Privacy Policy

Policy on the processing of personal data

Antirion SGR S.p.A., with registered office in Milano, Via Mazzini, 9 (hereinafter, also the “Data Controller“) may come into possession of the personal data of persons who voluntarily provide their contact details by filling in the specific form on the website www.antirionsgr.it (hereinafter, the “Website“).

Whereas ‘processing’ is defined as any operation, including the mere collection and/or storage, of personal data of any natural person (hereinafter, “Data Subject“), whereas ‘data controller’ is defined as the person who determines the purposes and means of the processing and ‘personal data’ is defined as any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, the personal data processed are those voluntarily provided to Antirion SGR S.p.A. by the Data Subjects, through the use of the dedicated section on the Website.

This policy is provided to the Data Subject by publication on the Website.

1. Data Controller

The Data Controller is Antirion SGR S.p.A, with registered office in Milano, Via Mazzini, 9, 20123, Tax Code and VAT 06817000968, R.E.A MI-1916983, e-mail ‘privacy@antirionsgr.it’, PEC ‘antirionsgr@pec.antirionsgr.it’, telephone +39 02 87246183, fax +39 02 87246187.

It is possible to directly contact the Data Controller free of charge by writing to the e-mail address ‘privacy@antirionsgr.it’ or by sending a registered letter with acknowledgement of receipt to the registered office, as identified above.

The Data Protection Officer appointed by the Data Controller is lawyer Francesco Conti, with office in Milano, Via Bigli, 28. It is possible to contact the Data Protection Officer free of charge at +39 02 83420630 and at the address already indicated ‘privacy@antirionsgr.it’, in addition to the PEC address ‘francesco.conti@milano.pecavvocati.it’

2. Nature of processed data and purposes of processing

The data being processed are the following:

1. data provided by the Data Subject to the Data Controller by filling out the form prepared for this purpose, such as personal data (name, surname, e-mail address), as well as any other data that the Data Subject will voluntarily provide in the request for information;
2. data collected by Antirion during navigation on the Site, such as IP address, information acquired through cookies;
3. data conferred by the Data Subject in the occasion of other possible contacts with the Data Controller using the Site (name, surname, e-mail address, professional position).

The data will be used for the following purposes:

• pursuit of the legitimate interest of the Data Controller – arising in this case exclusively as a result of the spontaneous and unsolicited contact by the Data Subject – in sending information on the Data Controller’s activities and, in general, on customer care;
• performance of obligations provided for by law, by a regulation or by EU legislation;
• performance of administrative activities;
• exercise of one’s rights in a court of law;
• compliance with specific requests from judicial authorities and/or public security authorities.

3. Compulsory/optional nature of data conferment

The provision of data is necessary for the purposes set out in point 2 above, as it is strictly functional to the performance of the services requested from time to time by the Data Subject to the Data Controller, as well as for the performance of legal obligations.

Since the service requested from the Data Controller arises from a spontaneous and unsolicited request by the Data Subject, in the form of spontaneous and unsolicited sending of data, any request for cancellation of data will make it impossible for Antirion SGR S.p.A to perform the requested services.

The user may propose such requests by sending an email to ‘privacy@antirionsgr.it’.

4. Categories of persons to whom the data may be communicated

Personal data may be communicated to certain parties, for the performance of the services requested and for the fulfilment of regulatory obligations.

In particular, the personal data of the Data Subject may be communicated to persons delegated and/or appointed by Antirion SGR S.p.A. to carry out activities or part of the activities related to the provision of the services requested and any other external collaborator, for this purpose appointed as Data Processor pursuant to Article 28 of the Regulation, which communication is necessary for the proper performance of the services.

The data will not be subject to further dissemination.

5. Data Processing modalities

Antirion SGR S.p.A, will carry out operations of collection, registration, conservation and archiving of personal data by means of manual, computeri and telematic tools with logic strictly related to the purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data collected.

The security of the data and their transmission is guaranteed by adequate protection systems such as antivirus, anti-ramsonware, firewalls and access passwords, and by physical measures to select and prevent access to the premises where the data are stored.

6. Legal basis of the processing

The legal basis for the processing is the legitimate interest of the Data Controller, the fulfilment of a contractual obligation, the fulfilment of legal provisions and the consent of the Data Subject.

7. Data retention periods

The processing of personal data with reference to the purposes referred to the previous point 2 will have a duration equal to that necessary for the fulfilment of Antirion SGR S.p.A’s obligations deriving from the requested services.

At the end of the period of data processing, the data will be deleted, or permanently anonymized.

8. Rights of the Data Subject

Among the rights recognized to the Data Subject who contacts Antirion SGR S.p.A. through the appropriate form on the Website are the following:

• to request from the Data Controller access to their personal data and policy relating to the same; the rectification of inaccurate data or the integration of incomplete data; the deletion of personal data concerning him/her (upon the occurrence of one of the conditions indicated in Article 17, paragraph 1 of the Regulations and in compliance with the exceptions provided for in paragraph 3 of the same article); the restriction of the processing of personal data conferred (upon the occurrence of one of the hypotheses indicated in Article 18, paragraph 1 of the GDPR);
• to request and obtain from the Data Controller – where the legal basis for the processing is a contract or consent, and the processing is carried out by automated means – the personal data provided in a structured, machine-readable format, also for the purpose of communicating such data to another data controller (so-called right to data portability);
• to oppose at any time the processing of personal data provided in the event of special situations concerning the user;
• to revoke at any time the consent given, limited to cases where processing is based on consent for one or more specific purposes and concerns common personal data (e.g. date and place of birth or place of residence), or special categories of data (e.g. data revealing the user’s racial origin, political opinions, religious beliefs, state of health or sex life). Processing based on consent and carried out prior to the revocation of such consent shall, however, remain lawful;
• to lodge a complaint with a supervisory authority (Italian Data Protection Authority – www.garanteprivacy.it).

9. Policy Updates

This Policy is subject to occasional revisions. If any changes are made to the processing, Antirion SGR S.p.A. will inform the Data Subject accordingly. Where required by current legislation, the Data Subject will have the right to consent to any new processing. In the event of refusal, the data of the Data Subject will not be processed according to the modifications contemplated by this Policy notice.

10. Transfer abroad

The personal data of the Data Subject will not be transferred to non-EU countries.