Information on the processing of personal data pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
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Effective from 19/09/2023

FOREWORD
This notice takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree no. 196 of 30 June 2003). The document has also been drafted on the basis of the Privacy Guarantor's Guidelines (especially the Guidelines for combating spam issued by the Privacy Guarantor on 4 July 2013).

Holder of the Treatment: IN ART S.R.L.
Site to which this privacy policy refers: https://www.inartmanagement.com/ (Site).
The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, you can send any request for information directly to the Data Controller.

GENERAL INFORMATION
This document describes how the Data Controller processes your personal data provided on the Site.
The main processing of your personal data is described below. In particular, the legal basis of the processing, whether the provision of personal data is obligatory and the consequences of not providing personal data are explained. In order to better describe your rights, we have specified if and when a certain processing of personal data does not take place.

Registration on the Site‍
The Site does not offer the possibility of registration. Therefore, the Controller does not process your personal data for this purpose.

Purchases on the Site‍
It is not possible to make purchases on the Site. Therefore, your personal data will not be processed for this purpose.The Data Controller does not process your data in order to send you "reminder" emails about purchases of products and/or services of the Data Controller.

Responding to your requests
Your data will be processed to respond to your requests for information. Providing it is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user's interest in receiving replies to communications sent to the Data Controller.

Generic marketing
Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis for this processing is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, and will also make it impossible for the Data Controller to conduct market surveys, including those aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to the e-mail address you provide on the Site.

Profiling
Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of your purchases, in order to send you advertising material and/or newsletters relating to its own products or those of third parties, of your specific interest. The legal basis for this processing is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to draw up your commercial profile, by surveying your purchasing choices and habits, as well as to send you advertising material relating to products of the Data Controller and/or third parties that are of specific interest to you. These communications will be sent to the e-mail address you provide on the Site.

Transfer of data‍
The Data Controller does not transfer your personal data to third parties.

Geolocation
The Site does not implement geolocation tools for the user's IP address.

Curriculum Vitae
It is not possible to send curriculum vitae through the Site. Therefore, your data will not be processed for these purposes.

Communication of personal data
In the ordinary course of its business, the Controller may communicate your personal data to certain categories of persons. In Article 2 you will find a list of the persons to whom the Controller communicates your personal data. To facilitate the protection of your rights, Article 2 may specify in certain cases when your data are not disclosed to third parties.
The 'communication' of personal data to third parties is different from the 'transfer' (regulated in the preceding point). In fact, in communication the third party to whom the data is transmitted may only use it for the specific purposes described in the relationship with the Data Controller. In the transfer, on the other hand, the third party becomes the autonomous Data Controller. Moreover, in order to transfer your personal data to a third party, your consent is always required.
Notwithstanding the foregoing, it is understood that the Data Controller may still use your personal data in order to properly fulfil its obligations under applicable laws.

SPECIFIC PRIVACY POLICY

Art. 1 Processing modalities
1.1 The processing of your personal data will be mainly carried out with the aid of electronic or in any case automated means, according to the methods and with the instruments suitable to guarantee security and confidentiality in compliance with the GDPR.
1.2 The information acquired and the methods of processing will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure IT environments appropriate to the circumstances.
1.3 The Site does not process "special data". Particular data are those which may reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-unionist character, state of health and sexual life.
1.4 No judicial data are processed through the Site.

Art. 2 Communication of personal data
The Data Controller may communicate your personal data to certain categories of subjects. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:
* The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to your personal data by virtue of regulatory or administrative measures.
* Your personal data may also be communicated to all those public and/or private subjects, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Offices of Labour, etc.), if the communication is necessary or functional to the correct fulfilment of the obligations deriving from the law.
* The Data Controller makes use of employees and/or collaborators in any capacity. For the proper functioning of the Site, the Data Controller may communicate your personal data to these employees and/or collaborators.
* In its ordinary Site management activities, the Data Controller makes use of companies, consultants or professionals in charge of installing, maintaining, updating and, in general, managing the Data Controller's hardware and software or which the latter uses to provide its services. Therefore, only with reference to these purposes, your data may also be processed by these subjects.
* In order to send its own communications, the Data Controller makes use of external companies in charge of sending this type of communications (CRM platforms). Your personal data (in particular your email) may therefore be communicated to these companies.
* The Data Controller does not use external companies to provide customer care services.
The Data Controller reserves the right to modify the above-mentioned list according to its ordinary operations. Therefore, you are invited to regularly access this notice to check to which entities the Data Controller communicates your personal data.

Art. 3 Retention of personal data
3.1 This article describes for how long the Data Controller reserves the right to retain your personal data.
* For marketing purposes, personal data will be retained until consent is revoked. For inactive users, personal data will be deleted after a period of one year from the sending of the last viewed email, if any.
3.2 Without prejudice to Article 3.1, the Data Controller may keep your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data
4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory point of view as it is governed by the GDPR. If the transfer of your personal data takes place to a country outside the EU and for which the European Commission has issued an adequacy opinion, the transfer is in any case considered safe from a regulatory point of view. This Article 4.1 indicates the countries to which your personal data may possibly be transferred and where the European Commission has issued an adequacy finding.
* You are therefore invited to access this article regularly to check whether your personal data is being transferred to a country with these characteristics.
4.2 Notwithstanding Article 4.1, your data may also be transferred to countries outside the EU and for which the European Commission has not issued an adequacy finding. You are therefore invited to regularly review this Article 4.2 to find out to which of these countries your data may be transferred. In order to enable the proper functioning of the Site, your personal data may be transferred to the U.S.. In these cases, the Data Controller will take all appropriate contractual measures to ensure an adequate level of protection of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission on 4 June 2021.
4.3 In this article, the Data Controller indicates the countries in which it may specifically conduct its business. This may imply the application of the legislation of the country in question, together with that of the GDPR.
* At the request of the user, the Data Controller will apply to the processing of personal data the legislation that may be more favourable under the user's national legislation.

Art. 5. Rights of the data subject
Pursuant to Art. 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:
* request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of processing concerning you or to object to their processing, as well as the right to data portability
* withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation
* to lodge a complaint with a supervisory authority (e.g. the Data Protection Authority).
The above rights may be exercised by making a request addressed without formalities to the contacts indicated in the Foreword.

Art. 6. Amendments and Miscellaneous
The Data Controller reserves the right to make changes to this notice at any time, giving suitable publicity to users of the Site and guaranteeing in all cases adequate and similar protection of personal data. In order to view any changes, you are invited to consult this policy on a regular basis. In the event of substantial changes to this privacy policy, the Data Controller may also give notice thereof by email.

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