Privacy Notice on the Processing of Personal Data for Website Browsing and Cookies – Articles 12 et seq. of Regulation (EU) 2016/679 (GDPR)

INTRODUCTION

In compliance with the provisions of EU Regulation 2016/679 (hereinafter, the GDPR), we hereby provide information on the processing of personal data provided by the data subject, in relation to dealings with Miller Vanguard Group S.r.l., understood as Miller Group, and its subsidiaries, affiliates or companies in which it holds an interest. This notice is provided pursuant to Article 13 of the GDPR.

DATA PROCESSOR: The Data Controller of your personal data is Miller Vanguard Group S.r.l., with registered office at Via Santa Tecla 5, 20129 Milan, VAT No. 13840370962, which you may contact for any information or request at the email address info@millergroup.it.

The data provided by the data subject will be processed in countries located within the European Union. Should the data subject’s personal data be processed in a country that is not part of the EU and is not mentioned in the preceding list, the rights granted to the data subject under EU legislation will be ensured and the data subject will be promptly informed.

PURPOSES OF PROCESSING

For all users of the website, personal data may be used to:

– enable functional browsing of the public web pages of the website;

– respond to requests received through the email addresses published on the website;

– obtain anonymous statistical information on the use of the website (e.g. analysis of the most visited pages);

– obtain anonymous statistical information on the geographical areas of origin;

– check that the website functions properly;

– ascertain any liability in the event of unlawful acts committed to the detriment of the website.

The personal data of users who register on the website in the sections specifically dedicated for this purpose will be processed, in addition to the purposes described above, also for purposes connected with the requested services and, in particular, to:

– request information on the products and services offered by the Group;

– view information material;

– enable browsing of the restricted web pages of the website;

– fulfil the contractual obligations of the requested service, where applicable;

– manage applications for a job position within the company;

– manage subscriptions to the information newsletter specifically prepared for users.

– send advertising and promotional information by email;

COOKIES

Through this notice, Miller Vanguard Group S.r.l. provides users with information on the types of cookies, namely text files that websites send to the visitor’s computer or another device connected to the Internet in order to uniquely identify the visitor’s browser or to save information or settings in the browser, which are used by the aforementioned company on its website.

Miller Vanguard Group S.r.l., in fact, uses cookies to improve its website and to provide services and features to users. It is possible to limit or disable the use of cookies through your web browser. However, in this case, some website features may become inaccessible.

This information is not collected in order to be associated with identified data subjects but, by its very nature, it could, through processing and association with data held by third parties, make it possible to identify users.

This category of data includes:

• the IP addresses or domain names of the computers used by users connected to the website;
• the URIs (Uniform Resource Identifiers) of the requested resources, 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 IT environment.

These data are used solely to obtain anonymous statistical information on the use of the website and to check that it functions properly, and are deleted immediately after processing.

• Cookies used by the Miller Group website:

Strictly necessary cookies

These cookies are essential to complete a transaction or finalise a request initiated by the user. For example, they are useful for remembering information provided by the user while browsing the website in order to respond to an express request from the user or to manage the login status during the session.

Functional cookies

These cookies allow the website to remember the choices made by the user in order to optimise its functions. For example, functional cookies allow the website to remember a user’s specific settings, such as country selection and, where set, permanent login status.

Analytical cookies

These cookies enable data to be collected on the user’s use of the website, including the items clicked while browsing, in order to improve the performance and design of the website itself. They may be shared with our third-party analytics-tool providers. However, they are used exclusively for purposes related to our website.

• How to disable cookies

The process for controlling and deleting cookies varies according to the browser used. To find out how to do this with a particular browser, you can use the Help function in the menu, which explains step by step how to control and delete cookies.

List of first-party cookies for which consent is not required

List of third-party cookies for which consent is required

Cookies for which consent is required

Should the user give consent to the cookies listed through one of the methods described in the short notice presented upon first access to the Miller Group website, or by following these instructions, the user may give a single consent for Miller Group and the indicated third parties to install the aforementioned cookies on their device and carry out the resulting processing, or may deny such consent to Miller Group and every other company.

Support in configuring your browser

If the user wishes, cookies can also be managed through their browser settings.

For further information and support, you can also visit the specific help page of the web browser you are using:

Internet Explorer:https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox:https://support.mozilla.org/it/kb/Gestione%20dei%20cookie

Safari:https://support.apple.com/kb/ph21411?locale=it_IT

Chrome:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=itOpera

Please note that if you have made your choices while browsing the pages of Miller Vanguard Group S.r.l. from a different device or simply a different browser, we will not be able to recognise your options and will present the notice again, asking you to make your choices again.

LEGAL BASIS FOR PROCESSING

This website processes data on the basis of consent. By using or browsing this website, the data subject implicitly consents to the possibility of storing only the strictly necessary cookies (hereinafter, “technical cookies”) for the operation of this website. For the other types of cookies, consent may be given or withheld through the appropriate flags in the banner displayed when the website is opened.

DATA RETENTION

Personal data collected while browsing will be retained for the time necessary to carry out the activities specified and for no longer than 14 months. Data voluntarily provided by the user will be retained until the data subject withdraws consent. Consents given with reference to non-technical cookies will be valid for 12 months, after which consent will be requested again.

PERSONAL DATA COLLECTED, WHETHER THE PROVISION OF DATA IS MANDATORY OR OPTIONAL, AND THE CONSEQUENCES OF ANY REFUSAL

Like all websites, this website uses log files, in which information collected automatically during users’ visits is stored. The information collected may include the following:

• Internet Protocol (IP) address;
• type of browser and parameters of the device used to connect to the website;
• name of the Internet Service Provider (ISP);
• date and time of visit;
• the visitor’s referring web page (referral) and exit page;
• where applicable, the number of clicks.

The above information is processed automatically and collected in order to check that the website functions properly, for statistical and security purposes.

For security purposes (anti-spam filters, firewalls, virus detection), automatically recorded data may also include personal data such as the IP address, which may be used, in accordance with applicable laws, to block attempts to damage the website itself or harm other users, or otherwise harmful or criminal activities. Such data are never used to identify or profile the user, but only to protect the website and its users.

The computer systems and software procedures responsible for operating this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes the IP addresses or domain names of the computers used by users connecting to the website, the URIs (Uniform Resource Identifiers) of the requested resources, 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 IT environment.

Apart from what is specified for browsing data, the user is free to provide additional personal data beyond those previously indicated by registering on the website.

Failure to provide personal data may make it impossible to obtain what has been requested, may make it impossible to provide certain services and may impair the website browsing experience.

Finally, by accessing the website, anonymous data will be recorded in order to understand the user experience.

The Data Controller specifies that it does not collect sensitive personal data of data subjects in any circumstances.

PROCESSING METHODS

Pursuant to and for the purposes of Articles 12 et seq. of the GDPR, the personal data of data subjects will be recorded, processed and retained in the electronic archives of Miller Vanguard Group, adopting technical and organisational measures aimed at protecting such data. The processing of the personal data of data subjects may consist of any operation or set of operations among those indicated in Article 4(1)(2) of the GDPR.

Personal data will be processed using tools and procedures suitable for ensuring their security and confidentiality and may be carried out directly and/or through delegated third parties with the aid of IT means or electronic tools.

POTENTIAL RECIPIENTS OF PERSONAL DATA

The data subject’s data may be processed by the employees and collaborators of the Group’s corporate functions responsible for pursuing the purposes indicated above. These employees and collaborators have been expressly authorised to process the data and have received adequate operating instructions pursuant to and for the purposes of Article 29 of the GDPR.

The data processed may be sent to and shared with suppliers and data managers that provide us with certain services (e.g. accounting services, email management services, companies providing IT support services), our advisers (e.g. accountants, etc.) and employees as authorised persons and/or data processors.

In addition, the data subject’s personal data may be disclosed to and processed by external parties acting as independent data controllers pursuant to Articles 4 and 24 of the GDPR, such as, by way of example, authorities and supervisory and control bodies.

RIGHTS OF DATA SUBJECTS:

The data subject may exercise the rights of access, rectification, erasure, restriction, portability and/or objection pursuant to and for the purposes of Articles 15 et seq. of the GDPR, and may request from the Data Controller access to their personal data and the rectification or erasure thereof, or restriction of processing concerning them, or object to their processing.

Before responding to requests, the Data Controller may verify the data subject’s identity in order to assess the legitimacy of the request received.

To exercise these rights, the data subject may contact the Joint Data Controller companies or independent Data Controllers in relation to the areas defined above at info@millergroup.it.

The data subject has the right to request a copy of their personal data in a structured, commonly used and machine-readable format.

The Data Controller will respond within 30 days of receipt of the formal request sent by the data subject.

In the event of a personal data breach concerning the data subject, the latter may lodge a complaint with the competent authority: “Data Protection Authority”.

THE DATA CONTROLLER