Privacy policy

PRIVACY NOTICE CONCERNING THE PROCESSING OF WEBSITE USERS' PERSONAL DATA PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679

In accordance with European legislation on the processing of personal data (Regulation (EU) 2016/679, the General Data Protection Regulation or GDPR), Across Galvani Trustees S.r.l. processes personal data in compliance with Article 5 of the GDPR, respecting the fundamental principles of lawfulness, fairness and transparency.

This Privacy Notice is provided pursuant to Articles 13 and 14 of the GDPR and is addressed to users of the website www.agtrustees.it (the "Website"), owned by Across Galvani Trustees S.r.l.

Data Controller

The Data Controller is Across Galvani Trustees S.r.l., with its registered office at Corso Matteotti 1, Milan, Italy.

Email: segreteria@agtrustees.it

Legal Basis for Processing and Voluntary Provision of Personal Data

Except as otherwise specified below in relation to browsing data, users are free to provide the personal data required to fulfil requests for services offered through the Website.

The Data Controller processes personal data voluntarily provided by users on the basis of their consent, expressed through explicit acceptance of this Privacy Notice and the specific processing methods and purposes described herein.

Failure to provide the information requested in fields marked with an asterisk may prevent the provision of the requested services and/or information.

Purposes of Processing

Across Galvani Trustees S.r.l. processes users' personal data on the basis of their consent for the following purposes:

  • Responding to requests for information submitted through dedicated forms on the Website, including text messages addressed to Across Galvani Trustees S.r.l.
  • Registering users for the mailing list associated with the Across Galvani Trustees S.r.l. newsletter.
  • Registering users to attend educational and information events promoted and organised by Across Galvani Trustees S.r.l. through the dedicated Events section.

Separate and explicit consent will be requested from users for each of the purposes listed above through the relevant forms.

Personal Data Processed

Data Collected During Website Browsing

The IT systems and software procedures used to operate this Website collect certain personal data during their normal operation. The transmission of such data is inherent in the use of internet communication protocols.

This category includes IP addresses or domain names of the computers and devices used by users, URI/URL (Uniform Resource Identifier/Locator) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's response, and other parameters relating to the user's operating system and IT environment.

These data are necessary for the provision of web services and are also processed to obtain statistical information on the use of the services and to monitor their proper functioning.

The data are retained for the minimum period required by applicable legislation.

They may also be used to establish liability in the event of suspected cybercrime affecting the Website and/or its users.

Data Voluntarily Provided by Users

The optional, explicit and voluntary sending of messages to the contact addresses of Across Galvani Trustees S.r.l., as well as the completion and submission of forms available on the Website, results in the collection of the sender's personal data necessary to respond to the enquiry, together with any other personal data included in the communication.

Specific privacy notices will be published by Across Galvani Trustees S.r.l. on the Website pages dedicated to the provision of particular services.

Cookie Policy

For information about the use of cookies and the identification of the specific cookies used, please refer to the Cookie Policy available on the Website.

The processing of personal data through technical cookies is carried out on the basis of the Data Controller's legitimate interests. Other cookies are used on the basis of the data subject's consent.

Methods of Processing

Across Galvani Trustees S.r.l. ensures that personal data are processed in full compliance with the GDPR, using manual, computerised and electronic systems.

Disclosure of Personal Data to Other Recipients

Recipients of the personal data collected and processed by the Data Controller include parties appointed as external Data Processors pursuant to Article 28 of the GDPR, specifically:

  • Providers responsible for the development, provision, operational management and maintenance of the technological platform used for the Website, www.agtrustees.it, appointed as external Data Processors under Article 28 of the GDPR.
  • Personal data collected by the Data Controller are also processed by personnel of companies controlled by Across Galvani Trustees S.r.l., acting on the basis of specific instructions issued by the Data Controller.
  • Apart from the parties identified above, personal data will not be disclosed to additional recipients unless such disclosure is required by specific legal or regulatory provisions.

International Transfers of Personal Data

Personal data collected for the purposes described in this Privacy Notice will not be disclosed to third parties other than those identified in the preceding section, nor will they be made publicly available or transferred abroad to companies or other entities located outside the European Union.

However, Across Galvani Trustees S.r.l. reserves the right to use cloud-based services whose providers may be established abroad, either within or outside the European Union.

In such circumstances, service providers will be selected from those offering appropriate safeguards, as provided for under Article 46 of the GDPR.

Withdrawal of Consent

Pursuant to Article 7 of the GDPR, data subjects may withdraw any consent they have previously given at any time.

Withdrawal of consent will result in the cessation of processing activities based on that consent in relation to personal data submitted through the relevant form.

To withdraw consent given when requesting a service offered through the Website, users may contact Across Galvani Trustees S.r.l. using the procedures established for exercising data subject rights, as described in the following section.

To withdraw consent to receive the newsletter, users may unsubscribe by clicking the link provided at the bottom of each newsletter email and/or by sending a specific request to the Data Controller using the contact details provided in this Privacy Notice.

Rights of Data Subjects

As data subjects, users may exercise the rights provided for under Articles 15 to 22 of Regulation (EU) 2016/679 (GDPR), including the right to:

  • Obtain confirmation as to whether personal data concerning them are being processed, including data not yet recorded, and receive such information in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
  • Obtain information concerning: a. The source of the personal data. b. The purposes and methods of processing. c. The legitimate interests pursued by the Data Controller or by third parties. d. The recipients or categories of recipients to whom personal data have been or may be disclosed. e. Any intention of the Data Controller to transfer personal data to a third country or an international organisation. f. The period for which personal data will be retained. g. The logic involved, as well as the significance and envisaged consequences of processing for the data subject, where processing is carried out using electronic means as part of automated data collection and/or profiling. h. The identity and contact details of the Data Controller, Data Processors, any designated representative and the Data Protection Officer (DPO), where appointed. i. The persons or categories of persons to whom personal data may be disclosed or who may have access to such data in their capacity as designated representatives, Data Processors or authorised personnel.
  • Request the updating, rectification or, where appropriate, completion of their personal data.
  • Request the erasure, anonymisation or blocking of personal data processed unlawfully, including data whose retention is no longer necessary for the purposes for which they were collected or subsequently processed.
  • Request the restriction of processing.
  • Request the portability of their personal data to another Data Controller.
  • Withdraw consent to processing.
  • Object, in whole or in part, on legitimate grounds, to the processing of personal data concerning them, even where such processing is relevant to the purposes for which the data were collected.

To exercise any of the rights listed above, users may contact Across Galvani Trustees S.r.l. at any time by:

  • Email: segreteria@agtrustees.it, indicating "PRIVACY" in the subject line.
  • Post: Across Galvani Trustees S.r.l., Corso Matteotti 1, Milan, Italy, marking the envelope "PRIVACY".

Right to Lodge a Complaint

Users who believe that the processing of their personal data through the Website infringes the GDPR have the right to lodge a complaint with the competent supervisory authority pursuant to Article 77 of the GDPR.

They also have the right to seek a judicial remedy before the competent courts pursuant to Article 78 of the GDPR.

Data Retention

Personal data will be retained for no longer than is necessary to fulfil the purposes for which they were collected and, in any event, no longer than the period provided for under applicable legislation.

Data will be retained in accordance with the principles of lawfulness, necessity and proportionality.

Automated Decision-Making

The Data Controller does not carry out any processing involving automated decision-making concerning natural persons in relation to the processing activities described in this Privacy Notice.

Changes to This Privacy Notice

This Privacy Notice may be subject to subsequent amendments, including as a result of changes in applicable legislation, updates to existing services or the introduction of new services by the Data Controller, or technological developments.

In such circumstances, users are encouraged to review the Privacy Policy available on the Website.