ICTLC S.p.A. with registered offices in Via Borgonuovo, 12 – 20121 Milan (Italy) (hereinafter only “ICTLC”), in its capacity as data controller regarding the processing of personal data pursuant to the Italian applicable law on data protection pro tempore in force (“Italian Data Protection Law”) and the EU Regulation 679/2016 – General Data Protection Regulation (“GDPR”) (hereinafter Italian Data Protection Law and GDPR are collectively referred to as “Applicable Law”) recognises the importance of personal data protection and considers that preserving the confidentiality of your personal data is one of the main objectives of its activity.
ICTLC informs you that processing of your data will be carried out in accordance with the principles of, lawfulness, fairness, transparency, accuracy, purpose and storage limitations, data minimisation, integrity and confidentiality. Your personal data will be processed in accordance with the legislative provisions of the Applicable Law and of the confidentiality obligations included therein.
Pursuant to the Applicable Law, the data controller of the processing activates carried out through the Website is ICTLC as defined above. ICTLC has appointed a data protection officer (“DPO”) who is freely contactable for any information relating to the processing of personal data by ICTLC (e.g., the list of data processors) at the following address: firstname.lastname@example.org.
“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, ICTLC collects 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 ICTLC 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 voluntarily basis
By means of the Website you may voluntarily provide Personal data such as name, e-mail address for subscribing the on-demand service “ICT Insider” or to contact ICTLC via the “Contact Us” form. ICTLC will process these data in accordance with the Applicable Law and on the presumption 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
ICTLC collects Personal Data using cookies. You may find further information on the use of cookie and similar technologies here.
The Personal Data that you provide by using the Website will be processed by ICTLC for the following purposes:
a. Purposes related to the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g., contact request made by using the “Contact Us” form available on the Website);
b. 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;
c. Purposes related to the compliance with a legal obligation to which ICTLC is subject;
d. Purposes necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request that does not require you prior consent under the Applicable Law.
The purpose referred to in point b) does not imply the processing of Personal Data, whilst the processing for the purpose referred to in points c) and d) constitutes a legitimate processing of Personal Data within the meaning of the Applicable Law because, once the Personal Data have been provided, the processing is indeed necessary to comply with a legal obligation to which ICTLC is subject or for the establishment, exercise or defence of legal claims.
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.
Your Personal Data may be disclosed, in close relation to the purposes specified above in section 3, only to:
a. subjects necessary for order fulfilment of the services offered through the Website e.g., sending e-mails and analysing data, which typically process Personal Data on behalf of ICTLC as data processors.
b. persons authorised by ICTLC to process Personal Data, that are committed to/ or under an appropriate statutory obligation of confidentiality (e.g., employees and lawyers of ICTLC) (a. and b. are hereinafter collectively referred to as “Recipients”);
c. law enforcement agencies and public authorities when so required by the Applicable Law.
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.
ICTLC will process your Personal Data only for the duration necessary to achieve the purposes described in section 3. Apart from the above, ICTLC will retain your Personal Data for a period of time necessary or permitted to comply with the Applicable Law (Artt.2946 and 2947(1)(3) of the Italian Civil Code). Further information regarding the period of retention of Personal Data and the criteria used to determine such period may be required to the DPO.
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: email@example.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.