Privacy Policy

PRIVACY STATEMENT PURSUANT TO ARTICLE 13 OF EU REGULATION 2016/679

regarding the data processed through this site

Under Section 4 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 (henceforward referred to as “EU Regulation”), Carter & Benson S.r.l. intends to inform anyone who visits this website about how your personal data will be used and processed.

Who is the Data Controller? And how can I reach them?

 
  1. Data Controller

Carter & Benson S.r.l.

Foro Buonaparte, 22

20121 – Milan (MI)

e-mail: carterbenson@legalmail.it

  • Purposes covered by the consent of the interested party (Article 6, paragraph 1 (a) GDPR.

Personal data may also be processed for certain purposes for which the interested party has given their consent. 

  1. Respond to requests or questions presented and sent to the contacts indicated on this site, in order to receive information about our products and services;
  2. Carrying out advertising or promotional activities, in the broadest sense of the term (for example sending newsletters and information material, sending brochures, organizing events, etc.) and other marketing activities, through automated methods of contact (for example: unattended calls, e-mails, sms, and various messaging systems, including instantaneous and on the internet, also to mobile phones) and non-automated (sending of paper mail and calls with operator);
  3. Profiling activities to analyze or predict aspects concerning the personal preferences, interests, behavior and commercial habits of said natural person, as well as market research and surveys in general.

The preservation time of personal data, in relation to the purposes referred to in this section is the following:

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

For the purposes: b, 24 months from the issue of consent unless revoked.

For the purpose: d, 12 months, from the issue of consent, unless revoked.

  • Categories of processed data

The data processed by the Data Controller are exclusively “personal data” (Art. 4.1 of EU Regulation).

In particular, the categories of relevant personal data can be, by way of example but certainly not exhaustive:

  • Personal and identification data (by way of example and not limited to: name, surname, etc.);
  • Contact details (address, e-mail address, IP address, telephone number and similar data).
  • Data relating to any services provided.
  • Recipients or categories of recipients of personal data (pursuant to Article 13 paragraph 1 (e) of EU Regulation*

As part of the aforementioned purposes, the Data Controller may communicate your data to the following:

  • Offices and internal functions of the Data Controller;
  • Control and supervisory bodies;
  • Companies and professional operators that provide IT services, including electronic data processing, software management, site management and IT consultancy;
  • Advertising and communication companies and agencies as well as marketing consultancy companies;
  • Mailing and hosting provider companies, postal couriers and companies that carry out enveloping and shipping of the material and communications indicated above and companies that perform documentation archiving activities.

* The complete and updated list of Owners, Managers, Recipients (pursuant to Article 4.9 of EU Regulation), is made available at the offices of the Owner.

  • Recipients or categories of recipients of personal data (pursuant to Article 13 paragraph 1 (f) of EU Regulation) and transfer of data to non-EU countries

The Data Controller informs you that it does not intend to transfer your data to countries outside the EU and the EEA for the purposes indicated above.

  1. Data subject’s rights

The data subject, in relation to the personal data covered by this information, has the right to exercise the rights provided for by the EU Regulation listed below:

  • right of access of the interested party [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);
  • right to rectify personal data [art. 16 of the EU Regulation] (the data subject has the right to rectify any inaccurate personal data concerning them);
  • right to cancel their personal data without undue delay (“right to be forgotten”) [art. 17 of the EU Regulation] (the interested party has, and will have, the right to have their data deleted);
  • right to limit the processing of personal data in the cases provided for by art. 18 of the EU Regulation, including in the case of unlawful processing or contesting the accuracy of personal data by the interested party [art. 18 of the EU Regulation];
  • right to data portability [art. 20 of the EU Regulation], (the interested party may request their personal data in a structured format in order to transmit them to another Data Controller, in the cases provided for by the same article); 
  • right to object to the processing of personal data [art. 21 of the EU Regulation] (the interested party has, and will have, the right to object to the processing of their personal data in the cases provided 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 interested party has, and 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 can revoke their consent at any time and the effects will take effect from the moment of revocation, subject to the terms established by law. In general terms, the withdrawal of consent is effective only for the future.

The aforementioned rights can be exercised in accordance with the provisions of the EU Regulation by sending an email to the address indicated in point 1.

Carter & Benson S.r.l., in compliance with art. 19 of the EU Regulation, proceeds to inform the recipients to whom the personal data have been communicated, of any corrections, cancellations or limitations of processing requested, where this is possible.

To allow a more rapid response of your requests made in the exercise of the aforementioned rights, the same may be addressed to the Data Controller by addressing them to the addresses indicated in point 1.

For a more complete list of the data subject’s rights click here. ** 

  1. Right to lodge a complaint (Article 13 paragraph 2 (d) of EU Regulation) 

If the interested party believes that his rights have been compromised, he has the right to lodge a complaint with the Guarantor Authority.

For more information on the rights and the exercise of the same, please refer to http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or by sending written notice to the Guarantor Authority for the Protection of Personal Data.

  • Possible consequence of failure to communicate data and nature of data provision (Article 13 paragraph 2 (e) of EU Regulation) 
  • In case of consent of the interested party

We inform you that the aforementioned purposes have consent as their legal basis and that, in relation to these purposes, the data subject can withdraw their consent at any time and the effects will take effect from the moment of revocation, without prejudice to the terms provided by law. In general terms, the withdrawal of consent is effective only for the future. Therefore, the processing that was carried out before the withdrawal of consent will not be affected and will maintain its legitimacy.

Failure or partial consent may not guarantee the complete provision of services, with reference to the individual purposes for which consent is denied. 

It should be noted that with reference to the request for information, while the consent to the processing of personal data remains free and optional, it is necessary to process the request. Therefore, the sending of the request or equivalent manifestation of will be considered as the release of consent, which will always be revocable with the consequences illustrated above.

When the data are no longer necessary, they are regularly deleted, if their cancellation is impossible or possible only in the face of a disproportionate effort due to a particular storage method, the data cannot be processed and must be stored in inaccessible areas.

  • Existence of an automated decision-making process (including profiling)

The use of purely automated decision-making processes as detailed in article 22 of EU Regulation is currently excluded. If in the future it is decided to establish such processes for individual cases, the interested party will be notified separately if this is required by law or if this information is updated.

  • Processing methods

Personal data will be processed in paper, computerized and telematic form and inserted in the relevant databases (potential customers, customers, users, etc.) to which the employees expressly designated by the Data Controller as Managers and Authorized of the processing of personal data, which may carry out consultation, use, processing, comparison and any other appropriate operation, including automated, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of the data as well as the accuracy, the updating and relevance of the data with respect to the declared purposes.

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Processing of data useful for navigation purposes

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

This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

Among the information that can be collected we have the IP addresses, the type of browser or operating system used, the addresses in URI (uniform resource identifier) ​​notation, the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request to the server was made, the method used and information on the response obtained, further information on the user’s navigation on the site (see also the specific section relating to cookies) and other parameters relating to the operating system and the user’s IT environment.

These same data could also be used to identify and ascertain responsibilities in case of any computer crimes against the site.

Notice regarding children under 14

Children under the age of 14 cannot provide personal data. Carter & Benson S.r.l. will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, should it be recognized that they are being used, Carter & Benson S.r.l. will facilitate the right of access and cancellation forwarded by the legal guardian or by whoever exercises parental responsibility.

Exercise of data subject’s rights

The data subject, in relation to the personal data covered by this information, has the right to exercise the rights provided for by the EU Regulation listed below:

    • Right of access by the data subject [art. 15 EU Reuglation]: the data subject has the right to obtain from the data controller confirmation that their personal data is being processed or not and, in this case, access to the information expressly provided for in the aforementioned article, including, by way of example and not limited to, the purposes of the treatment, the categories of data and recipients, the retention period, the existence of the right of cancellation, rectification or limitation, the right to lodge a complaint, all the information available on the origin of the data, the possible existence of a process automated decision-making pursuant to art. 22 of the Regulations, as well as a copy of their personal data.
    • Right to rectification [art. 16 EU Regulation]: the data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her;
    • Right to erasure (‘right to be forgotten’) [art. 17 EU Regulation]: the data subject has the right to cancel theri personal data without undue delay, if one of the reasons expressly provided for in the aforementioned article exists, including by way of example and not exhaustive, the lack of the need for processing with respect to the purposes, the withdrawal of consent on which the treatment is based, opposition to treatment in the event that it is based on legitimate interest that is not prevailing, unlawful treatment of data, cancellation due to legal obligations, data of minors processed in the absence of the conditions of applicability provided for by art. 8 of the Regulations;
    • Right to restriction of processing [art. 18 EU Regulation]: in the cases provided for by art. 18, including the unlawful treatment, the contestation of the accuracy of the data, the opposition of the interested party and the lack of the need for treatment by the owner, the data of the interested party must be processed only for storage unless the consent of the itself and the other cases expressly provided for in the aforementioned article;
    • Right to data portability [art. 20 EU Regulation]: the data subject, in cases where the processing is based on consent and on the contract and is carried out by automated means, may request to receive their personal data in a structured format, commonly used and readable by an automatic device, and has the right to transmit them to another owner;
  • Right to object [art. 21 EU Regulation]: the data subject has the right to object to the processing of their personal data, in the event that the processing is based on a legitimate interest that is not prevailing or is carried out for direct marketing purposes;
  • Right not to be subject to a decision based on automated processing, [art. 22 EU Regulation]: the data subject has the right not to be subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).

The above description does not replace the text of the articles cited therein which are referred to here in full and to which full reading is referred. (link agli artt. 15-22)

 

Changes and updates

This information shows the date of its last update in its header.

Carter & Benson S.r.l. it could also make changes or additions to said privacy policy also as a consequence of any subsequent amendments or regulatory additions.

** Legislative references on the rights of the data subject

 

Art. 15 GDPR

Right of access by the data subject 

1.The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

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

3.The controller shall provide a copy of the personal data undergoing processing. 2For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. 3Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

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

 

Art. 16 GDPR

Right to rectification 

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

Art. 17 GDPR

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 or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
  3. the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
  4. the personal data have been unlawfully processed;
  5. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
  6. the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2.Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

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

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  5. for the establishment, exercise or defence of legal claims.

 

Art. 18 GDPR

Right to restriction of processing

1.The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  1. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  3. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
  4. the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2.Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

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

 

Art. 19 GDPR

Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

 

Art. 20 GDPR

Right to data portability

1.The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

  1. the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
  2. the processing is carried out by automated means.

2.In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3.The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That 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 adversely affect the rights and freedoms of others.

 

Art. 21 GDPR

Right to object

  1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates 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 processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

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

4.At the latest at the time of the first communication with the data subject, 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.

5.In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

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

 

Art. 22 GDPR

Automated individual decision-making, 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 similarly significantly affects him or her.

2.Paragraph 1 shall not apply if the decision:

  1. is necessary for entering into, or performance of, a contract between the data subject and a data controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
  3. is based on the data subject’s explicit consent.

3.In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4.Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.