PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA

This privacy notice is provided pursuant to Article 13 of Italian Legislative Decree No. 196 of 30 June 2003, as amended (the Personal Data Protection Code), and pursuant to Article 14 of Regulation (EU) 2016/679 (GDPR).

We inform you that the personal data you provide will be processed in accordance with the protection principles laid down in the Personal Data Protection Code, as amended, and with all European and national legislation and/or measures issued by supervisory authorities, including those adopted after this privacy notice is signed.

To help you understand this privacy notice, the link below refers to Article 5 of the GDPR, which provides a list of useful definitions.

(See Article 5 of the GDPR at the bottom of the page)

1.PURPOSES OF PROCESSING

Processing is necessary for, and serves the purpose of, using the website www.millergroup.it.

Its purpose is to enable users to contact Miller Vanguard Group S.R.L. directly to obtain further information about its services, apply for a position within the company or request an informative newsletter specifically prepared for users.

The processing of Data is necessary to handle requests received from website users and to enable Miller Vanguard Group S.R.L. to answer questions, contact prospective candidates or customers, or send the informative newsletter to users who request it.

2.TYPES OF DATA COLLECTED AND PROCESSED

Users are informed that the personal Data collected and processed are classified as personal identification data.

To contact Miller Vanguard Group S.R.L. directly, each user will be required to provide the following personal data:

• first name;
• surname;
• personal email address;
• city of residence.

Refusal to provide these data will make it impossible to contact us. Mandatory fields are marked with an * (asterisk).

The following personal data may also be provided voluntarily to facilitate better communication:

• personal telephone number;
• residential address.

To apply for a position within Miller Vanguard Group S.R.L., each user will instead be required to provide the following personal data:

• first name;
• surname;
• personal email address;
• personal telephone number;
• province of residence.

Refusal to provide these data will make it impossible to contact us. Mandatory fields are marked with an * (asterisk).

To receive the informative newsletter from Miller Vanguard Group S.R.L., each user will be required to provide the following data:

• first name
• surname
• personal email address

Refusal to provide these data will make it impossible to receive the informative newsletter. Mandatory fields are marked with an * (asterisk).

3.CONTROLLER, PROCESSORS AND PERSONS AUTHORISED TO PROCESS DATA

The controller is Miller Vanguard Group S.R.L., acting through its legal representatives for the time being, with its registered office at Piazza Giuseppe Grandi 11, 20129, Milan, VAT No. 13840370962, certified email (PEC): millervanguardgroup@legalmail.it, email: info@millergroup.it.

4.PROCESSING METHODS

The personal Data provided will be processed at the premises of Miller Vanguard Group S.R.L., at Piazza Giuseppe Grandi 11, 20129, Milan, using non-digital procedures in the manner and to the extent necessary to pursue the purposes stated above, and will be stored at the same premises.

Users are also informed that the personal Data provided will be processed using computerised procedures in the manner and to the extent necessary to pursue the purposes stated above. For this purpose, the Controller uses mail.google.com (Gmail) to handle the requests it receives.

5.RETENTION PERIOD

The Data provided will be processed and retained by the Controller for purposes strictly related to handling requests received from users or contacting prospective candidates.

Once customers/candidates have been contacted, the data will be retained for a period of 60 days. At the end of this period, the data will be deleted.

6.USERS’ RIGHTS

Users may exercise their rights against the Controller at any time pursuant to Italian Legislative Decree No. 193/2006 and Regulation (EU) 2016/679.

For completeness, all the rights enshrined in the GDPR are set out below.

A.RIGHT OF ACCESS BY THE DATA SUBJECT – Article 15 of Regulation (EU) 2016/679

The data subject has the right to obtain from the controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access to the personal data and the following information:

1. a) the purposes of the processing;
2. b) the categories of personal data concerned;
3. c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
4. d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
6. f) the right to lodge a complaint with a supervisory authority;
7. g) where the personal data are not collected from the data subject, any available information as to their source;
8. h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data are transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

The controller provides a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information is provided in a commonly used electronic form.

The right to obtain a copy referred to in paragraph 3 must not adversely affect the rights and freedoms of others.

B.RIGHT TO RECTIFICATION – Article 16 of Regulation (EU) 2016/679

The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

C.RIGHT TO ERASURE (“RIGHT TO BE FORGOTTEN”) – Article 17 of Regulation (EU) 2016/679

The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies:

1. a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. b) the data subject withdraws consent on which the processing is based under Article 6(1)(a) or Article 9(2)(a), and there is no other legal ground for the processing;
3. c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
4. d) the personal data have been unlawfully processed;
5. e) the personal data have to be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject;
6. f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase them, the controller, taking account of available technology and the cost of implementation, takes reasonable steps, including technical measures, to inform controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

Paragraphs 1 and 2 do not apply to the extent that processing is necessary:

1. a) for exercising the right of freedom of expression and information;
2. b) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
3. c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);
4. d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. e) for the establishment, exercise or defence of legal claims.

D.RIGHT TO RESTRICTION OF PROCESSING – Article 18 of Regulation (EU) 2016/679

The data subject has the right to obtain from the controller restriction of processing where one of the following applies:

1. a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
2. b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
3. c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
4. d) the data subject has objected to processing pursuant to Article 21(1), pending verification of whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted under paragraph 1, such personal data, with the exception of storage, are processed only with the data subject’s consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing pursuant to paragraph 1 is informed by the controller before the restriction of processing is lifted.

E.RIGHT TO DATA PORTABILITY – Article 20 of Regulation (EU) 2016/679

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

1. a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b); and
2. b) the processing is carried out by automated means.

In exercising their right to data portability pursuant to paragraph 1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The exercise of the right referred to in paragraph 1 of this Article is without prejudice to Article 17. That right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The right referred to in paragraph 1 must not adversely affect the rights and freedoms of others.

F.RIGHT TO OBJECT – Article 21 of Regulation (EU) 2016/679

The data subject has the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Article 6(1)(e) or (f), including profiling based on those provisions. The controller no longer processes the personal data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing, including profiling to the extent that it is related to such direct marketing.

Where the data subject objects to processing for direct marketing purposes, the personal data are no longer processed for such purposes.

At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 is explicitly brought to the attention of the data subject and is presented clearly and separately from any other information.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.

Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to their particular situation, has the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

ARTICLE 4 GDPR

For the purposes of this Regulation:

Personal data: any information relating to an identified or identifiable natural person, also referred to as a “data subject”; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing: any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future;

Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

Pseudonymisation: the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

Filing system: any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;

Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

Recipient: a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not regarded as recipients; the processing of those data by those public authorities complies with the applicable data protection rules according to the purposes of the processing;

Third party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data;

Consent of the data subject: any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them;

Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed;

Genetic data: personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question;

Biometric data: personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person which allow or confirm the unique identification of that natural person, such as facial images or fingerprint data;

Data concerning health: personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about their health status;

Main establishment:

1. a) as regards a controller with establishments in more than one Member State, the place of its central administration in the Union, unless decisions on the purposes and means of the processing of personal data are taken in another establishment of the controller in the Union and that establishment has the power to have such decisions implemented, in which case the establishment having taken such decisions is considered to be the main establishment;
2. b) as regards a processor with establishments in more than one Member State, the place of its central administration in the Union or, if the processor has no central administration in the Union, the establishment of the processor in the Union where the main processing activities in the context of the activities of an establishment of the processor take place, to the extent that the processor is subject to specific obligations under this Regulation;

Representative: a natural or legal person established in the Union who, designated by the controller or processor in writing pursuant to Article 27, represents the controller or processor with regard to their respective obligations under this Regulation;

Enterprise: a natural or legal person engaged in an economic activity, irrespective of its legal form, including partnerships or associations regularly engaged in an economic activity;

Group of undertakings: a controlling undertaking and its controlled undertakings;

Binding corporate rules: personal data protection policies adhered to by a controller or processor established in the territory of a Member State for transfers or a set of transfers of personal data to a controller or processor in one or more third countries within a group of undertakings, or a group of enterprises engaged in a joint economic activity;

Supervisory authority: an independent public authority established by a Member State pursuant to Article 51;

Supervisory authority concerned: a supervisory authority which is concerned by the processing of personal data because:

1. a) the controller or processor is established on the territory of the Member State of that supervisory authority;
2. b) data subjects residing in the Member State of that supervisory authority are substantially affected or likely to be substantially affected by the processing; or
3. c) a complaint has been lodged with that supervisory authority;

Cross-border processing:

1. a) processing of personal data which takes place in the context of the activities of establishments in more than one Member State of a controller or processor in the Union, where the controller or processor is established in more than one Member State; or
2. b) processing of personal data which takes place in the context of the activities of a single establishment of a controller or processor in the Union but which substantially affects or is likely to substantially affect data subjects in more than one Member State;

Relevant and reasoned objection: an objection to a draft decision as to whether there is an infringement of this Regulation, or whether envisaged action in relation to the controller or processor complies with this Regulation, which clearly demonstrates the significance of the risks posed by the draft decision as regards the fundamental rights and freedoms of data subjects and, where applicable, the free flow of personal data within the Union;

Information society service: a service as defined in Article 1(1)(b) of Directive (EU) 2015/1535 of the European Parliament and of the Council (19);

International organisation: an organisation and its subordinate bodies governed by public international law, or any other body which is set up by, or on the basis of, an agreement between two or more countries.