Privacy Policy

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Information on personal data processing in accordance with Article 13 of EU Regulation 2016/679 (“GDPR”)

Dear User,

We inform you that the personal data you provide in the context of subscribing to the nurtureme service (“Newsletter” or “Service”) and for use of the Service will be processed by Diennea S.r.l., with registered office in Faenza (48018 - RA), Viale G. Marconi n. 30/14, VAT Identification number 02243600398, as Data Controller (hereinafter “Diennea” or the “Data Controller”). Such processing shall follow the principles of correctness, lawfulness, transparency and will safeguard your confidentiality and your rights.

This document has been written in order to allow you to understand how your personal information will be processed.


INDEX

1. Data Controller. Data Protection Officer (DPO)
2. Personal Data processed
        a. Newsletter subscription data
        b. Data generated using the Service
        c. Data provided in online forms
3. Purposes of processing
4. Grounds for processing and mandatory / discretionary nature of processing
5. Recipients of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Your rights


1. Data Controller. Data Protection Officer (DPO)

Diennea, as identified above, will process your personal data as Data Controller.
The Data Controller’s organization has a designated Data Protection Officer (DPO). It is possible to contact the Data Protection Officer by writing to: dpoATdiennea.com.


2. Personal Data processed

a. Newsletter subscription data

When you subscribe to the Newsletter, Diennea may process information related to you as an individual such as your name, surname, email address, online ID, the name of your company or the company you work for.

b. Data generated using the Service

Diennea will process further data generated by the use of the Service as follows:

a) in order to send you the Newsletter which, from time to time, will show you the content based on the interest you have expressed both during subscription and consultation phases of the Newsletter, we inform you that the Data Controller will collect and analyse data generated in your consultation of the newsletter articles by the analysis of the articles/texts/contents you consult (“clicks”).
Through the analysis of the clicks generated from the consultation of articles/news, we will be able to show you Newsletter content according to the interests you have expressed over time and offer a value-added service by arranging the individual articles and contributions based on your reading preferences. Only with the analysis of your clicks, can our Newsletter give immediate prominence to the news that interests you most;

b) the Data Controller collects data generated by the opening of the Newsletter and statistical events of your usage of the Service that are analyzed in order to evaluate Newsletter deliverability, to ensure the quality the Service and to prevent or correct malfunctions of the Service and illicit or non-compliant use.

c. Data provided in online forms

This document is intented also for the processing of data you voluntarily provide in the forms of the Service that you can freely fill in. In such situations, Diennea asks that you do not disclose Personal Data which may fall under the category of personal data referred to in Article 9 of the GDPR (“[…] data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation”) or other personal data or information, unless you consider this to be strictly necessary. If you provide us such information and data which are not necessary or relevant to the Service use or your request, we inform you that Diennea will proceed to their immediate deletion.


3. Purposes of processing

Diennea intends to process your Personal Data for the following purposes:

1) to send you the Newsletter, which will allow you to receive updates on the main news published on international multichannel marketing issues, according to your choices and reading preferences. Therefore, your personal data, including reading clicks, will be processed to provide you with the Service you requested. We remind you that at any time you can suspend receipt of the Newsletter and revoke the Service through the “Unsubscribe” link inserted in the footer of each email;

2) to fulfill the obligations provided for by law, regulations, EU legislation, or requests from competent Authorities;

3) to ensure the quality of the Service, by preventing or correcting failures, illicit use or misuse of the Service.


4. Grounds for processing and mandatory / discretionary nature of processing

The legal basis for the processing of Personal Data for the purposes referred to in aforementioned Section 3 are as follows:

- to provide you the Service (see point no. 1), Section 3. Purposes of processing), the legal basis is Article 6(1)(b) of the GDPR because the processing is necessary to fulfill your request (“[...] processing is necessary for 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”). The analysis of data generated by the use of the Service (clicks) to arrange content according to your reading preference is based on this same legal basis, given that our Newsletter is characterized by this functionality, which gives immediate emphasis to the news that most interest you (see letter a) of Paragraph Data generated using the Service). The provision of Personal Data for this purpose is optional. However, failure to provide your Personal Data would imply the inability for Diennea to send you the Newsletter;

- to fulfill legal obligations (see point no. 2), Section 3. Purposes of processing) is Article 6 (1) (c) of the GDPR (“[...] processing is necessary for compliance with a legal obligation to which the controller is subject”), because the processing is necessary for Diennea to fulfill legal obligations or to comply with requests made by Authorities. Such processing may involve the retention and the disclosure of your Personal Data to the Authorities;

- to ensure the quality and the smooth functioning of the Service (see point no. 3), Section 3. Purposes of processing and letter b) of Paragraph Data generated using the Service) is Article 6 (1) (f) of the GDPR, the legitimate interest of Diennea (“[…] processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject”). The provision of Personal Data for this purpose is optional. However, failure to provide your Personal Data would imply the inability to provide the Service.


5. Recipients of Personal Data

Your Personal Data may be shared for the purposes mentioned above with:
- subjects, bodies or authorities in order to disclose your Personal Data in accordance with the provisions of law or under the orders of the authorities;
- persons authorised by Diennea to process Personal Data required for carrying out activities strictly related to the provision of the Newsletter, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality (for example Diennea’ employees);
- subjects typically acting as data processors, such as suppliers with whom it is necessary to interact for the provision of services (for example, hosting providers) or suppliers delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communications networks).


6. Trasfers of Personal Data

We inform you that the Data Controller will not transfer your Personal Data outside the European Economic Area.


7. Retention of Personal Data

Personal Data processed to send you the Newsletter will be retained for the time necessary to provide our Service; in any case, as the Personal Data are processed for the provision of the Service, Diennea will retain the Personal Data for the period allowed by Italian law to protect its interests (art. 2946 and ensuing articles of the Italian Civil Code) in the case of claims.

The Personal Data processed for the fulfillment of legal obligations will be retained until the time provided by the specific obligations or applicable rules of law or the time prescribed at the request of the Authority.

Data generated from the opening of each Newsletter will be retained for 545 days.


8. Your rights

Under Articles 15 and following of the GDPR, you, as a data subject, are entitled to request from Diennea, at any time, access to your Personal Data, the correction and erasure of your Personal Data, as well as to object to its processing according to Article 21 of the GDPR. You are also entitled to request the restriction of the processing of your Personal Data (in the cases set out in Article 18 of the GDPR), and to obtain the Personal Data you have provided to Diennea in a structured, commonly used and machine-readable format (in the cases set out in Article 20 of the GDPR).

Requests should be made in writing to privacyATdiennea.com or to the registered office of the Data Controller.

In any case, you are entitled to file a complaint with the competent supervisory authority (the Italian Data Protection Authority), pursuant to Article 77 of the GDPR, if you believe that the processing of your data violates applicable law.

If you wish to terminate the provision of the Service and no longer receive the Newsletter, you can use the “Unsubscribe” link found in the footer of each email.


Diennea SRL · IT02243600398 · Viale Marconi 30/14 · 48018 Faenza (RA) · Italy · Privacy Policy · Terms of Use