Privacynotice.

Solwin Italy S.p.A. (hereinafter, the “Controller”).

How can I contact the Controller?

Email: contactus@solwin.com

Address: Piazzale Luigi Cadorna 4, 20123 Milan, Italy

Under the General Data Protection Regulation (GDPR), legal persons are not data subjects and the Regulation therefore does not apply to data relating exclusively to legal persons. However, where personal data relating to natural persons are provided in connection with an enquiry, those persons are data subjects under the GDPR and their personal data are processed in accordance with this Privacy Notice.

Contact us (any form of contact)

Purpose. The purpose of the processing is to receive and manage information and commercial enquiries submitted through the contact form, by direct email or by telephone, and to follow up on any potential collaboration, investment or land-related negotiation.

Legal basis. Steps taken at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR). In the event of a dispute, the data may also be processed for the establishment, exercise or defence of legal claims on the basis of the Controller’s legitimate interests.

Retention period. Personal data will be retained for a maximum period of 12 months from receipt of the enquiry. Where the enquiry results in a business relationship, the related correspondence will be retained for the duration of that relationship, without prejudice to any further retention required by law or necessary for the establishment, exercise or defence of legal claims.

Other information. The data processed in order to respond to an enquiry are: name, work email address, subject and message content. Providing the data is voluntary; however, if the necessary data are not provided, the Controller will be unable to respond to the enquiry.

Browsing data

Purpose. Website security and proper operation of web services.

Legal basis. The Controller’s legitimate interest in cybersecurity and the proper functioning of the website (Article 6(1)(f) GDPR).

Retention period. Browsing data are retained for the period strictly necessary for website security and operation, in accordance with the technical retention periods applied to system logs.

Other information. Browsing data may include, by way of example, IP address, date and time of the request, the resource requested, and information about the browser or device used. The website does not use analytics, profiling or advertising tools. For further information on the technical tools used by the website, please refer to the Cookie Policy.

Personal data will be processed lawfully, fairly and with the utmost confidentiality, in compliance with the appropriate security measures required by applicable law and the GDPR. Processing is carried out by digital means. Personal data will not be publicly disclosed. Users will not be subject to automated decision-making or profiling. The website does not use analytics tools, advertising pixels, social media tags, chat tools or third-party embedded content.

The Controller may disclose personal data to persons or entities where disclosure is required by law or otherwise necessary for the purposes described in this Privacy Notice.

The Controller also uses service providers and IT tools that process personal data on its behalf and are duly appointed as processors under Article 28 GDPR, including providers of hosting, contact-form and email services.

Personal data may be processed by authorised personnel of the Controller and, where necessary to handle an enquiry, disclosed to other Group companies, advisers and public authorities where required by law.

An up-to-date list of processors is available from the Controller.

The management and storage of personal data, in connection with the processing activities described in this Privacy Notice, are carried out using infrastructure and services located within the European Economic Area.

Where, due to specific requirements related to the services used by the Data Controller, it becomes necessary to transfer personal data to countries outside the European Economic Area, such transfers will be carried out in compliance with Chapter V of the GDPR and, as applicable, on the basis of an adequacy decision adopted by the European Commission or through appropriate safeguards pursuant to Article 46 GDPR, including the Standard Contractual Clauses adopted by the European Commission.

Information concerning the safeguards applicable to such transfers may be requested from the Data Controller using the contact details provided in this Privacy Notice.

a) Data subject rights

As a data subject, you have the rights set out in Articles 15 et seq. GDPR, including in particular:

• Right of access (Article 15 GDPR). You have the right to obtain confirmation as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and the information set out in Article 15 GDPR.
• Right to rectification (Article 16 GDPR). You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
• Right to erasure (Article 17 GDPR). You have the right to obtain erasure of personal data in the circumstances set out in Article 17 GDPR. Where a request cannot be granted, the Controller will provide the reasons within the time limits laid down by applicable law.
• Right to restriction of processing (Article 18 GDPR). You have the right to obtain restriction of processing in the circumstances set out in Article 18 GDPR, for example while the accuracy of contested data is being verified.
• Right to data portability (Article 20 GDPR). Where processing is based on a contract and carried out by automated means, you have the right, where the legal conditions are met, to receive personal data concerning you in a structured, commonly used and machine-readable format and to transmit those data to another controller.
• Right to object (Article 21 GDPR). Where processing is based on the Controller’s legitimate interests, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you. The Controller will then cease processing unless it demonstrates compelling legitimate grounds which override your interests, rights and freedoms or unless processing is required for the establishment, exercise or defence of legal claims.
• Right to lodge a complaint. You have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or another competent supervisory authority under Article 77 GDPR if you consider that the processing of your personal data infringes applicable data protection law.

b) How to exercise your rights

Data subjects may exercise the rights set out above at any time by contacting the Controller using the contact details provided in this Privacy Notice.