Privacy Policy pursuant to Regulation (EU) No. 2016/679 of the European Parliament and of the Council of April 27, 2016
1. Data Controller
The data controller of all personal data collected through this website is the limited liability company CycloneChem S.r.l. (VAT number 09379501217), with its registered office located at Via Cuma, 28 – 80126 Naples (NA), Italy (the “Data Controller”).
2. Purpose of Data Processing
1)Registration on Data Controller’s websites**: The Data Controller collects some of your personal data, as required in the specific registration form, in order to process your request to register on one or more of its websites. The processing of your personal data will allow you to access your profile, participate in initiatives promoted through the website, receive newsletters, and use other services offered by the Data Controller.
Legal basis and lawfulness of processing**: The legal basis for processing is contractual, as per Article 6(b) of the Regulation. The processing of your personal data will be based on the contractual relationship that is created between you and the Data Controller when you accept the terms and conditions of the specific website.
2) Subscription to services or purchase of products and/or services:
In order to allow you to subscribe to one or more services offered by the Data Controller, such as classroom or digital training courses, the Data Controller needs to collect some of your personal data as required in the subscription or purchase form.
Legal basis and lawfulness of processing:The legal basis for processing is contractual, as per Article 6(b) of Regulation (EU) 2016/679. The processing of your personal data will be carried out by the Data Controller to provide you with the requested services and will be based on the contractual relationship that arises between you and the Data Controller.
3) Participation in events: In order to allow you to participate in events organized by the Data Controller, it is necessary for the Data Controller to collect some of your personal data, as required in the registration form for the event.
Legal basis and lawfulness of processing**: The legal basis for processing is contractual, as per Article 6(b) of the Regulation. The processing of your personal data will be carried out by the Data Controller to register you for the event and ensure your participation, thus based on the contractual relationship created between you and the Data Controller.
4) Invitations to seminars, masterclasses, and events: The Data Controller will process your email address, as provided during registration for a course or event, to keep you updated about future events organized by the Data Controller.
Legal basis and lawfulness of processing: The legal basis for processing is legitimate interest, as per Article 6(f) of the Regulation. The processing of your personal data will be carried out by the Data Controller to update you on events, courses, and seminars, in line with your expressed interest in the services offered by the Data Controller, based on the legitimate interest of the Data Controller.
3. Data Retention Period
One of the principles applied to the processing of your personal data is the limitation of the retention period, as outlined in Article 5(1)(e) of Regulation (EU) 2016/679, which states: “Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.” Personal data may be retained for longer periods if processed exclusively for archiving in the public interest, scientific or historical research, or statistical purposes, as provided in Article 89(1), subject to the implementation of appropriate technical and organizational measures to safeguard the rights and freedoms of the data subject.
In light of this principle, your personal data will be processed by the Data Controller for as long as necessary to pursue the purposes outlined in this Policy. Specifically, your personal data will be stored for the minimum period required, as indicated by Recital 39 of Regulation (EU) 2016/679. For example, if the legal basis for processing is registration on this website, data will be retained for up to ten years from your deletion from the website, subject to any further retention period required by law, as also outlined by Recital 65 of Regulation (EU) 2016/679.
4. Location of Data Processing
our personal data will be processed by the Data Controller within the territory of the European Union.
If, for technical and/or operational reasons, it is necessary to involve parties located outside the European Union, we hereby inform you that such parties, if processing personal data on behalf of the Data Controller, will be appointed as Data Processors pursuant to Article 28 of Regulation (EU) 2016/679. The transfer of your personal data to such parties, for the performance of specific processing activities, will be governed in accordance with the provisions of Chapter V of the Regulation. All necessary precautions will be taken to ensure the maximum protection of your personal data during such transfers, based on: (a) adequacy decisions by the European Commission regarding third- country recipients; (b) standard contractual clauses adopted by the European Commission; (c) binding corporate rules.
In any case, you can request further details from the Data Controller if your personal data has been processed outside the European Union, requesting evidence of the specific safeguards adopted.
5. Rights of the Data Subject
As outlined by Regulation (EU) 2016/679, you have the right to exercise the following rights at any time in relation to the Data Controller:
Right of access: You have the right, pursuant to Article 15 of Regulation (EU) 2016/679, to obtain confirmation from the Data Controller whether or not your personal data is being processed. If processing occurs, you are entitled to access the personal data and the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients to whom your personal data has been or will be disclosed, particularly if recipients are in third countries or international organizations; d) the period of retention of the personal data or, if not possible, the criteria used to determine such period; e) the existence of the right to request rectification, deletion, or restriction of processing of your personal data or to object to such processing; f) the right to lodge a complaint with a supervisory authority; g) where the data was not collected from you, all available information about its origin; h) the existence of automated decision-making, including profiling, and at least in such cases, meaningful information about the logic involved, as well as the significance and consequences of such processing for the data subject.
Right of rectification: You may request, pursuant to Article 16 of Regulation (EU) 2016/679, the rectification of any inaccurate personal data. Considering the purposes of processing, you may also request the completion of incomplete personal data by providing a supplementary statement.
Right to erasure: You have the right, under Article 17 of Regulation (EU) 2016/679, to have your personal data erased without undue delay, and the Data Controller is obliged to erase your personal data if any of the following reasons apply: a) the personal data is no longer necessary for the purposes for which it was collected or otherwise processed; b) you have withdrawn your consent on which the processing is based and no other legal grounds for processing exist; c) you have objected to processing under Article 21(1) or (2) of Regulation (EU) 2016/679, and there are no overriding legitimate grounds for processing; d) the personal data has been processed unlawfully; e) the personal data needs to be erased to comply with a legal obligation under EU or national law. In some cases, as outlined in Article 17(3) of Regulation (EU) 2016/679, the Data Controller is entitled not to erase your personal data if processing is necessary for the exercise of the right to freedom of expression and information, compliance with a legal obligation, reasons of public interest, scientific or historical research, or statistical purposes, or for the establishment, exercise, or defense of legal claims.
Right to restriction of processing: You have the right to obtain the restriction of processing, pursuant to Article 18 of Regulation (EU) 2016/679, in cases where: a) you contest the accuracy of your personal data (restriction will last for the period necessary for the Data Controller to verify the accuracy of the data); b) processing is unlawful but you object to the erasure of the personal data and request instead the restriction of its use; c) the Data Controller no longer needs the personal data for processing, but the data is required for the establishment, exercise, or defense of legal claims; d) you have objected to processing under Article 21(1) of Regulation (EU) 2016/679, and are waiting for a determination on whether the legitimate grounds of the Data Controller override your rights. If processing is restricted, your personal data will only be processed with your consent or for the establishment, exercise, or defense of legal claims, or to protect the rights of another person or for public interest reasons. You will be informed before the restriction is lifted.
Right to data portability: You may, at any time, request and receive, pursuant to Article 20(1) of Regulation (EU) 2016/679, all your personal data processed by the Data Controller in a structured, commonly used, and machine- readable format, or request its transfer to another data controller. In this case, it is your responsibility to provide the details of the new data controller to whom you wish to transfer your personal data, giving us written authorization.
Right to object: Pursuant to Article 21 of Regulation (EU) 2016/679, you may object, at any time, to the processing of your personal data: a) when such data is processed for direct marketing purposes, including profiling related to such marketing, or b) for reasons related to your particular situation, if your personal data is processed based on the legitimate interest of the Data Controller or a third party, unless there are legitimate compelling reasons for processing that override your interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defense of legal claims.
To exercise any of your rights as described above, you may contact the Data Controller by sending a written request via email to Direzioneoperativa@cyclonechem.it or by postal mail to Via Cuma, 28 – 80126 Napoli (NA) – Italy.
Furthermore, you have the right to lodge a complaint with the supervisory authority. Without prejudice to your right to seek other administrative or judicial remedies, you may file a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) or another competent supervisory authority if you believe that the processing of your personal data violates the Regulation or applicable laws.
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