In compliance with the obligations under Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (the "Regulation"), we hereby inform you that illuminem S.r.l. ("illuminem" or the "Company") with registered office in Vicolo Sozomeno 2, 51100, Pistoia (PT), Tax Code and VAT No.02040550473, registered with the Companies' Register, REA No. 607886, PEC email@example.com, as Data Controller, will process your personal data, which may be collected by us, provided by you and/or communicated to us by other entities, during the navigation and use of our website https://illuminem.com/ (the "Website").
The processing of the data you have freely provided or otherwise collected during your navigation on the Website will be carried out in compliance with the personal data protection regulations in force. In particular, the processing will be based on the principles of fairness, lawfulness and transparency. The data will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed and will be collected and recorded only for the purposes indicated in this Policy.
What personal data we process?
We will process personal data we collect or you provide when browsing and using the Website, such as:
- user's IP address;
- user's data related to browsing on the Website;
- browser and device information;
- information that you provide, collected via cookies, pixel tags and other technologies, without disclosing your identity;
- information that has been aggregated in such a way that it no longer reveals your specific identity;
- name and surname, profile picture (in case of registration with Google), e-mail address, company and position held in it;
- user's date registration;
- user's reasons for using the Website;
- data relating to payment instruments.
For what purposes are your data processed?
illuminem will process your personal data for the following purposes:
- Comply with any type of obligation under current legislation;
- Allow you to register with the Website and offer the services available through the Website;
- Allow you to obtain the information you have requested through our contact form and allow us to respond to your specific requests of information;
- Inform you via newsletters about illuminem's promotions and commercial initiatives, organization and promotion of events, and customer satisfaction questionnaires (marketing purposes).
The Personal Data collected may also be processed in the context of possible corporate events (sale of the Company or business units), due diligence, in the event of the defense of a right in court, and in relation to the relevant preparatory activities.
Under which legal basis are your data processed?
Without prejudice to the legal obligations referred to in paragraph 2, letter a) (e.g. tax obligations), the processing of your personal data, provided by you for the purposes referred to in paragraph 2, letter b), is an essential condition for the conclusion of a contract with illuminem, as well as for illuminem to offer the services available through the Website and to manage the contract (e.g. for accounting and administrative purposes). Your refusal to provide such data will make it impossible to enter into a contract with the Company and therefore register with the Website.
The processing of your personal data collected for the purposes referred to in paragraph 2, letter c), is carried out on the basis of a legitimate interest of the Company, whose business is inevitably linked to the quality of the services offered on its Website and the experience of interaction with users and the satisfaction of their expectations.
The processing of your personal data for the purposes referred to in paragraph 2, letter d) is optional and is subject to your consent. The consent given for the said purpose may be revoked at any time. Failure to provide such consent will make it impossible for the Company to send you newsletters and other marketing communications. However, it will have no consequence on the usability of the Website.
In the event of processing in the context of any corporate events (sale of the Company or business units), due diligence, in the event of the defense of a right in court and in relation to the relevant prodromal activities, such processing will be carried out on the basis of the Company's legitimate interests in the continuation of its commercial activities and for the protection of its rights.
How are your data processed?
The processing of the personal data referred to in the preceding paragraphs shall be carried out mainly with the aid of electronic and computerized tools suitable to grant the security and confidentiality of such data.
Who we disclose your data to?
Personal data may be disclosed by the Company solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects: suppliers of services such as website hosting, data analysis, payment processing, information technology, and the use of related infrastructures, customer service, email delivery, auditing, and other services; consulting firms, law firms, accountants; companies controlling and/or affiliate to the Company.
Personal data may also be communicated, where requested, to the competent judicial authorities, public administrations, and supervisory and control authorities.
Personal data shall not, however, be disclosed to unspecified subjects. The Company, as data controller, also reserves the right to transfer your personal data to third countries. Transfers of data outside the European Economic Area are subject to a special regime under the Regulation, and will only be made to countries that ensure an adequate level of protection of personal data, on the basis of an adequacy decision by the Commission or where adequate safeguards have been adopted (including the standard contractual conditions provided by the European Commission), provided that the data subjects have effective rights of action and remedies.
How long do we store your data?
Your data will be stored, in accordance with the provisions of the relevant legislation in force, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the period of data retention take into account the period of permitted processing and the applicable regulations on taxation, statute of limitation periods and legitimate interests that constitute the legal basis of the processing. When the processing is based on your consent, your data may be stored until the consent is revoked. At the end of the retention period , the data will be deleted, aggregated or anonymised.
Which rights do you have?
The Regulation grants to you specific rights, including the right to request from the data controller:
- confirmation as to whether or not your personal data are being processed and, if so, to obtain access to it (right of access);
- the rectification of inaccurate personal data, or the integration of incomplete personal data (right to rectification);
- the erasure of the data, if one of the grounds listed in Article 17 of the Regulation applies (right to erasure);
- to restrict the processing of your personal data, if one of the grounds provided for in Article 18 of the Regulation applies (right to restriction of processing);
- to receive the personal data you have provided in a structured, commonly used and machine-readable format, and to transmit them to another data controller (right to data portability);
- to no longer process your personal data, on grounds relating to your particular situation (right to object).
You have the right to withdraw your consent to the processing of your personal data for marketing purposes, at any time, without affecting the lawfulness of the processing based on consent before the withdrawal.
To exercise your rights, you can write to illuminem S.r.l., Vicolo del Sozomeno 2, 51100, Pistoia, or send an email to firstname.lastname@example.org.
According to the Regulation, the Company is not authorized to charge you for complying with any of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, in particular, because of their repetitive character. In case you request more than one copy of your personal data or in cases of excessive or manifestly unfounded requests, the Company may (i) charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested or (ii) refuse to act on the request. In such cases, the Company will inform you about the costs before processing the request.
The Company may ask for additional information before processing requests if it needs to verify the identity of the individual who submitted them.
Without prejudice to any other administrative or jurisdictional remedy, the user shall also have the right to lodge a complaint with a supervisory authority if he/she considers that the processing of his/her personal data is carried out in breach of the Regulation.
The contact details of the supervisory authorities are provided below.
For Italy: Garante per la protezione dei dati personali, Piazza Venezia, 11, 00187 - Roma, Tel. +39 06 69677 1, Fax +39 06 69677 785, e-mail email@example.com.
You can find all the information and contact details of the supervisory authorities of each Member State of the European Economic Area at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
In any case, the Company is interested in being informed of any grounds for complaint and invites you to use the contact channels indicated above before referring the matter to the supervisory authority, so that any disputes can be prevented and resolved in an amicable and timely manner, with the utmost courtesy, seriousness and discretion.
Version published on 21.11.2023