controller’s legitimate interest, considering the balance between its rights and those of the Data Subject.

Promotional Activities on Services/Products Similar to Those Purchased

The processing of the Data Subject’s personal data is carried out for sending communications regarding promotions and offers on Services/Products of the Data Controller that are identical or similar to those covered by the existing contract with the Data Subject unless they have objected to such processing initially or in response to subsequent communications.

The legal basis for this processing is the Data Controller’s legitimate interest in promoting products or services that the customer may reasonably be interested in, considering the balance between the rights of both parties.

The Data Subject has the right to object at any time, for reasons related to their particular situation, to the processing of their personal data for this purpose.

Promotional Activities on Services/Products Offered by CIRCO12 SRL

The processing of the Data Subject’s personal data is carried out, subject to specific consent, for sending promotional communications and offers regarding the Data Controller’s Services/Products through traditional means (e.g., postal mail, operator-assisted phone calls) and/or automated methods (e.g., email, SMS, MMS, fax, prerecorded phone calls).

The legal basis for this processing is the Data Subject’s consent, given prior to the processing, which may be freely revoked at any time without affecting the lawfulness of processing carried out before the revocation.

Refusal to provide consent will result in the inability to receive the related services, without any negative consequences on the contractual relationship with the Data Controller.

Marketing Purposes Related to Products or Services of CIRCO12 SRL’s Partners

The processing of the Data Subject’s personal data is carried out, subject to specific consent, for sending promotional communications and offers regarding Services/Products of CIRCO12 SRL’s commercial partners through traditional means (e.g., postal mail, operator-assisted phone calls) and/or automated methods (e.g., email, SMS, MMS, prerecorded phone calls).

Refusal to provide consent will result in the inability to receive the related services, without any negative consequences on the contractual relationship with the Data Controller.

Profiling

The processing of Personal Data, including location data and socio-demographic data acquired during the provision of electronic communication services and from public sources, is carried out, subject to specific consent, for profiling purposes. This includes analyzing transmitted data and purchased Services/Products to offer advertisements and/or commercial proposals aligned with the preferences expressed by users. This activity will be conducted in an aggregated and anonymized manner through the implementation of data analysis models using statistical algorithms, predictive models, and data aggregation, strictly for the necessary time required for the pursued purposes, considering the nature of the marketed goods or provided services.

In any case, Personal Data will not be subject to decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the Data Subject in a similar manner.

Refusal to provide consent will result in the inability to receive the related services, without any negative consequences on the contractual relationship with the Data Controller.

5. Recipients of Personal Data

The collected personal data may be disclosed to entities that, depending on the case, will act as independent Data Controllers or Data Processors for the aforementioned purposes, in compliance with legal, regulatory, and/or European Union obligations, or due to a legitimate interest.

In particular, Personal Data may be made available to:

Entities responsible for performing activities related and instrumental to the processing (such as data storage service providers, IT service providers, social media management service providers, marketing companies, insurance companies, and banking institutions);
Commercial partners of CIRCO12 SRL;
Public administrations, authorities, and other entities in compliance with legal obligations.

Personal Data will not be disseminated (made available to unspecified parties).

6. Transfer of Data to Third Countries

The Data Subject’s Personal Data is stored in archives located within the European Union. If necessary to pursue the declared purposes, the Data Subject’s information may be transferred abroad to countries or organizations outside the European Union that ensure an adequate level of personal data protection as determined by a European Commission decision or, in any case, based on other appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission or the Data Subject’s consent.

The Data Subject has the right to obtain a copy of any data transferred abroad and a list of the countries/organizations to which the data has been transferred by writing to amministrazione@audant.it.

7. Data Retention Period

Personal Data will be stored in a form that allows identification of the Data Subject for no longer than necessary to achieve the purposes for which it was collected, taking into account the applicable laws governing the activities and sectors in which the Data Controller operates. Once these periods have expired, the data will be deleted or anonymized, unless further retention is necessary to comply with legal obligations (e.g., tax and accounting obligations) that persist even after the contract’s termination (Article 2220 of the Italian Civil Code) or to fulfill orders from Public Authorities and/or Supervisory Bodies.

The duration of cookies used on the website is available in the dedicated Cookie Policy.

In the case of litigation, the retention period mentioned above may be extended for up to 10 years from the settlement of the dispute.

8. Processing

Methods Processing will be carried out by authorized personnel who need access to the data in order to perform their duties. It will be conducted using electronic tools, in accordance with principles of lawfulness and fairness, ensuring the confidentiality and rights of the Data Subject at all times, in full compliance with the applicable regulations.

Profiling related to marketing (analysis of consumption habits and preferences) is performed through an automated process designed to study and analyze behavioral profiles and key characteristics of the customer base, with the aim of optimizing promotional activities for products and services.

9. Rights of the Data Subject

The Data Subject has the right to request from the Data Controller:

i. confirmation of whether or not their Personal Data is being processed, and if so, to obtain access to it (right of access);
ii. correction of inaccurate Personal Data or the completion of incomplete Personal Data (right of rectification);
iii. deletion of their Personal Data if one of the reasons provided by the Privacy Regulation applies (right to erasure);
iv. restriction of processing of their Personal Data in specific cases as outlined by the Privacy Regulation (right to restriction);
v. receipt of their Personal Data in a structured, commonly used, and machine-readable format, as provided to the Data Controller, and to transmit such data to another Data Controller (right to data portability);
vi. object, at any time, in whole or in part, to the processing carried out for the legitimate interest of the Data Controller and for marketing and profiling purposes (right to object);
vii. withdraw any given consent to the processing of Personal Data at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

Consent given for marketing activities via automated contact methods (e.g., SMS, MMS, fax, phone calls, emails, web applications) also extends to traditional contact methods (e.g., postal mail or phone calls with an operator). Similarly, opposition to marketing activities via automated contact methods extends to traditional contact methods. The Data Subject has the right to give consent or exercise the right to object with respect to one of the two marketing methods.

To exercise their rights, the Data Subject may send an email to amministrazione@audant.it or a written communication to the Data Controller at the registered office of CIRCO12 SRL.

The Data Subject also has the right to lodge a complaint with the competent supervisory authority in Italy (the Italian Data Protection Authority) or with the authority in the EU Member State where the violation occurred, as provided by Article 77 of the Regulation. Additionally, the Data Subject may seek judicial remedies as per Articles 78 and 79 of the Regulation.

10. Cookies

The information regarding the use of cookies can be found at the following link.