Privacy Notice on the Processing of Personal Data

[EU Regulation No. 2016/679]

Pursuant to Article 13 of EU Regulation No. 2016/679, also known as the General Data Protection Regulation (hereinafter the “GDPR”), Editrice Circolare Società Cooperativa (publisher of the magazine EconomiaCircolare.com) hereby informs you that your personal data (hereinafter the “Data”) will be processed in compliance with the GDPR and all other applicable legislation concerning the processing of personal data, in accordance with this Privacy Notice.

1. Data Controller. Data Protection Officer.

The Data Controller is Editrice Circolare Società Cooperativa, with registered office at Via Romanello da Forlì 18, 00176 Rome, Italy (hereinafter the “Data Controller”). The Data Protection Officer is Alessandra De Santis, who can be contacted at editricecircolare@pec.it for information concerning the processing of the Data.

2. Categories of Data.

The Data processed by the Data Controller include: (i) personal identification data (first name, last name, age, gender), residential or home address and contact details (telephone number, email address); (ii) bank and/or payment details required for the performance of contracts.

3. Purposes and legal basis of the processing. Legitimate interest.

The Data will be processed, including by automated means, for administrative purposes and to comply with legal obligations, pursuant to Article 6(1)(b) and (c) of the GDPR, as well as for the purposes of the legitimate interests pursued by the Data Controller, pursuant to Article 6(1)(f) of the GDPR, in relation to:

1. carrying out all stages connected with:
   
   1. subscription to the newsletter;
   2. subscription to standard or Community memberships;
   3. contributions to support the activities of the magazine
   4. participation in specific projects promoted by the Data Controller, including related operational activities (e.g. communications and/or summaries concerning payments);
2. compliance with internal administrative procedures and fulfilment of obligations under laws or regulations in force in Italy.

In any event, the processing of your Data based on the Data Controller’s legitimate interest is carried out not only in compliance with Article 6(1)(f) of the GDPR, but also in accordance with Recital 47 and Opinion No. 6/2014 of the Article 29 Data Protection Working Party, para. III.3.1.

4. Methods of processing.

Your Data are collected and recorded lawfully and fairly for the purposes indicated above and are processed in paper or automated form, including through their entry into and organisation within databases, in compliance with the security measures required under the GDPR and, in any event, in such a way as to ensure the security and confidentiality of the Data.

5. Recipients or categories of recipients.

The Data may be made accessible, disclosed or communicated to the following parties:

• public or private entities, natural or legal persons, whose services the Data Controller uses to carry out activities instrumental to achieving the purposes referred to above, or to whom the Data Controller is required to disclose the Data pursuant to legal or contractual obligations;
• employees and/or collaborators who process the Data on behalf of the Data Controller as authorised persons;
• consultants responsible for tax and accounting obligations who process the Data as Data Processors;
• non-profit organisations belonging to the group of which the Data Controller is part and which are project partners.

6. Transfer of Data abroad.

No transfer of Data abroad is envisaged.

7. Retention period.

The Data will be retained for no longer than 10 (ten) years for administrative purposes and, in any event, for no longer than is strictly necessary to pursue the Data Controller’s legitimate interest.

8. Rights of access, erasure, restriction and portability.

The Data Controller hereby informs you that you are entitled to exercise the rights set out in Articles 15 to 20 of the GDPR. By way of example, by sending a specific request to editricecircolare@pec.it, you may:

1. obtain confirmation as to whether or not personal data concerning you are being processed;
2. where processing is taking place, obtain access to the Data and information concerning the processing, as well as request a copy of the Data;
3. obtain the rectification of inaccurate Data and the completion of incomplete personal data;
4. obtain, where one of the conditions set out in Article 17 of the GDPR applies, the erasure of Data concerning you;
5. obtain, in the cases provided for under Article 18 of the GDPR, restriction of the processing of Data concerning you;
6. receive the Data concerning you in a structured, commonly used and machine-readable format and request that they be transmitted to another data controller, where technically feasible.

9. Right to object.

Pursuant to Article 21 of the GDPR, you also have the right to object at any time to the processing of your Data carried out for the purposes of the legitimate interests pursued by the Data Controller, by writing to editricecircolare@pec.it. If you object, the Data will no longer be processed unless there are legitimate grounds for the processing which override the interests, rights and freedoms of the data subjects, or where processing is necessary for the establishment, exercise or defence of legal claims.

10. Right to lodge a complaint with the Data Protection Authority.

The Data Controller also informs you that you may lodge a complaint with the Garante per la Protezione dei Dati Personali (Italian Data Protection Authority) if you believe that your rights under the GDPR or any other applicable legislation have been infringed, in accordance with the procedures indicated on the website of the Garante per la Protezione dei Dati Personali, available at: www.garanteprivacy.it.