|Company||Role in privacy management||Data processing operations|
|Arnoldo Mondadori Editore|
|Mondadori International Business|
|Giulio Einaudi Editore|
|Sperling & Kupfer Editori|
|Cemit Interactive Media|
Pursuant to and by operation of article 4 and article 28 of the Privacy Code, each company in the Group:
- acts as joint data controller for marketing and profiling purposes;
- is jointly and severally responsible with the other companies in the Group for the collection and subsequent use of personal data;
- decides, in conjunction with the other companies in the Group, how the data will be stored, who shall have access to the information stored in the CRM (Customer Relationship Management) database, and what kind of integrated marketing methods will be used;
- appoints the parent company Arnoldo Mondadori Editore S.p.A. as external data controller, who is in charge of managing the recording, organization, storage, adaptation, consultation and retrieval of personal data belonging to customers/prospects and contained in the single CRM database.
Extent of data flow
Personal data may flow within the organizational confines of any entities appointed as data controllers, as well as outside of said confines when third-party companies are enlisted to carry out operations in support of and on behalf of the joint data controllers. In addition, personal data may be used by individuals who are specifically appointed as Data Processors in charge of the service requested of them, and who are given detailed instructions on the security and correct use of said data.
More detailed information on the names of internal and external data controllers and processors can be requested by writing to firstname.lastname@example.org.
a) Definition and kinds of “personal data” that can be processed
As set forth in article 4 of the Privacy Code, the term “personal data” means “any information relating to a natural person who is identifiable or who can be identified, directly or indirectly, by reference to any other information, including a personal identification number”.
Arnoldo Mondadori Editore SpA may come into possession of the following kinds of personal data:
- personal data that has been entered in registration forms or freely provided during correspondence via telephone, live chat or e-mail, such as name, surname, domicile/residence address, date of birth, e-mail address, landline and/or mobile telephone numbers;
- data regarding personal tastes, preferences, habits, needs and consumer decision-making, as gathered from the website user data or in connection with specific customer loyalty programs.
b) Data processing: purposes and procedures
Arnoldo Mondadori Editore SpA may have to use software tools or paper-based methods to process one or more of the kinds of personal data listed in point c), for the purposes listed below:
- 1. Purposes related to and in support of submitted requests
This category includes all operations related to the provision of the specific service or activity that has been freely requested through filling in a form, sending an e-mail or making a phone call.
When filling in a form, all data provided in the fields marked with an * (asterisk) and any answers provided to questions marked with an * (asterisk) are required in order to carry out the request. Should this data not be provided, it will not be possible to fulfill the request.
- 2. Purposes related to advertising and/or marketing
This category includes all operations carried out in order to advertise products and/or services that are associated with or related to the product categories of the companies belonging to the Mondadori Group (the joint data controllers, as stated in the introduction above). Advertising services can also be tailored to third-party individuals or companies (when possible, please list the third-party individuals/companies), in this case without disclosing data. Any personal data collected with the consent of the data subject may be disclosed to third-party companies for these same purposes, and said third-party companies shall act as independent controllers thereof (in this regard, please see paragraph e) below, entitled Categories of potential recipients of data)
- 3. Purposes related to customer profiling, market research and statistical analysis
This category includes all activities associated with or related to profiling the data subject, with the aim of identifying personal tastes, preferences, habits, needs and consumer choices. In this way, the companies belonging to the Mondadori Group (the joint data controllers, as stated in the introduction above) can enhance the services that they provide.
The option of providing personal data – The user is not required to provide personal data for the purposes outlined in paragraphs 2 and 3 above. The collection of personal data is contingent upon free consent granted by the data subject to use his/her data for the purposes and under the conditions mentioned above. The data subject can express his/her consent by using the attached form.
Ways of contacting customers – Should the user grant his/her consent to being contacted for advertising and/or profiling purposes (as outlined in paragraphs 2 and 3 above), then both traditional and automated forms of contact may be used. Traditional forms include non-automated telemarketing and mailings, while automated forms include e-mail, SMS, MMS, fax and automated phone calls. The user may also withdraw his/her previously-granted consent at any time, including a partial withdrawal of consent: for example, the user may consent to being contacted by traditional means only.
c) Categories of potential recipients of data
Arnoldo Mondadori Editore SpA may want to disclose a user’s personal data to another entity as part of its regular business activity and/or for the purposes outlined in point d) above. In that regard, the following entities could be potential recipients of said data:
- 1. Third-party companies not affiliated with the Mondadori Group.
Disclosure of this sort may only occur after obtaining the user’s specific consent to do so. In that case, the data could be disclosed to other companies that are not affiliated with the Mondadori Group, for the purpose of advertising their products and/or services. Such companies may work in the following fields: publishing, consumer goods and retail, distance selling, interior decoration, telecommunications, pharmaceuticals, finance, insurance, and the automotive industry. Further information on the names of these individual third-party companies can be obtained by writing to Arnoldo Mondadori Editore SpA – Ufficio Privacy – via Mondadori, 1 – 20090 Segrate (MI), or by sending an email to email@example.com.
- 2. Public bodies
Personal data may be disclosed to public bodies or law enforcement agencies when required, in order to prevent or fight a crime.
Should it become necessary, the user may use the attached form to express his/her consent.
d) Transfer of personal data abroad
In carrying out the activities herein described, Arnoldo Mondadori Editore SpA shall not transfer any personal data abroad, be it within or outside the European Economic Area (EEA).
e) Dissemination of personal data
Any personal data collected is not and shall not be subject to dissemination, except for purposes of anonymous and aggregate statistical analysis.
f) Data subject’s rights
The data subject has the right to consult his/her own personal data and request that corrections and/or updates be made should the data be incomplete or inaccurate. The data subject also has the right to request the erasure of personal data if it was collected illegally, as well as to object to the processing of personal data on compelling legitimate grounds, in accordance with articles 7-10 of the Privacy Code.
Should the data subject withdraw his/her previously-granted consent to the use of personal data for the purposes of marketing, profiling or disclosure to third-party entities, then the processing of said data shall be discontinued accordingly.
Should a data subject wish to: exercise his/her rights; know the names of the internal and external data controllers and processors; obtain information on the companies belonging to the Mondadori Group; obtain information on third-party companies for which advertising is carried out, or which may be potential recipients of personal data; or withdraw previously-granted consent, then please contact the data controller at Arnoldo Mondadori Editore by writing to Arnoldo Mondadori Editore SpA – Ufficio Privacy – via Mondadori, 1 – 20090 Segrate (MI), or by sending an email to firstname.lastname@example.org.