Each of the above-mentioned companies acts as a joint data controller – pursuant to and by operation of article 4 and article 28 of the Privacy Code – for all data processing related to marketing and advertising, and are jointly and severally responsible for the collection and subsequent use of personal data. In addition, each company decides the following in conjunction with the others:
- how the data will be stored
- who shall have access to the information stored in the single database on the CRM (Customer Relationship Management) platform
- what kind of integrated marketing methods will be used.
Each company in the Mondadori Group has appointed the parent company, Arnoldo Mondadori Editore SpA, as the data processor in charge of managing the single database on the CRM platform. In this role, the data processor manages the phases of recording, organizing, storing, processing, selecting and extracting the personal data of customers/prospects. This is done to foster more effective marketing, which is a goal that all the companies in the group have in common.
Furthermore, personal data may be processed by individuals who are authorized as data processors both internally and externally, as well as by managers of the service requested by the user who have been authorized as persons in charge of data processing.
More detailed information on the names of internal and external data processors can be requested by writing to Arnoldo Mondadori Editore SpA – Ufficio Privacy – via Mondadori 1 – 20090 Segrate (MI) – email@example.com.
3. Type of data processed and the purposes of data processing
The website offers informative content, and at times interactive content as well. While browsing the website, therefore, information on the visitor may be collected in the following ways:
- Browsing data
During normal operation, the computer systems and software used to run this website collect some personal data; the transmission of this data is implicit in the use of communication protocols on the Internet.
Examples of the kind of data that fall under this category are as follows: IP addresses; the type of browser being used; the operating system; the domain name and the addresses of websites which were used to log in to or log out of this website; information on the pages that were viewed by the user within the website; login times; the time spent on each page; an analysis of browsing patterns within the website; and other parameters related to the user’s operating system and computing environment.
This kind of technical/computer data is collected and used in aggregate form only, and will not be used to identify the user. This data could also be used to determine responsibility in the event that computer crimes have been committed to the detriment of the website.
- Data that is voluntarily submitted by the user
This is all the personal data that is freely provided by a visitor to the website. This data, for example, could be provided to sign up and/or log in to a restricted area, to request information on a specific product or service by filling in a form, to write to an e-mail address, or to call a toll-free number (using VoIP technology) in order to contact customer service directly.
In some cases, this information could be used to build a user profile: should that occur, the user will be properly informed beforehand and be asked to give his/her free and specific consent to being the subject of marketing and/or profiling.
4. Ways that data is processed
For the most part, the processing of personal data is carried out through electronic procedures and media (DBs, CRM platforms, etc.), and only for the shortest time necessary to achieve the objectives for which the data has been collected.
5. Redirecting to external websites
The website may use so-called social plugins. Social plugins are special tools that allow a social network to embed its functions directly into the website (for example, Facebook’s “like” button).
All the social plugins that can be found on the website are marked with their respective logo, in order to identify the social network they belong to.
When a user visits a page on this website and interacts with the plugin (for example, by clicking the “like” button), or if a user decides to leave a comment, the browser transmits this information directly to the social networking service (in this case, Facebook), where it is stored.
6. Links to/from third-party websites
This website includes links to other websites of companies belonging to the Mondadori Group, as well as to third-party websites.
. The owner of this website disclaims all responsibility for any management of personal data by third-party sites and the management of authentication credentials provided by third parties.
7. Rights of data subjects
The individuals whose personal data is processed on this website (the so-called “data subjects”) have the right to know what data the company holds about them, why this data has been collected and how it is processed. They can also have the data extrapolated and made available, and if interested, add new data, or have the existing data updated and corrected. If a law has been broken, they also have to the right to demand that the data be blocked, deleted or transformed into an anonymous form.
In order to exercise these rights, obtain an updated list of data processors (should there be any appointed), report problems or ask for an explanation of how your personal data is being processed, please address your requests to the person in charge of data processing at Arnoldo Mondadori Editore S.p.A.. Please specify the subject of your request in the letter, which can be sent to the following address: Arnoldo Mondadori Editore SpA – Ufficio Privacy – via Mondadori 1 -20090 Segrate (MI) – firstname.lastname@example.org – ph. +39 02 75421.
8. Changes to the policy