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Privacy Extended

Fully privacy notice concerning the processing of personal data pursuant to Regulation (EU) 2016/679 (“GDPR”) and Italian Legislative Decree 196/2003, as amended by Legislative Decree 101/2018

Dear web surfer, user, listener, client

Please read our Privacy Notice carefully. It is applicable every time you access this website (“Site”) and decide to browse through it and use its services.

The purpose of this document is to disclose information regarding the processing of the personal data you provide us, and in particular regarding the purposes and methods adopted for the processing of your personal data, as well as the scope of their disclosure and dissemination, the nature of the data in our possession, their provision and the period for which they will be stored.

The purpose of this document is to fully describe the way we handle the processing of your personal data collected when you browse the Site or use the services it offers. The Privacy Notice does not apply to other websites that you may be able to link to from this Site.

ABOUT US

In executing its operations, LifeGate Consulting and Media SpA, single-member company administered and controlled by LifeGate SpA – Società Benefit, headquartered in Via Palermo, 8, Milan, VAT no. 02589580139 (hereafter also referred to as the “Company” or “Controller”) is very attentive to the security and confidentiality of the personal data of its users and clients.

The Company is the Controller of the processing of personal data collected on this Site.

PERSONAL DATA COLLECTED

The categories of personal data (hereafter, jointly referred to as “Data”) that the Company collects include:

Contact data – name, surname, address, telephone number, mobile phone number, email address etc.

Payment data – information relating to your purchase and payment (e.g. credit/debit card no., IBAN).

Other personal data – information you give us such as your place and date of birth, your education or professional position etc.

Interests – information you give us about your interests, including the products you purchase and other interests.

Data relative to use of the Site – information about how you use the Site, open and forward our communications, including information collected by means of cookies (see our Cookie Policy here – Cookie  – for all the details).

HOW YOUR DATA IS COLLECTED

The Company collects and processes your Data on the basis of the service you have requested, under the following circumstances, which are described in more detail in the section on the purposes of processing:

  1. when you make enquiries or sign up for our Initiatives or requests for titles of music tracks aired on LifeGate Radio;
  2. when you make a request to upload/download documents through the Site;
  3. when you register for our newsletter;
  4. when you register for events promoted on the Site;
  5. when you purchase products from our Site Store;
  6. if other companies in the LifeGate Group or business partners legitimately transfer your Data to us;

If you provide another person’s Data, you must first make sure that those data subjects have read this Privacy Notice. Please help us to keep your Data updated by notifying us of any changes.

PURPOSES OF DATA PROCESSING

  1. A) Establishing and implementing pre-contractual and contractual measures, and obligations thereof.

The Company may process your Contact Data, Payment Data and Other Personal Data for the purposes of establishing and implementing pre-contractual and/or contractual agreements, providing the services requested and responding to reports and complaints.

The Company may also use your Contact Data, your email address in particular, to give your information about initiatives of the Company or to provide you with the documents you requested through the Site.

Legal basis for the processing: performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; discharge of obligations laid down by law in connection with that contract.

You are required to provide your Data for this purpose because otherwise it would not be possible to process your request.

  1. B) Operational management and purposes strictly connected with access to the Site, in particular to its reserved areas.

The Company may process your Contact Data so you can complete the process to register on some sections of the Site and so you can access your Personal Area, in order to: (i) buy products from the Site Store; (ii) upload/download documents relating to the services you have purchased; (ii) proceed with other requests made through the Site.

Legal basis for the processing: discharge of contractual obligations laid down by law to enable you to register on the sections of the Site.

You are required to provide your Data for this purpose because otherwise it would not be possible for us to allow your registration on the sections of the Site.

  1. C) Analysing and improving our services – customer satisfaction

The Company may process your Contact Data to analyse, review and improve our services with a view to customer satisfaction.

Legal basis for the processing: legitimate interest of the Company to verify and improve the quality of its services.

  1. D) Sending periodic newsletters

The Company may process your Contact Data in order to send you periodic newsletters, which you specifically request when you register for the service. The newsletters contain news and articles about a range of topics of interest.

Legal basis for the processing: performance of a contract to which you are party.

You are required to provide your Data for this purpose because otherwise you would not be able to register and receive the newsletter.

  1. E) Marketing of special offers

Subject to your specific consent, the Company may process your Contact Data (email address) for marketing and advertising purposes aimed at notifying you of special offers by means of automated contact methods (email).

Legal basis for the processing: your consent.

You are not required to provide your Data for this purpose and if you do not provide your consent it will have no effect on any contracts between you and the Company.

You may withdraw your consent at any time, effective from subsequent processing.

  1. F) Marketing of products and services on behalf of companies in the LifeGate Group and other third parties.

Subject to your specific consent, the Company may process your Contact Data (email address) for the purposes of marketing products and services of the Lifegate Group, as well as for third parties (mainly in the publishing, finance, economics, industry, luxury, services, telecommunications, ICT, insurance and not-for-profit sectors), made through automated methods of contact (email).

Legal basis for the processing: your consent.

You are not required to provide your Data for this purpose and if you do not provide your consent it will have no effect on any contracts between you and the Company.

You may withdraw your consent at any time, effective from subsequent processing.

  1. G) Defending rights in judicial, administrative and out-of-court proceedings, and in the scope of disputes relating to the services offered.

The Company may process your Contact Data and Payment Data to defend its rights or take action or make claims against you or third parties.

Legal basis for the processing: legitimate interest of the Company to safeguard its rights.

You are required to provide your Data for this purpose because otherwise the Company would not be able to safeguard its rights.

  1. H) Purposes connected with the discharge of legal, regulatory and EU legislation, with provisions and/or requirements of authorities empowered by law and/or by oversight and compliance bodies

The Company may process your Contact Data and Payment Data to comply with its legal obligations.

Legal basis for the processing: discharge of obligations laid down by law.

You are required to provide your Personal Data for this purpose because otherwise the Company would not be able to discharge specific obligations laid down by law.

SECURITY OF THE PROCESSING

The Company takes all the security measures necessary to ensure protection and maintain the security, integrity and accessibility of your Data.

All your Data are stored on our secure servers (or duly archived hard copies) or on those of our suppliers or business partners, and they may be accessed and used in accordance with our standards and security policies (or equivalent standards for our suppliers or business partners).

If we have provided (or you have selected) a password so you can access our Site, applications or services, you will be responsible for keeping that password confidential and for compliance with any other security procedure that we inform you of.

Still, the Company cannot warranty to its users that the security measures adopted for the Site and for the transmission of data and information about the Site can restrict or completely eliminate the risk of unauthorised access or disclosure of data by devices belonging to the user. Therefore, we suggest that you make sure your computer is equipped with suitable software to protect data transmission on the web, whether incoming or outgoing (e.g. up-to-date antivirus programmes), and that your internet services provider has adopted appropriate measures for the security of data transmission on the web (e.g. firewalls and spam filters).

PERIOD OF DATA STORAGE

We store your Data for no longer than necessary in relation to the purposes for which they were collected or for any other related legitimate purpose. Therefore, if your Data are processed for two different purposes, we will store those Data until the termination of the purpose with the longer storage period. However, we will stop processing Data collected for the purpose whose storage period has expired.

When your Data are no longer necessary, or there is no longer an underlying legal basis for their storage, they are irreversibly anonymised (and can be stored in that manner), or safely destroyed.

Below are the storage periods for the different purposes listed above:

  • Establishing and implementing contractual measures, and obligations thereof: Data processed to fulfil any contractual obligation shall be stored for the full term of the contract and in any case for no longer than the following 10 years, in order to verify anything that is outstanding including accounting documents (e.g. invoices).
  • Operational management and purposes strictly connected with access to the Site, in particular to its reserved areas: the Data processed for this purpose shall be stored for the full term of the contract and in any case for no longer than 10 years after the last access to the Site.
  • Analysing and improving services – customer satisfaction: the Data processed for this purpose shall be stored for 24 months.
  • Sending periodic newsletters: the Data processed for this purpose shall be stored for the full term of the relationship and in any case for no longer than the following 10 years.
  • Marketing of special offers: the Data processed for this purpose shall be stored for 24 months from the time they are collected.
  • Marketing of products and services on behalf of companies in the LifeGate Group and other third parties: the Data processed for the purpose of marketing shall be stored for 24 months from the time they are collected.
  • Defending rights in judicial, administrative and out-of-court proceedings, and in the scope of disputes relating to the services offered: in these cases, we will store your Data for the period strictly necessary for the performance of these purposes.
  • Purposes connected with the discharge of legal, regulatory and EU legislation, with provisions and/or requirements of authorities empowered by law and/or by oversight and compliance bodies: in these cases, we will store your Data for the period strictly necessary for the performance of these purposes.

SHARING YOUR DATA

Your data will only be disclosed to third parties with your express consent, unless disclosure is required by law or is necessary for purposes envisaged by the law for which the data subject’s consent is not required; in these cases, the data may be made available to third parties who will process the data independently and solely for the aforementioned purposes (for example, in the event of a request from law enforcement agencies or the judiciary or other competent bodies or in order to perform obligations arising from the contract to which you are a party). Your Data will not be disseminated under any circumstances.

The Company may use third parties for the processing of your personal data, for certain activities. The third parties who carry out these operations have been carefully selected and are experienced, capable and reliable; they offer suitable assurances of full compliance with the applicable provisions on data processing, including data security.

These third parties will be appointed “Data Processors” for this purpose and will carry out their activities according to the instructions given by the Controller and under its control.  We periodically check that the Processors have duly discharged the tasks entrusted to them and that they continue to provide suitable assurances of full compliance with the provisions on the protection of personal data. You can ask the Data Controller for an updated list of the Processors at any time. Your Data are also processed by our data processing officers charged with the single services. They have received appropriate instructions and training for this purpose.

YOUR DATA PROTECTION RIGHTS AND YOUR RIGHT TO LODGE CLAIMS WITH THE SUPERVISORY AUTHORITY

Under certain conditions, you have the right to ask the Company for:

  • access to your Data;
  • a copy of the data you provided (data portability);
  • rectification of your personal data;
  • cancellation of Data that has no underlying legal basis for processing;
  • withdrawal of your consent, if the consent is the legal basis for processing;
  • restriction of the way we process your Data, within the limits set forth in the legislation to protect personal data;

Right to object: in addition to the rights listed above, you have the right, at any time, to object to the processing of your Data performed by the Controller to pursue its legitimate interests, for reasons connected to your own specific situation. You also have the right to object at any time to the processing of your data for marketing purposes.

You may exercise your rights at any time by sending a registered letter with proof of delivery to LifeGate Consulting and Media SpA, Milan, Via Palermo n. 8 or an email to

You can exercise those rights free of charge, and you are not subject to formal constraints, with some exceptions on the grounds of safeguarding the public interest (e.g. preventing or identifying crimes) and the interests of the Company (e.g. maintaining professional secrecy).  If you decide to exercise any of your aforementioned rights, the Company will confirm that you are entitled to exercise them and will normally reply to you within one month.

If you believe that your Personal Data are being processed in violation of the provisions of the GDPR, you have the right to lodge a complaint with the Italian supervisory authority (Garante), following the procedures and instructions published on the official website www.garanteprivacy.it, or to take legal action.

LINKS TO OTHER WEBSITES

Our Site may contain links to other websites which may have no connection with us.
The Controller does not control or monitor those websites and their content. The Controller is not liable for the content of those sites and the rules and regulations they adopt, also concerning your privacy and the processing of your personal data while you are browsing through those sites. Therefore, we recommend that you take all due care when you use the links on our site to connect to these sites. We also advise you to carefully read their terms and conditions of use and their privacy policies. Our Privacy Notice does not apply to third party websites. Our Site provides links to these sites solely to facilitate the user’s search and navigation and to make it easier to hyperlink to other sites on the internet. Providing links does not represent any recommendation or endorsement by the Controller to access and browse through these sites, nor any assurance of their content, or of the services or goods they provide and sell to internet users.

SOCIAL PLUGINS AND SOCIAL NETWORKS

Some pages of our Site may contain social network plugins (e.g. Facebook, LinkedIn, Instagram, etc.). If you access one of our webpages containing these plugins, your browser will connect directly to the social network servers and the plugin will be displayed on the screen through the browser connection. If you visit our web pages from social networks while you are connected to your social network account, your personal data may be associated with that account. And if you use the plugin functions, your Data will also be associated with your social network account. Additional information about how social networks collect and process your data, and about the rights of data subjects and how your privacy is protected in that context can be found in the data protection area on the pages of your social network account. If you, the data subject, do not want to associate visits to our Site with your social network account, you will need to log off your account before visiting our Site.

Your personal data are collected for the following purposes and using the following services: Interaction with social networks and external platforms. These services make it possible to interact with social networks or with other external platforms. In any case, interaction and data acquired are subject to your privacy settings on each social network. If an interaction service with social networks is embedded, even if users do not use that service, it may still collect data monitoring traffic on the pages where it is embedded.

AMENDMENTS AND UPDATES TO THIS PRIVACY NOTICE

The Company may amend or simply update all or part of this Privacy Notice, including as a result of changes to the laws or regulations that govern this matter and protect your rights. Users will be notified of amendments and updates to this Privacy Notice on the Homepage as soon as they are adopted. They are binding as soon as they are published on the Site. Therefore, we recommend that you visit this section regularly to check the most recent and up-to-date publication of the Privacy Notice.

Updated on 12 January 2021