[Last update 11 March 2021]
1) Holder of the treatment
The data controller is:
FREGNI STEFANIA, Via Guarini 22 – 41124 Modena (VAT number IT02898970369)
I inform you, pursuant to art. 13 EU Regulation no. 2016/679 (hereinafter, “GDPR”), that your data will be processed in the manner and for the following purposes.
For any doubt or need you can contact me at the following e-mail address: email@example.com
2) Types of data
I ask you to provide me only your name, your surname, the city in which you live and your e-mail address in order to send you periodic newsletters and become part of my mailing list, thus receiving free resources, communications regarding my initiatives, promotional offers on my services and products and affiliate links to products or services that I think may be useful to you.
By registering through one of the online forms on my website www.mymodenadiary.it and sending your data, you will be included in one or more E-mail lists managed by an autoresponder that will keep track, for each E-mail sent, of the opening or non-opening of the same, of the clicks on the links present in the body of the E-mails, of the days and opening hours of the E-mails and of the clicked links, as well as the number of open E-mails and clicked links.
Your data will be processed almost exclusively on digital media.
3) Purpose and legal basis
I ask for these personal data in order to process your subscription request to my Newsletter and/or to download free resources that I make available to those who want to register.
The newsletter and other emails you will receive may also contain commercial information, discounts and other promotions on my services or affiliate links to products or services that I think may be useful to you.
The legal basis of the processing lies in the consent given by selecting the appropriate box in the contact form (Point & Click).
4) Retention period
Your personal data will be kept until you voluntarily revoke your consent to receive the Newsletter via the appropriate “Unsubscribe” button in all the e-mails you will receive or until the owner decides to stop sending.
After 60 days from your unsubscription from my newsletter, your personal data will be completely deleted from my management system.
The processing of your data takes place mainly in electronic and/or semi-automated form.
5) Data recipients
Your data may be disclosed to third-party companies or other subjects (by way of example: accountant, lawyer and any freelance collaborators who could help me in the management of requests and in the organization of the back office), some in their capacity as external data processors and bound by my precise instructions and policies, as well as by obligations of confidentiality and secrecy.
Upon request, I can provide you with a list of my collaborators, data processors, if any, by writing to firstname.lastname@example.org.
Data processing is always carried out mainly in an automated manner, even in backups.
6) Transfer to third countries and guarantees
Personal data can be transferred or stored outside the EU.
In this case, the owners ensure that all the guarantees required by art. 44 and subsequent amendments of the GDPR.
For the United States, although there is no adequacy decision by the European Commission, I make sure that at the contractual level there are all suitable measures and guarantees to guarantee the security of your data.
The lack of adequate guarantees is not linked to the supplier in and of itself, which we make sure it takes all the necessary security measures to keep your data safe, but it is linked to the laws of third countries which are not always aligned with the guarantees of protection offered by the GDPR. However, this is an ever-changing situation and, in any case, my suppliers continue to comply with the terms of the Privacy Shield Framework.
In particular, I use the following external platforms:
Mailchimp, for the collection of lists and consents:
https://mailchimp.com/legal/ based in Atlanta (Georgia) which uses standard contractual clauses in order to guarantee the security of your data.
7) Nature of the provision of data
The provision of data is mandatory to receive the Newsletters and to download my free resources.
Failure to consent to the processing of the name and e-mail will prevent access to the services.
8) Rights of the interested party
According to the European Regulation, you have the right to ask:
- access to your personal data (therefore to know what personal data we hold);
- the rectification of inaccurate data or the integration of incomplete ones (in case some of your data has undergone changes, such as a new E-mail address);
- the deletion of personal data (upon the occurrence of one of the conditions indicated in art. 17, par. 1 of the GDPR and in compliance with the exceptions provided for in paragraph 3 of the same article);
- the limitation of the processing of your personal data (for example, you could ask us not to be subscribed to the My Modena Diary Newsletter even though you are a customer), if one of the hypotheses indicated in art. 18, par. 1 of the GDPR;
- opposition to processing (for example if you realize that your data is processed in a manner that does not comply with this information);
- request and obtain your personal data in a structured and machine-readable format, also in order to communicate such data to another data controller (right to portability);
- withdraw consent at any time, limited to cases in which the processing is based on consent for one or more specific purposes and concerns common personal data (for example date and place of birth or place of residence), or particular categories of data (for e.g. data revealing racial origin, political views, religious beliefs, health or sex life). The treatment based on consent and carried out prior to the revocation of the same retains, however, its lawfulness.
- lodge a complaint with a supervisory authority (Authority for the protection of personal data – www.garanteprivacy.it).
9) How to exercise the rights
You can exercise your rights at any time by sending an email to email@example.com.
10) Security guarantees of your data
I am particularly careful and respectful of your personal data and, therefore, I undertake to ensure that they can be treated correctly and to guarantee their safety and protection from the risks of loss, theft or abuse by third parties.
11) Further information
For any doubt or problem regarding the processing of your data, you can write to firstname.lastname@example.org.
So I invite you to consult it periodically according to your needs.
11/03/2021: first version