Privacy

PERSONAL DATA PROCESSING POLICY

Michela Bruni, is aware of the importance of protecting the right to privacy of the users of its website (the “Data Subjects”) and informs that the personal data collected through the navigation on the www.michelabrunireichlin.com website (the “Website”) will be processed in compliance with the legislation on the personal data protection. When using the services offered by the Website, the Data Subject will receive specific information regarding the further processing made by Michela Bruni.

Therefore, pursuant to Article 13 of Regulation (EU) no. 2016/679 (the “Regulation”), Michela Bruni provides the following information on the methods of persona data management and processing.

1. Types of data collected (“Data”), purpose and legal basis of processing

Navigation data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the users’ terminals that connect to the site, the MAC (Media Access Control) addresses, the addresses in the URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to forward the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and parameters related to the operating system and to the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site. The legal basis that legitimises such processing is art. 6 par. 1, lett. b) of the Regulation, since it allows the Data Subjects to use the service requested. The same data may also be used to fulfil legal obligations or to requests of the judicial Authority. The legal basis that legitimises such processing is art. 6 par. 1, lett. c) of the Regulation, since it is necessary to fulfil a legal obligation to which the Michela Bruni is subject.

Data provided voluntarily by the Data Subjects

Following the voluntary sending of e-mail messages to the e-mail addresses on the Website, Michela Bruni may process the sender’s e-mail address and the additional personal data contained in the message to respond to requests made by the user. Specific privacy policy will still be given when using particular tools provided by the site. The legal basis that legitimises such processing is art. 6 par. 1, lett. b) of the Regulation, since it is necessary to provide the requested service by the Data Subjects. The same data may also be used to fulfil legal obligations or to requests of the judicial Authority. The legal basis that legitimises such processing is art. 6 par. 1, lett. c) of the Regulation, since the processing is necessary to fulfil a legal obligation to which the Bruni Michela is subject.

Cookie

The site uses technical cookies (session and navigation), to ensure normal navigation and use of the website (allowing, for example, to authenticate the access in restricted areas). The site also uses third party analytics (with reduced identifying potentials), in order to monitor the use of the site by users for the purpose of optimising the web platform and statistics (analytical). For all information concerning the processing of personal data by means of cookies, please refer to the policy on the extended cookie, which can be found on each portal page at the link www.michelabrunireichlin.com/cookies

2. Data retention period

Personal data collected and processed when browsing the Website will be kept for the entire period of service providing and, in any case, deleted or rendered anonymous within 7 days. Personal data sent voluntarily by users through the tools on the site will be deleted after providing the service requested or having responded to them and in any case within the maximum period of 6 months from the end of this activity, with the exception of those required to comply with fiscal, accounting and administrative regulations or to fulfil other legal obligations and to document the activities carried out.

3. Modalities for data processing

The Data will be processed with electronic tools and will be stored on any type of appropriate support and will be organised in a database. Specific security measures are followed to prevent data loss, illicit or incorrect use and unauthorised access. The processing of the Data carried out by Michela Bruni does not involve automated decision-making processes.

4. Provision of Data

The provision of navigation data is a necessary for the provision of the requested service (navigation on the site) and mandatory for this purpose: the failure to communicate those data will result in the impossibility for Michela Bruni to allow navigation on the Website. The provision of the Data for further purposes is optional: failure to provide the Data, in such cases, will not affect the Data Subject, but may result in the inability to provide them with the feedback required.

5. Communication of Data

The Data may be communicated to: (i) subjects who are entitled and have the interest to access to the Data by law or secondary legislations; (ii) Data Controller’s internal staff; (iii) companies, associations or professional offices that provide services and activities, on behalf of the Data Controller, as Data Processors for the fulfilment of legal obligations, as well as for every organizational and administrative need necessary to provide the services requested. The details of the Data Processors are listed in an updated list available at Michela Bruni premises (to be requested at the addresses indicated in point 9). The Data will not be disseminated.

6. Data Transfer outside the European Union or to international organisations

Michela Bruni does not transfer the Data processed for the purposes indicated in this policy outside the EU or to international organizations.

7. Link to sites or services of third parties

This policy is provided only for the processing of personal data made through the Website or the tools provided by the same, and not for other websites that may be consulted by the Data Subjects through links, whose managers operate as independent data controllers. Before accessing the services of third parties, Data Subjects are therefore invited to read their privacy policies carefully.

8. Data subjects’ rights

The Data Subjects have the right to exercise at any time the rights provided for by the Regulation, such as:

– to obtain information on: (i) Data source; (ii) purposes and methods of processing; (iii) logic applied; (iv) identifying details of Data Controller and of Data Processors;

– to obtain: (i) access, updating, correction or integration of data; (ii) deletion, transformation into anonymous form or blocking of Data processed in violation of the law; (iii) the limitation of data processing; (iv) copy of the Data in standard format;

– to object, in whole or in part:

(a) for legitimate reasons, the processing of the Data, even if pertinent to the purposes of the collection;

(b) to the processing of the Data necessary (i) for the performance of a task carried out in the public interest or in the exercise of official authority vested in Michela Bruni or (ii) for the purposes of the legitimate interests pursued by the controller or by a third party, included profiling;

(c) to the processing of the Data for the purposes of sending advertising or direct sales material or for carrying out market research or commercial communication;

– to revoke the consent to processing, when this is based on the hypothesis provided for by art. 6, par. 1 (a) (when “the data subject has given consent to the processing of their personal data for one or more specific purposes“), or by art. 9, par. 2 (a) (when “the data subject has explicitly consented to the processing of such personal data for one or more specific purposes”) of the Regulation, at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation. In particular, in order to no longer receive e-mails or promotional mail, the Data Subjects can at any time request a free cancellation from the service by sending a message to the addresses indicated in points 9 and 10 of this statement.

If Data Subjects consider that the processing of the Data is in violation of the law, they have right to lodge a complaint with a supervisory authority, particularly in the Member State in which they usually reside or work or where the alleged violation has occurred. The Italian Supervisory Authority can be reached at the addresses on its own website

9. Data controller – Contact details

The Data Controller is Michela Bruni, Tax no 08349861008, in the person of the legal representative Michela Bruni Reichlin. Bruni Michela may also be contacted at the e-mail addresses mbr@michelabrunireichlin.com, even to exercise the rights listed above. Michela Bruni retains the right to update this personal data processing policy.