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NEWSLETTER PRIVACY POLICY
pursuant to Article 13 of Regulation (EU) 2016/679 on the processing of personal data

By subscribing to our newsletter, you declare that you are at least 18 years old and consent to the processing of your personal data to receive newsletters and other communications from Aglatech 14 S.r.l., in its capacity as Data Controller. Therefore, in compliance with the provisions of Article 13 of Regulation (EU) 2016/679 on the processing of personal data (hereinafter also referred to simply as the ‘GDPR’), we hereby provide you, as the Data Subject, with the necessary information regarding the purposes and methods for processing your personal data, as well as the scope of communication and dissemination thereof.


1. Processing purposes

Data processing is aimed at sending newsletters and/or communications and/or informative or promotional material by email, in relation to the Data Controller’s promotional activities and initiatives.


2. Data processing methods
Pursuant to Article 5 of the GDPR, personal data will be processed lawfully and fairly and will not be excessive in relation to the purposes set forth in point no. 1.
Your personal data will be processed in compliance with the principles of minimisation and storage limitation, pursuant to Article 5, par. 1, letter e) of the GDPR. It will be stored for 2 years from the moment you provide consent or, in any case, until you unsubscribe through the opt-out option provided at the bottom of every communication, unless otherwise required by law.
The processing is carried out by means of the operations or set of operations set forth in Article 4, par. 2 of the GDPR, and may be carried out with or without the aid of electronic or otherwise automated tools, based on logic that is fully in line with the purposes pursued.
The data processing is carried out by the Data Controller, Data Processors and duly authorised Data-Processing Operators. The full list of Data Processors is available on request from the Data Controller.


3. Legal basis for processing – Nature of data provision – Refusal to provide data
The provision of personal data for the purposes set forth in point no. 1 of this Privacy Policy is carried out pursuant to Article 6, par. 1, letter a) of the GDPR (explicit consent of the data subject), and is strictly necessary to allow the Data Controller to send newsletters and/or communications and/or informative or promotional material via email in relation to promotional activities and initiatives of the Data Controller. The data subject’s refusal to provide their personal data makes it impossible to fulfil the activities set forth in point no. 1.


4. Scope of data communication
Your data, forming the subject of the processing, may be communicated to parties acting as external Data Processors, pursuant to Article 28 of the GDPR, for example external collaborators, consultants and, in general, all those subjects to whom the communication is necessary for the correct fulfilment of the purposes set forth in point no. 1.
Data-Processing Operators and Data Processors will only process the data if this is necessary for the performance of their assigned tasks.
All this without prejudice to the guarantee of protection of the data subject’s rights.


5. Scope of data dissemination
Personal data is not subject to dissemination.     


6. Data transfer abroad

Personal data may be transferred to countries within the European Union within the scope of the purposes set forth in point no. 1.


 7. Rights of the Data Subject

Data subjects, pursuant to articles 15, 16, 17 and 18 of the GDPR, may enforce their rights by sending a request to the Data Controller via email at the following addresses (point no. 8).

In particular, under Article 15 of the GDPR, you can obtain from the Data Controller:

    • confirmation of the existence or otherwise of your personal data and its provision in intelligible form;

    • information on the origin of the data;

    • information on the purposes and methods of processing; 

    • information on the logic applied to the processing; 

    • information on the identification details of the Controller and of the persons to whom the data may be communicated;

    • updating, rectification and integration of data;

    • erasure, transformation into anonymous form or blocking of data processed in breach of the law;

    • limitation of processing.

The data subject may object, on legitimate grounds, to the processing of data concerning them, even if pertinent to the purpose of collection, and is also entitled to obtain data portability under Article 20 of the GDPR.

Pursuant to art. 77 of the GDPR, data subjects are also entitled to lodge a complaint with the Italian Data Protection Authority if they believe that the processing of their personal data is in breach of the provisions of the Regulation.


8. Data Controller – Data Protection Officer

The Data Controller is Aglatech 14 S.r.l. (Tax ID No. 08699190966), in the person of its legal representative pro tempore, with registered office in Milan (20123 – MI), Via Carducci, 26, email: privacy@aglatech.it