This information is provided in accordance with Article 13 of Regulation 2016/679 (GDPR), pursuant to Article 13 of Legislative Decree no. 196/2003 (Personal Data Protection Code) and applies to all personal data processed in the manner indicated below.
The Data Controller of the personal data collected is Divertimento Ensemble.
The personal data provided may be disclosed to appropriately appointed recipients who will process the data as data controllers and/or persons in charge of processing, in order to fulfill contracts or related purposes.
The complete list of data controllers and persons in charge of processing personal data can be requested by sending a specific request to [email protected].
In the event that personal data is transferred outside the European Union, for technical and operational purposes and to ensure high service continuity, the Data Controller ensures that the transfer is based on an adequacy decision by the Commission, in order to ensure that the level of protection of natural persons guaranteed by current legislation and in particular by EU Regulation 2016/679 is not compromised.
The personal data processed is collected because it is provided directly by the data subject or collected automatically.
The data provided directly by the data subject is all personal data provided to the Data Controller by any means, directly by the data subject.
The data collected automatically is browsing data. This data, although not collected for the purpose of being associated with the user's identity, could indirectly allow the user's identification through processing and association with data collected by the Data Controller.
After sending newsletters, the platform used allows us to detect the opening of a message and clicks within the newsletter itself, along with details relating to the IP address and browser/device used. The collection of this data is essential for the functioning of the implicit data renewal systems (see the Processing Methods section) and is an integral part of the operation of the sending platform.
The legal basis for the provision of personal data is contractual or pre-contractual requirements or the fulfillment of legal obligations to which the Data Controller is subject. For this reason, any refusal to process the data, or the failure to provide such data, or the inaccurate or partial provision of such data, may result in the inability to properly provide the service or the inability of the Data Controller to respond to requests for information sent by the data subject.
The provision of data for the purposes of sending newsletters for promotional, commercial, informational, or research purposes is optional, and refusal to provide consent to the processing will result in the inability to be updated on commercial initiatives and/or promotional campaigns, or to receive offers or other promotional materials.
The interested party may revoke his/her consent to receive promotional and commercial communications immediately by sending a request to the email address [email protected] or by clicking on the appropriate unsubscribe link found in the footer of each promotional and commercial email received.
The personal data provided may be disclosed to appropriately appointed recipients who will process the data as data controllers and/or as persons in charge of processing.
The Data Controller will not disclose any data subject information to third parties without their consent, except where required by law. In any case, the dissemination of processed personal data is excluded. The complete list of data controllers, joint controllers, and persons in charge of processing personal data can be requested by sending a specific request to [email protected].
Personal data is processed using automated tools for the time strictly necessary to achieve the purposes for which it was collected. In any case, an annual review of stored data is required to delete any data deemed obsolete, unless the law requires archiving.
Data processing generally takes place at the Data Controller's headquarters, by personnel or external collaborators duly designated as data controllers. A complete list of data controllers and data processors may be requested by sending a specific request to [email protected].
Specific security measures are implemented to prevent data loss, illicit or incorrect use, and unauthorized access.
Subscription and related processing are considered valid until the user unsubscribes, as indicated in each email, or 12 months after the last communication for which there is evidence of direct interaction (click, opening, reply).
Pursuant to Articles 15–21 of EU Regulation 2016/679, each data subject is granted a series of rights.
Requests referred to in the previous points must be submitted in writing to the Data Controller. The Data Controller will provide, within the time limits established by current legislation, a timely response to requests to exercise data subjects' rights.
Any clarification or request for information may be submitted in writing to the Data Controller.
The Data Controller reserves the right to periodically modify, supplement, or update this Privacy Policy in accordance with applicable legislation or provisions adopted by the Italian Data Protection Authority.
Such modifications or additions will be brought to the attention of all interested parties. We encourage users to review the Privacy Policy regularly to review the updated Privacy Policy and decide whether or not to continue using the services offered.