PRIVACY & COOKIE POLICY
This privacy policy is intended to provide all information regarding the processing of personal data carried out by E-New Normal S.r.l.s. when the user browses the company's website (as better specified below).
INTRODUCTION - WHO ARE WE?
E-New Normal S.r.l.s. with registered office at Via Paleocapa 6 – 20121 Milan.
VAT No.: 13083690969 (hereinafter, also the “Data Controller”), in its capacity as the controller of the personal data of users (hereinafter, the “Users”) who browse and use the services available on the website (hereinafter, the “Website”), provides the following privacy policy pursuant to Art. 13 of EU Regulation 2016/679 of April 27, 2016 (hereinafter, the “Regulation” or the “Applicable Law”).
HOW TO CONTACT US
The Data Controller takes the right to privacy and the protection of its Users' personal data very seriously. For any information regarding this privacy policy, Users may contact the Data Controller at any time using the following methods:
By sending a registered letter with return receipt to the Data Controller's registered office: Via Paleocapa 6 – 20121 Milan
By sending an email to: info@ennmedia.it
The Data Controller has not appointed a Data Protection Officer (DPO), as the Data Controller is not subject to the appointment obligation pursuant to Art. 37 of the Regulation.
WHAT DO WE DO? – PROCESSING PURPOSES
By browsing the Website, the User can stay updated on available content and learn about the services and initiatives promoted by the Data Controller. In particular, through the form in the “Contact Us” section, the User can contact the Data Controller for various purposes, such as, by way of example and not limitation, obtaining more information on the services offered through the Website or requesting to establish a collaboration with the Data Controller (hereinafter, the “Service”).
In relation to the activities that can be carried out through the Website, the Data Controller collects personal data relating to Users.
Users' personal data will be lawfully processed by the Data Controller for the following processing purposes:
a) Contact and/or information requests. The User's personal data collected by the Data Controller for the purposes of contact and/or information requests on the Website are those indicated from time to time in the specific contact form, which may include: first name, last name, email address, phone number, gender, city of residence and/or domicile, as well as any personal information that the User may voluntarily publish. The User's personal data will be used by the Data Controller solely for the purpose of verifying the User's identity, thereby preventing possible fraud or abuse, and contacting the User exclusively for service-related reasons (e.g., to respond to their contact request). Without prejudice to what is provided elsewhere in this privacy policy, under no circumstances will the Data Controller make Users' personal data accessible to other Users and/or third parties.
b) Legal obligations, that is, to comply with obligations provided for by law, an authority, a regulation, or European legislation.
Providing personal data for the aforementioned processing purposes is optional but necessary, as failure to provide it will make it impossible for the User to use the Service offered through the Website.
ADDITIONAL PROCESSING PURPOSES
1.1 Editorial newsletter
With the user's free and optional consent, some of the user's personal data (specifically name, surname, and email address) may also be processed by the Data Controller for the purpose of sending the newsletter.
If consent is not given, the ability to browse the website and/or use the service offered through the website will not be affected in any way.
If consent is given, the user may withdraw it at any time by submitting a request to the Data Controller in the manner indicated in paragraph 9 of this policy.
The user may also easily opt out of receiving further communications by clicking the appropriate link for withdrawing consent, which is included in every email containing the newsletter. Once consent is withdrawn, the Data Controller will send the user an email confirming that the withdrawal has been processed.
1.2 Marketing (sending advertising material and commercial communications)
Some of the user's personal data (specifically name, surname, email, and phone number) may also be processed by the Data Controller for marketing purposes (sending advertising material and commercial communications, direct sales, or conducting market research), or so that the Data Controller may contact the user via mail, email, telephone (landline and/or mobile, using automated calling systems with or without human intervention), and/or SMS and/or other messaging systems to present the user with offers, promotions, and commercial opportunities related to the purchase of products and/or services offered by the Data Controller and/or third-party companies.
If consent is not given, the ability to browse the website and/or use the service offered through the website will not be affected in any way.
If consent is given, the user may withdraw it at any time by submitting a request to the Data Controller in the manner indicated in paragraph 9 of this policy.
If the user wishes to withdraw their consent to receive promotional phone calls, they should send a request to the Data Controller using the methods indicated in paragraph 9 of this policy. If the user continues to receive promotional messages 24 hours after withdrawing consent, they are requested to report the issue to the Data Controller using the contact details provided in paragraph 9 of this policy.
LEGAL BASIS
Contact and/or information requests (as described in paragraph 3, letter a): the legal basis is Article 6(1)(b) of the GDPR, meaning the processing is necessary for the performance of a contract to which the user is a party or for the implementation of pre-contractual measures taken at the user's request.
Legal obligations (as described in paragraph 3, letter b): the legal basis is Article 6(1)(c) of the GDPR, as the processing is necessary to comply with a legal obligation to which the Data Controller is subject.
Additional processing purposes: for processing related to editorial newsletter and marketing activities (as described in paragraphs 1.1 and 1.2), the legal basis is Article 6(1)(a) of the GDPR, which is the data subject's consent to the processing of their personal data for one or more specific purposes. For this reason, the Data Controller asks the user to provide specific, free, and optional consent for each of these processing purposes.
PROCESSING METHODS AND DATA RETENTION PERIODS
The Data Controller will process user personal data using manual and electronic tools, with logic strictly related to the purposes themselves and, in any event, in a manner that ensures the security and confidentiality of the data.
User personal data will be stored for the time strictly necessary to fulfill the primary purposes described in paragraph 3 or, in any event, for the time necessary to protect the interests of both the users and the Data Controller in civil proceedings.
In the case referred to in paragraph 4, user personal data will be stored for the time strictly necessary to achieve the purposes indicated therein and, in any event, until the user withdraws their consent.
Any retention periods required by law or regulation remain unaffected.
SCOPE OF DATA DISCLOSURE AND DISTRIBUTION
User personal data may be disclosed to the Data Controller's employees and/or collaborators tasked with managing the Site and user requests. These individuals, having been instructed by the Data Controller in accordance with Article 29 of the GDPR, will process user data exclusively for the purposes stated in this policy and in compliance with applicable regulations.
Users' personal data may also be accessed by third parties who may process personal data on behalf of the Data Controller as Data Processors, such as, for example, IT and logistics service providers functional to the operation of the Website, outsourcing or cloud computing service providers, professionals, and consultants.
Users have the right to obtain a list of any Data Processors appointed by the Data Controller by making a request in the manner indicated in paragraph 9 of this policy.
COOKIE POLICY
This paragraph describes the characteristics and purposes of the cookies used on the Website, as well as instructions on how to object to their use.
2.1 Types of cookies
The Provision of the Data Protection Authority no. 229 of May 8, 2014, as supplemented and amended by the Guidelines of June 10, 2021, requires all website managers who use cookies or other tracking technologies to inform users about the types of cookies, if any, used by the website, and has classified cookies into two macro-categories: "technical" cookies and "profiling" cookies:
Technical cookies: these are used for the sole purpose of providing the services offered by the respective website. They are not used for further purposes and are normally installed directly by the owner or manager of the website. They can be divided into navigation or session cookies, which guarantee normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas); analytics cookies, assimilated to technical cookies when used directly by the website manager to collect information, in aggregate form, on the number of users and how they visit the website; functionality cookies, which allow the user to browse according to a series of selected criteria (e.g., language, products selected for purchase) in order to improve the service provided to them. Prior consent of users is not required for the installation of these cookies; however, they must be given the option to opt out of their storage;
Profiling cookies: these cookies are designed to create user profiles and are used to send advertising messages in line with the preferences expressed by the user while browsing the web. Due to the intrusive nature that such tracking tools can have on the private sphere of Users, European and Italian legislation requires that the user be adequately informed about their implementation on the website in order to provide valid consent for their storage.
2.2 Technical cookies used by the Website
The Website uses exclusively technical cookies necessary for secure and efficient navigation on the Website.
The cookies used on this Website avoid the use of computer techniques that could potentially compromise the confidentiality of User browsing and do not allow for the acquisition of personal identification data of the user.
This Website does not use profiling cookies.
DATA SUBJECT RIGHTS
Users may exercise the rights guaranteed to them by Applicable Law by contacting the Data Controller in the following ways:
By sending a registered letter with return receipt to the Data Controller's registered office: Via Paleocapa 6 – 20121 Milan
By sending an email to: info@ennmedia.it
The Data Controller has not appointed a Data Protection Officer (DPO), as the Data Controller is not subject to the appointment obligation pursuant to Art. 37 of the Regulation.
In accordance with Applicable Law, the Data Controller informs Users that they have the right to obtain information regarding: (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the event of processing carried out with the aid of electronic tools; (iv) the identification details of the Data Controller and the data processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of them as designated representatives or persons in charge.
Furthermore, Users have the right to obtain:
- access, update, rectification, or, where there is an interest, the integration of data;
- erasure, anonymization, or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
- certification that the operations referred to in points (a) and (b) have been brought to the attention, including as regards their content, of those to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a disproportionate effort compared to the right being protected.
Furthermore, Users have:
- the right to withdraw consent at any time, if the processing is based on their consent;
- (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used, and machine-readable format);
- the right to object:
i) in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even if relevant to the purpose of collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material, or for carrying out market research or commercial communication;
iii) if personal data are processed for direct marketing purposes, at any time, to the processing of data for such purposes, including profiling to the extent that it is related to such direct marketing.
- if they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State where they habitually reside, work, or where the alleged violation occurred). The Italian supervisory authority is the Garante per la Protezione dei Dati Personali, located at Piazza Venezia 11, 00187 – Rome (http://www.garanteprivacy.it/).
The Data Controller is not responsible for updating all links provided in this Privacy Policy; therefore, should a link not function or be outdated, Users acknowledge and agree that they must always refer to the document or section of the websites referenced by such link.