PRIVACY POLICY AND CONSENT TO THE PROCESSING OF PERSONAL DATA
Your personal data (hereinafter, the Data) will be processed, through IT and telematic methods and, for particular operations in order to allow your registration and access to the Condé Nast sites (hereinafter, the Sites), as well as to allow you to use the services connected to the Sites (in by way of example: prize shows, events, initiatives, etc …, hereinafter, the Services), in compliance with current legislation and as reported in this information.
A. DATA COLLECTED UPON REGISTRATION ON THE SITES AND SUBSEQUENTLY
Data collected directly from the user. When registering on the Sites, you will be asked to enter some Data. We invite you to check which Data are indicated as mandatory and which, on the other hand, as optional, it being understood that failure to provide the Data marked as mandatory prevents the registration to Sites; failure to provide data marked as optional does not prevent registration on the Sites, but may make some Services and / or some communication channels and / or participation in some events unusable (unless the user returns the Data later). In particular, if the user does not provide his / her mobile phone number, he / she cannot be contacted via text message or other mobile messaging, in case of consent, to be invited to previews, events and / or will not be able to participate in prize events and / or surveys that are carried out via text message or other mobile messaging. You will be able to associate an image (so-called “avatar” or similar) to your user profile and you will have the possibility to express preferences and establish which data to make public and which to keep confidential towards other users of the Sites. ‘user. The user can at any time change their profile and, in cases where the Data Controller allows it, enter the Data not previously provided for the purpose of using the Services and / or participating in initiatives that would otherwise be precluded. By registering on the Sites, users will benefit from a series of exclusive Services reserved for registered users. The Sites are managed by the Owner both by sending periodic e-mails to the e-mail address provided by the user, and by sending a newsletter if the user has requested its receipt. With these communications, the Owner will inform you of the Services present on the Sites, of the news concerning the Sites, as well as of the initiatives that will be organized in favor of the users of the Sites or, exclusively, of registered users (by way of example: prize events, discussion / comment areas, invitations etc …). The newsletter may also contain advertising banners, advertisements and advertising offers from both the Owner and third parties, if the user has given his express consent to receive commercial communications from third parties. Furthermore, the Data Controller manages user communities and reading panels through the Sites. In these areas, the Data Controller may also send research invitations and surveys to its own research communities, to users who purchase the Data Controller’s products and services, as well as to users who have consented to receiving communications from the Data Controller.
Data obtained from third parties. The Data Controller, in accordance with the applicable legislation, may also process some Data obtained from third-party companies, business partners of the Data Controller. The processing of such data takes place in the same manner in which the data obtained directly from the user are processed, in accordance with the provisions of this information. Such data, including information regarding interests, demographic status and online identifiers, can be combined with data obtained directly from the user, in order to generate targeted advertising.
B. REGISTRATION FOR SPECIFIC SERVICES
In order to be able to use some specific and additional Services, at the time of registration, you may have to communicate certain additional Data other than those already provided at the time of registration on the Sites or when registering for other Services. In this case, the requested data will be indicated as required and optional according to the same rules as in the previous point.
C. PURPOSE OF DATA PROCESSING
The Data will be processed by the Data Controller, according to principles of necessity, lawfulness, correctness, proportionality and transparency (i) to allow the use of the Sites and each individual Service (including, for example, the periodic newsletter) for which the performance; (ii) for any fulfillment deriving from legal obligations; (iii) for the sending of or in order to show certain advertising materials and the carrying out of promotional, marketing and / or direct sales activities of products and / or services sold and / or provided by the Data Controller, unless you decide to not to receive these communications when registering on the Sites or subsequently; (iv) only with your consent, for the sending by the Owner of commercial communications relating to products or services of selected third party partners, with whom the Owner has legal relationships (also by communicating data to third parties if specifically permitted); (v) only with your consent, to carry out profiling activities, by inviting you to participate in market research and by combining the data provided by the user with those obtained from third parties, i.e. to evaluate tastes, preferences and habits consumption of the user and for the subsequent sending to the latter of profiled marketing communications and / or targeted advertising; (vi) through the use of aggregated data in anonymous form, to analyze the activities on the Sites and provide a report about sales, customers, traffic patterns and other information to current and potential partners, advertisers, investors and other third parties set off.
If you give your consent to the profiling indicated in point (v) above, it will presuppose an automated activity in order to place you in a category of subjects with homogeneous characteristics in terms of purchase preferences (ie look-a-like models ) on the basis of your previous purchasing experiences, market analyzes and research (including surveys) in which you may have participated, your demographic class (in relation for example to gender, age and place of residence) and your activities on the Sites. The latter are recorded through the cookies present on the Sites (on which you see paragraph N below and the Condé Nast Cookie Policy where you will find detailed information, including on how to disable cookies). In particular, with reference to the construction of the aforementioned look-a-like models that group categories of users with homogeneous and similar characteristics on the basis of the demographic class of the users themselves (for example in relation to gender and age group), the aforementioned data will be transmitted anonymously to the data management platform (ie Data Management Platform) made available to the Data Controller by Permutive, the Data Controller’s supplier and will be matched to the profiles of subscribers and users who are members of the communities, in order to provide targeted advertising.
We would like to point out that if you had to withdraw your consent to the use of cookies for advertising purposes, you will continue to receive advertising on the Sites. Even if this advertising will not be based on your possible interests, using the information collected by cookies and technologies placed on your device, the aforementioned advertising will, where possible, be relevant to the context in which it is displayed on your device, based on the content of the sites you are visiting and your approximate location (as indicated by your IP address). the previous points (iv) and (v) can take place through automated contact tools (via email or text message), traditional (telephone calls with operator and postal items) and / or other types (through promotional contents that are shown to you online). In any case, you can revoke your consent, even partially, for example by consenting only to traditional contact tools or opposing the processing of your data for all or only some of the aforementioned purposes.
D. LEGAL BASES FOR DATA PROCESSING
The processing of data for the purpose indicated in point (i) of the preceding paragraph is carried out to allow you to use the Services, and therefore does not require your express consent (pursuant to Article 6.1 letter (b) of the Regulations). The processing of data for the purpose indicated in point (ii) of the preceding paragraph is carried out to comply with legal obligations, and therefore does not require your express consent (pursuant to Article 6.1 letter (c) of the regulation).
The processing of data for the purposes indicated in points (iii) and (vi) is carried out on the basis of the legitimate interest of the Data Controller (pursuant to Article 6.1 letter (f) of the Regulations), except for your opposition at the time of registration on the Sites or later. In particular, the Data Controller may carry out marketing activities directly, show you online advertising, and carry out analyzes on the use of the Sites in the absence of your express consent (by virtue of an assessment of the prevalence of your interest in carrying out these activities, in the absence of real prejudice to your interests, fundamental rights and freedoms and as foreseen by the Recital 47 of the Regulation which qualifies as “legitimate interest” to process personal data for direct marketing purposes), but only up to your opposition to such treatment. The processing of data for the purposes indicated in points (iv) and (v) of the preceding paragraph is carried out only in the presence of your express and specific consent and on the basis of the same. Where the legal basis of legitimate interest is invoked to process the Data in order to show you advertising based on the content of the Sites you are visiting, you can object to such processing by accessing the “Review your cookie choices” section.
The provision of Data for the purposes referred to in points (i) and (ii) of the preceding paragraph is therefore necessary for the purpose of registering with the Sites and to allow you to use the Services: failure to communicate them will make it impossible to register with Sites. The provision of data for the purposes referred to in points from (iii) to (vi) is optional, so that your refusal will make it impossible for the owner to carry out the activities described therein.
E. SCOPE OF COMMUNICATION AND DISCLOSURE OF DATA
The data you provide will be processed in compliance with the Regulations and, in any case, in such a way as to guarantee the security and confidentiality of the same, to prevent unauthorized disclosure or use, alteration or destruction. The data will be processed on paper and / or electronically, including with the aid of electronic and information means. The Data Controller will proceed to process your data in its own technological infrastructure and / or using the technological infrastructures of third party suppliers appointed as data processors.
The Data may be disclosed, exclusively for the purposes indicated in this statement, to the categories of subjects indicated below and acting as data processors on behalf of the Data Controller:
(i) people, companies, associations or professional firms that provide assistance and consultancy services and activities to the Data Controller, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;
(ii) companies that provide certain services relating to the Sites on behalf of the Owner, with particular but not exclusive reference to the analysis of Data, the management of payment services, marketing activities, the management of services provided through the Sites and their personalization in favor of the user.
The Data may also be communicated, exclusively for the purposes indicated in this statement, to the categories of subjects indicated below and who act as data processors on behalf of the Data Controller or independent data controllers):
(i) companies belonging to the same corporate group as the Data Controller, with particular but not exclusive reference to data analysis activities in aggregate and anonymized form, identity management of user profiles on the Sites, profiling and profiled marketing;
(ii) subjects whose right to access the Data is recognized by law and secondary legislation;
(iii) third party companies and customers with whom the Data Controller collaborates as a commercial partner (e.g. for the promotion of goods and services).
The list of names of the subjects to whom your data are or may be communicated can be provided by requesting it at [email protected]. The treatment will be entrusted, in the single operations, to natural persons appointed in charge of the treatment.
If for technical and / or operational reasons it becomes necessary to make use of subjects the processing will be regulated in accordance with the provisions of Chapter V of the Regulation and authorized on the basis of specific decisions. All the necessary precautions will therefore be taken in order to guarantee the most complete protection of personal data, basing this transfer: a) on adequacy decisions of the third country recipients expressed; b) on adequate guarantees expressed by the third party recipient pursuant to art. 46 of the Regulation; c) on the adoption of binding corporate rules, (so-called corporate binding rules) or standard contractual clauses (so-called standard contractual clauses).
F. USERS UNDER AGE
The Owner encourages parents to monitor their children’s use of the Internet for a safe and filtered use of its contents, including through the use of parental control tools. In addition to ensuring an online environment suitable for minors, these tools can prevent the disclosure of personal data by children or young people who do not have the consent of their parents. As regards the collection and processing of personal data, the Data Controller does not carry out any processing of the personal data of minors without the consent of their parents. Registration on the Sites is therefore permitted only to users of age or to users who have reached the age of 16. The Owner, however, encourages the registration to the Sites of the parents of registered users minors: in this way parents have the opportunity to use the Services and to always be aware of the initiatives that the Owner makes available to their children, and to check them. thus the correspondence to one’s own expectations and to one’s own models and educational paths. In relation to the provision of some Services, the Owner does not require users to disclose their age, and / or is not in a position to find out about the age of the users. The Data Controller therefore invites all users who are under the age of 18 not to communicate their personal data in any case without the authorization of a parent, reserving the right to inhibit access to the Services and / or exclude from the Sites any user who has concealed their minor age or has in any case communicated their personal data in the absence of the consent of their parents even though they are under the age of 18.
G. LINKS TO THIRD PARTY SERVICES SITES
Within the Sites and / or other messages and / or communications that the Data Controller will send to the user as part of the provision of the Services, banners, advertisements and / or advertisements from third parties, advertisers or commercial partners may be contained of the Owner. The Data Controller informs users that by adhering to the proposals of the aforementioned third parties, users will be able to purchase goods or services and access multimedia pages of exclusive relevance to such third parties, which are outside the control of the Data Controller and which are not in any manner required to comply with the provisions of this information. The Data Controller therefore invites users to provide their data to such third parties only in the face of suitable guarantees of confidentiality and to pay the utmost attention before joining the services they offer, in relation to which the Data Controller will not be able to carry out any checks. , nor will it be involved in any other way, nor responsible.
H. PERIOD OF STORAGE OF PERSONAL DATA
The Data collected for the processing purposes indicated in points (i), (ii), (iii) and (vi) of the paragraph “Purpose of data processing” will be kept until the account is canceled on the Sites, or until your express request for deletion of data (which, in the case of data provided for the purposes referred to in points (i) and (ii), will however result in the cancellation of the account and the inability to further use the Services) except in the case of exceptional need for the Data Controller to keep the Data to defend their rights in relation to disputes outstanding at the time of the request or on the recommendation of the public authorities. The Data collected for the processing purposes indicated in points (iv) and (v) of the paragraph “Purpose of data processing” will be kept until you withdraw your consent to the activities described therein or until your account on the Sites is canceled. , or to the express request for cancellation of such Data, except for the exceptional need of the Data Controller to keep the Data to defend their rights in relation to disputes outstanding at the time of the request, or on the indication of the public authorities.
I. YOUR RIGHTS
We remind you that you have the right:
– to obtain the termination of the processing in cases where your data are processed for direct marketing and / or profiling purposes, also in relation to products or services identical to those already purchased by the Data Controller and / or provided through the Sites (cd right to object)
– to obtain information in relation to the purposes for which your data are processed, the period of processing and the subjects to whom the data are communicated (so-called right of access)
– to obtain the correction or integration of inaccurate data concerning you (so-called right of rectification)
-to keep keep the deletion of the Data concerning you in the following cases (a) the Data are no longer necessary for the purposes for which they were collected; (b) You have withdrawn your consent to the processing of data if they are processed on the basis of your consent; (c) You have objected to the processing of the Data concerning you in the event that they are processed for a legitimate interest of the Data Controller; or (d) the processing of your data does not comply with the law. However, we point out that the retention of the Data by the Data Controller is lawful if it is necessary to allow you to fulfill a legal obligation or to ascertain, exercise or defend a right in court (so-called right of cancellation)
– to obtain that the Data concerning you are only stored without any other use being made of them in the following cases (a) you contest the accuracy of the Data, for the period necessary to allow us to verify the accuracy of such Data; (b) the processing is unlawful but you still oppose the cancellation of the data by the Data Controller; (c) the Data is necessary for you to ascertain, exercise or defend a right in court; (d) You have opposed the processing and are awaiting verification of the possible prevalence of the legitimate reasons of the Data Controller with respect to those of the interested party (c.f. right of limitation)
– to receive the Data concerning you processed by automated means in a commonly used format, readable by an automatic and interoperable device, if they are processed by virtue of registration on the Sites or on the basis of your consent (so-called portability right).
Finally, we remind you that you have the right to contact the Guarantor for the protection of personal data Piazza Venezia, 11 – 00187 Rome RM) to assert your rights in relation to the processing of your personal data.
L. CONTACTS TO ENSURE YOUR RIGHTS
The data controller of your personal data is Edizioni Condé Nast S.p.A .. The Data Controller has appointed pursuant to art. 37 ff. of the Regulations a Data Protection Officer (also known as DPO), domiciled for the assignment at Edizioni Condé Nast S.p.A. and who can be contacted for questions relating to the processing of your data at [email protected]. By writing to the same email address you can exercise the rights indicated in the preceding paragraph. You can also modify at any time the consents issued regarding the processing of your data by the owner, directly through the privacy settings of your account.
In addition to the foregoing, if the promotional e-mail messages sent by the Owner are no longer of your interest, it will be sufficient to click on the link at the bottom of these e-mails, to no longer receive any communication to that effect.
M. CHANGES TO THIS INFORMATION NOTICE
Without prejudice to the fact that the Data Controller in any case does not proceed with processing operations other than those expressly authorized and / or requested by each user, this information may be subject to changes to comply with new provisions of the law, with the changed processing policies of personal data by the Owner and / or following changes in the characteristics of the Sites and / or Services. Each updated version of this information will be made available on the Sites in the dedicated section: the Owner therefore invites all users to periodically consult the Sites to always be informed of the latest published version.
N. NAVIGATION OF THE SITES AND COOKIES
A “cookie” is a small string of data containing an anonymous unique identification code that is sent to your browser from a web server and which are subsequently stored on the hard drive of the user’s computer. The cookie is then reread and recognized by the website that sent it each time subsequent connections are made. Thanks to cookies, the recognition of the registered user by the Sites can be facilitated, for example avoiding the need to authenticate (by means of “log-in” and “password”) at each access to the same Sites. Furthermore, cookies can allow users to customize their use of the Sites by saving their favorite settings. Cookies also record some information relating to the user’s navigation on the Sites that can be used to improve the performance of the Sites and offer personalized services or advertising.
Each user has the right to disable cookies (i) through the software used on their personal computer to consult the Internet (so-called “browser”), (ii) expressing their consent to the use of cookies by clicking on the “Accept cookies “of the banner that appears on the first visit to the Sites, or at any time during each browsing experience (iii) by selecting the different options available to limit or block configurable cookies by accessing the “Review your cookie choices” section (present in the footer of the Sites). We therefore invite you to check your browser settings and those on the “Review your cookie choices” page of the Sites, in order to adjust them according to your preferences, however bearing in mind that to use some Services it may be necessary to enable reception of some cookies (in such cases you will be duly informed).
The technological platform through which the Sites are made available to the user, also through cookies, automatically records some information on the personal computer and on the user’s navigation, such as: the name of his Internet access provider, site of origin, pages visited, date and duration of the visit, etc … This information is used to allow access to the Sites and / or the enjoyment of certain Services and / or for purposes of Identity Management (ie management of the identity of the profiles of users on the Sites) and in the context of other IT services and / or can be used in aggregate form for statistical purposes. Through cookies, the Sites also have the ability to analyze, on the basis of aggregate data, the interests and preferences expressed by the user within the services made available and, exclusively with your consent, to show targeted advertising and content. personalized, as well as to measure the effectiveness of such advertising campaigns.