INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 D.LGS.196 / 03

 

Growth Capital Srl with registered office in Piazza Armando Diaz No. 5, pursuant to Article 28 of Legislative Decree 196/03 is the Data Controller (hereinafter "GC") and in fulfillment of the obligations provided for by Article 13 of Legislative Decree 196/03 provides this Information which details the methods and limits of the processing of personal data.

 

Definitions

For "personal data" (pursuant to art. 4 number 1 of EU Regulation 2016/679): any information concerning an identified or identifiable natural person ("interested party"); the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social.

By "processing", (pursuant to art. 4 number 2 of EU Regulation 2016/679), we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

 

Who is the data controller?

Company name: Growth Capital Srl

Registered office address: Piazza Armando Diaz, n. 5, 20123 Milan

Telephone contact details: + (39) -02-782138

Contact details email: info@ aroad.com

 

GC can be contacted at the above addresses.

 

Data processing carried out through the site

 

PERSONAL DATA COLLECTED

GC collects and processes the personal data provided by the interested parties, such as identification and / or personal data (for example, name, surname, address, telephone, tax data, and email address, etc.).

 

PURPOSE OF THE TREATMENT

The purposes of the processing of personal data are as follows:

  1. the fulfillment of obligations established by laws, regulations or community legislation in relation or in any case connected to the existing and / or future legal relationship;

  2. Possible registration on the site in order to have access to the reserved area, as well as to propose your own project or business idea;

  3. Presentation and / or completion of the request for collaboration / consultancy / advisory, as well as use and / or sharing of information with any interested / involved parties;

  4. Execution and organizational management of the existing and / or future legal relationship, from the earliest stages of establishment to operational development;

  5. Internal statistical analysis in aggregate form;

  6. Possible subscription to the newsletter for sending promotional and informative material.

The following table specifies the legal basis, the categories of data, the categories of personal data and the relative retention period for each of the purposes identified above:  

 

 

 

 

 

 

 

 

   

 

 

 

 

 

 

 

 

* Categories of recipients

In relation to the purposes indicated, the data may be communicated to the following subjects and / or to the categories of subjects indicated below, or they may be communicated to companies and / or persons, in EU countries, which provide services, including external ones, on behalf of the Data Controller. Among these **, for greater clarity and by way of example but not limited to, their different types are indicated:

  • IT service company;

  • Communication agencies;

  • Law firms;

  • Collaborators / professionals / consultants;

  • Potential investors or individuals interested in the proposed activities;

  • Marketing consultancy firm;

  • Control and supervisory bodies.

(**) the list of external recipients / managers with further data useful for identification is available from the Data Controller.

 

TRANSFER OF DATA TO A NON-EU THIRD COUNTRY

The Data Controller does not transfer personal data to non-EU territory.

 

STORAGE PERIOD

Please refer to table 1 in column 4 (retention period of personal data).

 

RIGHTS OF THE INTERESTED PARTY

The interested party, in relation to the personal data covered by this information, has the right to exercise the rights provided for by the EU Regulation listed below:

  • right of access of the interested party [art. 15 of the EU Regulation] (consisting in the possibility of being informed about the processing carried out on their personal data and possibly receiving a copy);

  • right to rectify personal data [art. 16 of the EU Regulation] (the interested party has the right to rectify inaccurate personal data concerning him);

  • right to cancel personal data without undue delay ("right to be forgotten") [art. 17 of the EU Regulation] (the interested party has, and will have, the right to have their data deleted);

  • right to limit the processing of personal data in the cases provided for by art. 18 of the EU Regulation, including in the case of unlawful processing or dispute of the accuracy of personal data by the interested party [art. 18 of the EU Regulation];

  • right to data portability [art. 20 of the EU Regulation], (the interested party may request their personal data in a structured format in order to transmit them to another Data Controller, in the cases provided for by the same article);

  • right to object to the processing of personal data [art. 21 of the EU Regulation] (the interested party has, and will have, the right to object to the processing of their personal data in the cases provided and regulated by art. 21 of the EU Regulation);

  • right not to be subjected to automated decision-making processes [art. 22 of the EU Regulation] (the interested party has, and will have, the right not to be subjected to a decision based solely on automated processing).

The aforementioned rights can be exercised in accordance with the provisions of the EU Regulation by sending an email to growthcapital@crossborder.it.

GC, in compliance with art. 19 of the EU Regulation, proceeds to inform the recipients to whom the personal data have been communicated, of any corrections, cancellations or limitations of the processing requested, where this is possible.

If the processing purpose pursued by GC has consent as its legal basis, the interested party has the right to proceed, at any time, with the revocation by sending an email to the above address. Pursuant to art. 7 of the EU Regulation, the withdrawal of consent does not affect the lawfulness of the processing based on the consent made prior to the withdrawal. If the interested party considers that his rights have been compromised, he has the right to lodge a complaint with the Guarantor Authority.

For further information on the rights and on the exercise of the same, please refer to the paragraph "Regulatory references on the rights of the data subject".

The Company does not make use of any automated decision-making process.

 

METHOD OF TREATMENT

Personal data will be processed in paper, computerized and telematic form and inserted in the relevant databases (potential customers, customers, users, etc.) to which the employees expressly designated by the Data Controller as Managers and Appointees of the processing of personal data, which may carry out consultation, use, processing, comparison and any other appropriate operation, including automated, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of the data as well as the accuracy , the updating and relevance of the data with respect to the declared purposes.

 

Processing of data useful for the purpose of navigation

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

Among the information that can be collected we have the IP addresses, the type of browser or operating system used, the addresses in URI (uniform resource identifier) notation, the domain name and the addresses of the websites from which the access or exit (referring / exit pages), the time at which the request was made to the server, the method used and information on the response obtained, further information on the user's navigation on the site (see also the relative section to cookies) and other parameters relating to the user's operating system and IT environment.

These same data could also be used to identify and ascertain responsibilities in the event of any computer crimes against the site.

 

Use of cookies

There are two basic macro-categories, with different characteristics: technical cookies and profiling cookies.

Technical cookies are generally necessary for the website to function properly and to allow navigation; without them you may not be able to display the pages correctly or to use some services. For example, a technical cookie is essential to keep the user connected throughout the visit to a website, or to memorize the settings of the language, display, and so on. Technical cookies can be further divided into:

  • navigation cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);

  • analytics cookies, similar to technical cookies only when used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site.

  • functionality cookies, which allow the user to browse according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.

Profiling cookies are more sophisticated! These cookies have the task of profiling the user and are used in order to send advertising messages in line with the preferences expressed by the user while browsing.

Cookies can, again, be classified as:

  • session cookies, which are deleted immediately when the browser is closed;

  • persistent cookies, which - unlike session cookies - remain in the browser for a certain period of time. They are used, for example, to recognize the device that connects to the site, facilitating authentication operations for the user.

  • first-part cookies (first-part cookies) i.e. cookies generated and managed directly by the manager of the website on which the user is browsing.

  • • third-party cookies (third-part cookies), which are generated and managed by parties other than the operator of the website on which the user is browsing (as a rule, by virtue of a contract between the website owner and the third part).

 

WHICH COOKIES DOES GROWTH CAPITAL USE?

This site, in particular, uses third-party cookies using the Google Analytics service, provided by Google Inc., to generate statistics on the accesses made and the pages, parts or elements most appreciated by users. This site also adopts tools that reduce the identifying power of cookies, such as the anonymization of the users' IP address, before processing or storage by Google takes place. For more information, regarding these cookies not owned by us, you can consult the information provided by Google at the following addresses:

You can choose to disable Google Analytics by installing on your browser the add-on for deactivation    _cc781905-5cde-3194-bb3b-136bad5cf5890d_ 3194-bb3b-136bad5cf589094 _cc7 136bad5cf58d_       _cc781905 -5cde-3194bbadd-136bcc5-135_b58905-bbc5-3194bcc5-136bcc5_ 3194-bb3b-136bad5cf58d_       3194bde-51384bd3-136bad5cf58d_ _cc79094-badd5-136bcc5-3194bd3-136bad5cf58d_       _cc781905-5cde-3194-bb589094-136bad5cde-3194-bb589094-136bad5ccc3 -bb3b-136bad5cf58d_.

The following tables specifically indicate the cookies ** used.

 

 

 

 

 

 

 

 

 

 

 

 

 

* This website adopts tools that reduce the identifying power of cookies, such as the anonymization of the users' IP address before processing or storage by Google inc.

Finally, below are the links to the most popular browsers, where there is information on how to disable the storage or delete the cookies already stored on the browser:

 

Notice regarding children under 16

Children under the age of 16 cannot provide personal data. GC will not be in any way responsible for any collection of personal data, as well as false declarations, provided by the minor, and in any case, if it is used, GC will facilitate the right of access and cancellation forwarded by the guardian. legal or by whoever exercises parental authority.


Exercise of the rights of the interested party

The interested party, in relation to the personal data covered by this information, has the right to exercise the rights provided for by the EU Regulation listed below:

 

Right of access by the interested party (Article 15 of the EU Regulation):

the interested party has the right to obtain from the owner confirmation that their personal data is being processed or not and, in this case, access to the information expressly provided for in the aforementioned article, including by way of example and not limited to the purposes of the processing, the categories of data and recipients, the retention period, the existence of the right of cancellation, rectification or limitation, the right to lodge a complaint, all available information on the origin of the data, the possible existence of a process automated decision-making pursuant to art. 22 of the Regulations, as well as a copy of their personal data.

 

Right of rectification (Article 16 of the EU Regulation):

the interested party has the right to obtain from the data controller the correction and / or integration of inaccurate personal data concerning him, without undue delay;

 

Right to cancellation (right to be forgotten) (Article 17 of the EU Regulation):
the interested party has the right to cancel his / her personal data without undue delay, if one of the reasons expressly provided for in the aforementioned article exists, including by way of example and not exhaustive, the lack of the need for processing with respect to the purposes, the withdrawal of consent on which the treatment is based, opposition to treatment in the event that it is based on non-prevailing legitimate interest, unlawful data processing, cancellation due to legal obligations, data of minors processed in the absence of the conditions of applicability provided for by art. 8 of the Regulations;

 

Right to limitation of processing (Article 18 of the EU Regulation):

in the cases provided for by art. 18, including the unlawful processing, the contestation of the accuracy of the data, the opposition of the interested party and the lack of the need for processing by the owner, the data of the interested party must be processed only for storage unless the consent of the itself and the other cases expressly provided for by the aforementioned article;

 

Right to data portability (Article 20 of the EU Regulation):

the interested party, in cases where the processing is based on consent and on the contract and is carried out by automated means, may request to receive their personal data in a structured format, commonly used and readable by an automatic device, and has the right to transmit them to another holder;

 

Right to object (Article 21 of the EU Regulation):

the interested party has the right to object to the processing of their personal data, in the event that the processing is based on a legitimate interest that is not prevailing or is carried out for direct marketing purposes;

Right not to be subjected to automated decision-making processes (Article 22 of the EU Regulation):
the interested party has the right not to be subjected to a decision, including profiling, based solely on automated processing (for example carried out exclusively through electronic tools or computer programs).

The above description does not replace the text of the articles cited therein which are referred to here in full and to whose full reading please refer to the paragraph Legal references on the rights of the interested party

 

Right to lodge a complaint:

If the interested party considers that his rights have been compromised, he has the right to lodge a complaint with the Guarantor Authority for the protection of personal data, according to the methods indicated by the same Authority at the following internet address: _cc781905-5cde-3194-bb3b- 136bad5cf58d_Click here

For more information on the rights of the data subjects provided by the Guarantor, please refer to the paragraph Regulatory references on the rights of the data subject

 

Changes and updates

This information shows the date of its last update in its header.
GC may also make changes and / or additions to this privacy policy also as a consequence of any subsequent amendments and / or regulatory additions.

 

Normative references on the rights of the interested party

 

ARTICLE 15 RIGHT OF ACCESS OF THE INTERESTED PARTY

The interested party has the right to obtain from the data controller confirmation as to whether or not personal data concerning him is being processed and, in this case, to obtain access to personal data and the following information:

  1. the purposes of the processing;

  2. the categories of personal data in question;

  3. the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if they are recipients of third countries or international organizations;

  4. when possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period;

  5. the existence of the right of the interested party to ask the data controller to correct or delete personal data or limit the processing of personal data concerning him or to oppose their treatment;

  6. the right to lodge a complaint with a supervisory authority;

  7. if the data are not collected from the interested party, all available information on their origin;

  8. the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the 'interested.

  1. If personal data are transferred to a third country or to an international organization, the interested party has the right to be informed of the existence of adequate guarantees pursuant to Article 46 relating to the transfer.

  2. The data controller provides a copy of the personal data being processed. In the event of further copies requested by the interested party, the data controller may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format.

  3. The right to obtain a copy referred to in paragraph 3 must not affect the rights and freedoms of others.

 

ARTICLE 16 RIGHT OF RECTIFICATION

The interested party has the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the interested party has the right to obtain the integration of incomplete personal data, also by providing an additional declaration.

 

ARTICLE 17 RIGHT TO ERASURE ("RIGHT TO BE FORGOTTEN")

The data subject has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay and the data controller is obliged to cancel the personal data without undue delay, if one of the following reasons exists:

  1. the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

  2. the interested party revokes the consent on which the processing is based in accordance with Article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), and if there is no other legal basis for the processing;

  3. the interested party opposes the processing pursuant to Article 21, paragraph 1, and there is no legitimate overriding reason to proceed with the processing, or opposes the processing pursuant to Article 21, paragraph 2;

  4. the personal data have been unlawfully processed;

  5. personal data must be deleted to fulfill a legal obligation under Union law or the law of the Member State to which the data controller is subject;

  6. the personal data have been collected in relation to the offer of information society services referred to in Article 8

 

If the data controller has made personal data public and is obliged, pursuant to paragraph 1, to delete them, taking into account the available technology and the implementation costs, it adopts reasonable measures, including technical ones, to inform the data controllers that they are processing the personal data of the request of the interested party to delete any link, copy or reproduction of his personal data.

 

Paragraphs 1 and 2 do not apply to the extent that processing is necessary:

  1. to exercise the right to freedom of expression and information;

  2. for the fulfillment of a legal obligation that requires the processing provided for by the law of the Union or of the Member State to which the data controller is subject or for the performance of a task carried out in the public interest or in the exercise of public authority referred to the data controller is invested;

  3. for reasons of public interest in the field of public health in accordance with Article 9 (2) (h) and (i) and Article 9 (3);

  4. for archiving purposes in the public interest, for scientific or historical research or for statistical purposes in accordance with Article 89, paragraph 1, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously prejudice the achievement of the objectives of that treatment;

  5. for the assessment, exercise or defense of a right in court.

 

ARTICLE 18 RIGHT TO LIMITATION OF PROCESSING

The interested party has the right to obtain from the data controller the limitation of the processing when one of the following hypotheses occurs:

  1. the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data;

  2. the processing is unlawful and the interested party opposes the cancellation of personal data and requests instead that its use be limited;

  3. although the data controller no longer needs it for processing purposes, personal data are necessary for the data subject to ascertain, exercise or defend a right in court;

  4. the interested party opposed the processing pursuant to article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.

 

If the processing is limited pursuant to paragraph 1, such personal data are processed, except for storage, only with the consent of the interested party or for the ascertainment, exercise or defense of a right in court or for protect the rights of another natural or legal person or for reasons of significant public interest of the Union or of a Member State.

 

The interested party who has obtained the processing limitation pursuant to paragraph 1 is informed by the data controller before said limitation is revoked.

 

ARTICLE 19 OBLIGATION TO NOTIFY IN THE EVENT OF CORRECTION OR CANCELLATION OF PERSONAL DATA OR LIMITATION OF PROCESSING

The data controller communicates to each of the recipients to whom the personal data have been transmitted any corrections or cancellations or limitations of the processing carried out pursuant to article 16, article 17, paragraph 1, and article 18, except for this proves impossible or involves a disproportionate effort. The data controller informs the data subject of these recipients if the data subject requests it.

 

ARTICLE 20 RIGHT TO DATA PORTABILITY

The interested party has the right to receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to a data controller and has the right to transmit such data to another data controller without impediments from part of the data controller to whom he provided them if:

  1. the processing is based on consent pursuant to article 6, paragraph 1, letter a), or article 9, paragraph 2, letter a), or on a contract pursuant to article 6, paragraph 1, letter b) : And

  2. the processing is carried out by automated means.

 

In exercising their rights regarding data portability pursuant to paragraph 1, the interested party has the right to obtain the direct transmission of personal data from one data controller to another, if technically feasible.

The exercise of the right referred to in paragraph 1 of this article is without prejudice to article 17, This right does not apply to the processing necessary for the performance of a task in the public interest or connected to the exercise of public authority vested in it. the data controller.

The right referred to in paragraph 1 must not affect the rights and freedoms of others.

 

 

 

ARTICLE 21 RIGHT OF OBJECTION

The interested party has the right to object at any time, for reasons connected to his particular situation, to the processing of personal data concerning him pursuant to article 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions, the data controller refrains from further processing personal data unless he demonstrates the existence of compelling legitimate reasons to proceed with the processing that prevail over the interests, rights and freedoms of the interested party or for the verification, exercise or defense of a right in court.

If personal data are processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data concerning him for these purposes, including profiling to the extent that it is connected to such direct marketing.

If the data subject objects to the processing for direct marketing purposes, the personal data are no longer processed for these purposes.

The right referred to in paragraphs 1 and 2 is explicitly brought to the attention of the interested party and is presented clearly and separately from any other information at the latest at the time of the first communication with the interested party.

In the context of the use of information society services and without prejudice to Directive 2002/58 / EC, the interested party can exercise his right to object by automated means using specific techniques.

If personal data are processed for scientific or historical research purposes or for statistical purposes pursuant to Article 89, paragraph 1, the interested party, for reasons connected with his particular situation, has the right to object to the processing of personal data that concerns, except if the processing is necessary for the performance of a task of public interest.

 

ARTICLE 22 AUTOMATED DECISION-MAKING PROCESS RELATING TO INDIVIDUALS, INCLUDING PROFILING

The interested party has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way.

Paragraph 1 does not apply if the decision:

  1. it is necessary for the conclusion or execution of a contract between the data subject and a data controller;

  2. is authorized by the law of the Union or of the Member State to which the data controller is subject, which also specifies adequate measures to protect the rights, freedoms and legitimate interests of the data subject;

  3. is based on the explicit consent of the interested party.

 

In the cases referred to in paragraph 2, letters a) and c), the data controller implements appropriate measures to protect the rights, freedoms and legitimate interests of the data subject, at least the right to obtain human intervention by the data controller. , to express their opinion and to contest the decision.

The decisions referred to in paragraph 2 are not based on the special categories of personal data referred to in Article 9 (1), unless Article 9 (2) (a) or (g) applies, and not adequate measures are in place to protect the rights, freedoms and legitimate interests of the data subject.

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