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”, or "GDPR"), we hereby inform you that illuminem S.r.l. ("illuminem" or “us”) 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 illuminem@pec.it, 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 websites, https://illuminem.com/ (the “Media Website”). and https://data.illuminem.com/ (the "Data Hub Website"), together referenced as the “Websites”.

 

The processing of the data you have freely provided or otherwise collected during your navigation on the Websites 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.

 

 

This privacy notice applies to broadly three categories of individuals:

 

1. Our Websites visitors: where we collect browsing data, such as IP addresses through “cookies”;

2. Our Subscribers: where we collect browsing data and the data provided to us in the context of creating an Account on our Websites; and

3. Various individuals whose information has been either sourced by ourselves or provided to us by our data partners.

 

 

When you browse our Websites, certain information about the device you use to access the Internet is transmitted to us with the help of various technologies, commonly referred to as “cookies”. This is true even if you don't have an Account with us and even where you haven't purchased a Subscription.

 

If you are a Website visitor, we will usually collect the following personal information: IP address; general location (e.g. state), data related to browsing on the Websites; 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.

 

Such personal information is processed for the following purpose(s): to display our Websites, to ensure its proper functioning, to ensure its security and to improve it (on the basis of analytics).

 

In order to process such personal information, we rely on the following legal base(s): when the processing is in connection with ensuring the proper functioning of our Websites it is necessary for the pursuit of our legitimate interests, that are to deliver a running and safe online presence (art 6.1.f. GDPR); when the processing is in connection with improving our Websites, it is subject to your consent when required by law (art 6.1.a. GDPR), or where that is not required, it is necessary for the pursuit of our legitimate interests, that are to improve our online services (art 6.1.f. GDPR).

 

To exercise your choice for non-essential cookies, please use the banner on the Websites.

 

 

illuminem’s Data Hub is a B2B service for accessing sustainability data and information on companies. If you wish to subscribe for our services, we'd need to ask you for some basic contact and payment details. We also ask new Subscribers to respond to a short survey about the company they work for.

 

If you are a Subscriber visitor, we will usually collect the following personal information: full name, professional email address, job title, payment details, user’s date registration, data relating to your usage of our Websites, your responses to our onboarding survey about the company you work for, and answers to other surveys presented on our Websites.

 

Such personal information is processed for the following purpose(s):

1. to comply with any type of obligation under current legislation (e.g. tax obligations);

2. to allow you to register with the Websites, onboard you as a new customer (we need to know who our customers are) and offer the services available through the Websites. Without prejudice to the legal obligations referred to in the previous bullet point, the processing of your personal data, provided by you for the purposes referred to here, 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.

3. to take payment from you (so we can provide our services)

4. to manage our commercial relationship with you (so we can contact you and ensure a satisfactory customer experience), including to allow us to respond to your specific requests of information through our contact form. The processing of your personal data collected for the purposes referred to here, 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.

5. to inform you via newsletters about illuminem's promotions and commercial initiatives, organization and promotion of events, customer satisfaction questionnaires (marketing purposes); The processing of your personal data for the purposes referred to here 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.

6. We may share your personal data with Subscribers to the Websites in order for them to contact you about their offers and other marketing purposes. The processing of your personal data for the purposes referred to here is optional and subject to completing a survey. You can object to this processing at any time by contacting us at info@illuminem.com.

7. 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. In the event of processing for the purposes referred to here, 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.

 

In order to process such personal information, we rely on the following legal base(s): taking steps to enter into a contract with you and later, performing the of the contract between us and you (art 6.1.b GDPR).

 

 

In order to provide our service, we gather information about decision makers in the sustainability area. Such decision makers are usually employees in companies tasked with responsibilities around furthering the company's sustainability agenda and maturity. Such personal information is public and is either collated by ourselves or by our partners (e.g. companies such as RocketReach). To understand more about RocketReach’s database, please read this article. To opt out from RocketReach’s database, please visit this link. When it comes to such information, we will usually collect the following personal information: your name, location, job title, job seniority, career history, education, employer name, and contact details such as professional email and phone number. All this information is collected only insofar as available publicly online or provided by RocketReach. Such personal information is processed for the following purpose(s): the information is processed for the purpose of collating it and presenting it to our Subscribers for their lead generation (e.g. direct marketing) purposes. We contractually ask our Subscribers to comply with applicable data protection law when using this information. In order to process such personal information, we rely on the following legal base(s): the processing is necessary for the pursuit of our legitimate interests, that are to deliver our services to our Subscribers (art 6.1.f. GDPR).

 

When it comes to such information, we will usually collect the following personal information: your name, location, job title, job seniority, career history, education, employer name, and contact details such as professional email and phone number. All this information is collected only insofar as available publicly online or provided by RocketReach.

 

Such personal information is processed for the following purpose(s): the information is processed for the purpose of collating it and presenting it to our Subscribers for their lead generation (e.g. direct marketing) purposes. We contractually ask our Subscribers to comply with applicable data protection law when using this information.

 

In order to process such personal information, we rely on the following legal base(s): the processing is necessary for the pursuit of our legitimate interests, that are to deliver our services to our Subscribers (art 6.1.f. GDPR).

 

 

The processing of the personal data referred to in the preceding paragraphs is carried out mainly with the aid of electronic and computerized tools suitable to grant the security and confidentiality of such data.

 

 

Personal data about Websites’ visitors and Subscribers may be disclosed by illuminem 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 illuminem, sellers of sustainability solutions.

 

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. Illuminem, 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 applicable law, 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.

 

The above applies equally to personal data about individuals listed on the Data Hub Website. In addition, we disclose such data to our Subscribers, as described above.

 

 

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.

 

Websites’ visitor data is usually stored for no longer than 2 years after their last visit to our Website. Subscriber data is usually stored for no longer than 7 years after a Subscription is canceled. Personal information of individuals listed on the Data Hub Website is usually stored until it becomes outdated.

 

 

Applicable law 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 GDPR applies (right to erasure);

• to restrict the processing of your personal data, if one of the grounds provided for in article 18 of the GDPR 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 info@illuminem.com. 

 

According to the Regulation, the Company is not authorized to charge you for complying with any of the requests set out in this section, 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 GDPR.

 

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 protocollo@gpdp.it.

 

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 November 7th, 2024.