INFORMATIVA PRIVACY

PRIVACY POLICY

PRIVACY POLICY

Pursuant to art. 13 of Regulation (EU) 2016/679 and Legislative Decree 196/2003

This scope of this privacy policy is to describe the purposes and methods by which:

1.     AVM S.r.l., with registered office at Via Vittor Pisani 19, 20124 - Milan (MI), as independent Data Controller (“AVM”), collects and processes personal data relating to the user (User/s) who visits the website https://www.montenapoleone.luxury/it.html (“Site”);

 

2.     The company MonteNapoleone Lounge S.r.l., with registered office at Via Vittor Pisani 19, 20124 Milan (MI), also as independent Data Controller (“MonteNapoleone Lounge”), collects and processes personal data relating to Users who register on the site for the purpose of using the services offered in the Exclusive Services section of the Site;

 

 

3.     Associazione Montenapoleone District, with registered office at Via Bigli 24 – 20121 Milan (MI), as independent Data Controller (“Associazione”), processes personal data of (i) interested parties who, during events promoted by the Associazione or in the context of informal contacts with people who work with the Associazione, have supplied their business card and/or personal details and/or expressed their interest in being kept up to date and remaining in contact with the Associazione and its events, (ii) Site users who contact the Associazione via email through the “The Associazione and Events” section of the Site in order to be kept up to date about the Associazione’s events and initiatives.

Information contained in this privacy policy is provided in accordance with Art. 13 of Regulation (EU) 2016/679 of 27 April 2016 (Regulation), Legislative Decree 196/2003 (Privacy Act), and the Provisions issued by the Italian Data Protection Authority and E.U. guidelines. 

***

1.     Data processing carried out by AVM

AVM makes use of cookies to receive and collect information about Users visiting and interacting with the Site to carry out analyses and gather statistics on the use and functionality of the Site, in order to improve the performance and services offered through the Site as set out in more detail below.

 

Data supplied by the User shall not be disseminated but may be shared with the following categories of subject for the purposes outlined above:

(i)              People, companies or professional offices that provide assistance and consultancy services to AVM, particularly, but not limited to, accounting, administrative, IT, legal, fiscal and financial matters;

(ii)             Subjects whose right to access data is recognized by statutory provisions or orders from authorities.

Such subjects shall use the data according to law as independent data controllers or as data processers. Users’ data may also be brought to the knowledge of our staff who will process same as data processers.

Cookie Policy

We inform you that as Users browse the Site, AVM collects some personal data such as pages viewed, links or keys clicked by the User, date and time of access, and IP address (so called web browsing data). AVM collects such data through cookies or similar technology.

Cookies are small dimension text files memorized on your computer or mobile device when you visit a website so that they can be retransmitted to the same website the next time you visit it.  AVM uses cookies to enable the Site to function or improve its performance, but also to provide information about the Site or Users’ browsing habits.

The Site uses the following types of cookie:

-        Technical Cookies: are essential to enable Users to navigate the Site and use its functions, allow the website to remember choices made by the User (language, country of origin etc. for example), to distribute requests to a number of servers and allow the User to view content and videos. Being essential for the proper functioning of the Site, these cookies do not require the User’s consent.

 

-        AVM’s performance and analytics cookies: may be session or persistent cookies, and their use is limited to Site performance and improvement. These cookies allow the Site to recognize and keep track of Users, and measure how they interact with content in order to improve the Site. For example, establishing whether Users are able to find the information they are looking for easily, or identify which aspects of the Site are of the greatest interest. AVM uses these cookies to carry out anonymous statistical analyses of the way Users browse the Site, the number of pages visited or the number of clicks made on a page during browsing. These cookies come under the technical cookies privacy policy and so do not require the User’s consent;

 

-        Third party performance and analytics cookies: AVM may also use third party performance and analytics cookies for the same purposes as described above, and particularly Google Analytics to analyse how Users use the Site, which pages they visit most often or the number of clicks made on a page during browsing. AVM processes the results of these analyses only if the third party uses cookies in connection with the browser installed on the User’s computer or other devices used to browse the Site. To enable these cookies, the User may choose whether to give their consent (which then forms the legal grounds for lawful processing) through the AVM cookie consent banner displayed on the Site home/landing page when the User accesses the Site. For information on how to manage performance and analytics cookies installed by Google Analytics as well as disable them, we recommend consulting the Privacy Policy and cookies options at the following link: https://policies.google.com/privacy?hl=en&gl=uk.

 

Finally, to find out more about the cookies present on the Site and how to manage or disable third party cookies, the User should visit the www.youronlinechoices.com.

In addition to being able to accept or refuse all or some of the cookies used on the Site in the manner described in this privacy policy, in future, whenever Users so desire, they can also eliminate cookies placed on the Site also through their browser settings.

Most browsers are set to accept cookies. However, users can configure their browser to restrict the number of cookies accepted or block all cookies by changing their browser settings in the following ways:

Microsoft Internet Explorer - Click on “Tools” in the upper right corner. Next select “Internet Options” and click on the” Privacy” tab. Users can then choose one of the cookie settings options;

Google Chrome Click the “spanner” icon in the upper right corner and select “Settings”. Then select “Show advanced settings”. In the Privacy section click “Content settings”. Users can change to their preferred setting in the Cookies section;

Mozilla Firefox Select ‘Options’ from the drop down menu in the upper left corner. Select ‘Privacy & Security’ from the pop-up window. Users can change cookie settings here;

Safari Select “Preferences” from the drop-down menu in the upper right corner. Select “Security”. Users can change cookie settings here.

However, it should be pointed out that by disabling all cookies on the Site (including technical cookies), some functions will be compromised, The website www.allaboutcookie.org contains instructions for management of cookies on the most widely used browsers, alternatively consult the instructions for the software used on your device.

In cases expressly provided for by law, Users may exercise the rights referred to in Arts. 15 to 22 of the Regulation, and more specifically may: request access to information regarding processing of their personal data; rectification of inexact or incomplete data; erasure of data; restriction of data processing; receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller or request direct transmission from one controller to another if technically feasible (data portability); object, for legitimate reasons, to the total or partial processing of personal data concerning them. Such rights may be exercised directly by forwarding a letter to the following email address: avmsrl@legalmail.it.

Should the User consider processing of the data provided contravenes personal data protection law, they have the right to lodge a complaint with the Data Protection  Authority (www.garanteprivacy.it).

 

***

2.     Data processing carried out by MonteNapoleone Lounge

MonteNapoleone Lounge collects and processes personal data of Users who register on the Site to (i) enable the latter to make use of the services offered in the “Exclusive Services” section of the Site, (ii) protect its own and third parties’ legitimate rights and interests (e.g. management of disputes in the event of defaults, protests, litigation and/or transactions) and (iii) compliance with obligations provided for by laws, regulations and E.U. rules, or by provisions laid down by law by the competent authorities.

The legal ground for lawful processing of the User’s data for the supply of services referred to in the “Exclusive Services” section is the agreement to provide and proper performance of the service requested by the User. The legal ground for lawful processing for the management of disputes in the event of defaults, protests, litigation and/or transactions, is the pursuit of a MonteNapoleone Lounge or third party’s legitimate interest, which on the basis of assessments carried out by same, is not detrimental to the User’s rights. The legal ground for lawful processing for legal obligations and/or those deriving from competent authorities, is compliance with such obligations.

Consequently, data supply for the purposes described does not require the User’s consent in that it is necessary for registration on the Site and to use the services requested, as well as the connected purposes described above. Failure to supply data, therefore, will make it impossible to receive such services. Data supplied may be shared with people and/or companies or bodies that provide MonteNapoleone Lounge with services or assistance for example, accounting, administrative, IT, legal, fiscal and financial matters, and to other subjects whose right to access data is recognized by statutory provisions or orders from authorities. Such subjects shall use the data as independent data controllers or as data processers. Users’ data may also be brought to the knowledge of our staff who will process same as data processers. Data will be stored for the duration of the service requested, and for 3 years once provision and use of the service has terminated, after which it will be stored in accordance with the ordinary periods of prescription laid down in the Civil Code or by specific legal provisions, for purposes of an administrative nature and/or to assert or defend a right or legitimate interest of the Controller or third party.

We inform you that in the cases expressly set out in the GDPR, you may exercise the rights referred to in arts. 15 et seq. of the GDPR. Specifically you may request access to information relating to processing of your personal data; rectification of inexact or incomplete data; erasure of data; restriction of data processing; receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller or request direct transmission from one controller to another if technically feasible (data portability); object, for legitimate reasons, to the total or partial processing of personal data concerning you. Such rights can be exercised directly by forwarding a letter to the following email address: contact@mnlounge.it

Should Users consider processing of the data provided contravenes personal data protection law, they have the right to lodge a complaint with the Data Protection  Authority (www.garanteprivacy.it).

***

 

3.     Data processing carried out by Associazione MonteNapoleone District

Associazione MonteNapoleone District processes personal data of interested parties who, during events promoted by the Associazione or in the context of informal contacts with people who work with the Associazione, have supplied their business card and/or personal details (i.e. name and surname, job title, email address, telephone number etc.) and/or expressed their interest in being kept up to date and remaining in contact with the Associazione and its events, as well as Users who contact the Associazione via email through the “The Associazione and Events” section of the Site in order to be kept up to date about events and initiatives (i) to enable same to be kept up to date about the Associazione’s events and/or initiatives promoted by the latter by way of invitations and notifications sent by email or paper mail to address supplied by them; (ii) for management of disputes in the event of defaults, protests, litigation and/or transactions, prevention of fraud and/or illegal activities etc., and (iii) where necessary, compliance with obligations provided for by laws, regulations and E.U. rules, or by provisions laid down by law by the competent authorities.

The legal ground for lawful processing for the purpose of sending information to the parties described at (i) above, is the pursuit of a legitimate interest of the parties concerned and the Associazione. In other words, to keep in contact with those who have shown an interest to that effect, and provide them with updates and information about events and initiatives promoted by the Associazione as they have requested. The legal ground for lawful processing for the management of disputes in the event of defaults, protests, litigation and/or transactions is the pursuit of a legitimate interest of the Associazione or a third party. The legal ground for lawful processing for legal obligations and/or those deriving from competent authorities, is compliance with such obligations and/or provisions.

The supply of data by interested parties is totally optional, but failure to supply will make it impossible to stay in contact with the Associazione and be updated about initiatives and events promoted by it.  For the reasons set out above, processing interested parties’ data with regard to the interest shown in the Associazione does not require their specific consent. However, the party concerned may at all times refuse further communications from the Associazione simply by contacting it at the addresses given below.  

Data supplied may be shared with people and/or companies or bodies that provide the Associazione with services or assistance for example, accounting, administrative, IT, legal, fiscal and financial matters, and to other subjects whose right to access data is recognized by statutory provisions or orders from authorities. Such subjects shall use the data as independent data controllers or as data processers. Data may also be brought to the knowledge of our staff who will process it as data processers.

Data will be processed until the party concerned decides they no longer wish to receive information about initiatives and events promoted by the Associazione, and sends an email to segreteria@montenapoleonedistrict.it or events@montenapoleonedistrict.it stating their intention. Following receipt of such notice, data will be stored in accordance with the ordinary periods of prescription laid down in the Civil Code or by specific legal provisions, for purposes of an administrative nature and/or to assert or defend a right or legitimate interest of the Controller or third party.

We inform you that in the cases expressly set out in the GDPR, you may exercise the rights referred to in art. 15 et seq. of the GDPR, and specifically you may: request access to information relating to processing of your personal data; rectification of inexact or incomplete data; erasure of data; restriction of data processing; receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller or request direct transmission from one controller to another if technically feasible (data portability); object, for legitimate reasons, to the total or partial processing of personal data concerning you. Such rights can be exercised directly by forwarding a letter to the one of the email addressed given above.

Should Users consider processing of the data provided contravenes personal data protection law, they have the right to lodge a complaint with the Data Protection  Authority (www.garanteprivacy.it).

***

This Privacy Policy may be amended at any time, in a manner visible to Users and interested parties through publication on the Site. We therefore invite you to check the Site for updates. Should the changes be particularly significant and/or have a serious impact on the rights of the interested parties, the Data Controller may advise the interested parties also in other ways (e.g. by forwarding an email).

 

Privacy Policy updated on 24 October 2018