“Privacy Policy”
Pursuant to EU Regulation 2016/679
milanolocare SRL, email address: agency@milanolocare.it, in its capacity as “Data Controller” (hereinafter the “Controller”) of your personal data (hereinafter, collectively, also the “Data”), of which you are the “Data Subject”, pursuant to EU Regulation 2016/679 (hereinafter the “Regulation”), and which the Controller has obtained following the assignment of the brokerage mandate, hereby provides you with the following information so that you may give specific, unequivocal, informed, free and conscious consent to the Processing of the Data, which may also take place using IT and/or telematic tools.
1) Source of the Data.
The data necessary for the performance of the contractual relationship between the Parties, as well as the data otherwise acquired within the scope of such activity, are collected by the Controller directly from you and/or through third parties, as well as obtained by consulting certain external public and private databases.
2) Availability of the Privacy Policy.
The Controller provides you with the possibility of consulting this privacy policy: a) whenever it collects Clients’ personal data; b) whenever an express request is made to the Controller; c) through online consultation by accessing the home page of the website www.milanolocare.it
3) Purposes of Data processing.
The Controller processes your data for its institutional purposes, connected with or instrumental to its activity, for the following purposes:
a) purposes provided for, in particular, by anti-money laundering legislation Legislative Decree 231/2007, as amended and supplemented by Legislative Decree 90/2017, and, in any case, connected with obligations provided for by laws, regulations and EU legislation, as well as provisions issued by Authorities legally entitled to do so or by supervisory and/or control bodies;
b) contractual purposes, connected with and instrumental to the establishment and management of relationships with customers, such as, for example, the acquisition of preliminary information for the possible conclusion of a contract;
c) detection of the level of satisfaction with the quality of the services, carried out directly by the Controller or through specialized companies by means of personal or telephone interviews, interactive questionnaires, and market surveys;
d) promotion of the Controller’s services carried out through the sending of advertising material, telephone contacts and any other form of electronic communication, including the sending of emails, SMS, MMS, and publication on social networks;
e) communication and/or transfer of data to third parties for the promotion and/or sale of products and services, using traditional and/or automated methods.
With reference to the purposes referred to in points c), d), and e), we inform you that, at any time, you may withdraw the consent given according to the methods specified in this privacy policy.
4) Nature of the provision of Data.
You have the right to know that the provision of data may be mandatory or optional, and may also entail consequences in the event of refusal.
In this regard, we specify that:
a) the provision of your consent for the purposes referred to in letters a) and b) of point 3 is mandatory, as it is required by law or necessary to fulfill contractual obligations, as indicated by Article 6, paragraph 1, letters b and c) of the EU Regulation. Refusal to give your consent for the purposes indicated in letter b) of point 3) will therefore prevent the Controller from carrying out the assignment you have entrusted to it or from concluding the contract to which you are a party;
b) refusal to process the Data for the purposes referred to in letters c), d), and e) of point 3 is, instead, optional, will not entail any prejudicial consequence for you and may be withdrawn by you at any time, limited to the purposes connected with the sending of advertising material, detection of the level of satisfaction with the quality of services, carrying out market research or commercial communications, through telephone contacts or any other form of electronic communication, including the sending of emails, SMS, MMS, WhatsApp messages, publication on websites, social networks, etc., carried out directly by the Controller or through specialized companies by means of personal or telephone interviews and interactive questionnaires.
5) Special categories of data.
Article 9 of the Regulation defines as special those data suitable for revealing racial and ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic and biometric data, data relating to health or to a person’s sex life or sexual orientation. It is possible that the Controller may come into possession of special categories of data in relation to the specific operations requested by you. In such case, you have the right to express specific consent to the processing of your sensitive data and the Controller may use them exclusively to the extent strictly necessary to perform the services and operations requested.
6) Data retention.
The Data will be retained for the time necessary to manage the contractual relationship and fulfill legal obligations, with particular reference to anti-money laundering legislation. The Data are always processed in full compliance with the principle of proportionality of processing Article 5, paragraph 1, letter c) of the EU Regulation, according to which all personal Data and the various methods of their processing must be relevant and not excessive in relation to the purposes pursued, so as to ensure adequate security and confidentiality, also to prevent unauthorized access to or use of personal data and the equipment used for processing, as well as lawful and fair processing.
7) Data retention periods.
Pursuant to Article 13, paragraph 2, letter a) of the Regulation, below are indications regarding the retention periods of the Data according to the different processing purposes:
• with reference to letters a) and b) of point 3, the Data are retained for the period necessary to manage the contract and fulfill legal obligations;
• with reference to letters c), d), and e) of point 3, the retention periods are set at 10 years.
8) Methods of Data processing.
In relation to the purposes indicated in point 3, the personal Data may also be processed by a “Processor”, meaning the natural person or company, including entities external to the Controller, to whom specific and defined tasks of management and control of the data processing may be assigned, and by one or more “Person/s in charge”, who will carry out the material processing or use of the Data on the basis of the instructions received from the Controller or the Processor. These subjects, where not expressly indicated in this privacy policy, are to be considered not yet appointed, and not necessarily to be appointed if the processing is occasional; their data will be provided to you in the event of their appointment.
Always in relation to the purposes indicated above, the Data may be processed through manual, IT and/or otherwise automated tools, according to logics strictly connected with the purposes of the processing and, in any case, in such a way as to guarantee their security and confidentiality, including in the case of processing through remote communication tools.
9) Transfer of Data abroad.
The Data may be transferred to European Union countries and to third countries, meaning countries not belonging to the European Union, exclusively within the scope of the purposes referred to in letters a) and b) of point 3. In such case, the intention to transfer the personal data must be communicated to you in advance and authorized by you only where an adequate level of data protection equivalent to the European level is guaranteed.
10) Communication of Data.
The Data, by reason of the relationship established and in order to facilitate and enable the conclusion of the transaction, may be communicated to: i) external collaborators; ii) other business agents in brokerage, including companies, identified by the Controller in order to collaborate in the performance of the assignment entrusted by the Data Subject; iii) banks and other entities operating in the banking sector; iv) counterparties and their possible technicians and consultants; v) notaries for the preparation of notarial deeds and/or related activities pertaining to the assignment conferred on the Controller; vi) companies and/or professionals who provide services for the handling of technical/cadastral/building/urban-planning/legal and tax procedures; vii) insurance companies for the stipulation of policies relating to the assignment conferred on the Controller; viii) websites for real estate advertising purposes; ix) arbitration panels and, in general, all those public and private subjects to whom communication is necessary for the proper fulfillment of the purposes indicated in point 3); x) Supervisory/Control Bodies and other Authorities, for purposes connected with obligations provided for by law, including anti-usury law and anti-money laundering legislation, and/or by regulations, as well as by provisions issued by such Authorities.
All subjects belonging to the categories to which the Data may be communicated will use the Data as “controllers” pursuant to the law or specific consent, in full autonomy, being unrelated to the original processing carried out by the Controller, or as “external processors”. To know at any time the subjects to whom your data will be communicated, you need only request the updated list by writing to the Data Controller at the Controller’s registered office.
Finally, your Data will be known by all employees and collaborators of the Controller, designated as processors and/or persons in charge of processing, in relation to the performance of the duties and tasks assigned to each of them.
The Data processed by the Controller will not be disseminated.
11) Rights of the Data Subject.
Within the limits and under the conditions provided for by Articles 15 – 23 of the Regulation, the Controller guarantees and recognizes your exercise of the following rights:
• the right to access the personal data present in its paper and/or electronic archives;
• the right to request their rectification, updating and erasure, if incomplete or incorrect, as well as to object to their processing for legitimate and specific reasons;
• the right to obtain the rectification of inaccurate personal data without undue delay. Taking into account the purposes of the processing, you have the right to obtain the completion of incomplete personal data, including by providing a supplementary statement;
• the right to obtain the erasure of personal data concerning you without undue delay where one of the grounds referred to in Article 17, paragraph 1 of the Regulation applies;
• the right to obtain restriction of processing where one of the cases referred to in Article 18, paragraph 1 of the Regulation applies;
• the right to data portability within the limits and in the manner provided for by Article 20 of the Regulation.
You also have, at any time, the right to withdraw consent to the processing of your data without this affecting in any way the lawfulness of the processing based on the consent given before withdrawal, as well as the right to object at any time to processing for marketing purposes right to object.
You have the right to receive information regarding the action taken in relation to one of the above requests or the effects arising from the exercise of one of the above rights, without undue delay and, in any case, no later than one month from receipt of the request itself, which may be extended, if necessary, by two months; you also have the right to lodge a complaint with a supervisory authority and to seek judicial remedy.
Without prejudice to the case in which the processing of the Data violates the general principles laid down by the Regulation, the exercise of these rights must be relevant and reasoned and may not imply the withdrawal of the consent given or the request for erasure of the Data provided by you for the conclusion and performance of the contract referred to in point 3) letters a) and b), to the extent and for as long as the Data are necessary for such purpose.
The rights in question may be exercised, also through an appointed person, by sending a request to the Data Controller at the following addresses:
Viale Toscana 12A, Milan (MI), email address: agency@milanolocare.it
In exercising your rights, you may grant, in writing, a mandate or power of attorney to natural persons, entities, associations or bodies; you may also be assisted by a trusted person. In order to guarantee the effective exercise of your rights, the Controller will adopt appropriate measures aimed at facilitating access to the Data, simplifying the procedures and reducing the time needed to respond to your request.
Finally, please note that you may lodge a complaint with the supervisory authority, namely the Italian Data Protection Authority, through the following means:
a) registered letter with return receipt addressed to Garante per la protezione dei dati personali, Piazza di Monte Citorio n. 121, 00186 Rome;
b) email to: garante@gpdp.it, or protocollo@pec.gpdp.it;
c) fax to the number: 06/69677.3785.
All related information on complaints that may be lodged by you is available on the Authority’s website at www.garanteprivacy.it
