This section sets out how the site is managed with regard to the processing of personal data of its users.
This policy is also provided pursuant to Article 13 and 14 of Regulation (EU) 2016/679 to those who interact with the web services offered by Intesa Sanpaolo Innovation Center S.p.A., with registered office in Corso Inghilterra 3, 10138 Turin, and Cariplo Factory S.r.l., with registered office in Via Daniele Manin 23, 20121 Milan, as autonomous Data Controllers (hereinafter the “Companies” or “Data Controllers”), accessible electronically at the URL:
This document also considers Recommendation No. 2 of 2001 that the European data protection authorities have adopted to set out minimum requirements for the collection of on-line personal data.
The policy is provided only for the website www.circulareconomylab.it and not for other websites that may be consulted by the user through any links in such website.
Data, purposes, and methods of processing
The data provided and processed by Cariplo Factory s.r.l. and Intesa Sanpaolo Innovation Center S.p.A. concern common, personal and sensitive data. The data is processed in accordance with the obligations of correctness, lawfulness and transparency in compliance with the applicable legislation, protecting the confidentiality and rights of interested parties. The provision of the requested data is compulsory in accordance with the applicable laws and regulations and their non-provision may prevent access to the requested service.
The processing operations connected to the web services of this site are carried out only by technical personnel authorised to the processing and are disclosed to third parties only if necessary for this purpose. The personal data provided by users who request information material are used only to perform the service requested and are disclosed to third parties only if necessary for this purpose.
Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are adopted to prevent data loss, illegal or incorrect use and unauthorised access.
The data provided by the user, including through the completion of application forms, are used to register and participate in the initiatives promoted by the data controller both in the context of the Circular Economy Lab project and for other initiatives promoted by the data controllers themselves. For the pursuit of these purposes, it may be necessary to disclose your Personal Data to promoters and investors of the Circular Economy Lab initiative.
To achieve the purposes indicated above, it might be necessary for the Companies to communicate your Personal Data also to Third parties operating within and outside the European Union and that process your Personal Data as part of providing and managing procedures and IT systems.
The IT systems and software procedures used to operate this website acquire, during their normal operation and only for the duration of the connection, some personal data whose transmission is implied by the use of Internet communication protocols (“navigation data”).
These data will not be collected to be associated with identified data subjects, but by their very nature could, through processing and association with data retained by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of the computers used by users of the site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.
These data are processed for the following purposes:
• instructions given by Supervisory and Control Bodies, also in relation to the obligations to monitor operational and credit risks at Banking Group level; the processing of the user’s Personal Data to comply with legal requirements is mandatory and the user’s consent is not required.
• to pursue a legitimate interest of the Companies or third parties if such interest is not in conflict with the interests or fundamental rights and freedoms of the data subjects (Article 6.1 letter f) of Regulation (EU) No. 679/2016), i.e.:
- ascertainment of liability in case of cybercrimes to the detriment of the site and for verification in case of disputes;
- to pursue any further legitimate interests; In the latter case, the Data Controller may process the user’s Personal Data only after having informed the user and having verified that the pursuit of its legitimate interests or those of third parties does not violate the user’s rights and fundamental freedoms;
and the user’s consent is not required.
Navigation data will remain on the servers for 12 months. Personal Data may also be processed for a longer period if an action interrupting and/or suspending the limitation period justifies an extension of the data storage.
Data voluntarily provided by the user
The optional, explicit, and voluntary sending of e-mails to the addresses indicated on this site implies the acquisition of the sender’s address, as this information is necessary to respond to requests, as well as any other personal data included in the message. The provision of personal data is optional but is strictly necessary for the processing of the requests made by the user and for performance of the services offered.
Rights of the data subject
Data subjects have the right at any time to exercise the rights provided for in the Regulation (right of access, rectification, erasure, restriction of processing, portability of data, objection). All requests relating to the exercise of the aforementioned Articles 15 - 22 of the Regulation may be submitted to:
- Intesa Sanpaolo Innovation Center S.p.A., with registered office in Corso Inghilterra 3, 10138 Turin, through Intesa Sanpaolo S.p.A. Tutela Aziendale - Privacy, Piazza San Carlo 156 - 10121 Turin; e-mail address email@example.com.
- Cariplo factory S.r.l., with registered office in Via Daniele Manin 23, 20121 Milan; e-mail address firstname.lastname@example.org;
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