1. Data Controller
Italian Interactive & Digital Entertainment Association (hereinafter “Data Controller”), with legal seat in (20121) Milan (MI), Piazzale Cadorna n. 2.
Address for exercising rights: firstname.lastname@example.org
Pursuant Article 13 of the EU Regulation No. 2016/679 of April 27, 2016 (hereinafter “GDPR”), Your personal data are collected and processed by the Data Controller for the purpose listed below and related to the provision and management of services offered by this website and related services (hereinafter “Website”).
By processing of personal data we mean any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, comparison or interconnection, limitation, cancellation or destruction.
We inform You, therefore, that such data will be processed manually and/or with the support of computerized or telematic means for the following purpose.
3. Purpose of processing the personal data.
- First of all, the processing of the personal data that You are required to provide for registering on the Site pursues the purposes of allowing the Data Controller to provide the Services, allowing you to access and navigate within the Site through its web pages. The processing of personal data may also pursue pre-contractual purposes, such as answering specific requests from the data subject. However, the personal data indicated above are processed only for the purpose of allowing access to the Site, navigation and registration to the website. Registration also allows access to the personal area made available on the same site. Your personal data (non-sensitive) processed by the Data Controller are required for the above purposes, and in particular may be processed common personal data such as: name, surname, e-mail. The processing will not concern personal data included in the category of "sensitive" or "particular data".
- Secondly, Your personal data (sensitive and non-sensitive) will also be processed in order to fulfil the obligations provided by the law, the regulations or by European legislation.
4. Secondary purposes of personal data processing - Promotional, advertising and marketing purposes.
Your personal data may be processed either in paper form or by automated/computerized means, for secondary promotional, advertising or marketing purposes connected with the promotion of services and/or events of the Controller such as, by way of example but not limited to, the sending of newsletters via email with promotional or advertising messages (hereinafter "Processing for Marketing Purposes").
By giving consent, the user specifically acknowledges such Marketing Purposes in the broad sense of the treatment (including the management and administrative activities resulting therefrom) and expressly authorizes, once consent has been given according to the procedures provided, said treatment pursuant to Article 6, Paragraph 1, letter (a) of the Privacy Regulation. In order to proceed with the Processing for Marketing Purposes, it is mandatory to obtain a specific, separate, express, documented, prior, informed, free and completely optional consent. With a view to absolute transparency, we therefore inform You that the data will be collected and subsequently processed on the basis of specific consent:
a) for sending advertising and information material (e.g. Newsletters) of a promotional nature or of a commercial solicitation nature to subjects who have given informed consent;
b) for carrying out direct sales or placement of services of the Controller;
c) for sending commercial information; making interactive commercial communications also pursuant to Article 58 of Legislative Decree 206/2005, by email service;
e) for sending unsolicited commercial communications, pursuant to Article 9 of Legislative Decree No. 70 of April 9, 2003 implementing the so-called Electronic Commerce Directive 2000/31/EEC, which provides that unsolicited commercial communications must be immediately and unequivocally identifiable as such and must contain an indication that the recipient of the message may object to the receipt of such communications in the future.
Therefore, by giving the optional consent, the user specifically acknowledges and authorizes such further, possible secondary processing.
We specifically and separately inform You, as required by Article 21 of the Privacy Regulation, that if personal data is processed for direct marketing purposes, the user has the right to object at any time to the processing of personal data concerning him for such purposes and that if the person concerned objects to the processing for direct marketing purposes, personal data may no longer be processed for such purposes.
The provision of personal data to the Controller and the provision of both consent to the Processing for Marketing Purposes and the separate consent to disclosure to third parties for the Processing for Marketing Purposes for the purposes and in the manner described above are absolutely discretionary and optional (and in any case revocable without formality, even after the provision, by sending an e-mail to email@example.com) and failure to provide the data will not result in consequences other than the impossibility for the Controller and for any third party to proceed with the marketing purposes mentioned previously.
5. Compulsory or Optional consent for the pursuit of the primary purposes of the processing of personal data.
In accordance with the applicable provisions of the GDPR, the Controller for the purposes referred to in Paragraph 3 of this Policy is not obliged to gather specific consent for the processing of personal data common to users who register to the website. The processing of such data described above pursues primary purposes for which Article 6 of the GDPR excludes the need to obtain a specific consent of the user, because the processing is necessary to comply with an obligation under the law, regulation or European legislation, or because the treatment is necessary to perform obligations resulting from a contract (in the case: the general conditions of access and navigation of the Website) of which the person concerned is a party or to fulfill, before the conclusion of the contract, specific requests of the person concerned or - finally - because the processing of data pursues administrative-accounting purposes.
If the data subject does not intend to provide the personal data requested and necessary based on the above, the consequence would be that it would be impossible to access to the Website
6. Communication and disclosure of personal data.
The data processed for the purposes set forth in Paragraphs 1 may be communicated to any other third party when such communication is required by law, including the scope of prevention/repression of any illegal activity related to access to the Website.
With reference to Article 13, Paragraph 1, letter (e) of the Privacy Regulation, the subjects or categories of subjects who may become aware of the personal data (both common and sensitive) of the user, as managers or agents, are indicated and a list by category is provided below:
- Companies, postal offices or third parties appointed to pack, ship or deliver products ordered from the website;
- companies, consultants or professionals who may be appointed by IIDEA to install, maintain, update and, in general, manage the hardware and software owned by IIDEA that IIDEA uses to provide its services;
- public and/or private entities, natural and/or legal persons (legal, administrative and tax consultancy firms, Judicial Offices, Chambers of Commerce, Chambers and Labour Offices, etc.), if the communication is necessary or functional to comply with the contractual obligations undertaken, as well as the obligations under the law;
- to third parties, affiliates, partners of IIDEA initiatives for their own commercial and advertising purposes.
The updated list of the data processors – if appointed – is available at the operative seat of the Data Controller in (20121) Milan (MI), Piazzale Cadorna n. 2.
Personal data will not be disclosed.
7. Data retention and other information.
The data collected will be stored for a period not exceeding the achievement of the purposes described in Paragraph 1, for allow the browsing in the Website and answer the possible requests of the data. After, the personal will be stored in Data Controller’s server to answer further requests from the data subject and for legal requirements. If the user of the Site, following the ending of the browsing, requests the cancellation of their data, exercising the rights under Paragraph 7, the Data Controller will not be able to respond to any requests made by the data subject.
Furthermore, the five-year or ten-year periods of storage required by the law for accountancy and fiscal purpose remain unaffected.
The data collected are processed within the registered office and operational headquarters of the Controller.
Pursuant Article 13, par. 1, letter (f) GDPR, we inform you that all the personal data will not be transfer to any third country or international organization, neither within nor outside the European Union.
8. Exercise of rights by the data subject.
Pursuant Articles 13, paragraph 2, letters (b) and (d), 15,18,19 and 21 of the Privacy Regulation, we inform You that:
a) You have the right to request the Controller the access to personal data, rectification or cancellation of the same or the limitation of the processing that concerns You or to refuse its treatment, in addition to the right of data transfer;
b) You have the right to file a complaint before the Data Protection Authority, following the procedures and instructions published on the official website of the Authority on www.garanteprivacy.it;
c) any rectification, cancellation or restriction of the processing carried out at Your request - unless this proves impossible or involves a disproportionate effort - will be communicated by the Controller to each of the recipients to whom the personal data have been transmitted. The Controller may inform You of such recipients at Your request
Exercise of the rights is not subject to any formal constraint and is free of charge.
For Your convenience, Articles 15 to 23 of the Regulations are available at the following link: