Privacy Policy – Processing of Exhibitor's personal data Art. 13 of Regulation (EU) 2016/679 - General Regulation on Data Protection - The Data Controller of Personal Data

 

DATA CONTROLLERS In compliance with the provisions of European Regulation 2016/679 (hereinafter GDPR) we inform you that your data will be processed by the companies Made in Steel s.r.l. (hereinafter referred to as MIS only) and Siderweb S.p.A. (hereinafter referred to as SW only) as joint data controllers, both with registered offices in Flero (BS), via Don Milani 5,  contact details: info@madeinsteel.it; tel. +390302548520 (both companies are Data Controller). As required by art. 12 GDPR, pursuant to art. 4 of EU Reg. 2016/679 the Data Controller adopts the following information policy to provide the Exhibitor with the information referred to in art. 13 GDPR and with the communications referred to in art. 15 to 22 and 34 GDPR relating to the processing of the data provided to participate as an exhibitor in the exhibition Made in Steel 2021 (hereinafter also referred to as "Exhibition" or "Event").

 

DATA PROTECTION OFFICER Mr. Alessandro Donati is the Data Protection Officer of the Data Controller and can be contacted by email at alessandro.donati@studiogoriominervini.it.

 

PROCESSING, PURPOSES AND DATA PROCESSED The Data Controller informs the Exhibitor that the personal Data submitted by filling in the documentation and/or forms useful and/or necessary to participate in the Event (and not included in the special categories of personal data as listed in art. 9 GDPR) and concerning himself/herself (also in the case of a self-employed person, small entrepreneur, or professional) or his/her employees, agents, representatives or consultants (hereinafter referred to as Data) will be processed in accordance with the provisions of GDPR, both in print and by electronic means, using special IT procedures, and suitable methods to ensure proper management. The processing is carried out in accordance with the conditions of lawfulness provided for by art. 6 GDPR and for the purposes inherent to the business relationship with the Data Controller. Therefore, its legal basis is justified by the reasons for which contact occurs with the Data Controller and therefore, in this specific case, the participation in the Event (Purpose). In relation to such Purpose, the processing of the Data provided to the Data Controller may include the organization, retention, consultation, communication of future initiatives, the elaboration, extraction, processing in the EU and  in non-EU territory only in the cases regulated by art. 45 and 46 GDPR, modification, statistics, cancellation, soft spam and light marketing by the Data Controller, also for administrative, fiscal, accounting and/or organizational aims and to comply with the relevant regulatory obligations. In view of the Exhibitor's interest in being informed about the dates of the next editions of the Event, reminders of upcoming editions and communications about future initiatives strictly connected to the Exhibition will be sent to the Exhibitor's provided email by soft spam only.

 

CONSENT Except for the above-mentioned Purpose, the Data Controller will process data after obtaining express consent which must be given explicitly, and for the following reasons only:

  • A)    Creation of Databases that may be used in non-EU territory by the Data Controller or their managers (Please note: in relation to the Transfer of data to non-EU territories, the Data Controller states that the data provided may also be transferred to non-EU countries in accordance with the provisions of Chapter V of the EU Reg.; consent under letter A is requested by the Data Controller exclusively for the hypothesis of Article 49 a EU Reg.. In such cases, in order to prevent the potential risk arising from the data transfer in a country not covered by the provisions of art. 45 and 46 EU Reg., the Data Controller will transfer the data to the country identified only after obtaining specific guarantees by the receiving third party on the processing of data. The relevant specifications can be found in the Data Controller's DPA).
  • B)    Direct and indirect marketing, i.e., with the aim of sending advertising material, for direct sales or to carry out market research or for commercial communications, by means of automated contact tools such as e-mail, fax, mms (multimedia messaging service) or sms (short message service), etc., not only by automated procedures of contact, but also by traditional means, such as paper mail or calls made by the Data Controller or their staff.
  • C)    Publication of data in the catalogue and the exhibitors’ map (both in print and online) (Please note: the Data Controller will include the Exhibitor's data in the printed (available at the fair) and online catalogue as well as in the hall map (both in print, available at the fair, and online) only if explicit consent is provided).
  • D)    Transfer of personal data (surname and first name of the natural person taking part in the Event, company name and company email address) to third parties (in particular to companies directly connected to the Data Controller, or to the Partners and Sponsors of the Exhibition) for third party marketing activities, in particular sending by email promotional and/or commercial communications and/or newsletters regarding third party products as well as market research and statistical analysis.

Data may be processed both on paper and by electronic means by expressly authorized individuals. As required by art. 13, paragraph 2, letter F, the Data Controller confirms that the processing is not based on an automated decision-making process.

 

AUDIO-VIDEO FOOTAGE DURING THE EVENT The Data Controller has the right to make audio/video recordings and photographs (films, drawings or other) during the Exhibition, which may include one or more Event attendees , photos of the whole Exhibition and/or  detailed photos of individual stands, representatives, exhibitors, employees or consultants of the Exhibitor and to use such material for marketing and telemarketing communications, also on behalf of third parties (with and without transfer of personal data) as well as dem marketing, or for journalistic purposes, by means of traditional (including paper) or non-traditional/IT systems (such as, for example, mms, sms, whatsapp, social, platforms, etc.). Since the Event is public, there is no need for the consent of the person portrayed under Article 97 of Law No 633/1941. In any case, where necessary, please be aware that the voluntary act of the data subject to register for the Event and/or the individual happening at the Event and/or, in any case, to take part in it and/or to go to the areas specifically dedicated to the Event is considered an expression of consent as an unequivocal positive act, also with reference to minors under parental responsibility in case they are photographed and/or videotaped during the Event (without prejudice to the prohibition to bring minors to the Event). The expressed consent entitles the Organizer and the Data Controller to process the image of the data subject, free of charge and without time limits, for the production of multimedia material to be used as a promotional and/or publicity tool on their institutional web page and on official social pages (Facebook, LinkedIn, Instagram, Twitter, etc.), and allow its possible dissemination for journalistic, informative, promotional and commercial purposes. Therefore, the Data Controller and the Organizer have the right to use the aforesaid images free of charge, for the above-mentioned purposes, in accordance with articles 96 and 97 of law no. 633/1941, and are authorised to use them, without any restriction, by any means of communication (including, by way of example, brochures, presentations, catalogues and, in general, printed material for promotion, TV, pay per view, etc.) and dissemination via the Internet (company website, social networks, platforms, etc.) or magazines and other publications, including electronic ones, with every right to adaptation and reproduction, for all purposes permitted by  law. To this end, the Exhibitor declares and assures the Organizer and the Data Controller that the following arrangements have been made: (i) collection, where necessary, of the consent of the data subjects - following appropriate information - to the processing by the Data Controller of their data, photos, video recordings, etc., including their disclosure for divulgation, promotion and advertising purposes in accordance with Regulation (EU) 2016/679 - General Regulation on the Protection of Personal Data; (ii) obtain permission by the natural persons, the Exhibitor’s representatives, associates, employees and consultants portrayed or filmed on the occasion of the aforementioned event to use and disclose their images, pursuant to Articles 96 and 97 of Law no. 633/1941 on copyright, and in the terms mentioned above. In relation to points (i) and (ii) above, the Exhibitor undertakes to indemnify for and hold the Data Controller harmless from any and all disputes, demands, or claims made by the aforesaid subjects and relating to the use and/or disclosure of the relevant images mentioned above. Any use of portraits that may be prejudicial to the honour, reputation and/or dignity of the person portrayed is expressly excluded. 

 

DATA SUBMISSION The submission of Data is voluntary. However, any refusal by the Exhibitor to provide Data, including data that does not require specific consent, will result in the failure to continue the business relationship and, therefore, will jeopardise the Exhibitor's participation in the Exhibition. Please note that, pursuant to art. 6 and art. 4 paragraph 11 GDPR, by filling in the documentation and/or forms useful and/or necessary to participate in the Event, the Exhibitor authorises the Data Controller to process the Data provided which does not require specific consent. Provided that all required documentation has been sent, when no consent is given to the processing of data for the purposes expressed in points A, B, C and D, the Exhibitor will be allowed to participate in the Event but will not be able to access some of the services promoted during and after the Event.

 

DATA RETENTION The Data submitted with the consent legitimating its Processing, will be retained until revocation of the same. With regard to other listed forms of Data Processing, the Data will be retained for a period of time not exceeding the time necessary to achieve the purposes for which it was collected and subsequently processed. In particular, the Data collected for contractual purposes will be retained for the time necessary for the fulfilment of all contract obligations and all the legal obligations in compliance with the current legislation, including subordinate laws, and in any case for a maximum of 10 years from the termination of the contract or, if subsequent, from a binding decision issued by an administrative or judicial authority. In any event, any obligations to retain data for longer periods of time remain valid if prescribed by law in relation to particular categories of data, or if this is necessary to protect the rights of the Data Controller in the event of any disputes arising in connection with the provision of the service. In case of failure to finalize the contract, the personal data collected to draft the contract  will be deleted after five editions of the Exhibition.

 

DATA RECIPIENTS The Data may be disclosed to employees and consultants authorized by the Data Controller to process the data to carry out the above mentioned administrative, technical and security activities related to the organization and management of the Exhibition and the provision of the services requested by the Exhibitor. The Data Controller will also communicate the data to third parties for the production of printed and online catalogues as well as to other companies for the organization of conferences held during and after the Event, for the communication to employees for the publication of promotional and/or trade specific journalistic articles in the context of the Event as well as the communication to third parties appointed by the Data Controller to promote the Event. The Data will also be communicated to Evobusiness S.r.l. for inclusion in the match making service and to third party companies, to Fiera Milano S.p.A. and to entities belonging to  Fiera Milano group to include data in the E-service platform as well as for administrative, fiscal, accounting and/or organizational purposes, and to trusted entities to provide organizational and technical services pertaining to the event, such as, for example,  fitters, assistance and maintenance companies, printers, data processing companies, administrative consulting firms, companies evaluating the results of the event, identified as data processors, in compliance with the specific obligations set out in the relevant service contracts. Any Data communication will exclusively be related to the management of the Exhibition.

 

RIGHTS OF THE DATA SUBJECT The data subject has the following rights:

  • to access or obtain confirmation whether or not personal data concerning him/her are being processed and, if so, to obtain access to such data, including a copy thereof;
  • to rectify, or to obtain without undue delay the rectification of inaccurate personal data concerning him/her and/or the integration of incomplete personal data;
  • to erasure (right to be forgotten), or to obtain without undue delay the erasure of his/her personal data;
  • to restrict processing, or to obtain the restriction of processing, in the cases referred to in art. 18 of the Regulation;
  • right of portability of the data, or to receive from the Data Controller his/her personal data, in a commonplace, machine readable format, and the right to transfer it to another Data Controller without hindrance, if the processing is based on consent and is carried out by automated means, as well as to obtain that Data is transferred directly to another Data Controller if this is technically feasible;
  • to object, at any time, on grounds related to his or her particular situation, to the processing of his/her personal data, based on the lawfulness of the legitimate interest or the fulfilment of a task in the public interest or the exercise of public authority, including profiling, unless there are legitimate reasons for the Data Controller to continue processing which override the interests, rights and freedoms of the Data Subject or for the determination, exercise or defence of a right in court. In addition, the right to object at any time to the processing if the personal data is processed for direct marketing purposes, including profiling, in so far as it is related to such direct marketing;
  • to revoke consent at any time. Revocation of consent shall not affect the lawfulness of processing based on consent before revocation;
  • to lodge a complaint to the Data Protection Authority, Piazza di Montecitorio 121, 00186, Rome (RM).

To exercise the above rights or to obtain further information on the data processing, please send an e-mail to the DPO, with the name and surname of the data subject, the name of the Exhibitor and the right you wish to exercise.

 

TRUTHFULNESS AND CORRECTNESS OF DATA It is understood that the person filling in the documentation and/or forms for participation in the Exhibition shall also be liable for the correctness and truthfulness of the Data provided. In the event that data relating to third parties is reported, the Exhibitor (and the Customer, if any) is responsible both for the correctness and truthfulness of the Data, as well as for the possibility of communicating the same, and will guarantee that the data can be lawfully used by the Data Controller and will hold the Data Controller harmless from any and all claims that may arise, releasing the Data Controller also  from any and all claims for direct and/or indirect damages. CONSENT Having read the privacy policy, the Exhibitor gives his/her consent to:

  • A)    data processing for the creation of databases that may be used in non-EU territory by the Data Controller or their managers

Yes* No*

  • B)    indirect and direct marketing, i.e., sending advertising material, direct sales or carrying out market research or commercial communications, through the use of automated contact tools such as e-mail, telefax, mms (multimedia Messaging service) or sms (short message service) etc., not only through automated contact methods, but also through traditional methods, such as paper mail, conducted by the Data Controller or their staff

Yes* No*

  • C)    dissemination of data also by means of the printed and online catalogue and the printed and online exhibitors’ plan

Yes* No*

  • D)    Transferring the following personal data to third parties (in particular to companies directly connected to the Data Controller, or to the Partners and Sponsors of the Event) for the purpose of third party marketing activities, in particular promotional and/or commercial communications and/or newsletters regarding third party products by email, as well as market research and statistical analysis: surname and first name of the natural person taking part in the Event, company name and company email address,.

Yes* No* (* compulsory fields)

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