Privacy Policy

Privacy Policy — Colombo & Partners

COLOMBO AND PARTNERS SRL — VAT no. 10426020961

This notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR) and Article 13 of Legislative Decree no. 196/2003 (the Italian Personal Data Protection Code) to users accessing the website www.colomboandpartners.it, and covers all personal data processed in the manner described below.

THE DATA CONTROLLER

The Data Controller for the personal data collected is Colombo&Partners SRL, VAT no. 10426020961.

DATA COLLECTED

This website does not collect personal identity data.

The personal data processed is either provided directly by the data subject or collected automatically.

Data provided directly by the data subject means any personal data supplied to the Data Controller by any means, provided directly by the data subject by email only. Specifically, the following personal data is collected and processed:

– data collected: first name, surname, email address, telephone number

Data collected automatically consists of browsing data. Although this data is not collected in order to be associated with the user’s identity, it may indirectly allow identification through processing and correlation with data held by the Data Controller. Specifically:

– data collected: IP address and browser. In no case does this website disclose such information to third parties; it is neither analysed nor processed in any way.

Following the sending of a newsletter, the platform used is able to detect the opening of a message and the clicks made within the newsletter itself, together with details relating to the IP address and the browser/device used. The collection of this data is essential to the operation of the implied renewal of processing (see the section “Methods of Processing”) and forms an integral part of the sending platform’s functionality.

LEGAL BASIS AND PURPOSES OF PROCESSING

Data is processed exclusively for the purposes for which it is collected, as set out below.

We use the data provided by data subjects for the following purposes:

Solely for the purpose of providing information about the services offered by this company.
Only where the user has given specific consent, to enable participation in further specific services, such as the sending of future informational and promotional communications by email or by electronic means.

The provision of the data listed in the “Data Collected” section for the purposes referred to above is mandatory in order to allow the user to access the service. For this reason, consent is mandatory, and any refusal to allow processing, or any failure to provide the data or provision of inaccurate or incomplete data, may result in the service not being properly delivered.

The provision of data for the purpose of sending newsletters for promotional, informational or research purposes is optional, and any refusal to give the relevant consent to processing will mean that the data subject cannot be kept informed of commercial initiatives and/or promotional campaigns, cannot receive offers or other promotional material, and cannot be sent personalised offers. Colombo&Partners does not disclose any user information to third parties without the user’s consent, except where required by law.

The dissemination and transfer of data outside the EU is excluded in all cases.

WITHDRAWAL OF CONSENT

The data subject may withdraw consent to receiving promotional and commercial communications with immediate effect, by sending a request to info@colomboandpartners.it

METHODS OF PROCESSING

Personal data is processed by automated means for no longer than is necessary to achieve the purposes for which it was collected. In all cases, the data retained is reviewed annually so that any data considered obsolete can be deleted, unless retention is required by law.

Data is generally processed at the offices of Colombo & Partners by staff or external collaborators duly designated as data processors. A complete list of the data processors and of the persons authorised to process personal data may be obtained by sending a request to info@colomboandpartners.it

Subscription and the related processing remain valid until the user unsubscribes, using the link included in every email, or after 12 months from the last communication for which there is evidence of direct interaction (click, opening, reply).

Specific security measures are in place to prevent data loss, unlawful or improper use, and unauthorised access.

RIGHTS OF THE DATA SUBJECT

Pursuant to Article 7 of the Italian Personal Data Protection Code and Article 13 of the GDPR, every user has the right to obtain confirmation as to whether or not their personal data exists, even if not yet recorded, and to have that data communicated in an intelligible form.

In particular, the data subject has the right to obtain from info@colomboandpartners.it information as to:

the origin of the personal data;
the purposes and methods of processing;
the logic applied where processing is carried out by electronic or automated means;
the identifying details of the Data Controller, the data processors and the designated representative;
the parties or categories of parties to whom the data may be disclosed, or who may become aware of it in their capacity as designated representative within the territory of the State, as data processors or as authorised persons.

The data subject also has the right to obtain from info@colomboandpartners.it

the updating, rectification or, where applicable, integration of their data;
the erasure, anonymisation or blocking of any data processed unlawfully;
access to their data, that is, confirmation as to whether or not personal data concerning them is being processed;
restriction of processing;
data portability, that is, the right to receive the personal data concerning them in a structured format;
the right to lodge a complaint with the supervisory authority.

Finally, the data subject has the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even where the data is relevant to the purpose of collection. In particular, the data subject has the right to object to the processing of personal data concerning them for the purpose of sending advertising or direct marketing material, or for the purpose of carrying out market research or commercial communication. Requests relating to the points above should be sent by email to info@colomboandpartners.it

UPDATES AND CHANGES

Colombo & Partners reserves the right to amend, supplement or periodically update this notice in accordance with applicable legislation or with measures adopted by the Italian Data Protection Authority (Garante per la protezione dei dati personali).

Any such changes or additions will be brought to the attention of data subjects by means of a link to the Privacy Policy page on the website, and will be communicated directly to data subjects by email.

We invite users to review the Privacy Policy regularly in order to check the current version of the notice and to decide whether or not to continue using the services offered.