Last Change: 20th June 2024

Data protection is a very serious matter for us, so we would like to inform You about the way in which your data is processed and the rights You can exercise under current data protection legislation, in particular EU Regulation 2016/679 (hereinafter also: "GDPR"). 

1. Data controller

Ipazia S.p.A.

Piazza Pio XI, n. 1

20123 – Milan (MI)

E-mail contact: info@ipazia.com

Data Protection Officer (DPO)

Avv. Vera Cantoni,

Via F. Turati n. 26, 20121, Milano (MI)

E-mail contact: dpo@ipazia.com

2. Categories of processed personal data

The categories of 'personal data' (ex-Art. 4.1 of the GDPR) processed by the Data Controller may include, but are not limited to:

• Biographical and identifying data (e.g. first name, surname, etc.);

• Contact data (address, e-mail address, IP address, telephone number, social network accounts, etc.).

• Data on applications and requests processed.

3. Purposes and legal bases of personal data processing

3.1 Purposes covered by the data subject's consent (ex-Art. 6(1)(a) GDPR)

Personal data may also be processed for certain purposes for which the data subject has given his or her consent.

a. Responding to requests or queries submitted and sent to the contacts indicated on this site, in order to receive information also about our products and services, as well as sending quotations.

The retention period of personal data for the purposes of this section is:

For the purpose: a, until the request is processed.

4. Recipients or categories of recipients of personal data (ex-Art. 13(1)(e) of the GDPR) *

Within the scope of the above-mentioned purposes, the Data Controller may communicate your data to

• Controller's own internal offices and functions;

• Companies and professionals providing IT services, including electronic data processing, software management, and IT consulting;

• Hosting companies.

* More information on the Recipients (ex-art. 4.9 of the GDPR) is available from the Data Controller at the above-mentioned addresses.

5. Recipients or categories of recipients of personal data (ex-Art. 13(1)(f) of the GDPR)* and transfer of data to non-EU countries

The Data Controller informs You that it has no intention of transferring your data to countries outside the EU and EEA for the above-mentioned purposes.

6. Rights of the data subject

The data subject, in relation to the personal data covered by this information notice, is entitled to exercise the rights provided for in the EU Regulation below:

• the data subject's right of access [Art. 15 of the EU Regulation] (consisting in the possibility of being informed about the processing carried out on one's personal data and possibly receiving a copy of it);

• Right to rectification of one's personal data [Art. 16 of the EU Regulation] (the data subject has the right to rectification of inaccurate personal data concerning him/her);

• right to erasure of one's own personal data without undue delay ('right to be forgotten') [Art. 17 of the EU Regulation] (the data subject has, as well as will have, the right to erasure of his or her own data);

• the right to limitation of the processing of one's personal data in the cases provided for in Article 18 of the EU Regulation, including in the case of unlawful processing or contestation of the accuracy of personal data by the data subject [Article 18 of the EU Regulation];

• right to data portability [Art. 20 of the EU Regulation], (the data subject may request his or her personal data in a structured format in order to transmit them to another data controller, in the cases provided for in the same article);

• Right to object to the processing of one's own personal data [Art. 21 of the EU Regulation] (the data subject has, as he or she will have, the right to object to the processing of his or her own personal data in the cases provided for and regulated by Art. 21 of the EU Regulation);

• right not to be subjected to automated decision-making processes [Art. 22 of the EU Regulation] (the data subject has, as will have, the right not to be subjected to a decision based solely on automated processing).

With regard to the purposes for which consent is required, the Data Subject may revoke his or her consent at any time and the effects shall run from the time of revocation, subject to the time limits provided for by law. In general terms, revocation of consent has effect only for the future.

The aforementioned rights may be exercised in accordance with the EU Regulation by sending an e-mail to the address given in section 1.

Ipazia S.p.A., in compliance with art. 19 of the EU Regulation, will inform the recipients to whom the personal data have been communicated of any rectification, cancellation or restriction of processing requested, where possible.

7. Right to lodge a complaint (ex-Art. 13(2)(d) GDPR)

If the data subject considers that his or her rights have been compromised, he or she has the right to lodge a complaint with the Supervisory Authority. For further information on your rights and how to exercise them, please visit http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or send written notice to the Data Protection Authority.

8. Possible consequence of non-disclosure of data and nature of the provision of data (pursuant to Article 13(2)(e) of the GDPR)

8.1 In the case of the fulfilment of any legal or contractual obligations

For the sake of completeness, despite the fact that there are no such purposes on such legal basis, we inform You that if the processing purposes have a legal or contractual (or even pre-contractual) obligation as a legal basis, the data subject must necessarily provide the requested data.

Failure to do so will make it impossible for the Controller to pursue the specific processing purposes.

8.2 In case of consent of the data subject

We inform You that the above-mentioned purposes have consent as their legal basis and that, with regard to these purposes, the Data Subject may revoke his or her consent at any time and the effects will be effective from the time of revocation, subject to the time limits provided for by law. In general terms, withdrawal of consent has effect only for the future. Therefore, the processing that was carried out before the revocation of consent will not be affected and will retain its legitimacy.

Failure to give consent (or withdrawal of consent) may not guarantee the full provision of services or activities, with reference to the individual purposes for which consent is withheld and shall not prejudice or prevent other purposes (and activities related thereto) not expressly involved or affected by the withholding of consent or not based on that legal basis.

Please note that with reference to the request for information, while consent to the processing of personal data remains free and optional, it is necessary for the request to be processed. Therefore, the sending of the request or equivalent manifestation of will shall be considered as the granting of consent, which shall always be revocable with the consequences outlined above.

When the data are no longer needed, they are routinely deleted; if deletion is impossible or only possible with disproportionate effort due to a particular storage method, the data may not be processed and must be stored in inaccessible areas.

9. Existence of automated decision-making (including profiling)

The use of purely automated decision-making processes as detailed in Article 22 of the GDPR is currently excluded. Should it be decided in the future to establish such processes for individual cases, the data subject will be notified separately if this is required by law or updated in this policy.

10. Processing methods

Personal data shall be processed in paper, computerized and telematic form and entered in the relevant databases, which may be accessed and thus become known to the employees expressly designated by the Data Controller as Persons in charge of and authorized to process personal data, who may carry out consultation, use, processing, comparison and any other appropriate operation, including automated operations, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of the data as well as their accuracy, updating and relevance to the stated purposes.

Processing of data useful for navigation purposes

The computer systems and software procedures used to operate this website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected in order to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.

The information that may be collected includes IP addresses, the type of browser or operating system used, URI (uniform resource identifier) notation addresses, the domain name and addresses of the websites from which the request was made (referring/exit pages), the time the request was made to the server, the method used and information about the response obtained, further information about the user's navigation on the site (see also the section on cookies) and other parameters relating to the user's operating system and computer environment.

This same data could also be used to identify and ascertain liability in the event of any computer offences against the site.

Notice concerning children under 14 years of age

Children under the age of 14 may not provide personal data. Ipazia S.p.A. will not be in any way responsible for any collection of personal data, or false declarations, provided by minors, and in any case, should it be found to be used, Ipazia S.p.A. will facilitate the right of access and cancellation forwarded by the legal guardian or those exercising parental responsibility.

Changes and updates

This notice shows the date of its last update in its header. Ipazia S.p.A. may also make changes and/or additions to this privacy policy as a consequence of any subsequent regulatory changes and/or additions.

Legal references on the rights of the data subject

Article 15

The data subject's right of access

1. L'interessato ha il diritto di ottenere dal titolare del trattamento la conferma che sia o meno in corso un trattamento di dati personali che lo riguardano e in tal caso, di ottenere l'accesso ai dati personali e alle seguenti informazioni:

1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and to the following information:

(a) the purposes of the processing;

(b) the categories of personal data concerned;

(c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organizations;

(d) where possible, the expected period of retention of personal data or, if this is not possible, the criteria used to determine that period;

(e) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data concerning him or her or to object to the processing of personal data concerning him or her;

(f) the right to lodge a complaint with a supervisory authority;

(g) where the data are not collected from the data subject, all available information on their origin;

(h) the existence of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and, at least in such cases, meaningful information on the logic used, as well as the importance of such processing for the data subject and the envisaged consequences thereof.

2. Where personal data are transferred to a third country or an international organization, the data subject shall have the right to be informed of the existence of appropriate safeguards within the meaning of Article 46 relating to the transfer.

The controller shall provide a copy of the personal data undergoing processing. Where further copies are requested by the data subject, the controller may charge a reasonable fee based on administrative costs. If the data subject makes the request by electronic means, and unless otherwise specified by the data subject, the information shall be provided in a commonly used electronic format.

4. The right to obtain a copy referred to in paragraph 3 shall not infringe the rights and freedoms of others.

Article 16

Right of rectification

The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him/her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration.

Article 17

Right to erasure ('right to be forgotten')

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him/her that

concern them without undue delay, and the controller is obliged to erase the personal data without undue delay, if one of the following grounds exists:

(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a) and if there is no other legal basis for the processing;

(c) the data subject objects to the processing pursuant to Article 21(1) and there is no overriding legitimate ground for processing, or objects to the processing pursuant to Article 21(2);

(d) personal data have been unlawfully processed;

(e) the personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;

(f) the personal data were collected in connection with the offering of information society services as referred to in Article 8(1).

2. Where the controller has made personal data public and is obliged under paragraph 1 to erase them, the controller shall, taking into account available technology and the costs of implementation, take reasonable steps, including technical measures, to inform the controllers who are processing the personal data of the data subject's request to erase any link, copy or reproduction of his or her personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that the processing is necessary:

(a) for the exercise of the right to freedom of expression and information;

(b) for compliance with a legal obligation to which the processing is subject under Union or Member State law or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) for reasons of public interest in the field of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);

(d) for archiving in the public interest, scientific or historical research or statistical purposes in accordance with Article 89(1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously jeopardize the attainment of the objectives of such processing; or

(e) for the establishment, exercise or defense of legal claims.

Article 18

Right of restriction of processing

1. The data subject shall have the right to obtain from the controller the restriction of processing when one of the following cases occurs:

(a) the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such personal data;

b) the processing is unlawful and the data subject objects to the deletion of the personal data and requests instead that their use be restricted;

(c) although the data controller no longer needs them for the purposes of processing, the personal data are necessary for the establishment, exercise or defense of legal claims by the data subject;

(d) the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.

2. Where processing is restricted pursuant to paragraph 1, such personal data shall, except for storage, only be processed with the consent of the data subject or for the establishment, exercise or defense of legal claims or the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State.

3. A data subject who has obtained a restriction of processing pursuant to paragraph 1 shall be informed by the controller before that restriction is lifted.

Article 19

Obligation to notify in case of rectification or erasure of personal data or restriction of processing

The controller shall communicate to each of the recipients to whom the personal data have been transmitted any rectification or erasure or restriction of processing carried out pursuant to Article 16, Article 17(1) and Article 18, unless this proves impossible or involves a disproportionate effort. The controller shall inform the data subject of such recipients if the data subject so requests.

Article 20

Right to data portability

1. The data subject shall have the right to receive in a structured, commonly used and machine-readable format the personal data concerning him/her that he/she has provided to a data controller and shall have the right to have those data transmitted to another data controller without hindrance by the data controller to whom he/she has provided them if:

(a) processing is based on consent within the meaning of Article 6(1)(a) or Article 9(2)(a) or on a contract within the meaning of Article 6(1)(b): and

(b) the processing is carried out by automated means.

2. When exercising his or her data portability rights pursuant to paragraph 1, the data subject shall have the right to obtain the direct transmission of personal data from one controller to another, if technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17, This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right referred to in paragraph 1 shall not infringe the rights and freedoms of others.

Article 21

Right of opposition

1. The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data relating to him or her pursuant to points (e) or (f) of Article 6(1), including profiling on the basis of those provisions, The controller shall refrain from further processing the personal data unless he or she can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him/her carried out for such purposes, including profiling insofar as it is related to such direct marketing.

3. If the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information at the latest at the time of the first communication with the data subject.

5. In the context of the use of information society services and without prejudice to Directive 2002/58/EC, the data subject may exercise his/her right to object by automated means using specific techniques.

6. Where personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1), the data subject shall have the right, on grounds relating to his or her particular situation, to object to the processing of personal data relating to him or her, except where the processing is necessary for the performance of a task carried out in the public interest.

Article 22

Automated decision-making process concerning natural persons, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way.

2. Paragraph 1 shall not apply in the event that the decision:

(a) is necessary for the conclusion or performance of a contract between the data subject and a data controller;

(b) is authorized by Union law or by the law of the Member State to which the data controller is subject, which also lays down appropriate measures to protect the rights, freedoms and legitimate interests of the data subject;

(c) is based on the explicit consent of the data subject.

In the cases referred to in paragraph 2(a) and (c), the data controller shall implement appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least the right to obtain human intervention by the data controller, to express his or her point of view and to contest the decision.

4. The decisions referred to in paragraph 2 shall not be based on the special categories of personal data referred to in Article 9(1), unless Article 9(2)(a) or (g) applies and appropriate measures are in place to protect the rights, freedoms and legitimate interests of the data subject.