ANIMA Federation of National Associations of Mechanical and Allied Industries (C.F. 80067530156) with registered office in Milan, via Angelo Scarsellini 13 (20161); telephone: 02 4541 8500; e-mail: firstname.lastname@example.org (hereinafter also only "ANIMA" or "Federation" or the "Data Controller"), pursuant to EU Regulation 679/2016 - laying down provisions for the protection of individuals with regard to the processing of personal data and the free movement of such data ("GDPR"), as Data Controller, informs you of the following.
1- ANIMA, which is a member of Confindustria (the Confederation of Italian Industry), has as its corporate purpose, among others, to "encourage and develop, by the most appropriate means, technical, scientific and economic cooperation for the improvement of production; to establish relations with other national and foreign Federations or Industrial Associations". To this end, ANIMA controls, through the majority or all of its shareholdings, a number of companies (namely: ASA Azienda Servizi Anima S.r.l., Icim Group Srl, Tifq Srl and Tifqlab Srl and collaborates with Easyfrontier Srl, a partner in the Easy Customs service) which, taken together with ANIMA itself, constitute the so-called ANIMA System, through which the Federation pursues and implements its statutory aims and provides services to member companies.
2 - ANIMA is aligned with the high standards of confidentiality of personal data introduced by the GDPR, based on the principles of correctness, lawfulness, transparency and protection of privacy and the rights of the data subject.
3 - ANIMA commonly collects and uses, in the performance of its institutional activities, Personal Data referring to member companies, their respective directors, managers, employees, collaborators and consultants; such Personal Data - which have been collected because they have been transmitted by member companies in compliance with the obligations incumbent upon them or have been collected directly by the Federation (for example: on the occasion of the participation in meetings, events, courses, webinars or conventions, or through spontaneous contribution by the data subject) also through the companies of the ANIMA System - are used for communications of invitations to meetings, events, courses, conventions, webinars as well as the sending of promotional material on ANIMA initiatives through newsletters, as well as, obviously, for the purposes indicated within its own statute.
4 - ANIMA guarantees each interested party the exercise of his/her rights as better specified in paragraph 8 below.
IN VIEW OF THE ABOVE, ANIMA INFORMS THAT
1. Data Controller and Data Processor
The Data Controller is ANIMA (as defined above), with registered office in Milan, via Angelo Scarsellini 13.
The companies belonging to the ANIMA System, as defined above, which provide ANIMA with specific processing services or perform activities connected with, instrumental to or in support of those performed by ANIMA, have also been appointed as Data Processors.
2. Categories of data processed
Your Personal Data that will be processed by ANIMA are: name, surname, title, role/assignment, address, telephone number, e-mail address, fiscal code directly provided by you (hereinafter "Personal Data"). They are recorded in the database of ANIMA and of the ANIMA System by virtue of the statutory purposes of the Federation as well as those better described in paragraph 3 below.
3. Purpose of processing and legal basis
Your Personal Data are processed for the following purposes:
(A) as a function of the membership relationship and, in any case, for the pursuit of the institutional aims of the Federation: statutory, administrative and association management in general.
For the pursuit of the purpose referred to in letter (A) above, the legal basis is the signing of the application for membership of ANIMA.
(B) to inform you - by means of automated tools (email, sms, mms and instant messages) or traditional tools (telephone calls with operator, paper mail) - about initiatives, activities and projects of the Federation (meetings, courses, conventions, competitions, webinars, etc.), for the sending of informative and promotional material and newsletters, in any case for any other activity promoted by ANIMA that ensures the correct and lawful processing of data, safeguarding their confidentiality and integrity.
For the pursuit of the purposes referred to in letter (B) above, the legal basis is your prior specific consent.
(C) communication of your Personal Data to speakers and/or partners of webinars, conferences or courses in which you take part.
For the pursuit of the purpose referred to in letter (C) above, the legal basis is your prior specific consent.
4. Processing methods and compulsory or optional nature of providing Personal Data - consequences of refusal to provide them
The processing of your Personal Data, of which ANIMA is the Data Controller, for the purposes described in points (A), (B) and (C) of paragraph 3 above, may be carried out with or without the aid of electronic or automated means.
Said processing will include - in compliance with the principles of correctness, lawfulness, transparency and protection of confidentiality - the operations strictly necessary for the purpose.
The provision of Personal Data for the pursuit of:
- purposes referred to in letter (A) of paragraph 3 (management of the membership relationship) is necessary for membership of ANIMA and the management of the membership relationship and any refusal to provide such information will make it impossible to join ANIMA and to perform even partially the activities provided for by the statute of the Federation;
- the purpose of letter (B) of paragraph 3 (marketing) is optional; however, failure to provide such information will not have any consequence on your ability to join ANIMA but it will not be possible to inform you about promotional and commercial initiatives and to send you invitations to events, courses, conferences, workshops, webinars and/or newsletters;
Furthermore, we would like to inform you that, where you have given your consent to authorise the Data Controller to pursue the purposes set forth in paragraph 3(A) above, you will remain free at any time to withdraw your consent and/or to object to the processing of your data for the aforesaid purposes and/or methods, by sending a clear written communication to that effect, without any formality, to the addresses better specified in paragraph 9 "Contacts for the exercise of data subject's rights and for further information". As regards the receipt of newsletters, you may also simply click on the unsubscribe link indicated at the bottom of the email you will receive.
- The purpose of letter (C) of paragraph 3 (communication of Personal Data to speakers and/or partners of conferences/courses/webinars) is optional; however, failure to provide such data will not have any consequence on the possibility to join ANIMA but it will not be possible to communicate your Personal Data to speakers and/or partners of webinars/courses.
5. Storage of Personal Data
Your Personal Data processed for:
- the management of the association relationship with ANIMA will be processed for the entire duration of the association relationship and subsequently for 10 years, except in the event of litigation, legal requirements or specific requests by the competent authorities;
- for marketing purposes for two years from the collection of consent and in any case until such consent is revoked.
Your Personal Data will not be subject to dissemination or fully automated processing.
6. Recipients of Personal Data
Your Personal Data may be communicated to the following entities:
subjects assigned to data processing by ANIMA to whom specific instructions have been provided in writing:
- (i) employees and collaborators of ANIMA who manage the database of records, communications and invitations to courses, webinars, conventions and events organised by ANIMA, also with their own speakers and/or partners;
(ii) subjects that provide services for ANIMA and appointed by the latter in writing as external data processors:
- companies providing the GoToWebinar (LogMeIn Inc.) and Mailup (MailUp S.p.A) platforms;
- companies belonging to the ANIMA system, as defined above, which provide ANIMA with specific processing services or perform activities connected with, instrumental to or in support of those carried out by ANIMA;
(iii) other third parties who process personal data as independent data controllers:
- Public Authorities that have access to personal data by virtue of regulatory or administrative measures;
- 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 obligations arising from the law;
- speakers and/or partners of events/webinars/conferences/courses in which you participate in order to allow them to pursue their own purposes.
A complete and up-to-date list of all the recipients of your Personal Data can be obtained by making an express request to the e-mail address email@example.com.
7. Transfer of Personal Data outside the EU
Your Personal Data will be transferred to non-EU countries, in particular to the USA. In this regard, ANIMA informs you as of now that such non-EU data transfer will always take place in accordance with the provisions of the applicable privacy legislation, i.e. on the basis of an adequacy decision issued by the European Commission in relation to the non-EU country to which the Personal Data will be transferred or, failing that, through the collection of consent, when necessary, or through the adoption of any other measure necessary to ensure the security of the Personal Data being transferred. Such measures include, for example, contractual arrangements based on so-called standard contractual clauses as developed by the European Commission.
8. Rights of the data subject
Il GDPR Le conferisce l’esercizio dei seguenti specifici diritti:
- your right to request access to your Personal Data together with information about the purpose of the processing, the category of Personal Data processed, the entities or categories of entities to whom the data have been or will be disclosed (including whether such entities are located in third countries or are international organisations), where possible, the storage period of personal data or the criteria used to determine this period, the existence of your rights to rectification and/or erasure of personal data, to restriction of processing and to object to processing, your right to lodge a complaint with a supervisory authority, the origin of the data, the existence and the logic applied in case of automated decision-making. If you exercise this right, and unless you indicate otherwise, you will receive an electronic copy of your personal data being processed.
- the right to obtain:
- the rectification of your Personal Data, if they are inaccurate or incomplete;
- the deletion of your Personal Data, if any of the conditions set forth in Article 17 of the GDPR apply (for example: your Personal Data are no longer necessary in relation to the purposes for which they were collected, you decide to revoke your consent to the processing - where this is the legal basis - and there is no other legal basis for the processing itself, you object to the processing and no other legitimate interest of the Data Controller prevails, your Personal Data are unlawfully processed);
- the limitation of the processing of your Personal Data 1) for the time necessary for ANIMA to ascertain the accuracy of your Personal Data (in the event that you have contested it); or 2) where the processing of your Personal Data is unlawful and you request, in lieu of the deletion of your Personal Data, the limitation of the processing thereof, or 3) when ANIMA no longer needs your Personal Data but the same are necessary for you to ascertain, exercise or defend a right in a court of law, or, finally, 4) for the time necessary to assess whether the legitimate reasons of the Controller prevail over yours, if you have objected to the processing of your Personal Data pursuant to point c below;
- your Personal Data in a structured, commonly used and machine-readable format also for the purpose of transmitting them to another data controller, if the processing is based on consent or on a contract and is carried out by automated means (so-called right to data portability). If it is in your interest, you may ask ANIMA to transmit your personal data directly to the other data controller, if this is technically feasible.
- the right to object to the processing of your Personal Data, where such processing is carried out pursuant to Article 6.1(e) (i.e. for the performance of a task carried out in the public interest or in connection with the exercise of official authority vested in the Controller) or (f) (i.e. to pursue a legitimate interest of the Controller) of the GDPR, unless there are compelling legitimate grounds for the Controller to proceed with the processing, pursuant to Article 21 of the GDPR.
- the right to withdraw your consent at any time without prejudice to the lawfulness of the processing of your Personal Data based on your consent and carried out before the withdrawal.If carried out, you also have the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in a similar way, as well as the right to obtain human intervention by the controller, to express your opinion and to contest the decision.
- If you are not satisfied with the processing of your Personal Data carried out by ANIMA, you may lodge a complaint with the Garante per la protezione dei dati personali, following the procedures and instructions published on the official website of this authority (www.garanteprivacy.it).
- Any rectification or erasure of your Personal Data or limitation of processing carried out at your request - unless this proves impossible or involves a disproportionate effort - shall be communicated by ANIMA to each of the recipients to whom your Personal Data may have been transmitted in accordance with this policy.