Data Controller
Fincons S.p.A., is the Data Controller pursuant to art. 24 of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, “Regulation”). In accordance with art. 13 of the Regulation, Fincons let data subject know how personal information is handled for marketing purposes.
Personal data collected
The main types of Personal data we collect are:
- Identification data (e.g. first name and last name, telephone number, e-mail address, etc.);
- Additional Information that data subject directly provides, relating to an existing legal relationships.
Following the sending of a newsletter or other promotional communication our system notifies us if the e-mail has been opened and detects technical details of IP address and browsers and devices used.
Data Controller details
Company name: Fincons S.p.A.
Registered office: Milano (MI), Corso Magenta, n. 56
Operational headquarters: Vimercate (MI), via Torri Bianche, n. 10
Tel: +(39).039.657081
E-mail: privacy@finconsgroup.com
Data Protection Officer (DPO)
Address: Vimercate (MI), via Torri Bianche, n. 10
E-mail: dpofincons@finconsgroup.com
Purposes of the processing of Personal Data
The legal basis for the processing of Personal Data is the execution of a contract, as well as the data subjects’ consent. Any refusal to provide the data for marketing purposes will result in the impossibility for the data subjects to be informed about marketing and promo-advertising initiatives from Fincons and to receive newsletters and other commercial communications of interest.
Upon data subjects’ prior express consent and until that consent is withdrawn, any personal data that may be included in a customer relationship management system (CRM), may also be processed for marketing purposes, in other words, by way of example, for the sending of promotional and commercial communications related to services offered by FINCONS, as notification of events, both by automated means of contact (e.g. SMS, fax, e-mail and web applications) and by traditional means of contact (such as telephone calls with an agent and traditional mail).
With regard to the e-mails that will be sent, the following actions performed by data subjects shall be tracked:
- actual receipt of the e-mail;
- opening of the e-mail;
- any action carried out (such as clicking on a link contained in the e-mail).
*Recipients of Personal data
Data subjects’ Personal data may be shared, for the marketing purposes referred to above, within the organization with the relevant offices entrusted with the execution of certain processing activities, and with contractors** appointed as Data Processors.
(**) the list of external personal data processors/receipients is available at the above mentioned Controller’s Operational headquarters.
Data transfer outside the EU
Some of data subjects’ personal information may be shared with recipients based outside the European Economic Area. In particular, personal data may be shared with Fincons Group companies, such as Fincons Group AG, Fincons Consulting LTD, Fincons.FR SAS, Fincons.DE GmbH, Fincons.BE S.r.l. and Fincons US, Inc.
With specific regard to Switzerland, United Kingdom, United States of America and other countries where Fincons Group companies are situated, Fincons ensures that the processing of their personal data takes place in compliance with the Regulation. Indeed, transfer can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis.
Data retention
Any data provided to subscribe to our newsletter or to receive commercial communications of interest will be held and processed by us for up to 24 months; however, before data deletion, a notification will be sent to data subjects by e-mail.
Data subjects’ rights
Data subjects can always contact Fincons by e-mail at privacy@finconsgroup.com in order to enforce their rights, pursuant to art. 15 of the Regulation, in particular: right to access and obtain copy of their personal information, right to correct their personal information, right to be forgotten /have data deleted.
Data subjects can always unsubscribe from our contact list by clicking “Unsubscribe”.
If data subjects believe that the processing of their personal data is contrary to the law, they are always entitled to propose a complaint to the competent Supervisory Authority (Data Protection Board).
Link to Italian Authority website:
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524
Processing modalities
Data subjects’ data are subject to both paper and electronic processing and will be stored in our database. The processing of personal data will be carried out by relevant processors appointed by the Controller for the purpose of collection, registration, organization, conservation, cancellation and destruction, and through appropriate tools in such a way to ensure safety and confidentiality, as well as correctness and compliance.