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Privacy

This privacy policy describes the management procedure for the Portal, accessible to users of the http://www.investinlombardy.com website of which PROMOS is the Holder and the various personal data processing activities it carries out, with specific reference to the processing of personal data of the surfers accessing it and interacting with it. Users are informed that PROMOS will provide some of its services that are in this portal only after registration by filling in predefined forms and their online approval.

The disclosure is not valid for other websites accessible through links, for which Promos is in no way responsible.

Disclosure on the processing of personal data pursuant to Art. 13 of the Legislative Decree no. 196/2003

PROMOS, the manager of this Portal, aims at describing accurately the processing methods for the personal data of its users and provides a disclosure pursuant to Art. 13 of the Legislative Decree no. 196 dated June 30, 2003 (“Privacy Code”) concerning the various services offered and its activities involving personal data processing, in any case.For this scope, users are informed that following the consultation, registration or interaction with this website data related to identified or identifiable individuals may be processed. The processing of personal data takes place at the Milan headquarters, at the address Via Meravigli 9/B and/or of by persons specially appointed as managers and/or in charge of the processing using automated tools for the time strictly necessary to attain the purposes for which they were collected. The processing of personal data covers all operations indicated in art. 4, paragraph 1, letter. a) of the Privacy Code. Some of the processing operations, could also be performed by third parties, acting as autonomous holders (or co-holders) of the processing.

Different types of data collection take place through this website and the various institutional activities carried out by PROMOS:

a) necessary and automatic collection of the visitor’s data necessary to interact with the website;

b) collection and processing of data of those involved to carry out the institutional and/or promotional activities of the Chamber of Commerce such as organising entrepreneurial missions, business meetings, participation in fairs, events, training courses, conferences and the provision of specialist assistance services (even in collaboration with external parties such as the Milan Chamber of Commerce (CCIAA) or other Special Companies belonging to it), through this institutional website or paper forms filled out and undersigned by those involved;

c) processing correlated to data collection, entered voluntarily by the visitor through registration on online services, through filling in the specific electronic form arranged inside the website pages (e.g. newsletters), or by sending e-mails to the indicated addresses to contact PROMOS or its individual offices or to give feedback to the information requests of those involved;

d) registration for the subscription to the newsletter and to receive institutional or promotional communications from PROMOS, through information processing automatic systems, aimed at improving the communication with users, as well as to inform regularly enterprises, professionals and individuals on initiatives set up by PROMOS.

e) processing correlated to the receipt and management of Resumes submitted voluntarily by the users or requested expressly by PROMOS for purposes correlated to the possible establishment of a working/collaboration relationship ;

f) possibly carrying out anonymous and/or statistical surveys aimed at carrying out, by PROMOS, the institutional promotion, monitoring, studying and analysing activities of the entrepreneurial system and socio-economic, local and general context. The personal data of the involved individual will be processed by PROMOS with automated and/or manual procedures only for the purposes for which they are collected (to receive the newsletter and the institutional/promotional communications) and for the time strictly necessary to provide the service (this information will be deleted immediately if the person involved withdraws their registration and, in any case, the data will not be disclosed to unauthorised third parties).

Any browsing statistics on the users inside the website (visited pages, downloaded pages, etc.) will be made in a completely anonymous way and only for the purpose of improving the website and the services offered by PROMOS.PROMOS, generally, by addressing its services to enterprises, professionals, artisans and citizens, can process personal data of the involved parties (identified or identifiable individuals) for administrative - accounting and/or institutional – promotional purposes. Some registration forms for the services provided on the website may require a specification for the category of interest of the involved user (entrepreneur, professional, citizen, private individual, etc.) to fulfil instrumental scopes for the request sent by those involved to allow that the information provided is conveyed to the areas of interest.

The type of personal data collected and processed will only be of general nature and limited to those in the various forms that are on the website, related to any other special service offered by PROMOS and eventually by the Chamber of Commerce of Milan (CCIAA) and/or its Special agencies .

However, for the activities of mailing and newsletters, the collection and processing of some data could, in some cases, be aimed at the realisation and completion of statistical, research or survey operations, also through specific initiatives or by filling online questionnaires, as well as receiving information on events/conferences, other initiative by the Chamber of Commerce or special agencies (also within services developed by the Chamber of Commerce of Milan and its Special Agencies).

In fact, PROMOS, being the Special Agency for International Activities of the Chamber of Commerce of Milan, pursues, also through mailing and newsletter activities, the institutional scopes in the field of internationalisation and territorial marketing to support the competitiveness and development of Lombard companies on foreign markets and empower the capacity of the system of Milan and Lombardy to attract foreign resources.

The treatments related to the services of this Portal are handled only by staff in charge of the processing or by internal or external Processing Managers (e.g. SiComunicaWeb S.r.l.), specially appointed for this purpose.

Therefore, access to data for the achievement of the purposes mentioned above is allowed to, within their respective functions or duties and, in any case, according to the procedures and within the limits laid down in the respective deeds for the appointing of managers or persons in charge, in addition to the company’s legal representatives and to the person responsible for the management of instances pursuant to the former article 7 of the Code, the manager of the information systems (limited to the service and maintenance activities on the electronic instruments), the persons responsible for the different areas and the PROMOS functions.

For exclusively organisational and operational needs, we have appointed certain managers for the processing of personal data of users/persons involved in the processing for purposes strictly related and correlated to the performance of the services that are offered. These managers were chosen because they have proven their experience in personal data processing and have provided sufficient guarantees on the compliance with the enforced provisions on processing, including the data security profile. The managers carry out the personal data processing of those involved by operating according to the processing instructions given by PROMOS.

From time to time it is verified that they have fulfilled their tasks timely and that they continue to offer sufficient guarantees of compliance with the provisions on personal data protection.The updated list of all the internal and external data processing Managers is available at the Holder’s main office; to obtain this list, it is possible to write to the following e-mail address: privacypromos@mi.camcom.it.

The personal data provided voluntarily by the users forwarding their request for information or that send information material or proposals of various nature are used only to perform the service or performance requested and acknowledge the message; they may be disclosed to third parties only if necessary for the purpose and after informing the interested party.

With the exception of browsing data that are stored only for a week after their collection, the other data will be stored according to the purpose for which they were conferred and, anyhow, in compliance with enforced regulations. In compliance with the provisions of art. 11, paragraph 1, letter. c) of the Code, the personal data will be updated following an indication received from the individual involved, in congruence with the provisions of art. 7, paragraph 3, letter. a) of the Code. Email communications can continue to be sent to the addresses communicated for the newsletter subscription until the user asks to terminate this processing by sending an email for this matter to the following address: privacypromos@mi.camcom.it.

The user is free to provide personal data included in the registration forms on the website to subscribe to the services provided by PROMOS. However, some personal information requested are mandatory in order to be able to provide online services or send the newsletter. Their non-conferment makes it impossible to obtain the service or what has been expressly requested.

The user’s personal information, processed by PROMOS with automated and/or manual procedures only for the purposes for which they were collected and for the time strictly necessary to provide the service, shall be deleted immediately if the person involved withdraws their registration for the services or exercises, successively, the rights of which at Article 7 of the Legislative Decree no. 196/2003. The data will not be disclosed to third parties, except in aggregate and anonymous form.

It is reiterated that this information does not refer to processing made by other PROMOS partner sites (e.g. other Special Companies, etc.), to which the user can access through links or banners (on the homepage or inside pages). For these processing operations, the respective Holders should provide an independent self-disclosure. It is précised, in particular, that the data processing provided by accessing third-party sites, accessible through the links on the website, are carried out by persons other than PROMOS.

The involved party has the right, at any time, to obtain the confirmation on the existence or not of the data, to request their origin, creation, deletion, update, adjustment, to oppose to the processing for legitimate reasons or in case of using the data to send institutional advertising material or to carry out surveys (art. 7 of the Legislative Decree no. 196/03) by writing to PROMOS Promozione Sviluppo, Via Meravigli 9/b – 20123 Milan, or just by sending a fax to + (39) 02 8515.5227 - 5394 or an email to the following address privacypromos@mi.camcom.it. If, following a request under Article 7 of the Code, the existence of data concerning the involved party is not confirmed, the latter may be asked to contribute to the costs for an amount not exceeding € 10.00.

Please indicate in the subject matter of the communication: “Request pursuant to Art. 7 of the Legislative Decree no. 196 dated June 30, 2003 - Code on the protection of personal data”.

Specific security measures are observed to prevent data loss, misuse, unauthorised access or processing that are not allowed or do not comply with the scopes of the collection. ,The data holder is PROMOS Promozione Sviluppo, with main office in via Meravigli

9/b -20123 Milan, VAT 05121090962, Fiscal Code 97425540156.The outsourcing processing managers are:

- for the processing of the data necessary to perform the construction activities for the Invest in Lombardy website and the hosting activity the appointed company is SiComunicaWeb Srl Via Domenico Trentacoste, 9 20134 Milan

Data processing location

The processing connected to the web services of this site take place at the PROMOS main office and are handled only by technical personnel of the offices in charge of the processing, or by others in charge of the occasional maintenance operations. No data deriving from the web service will be communicated or spread.

Types of processed data

Surfing data

The computer systems and software procedures to operate this website acquire, during their normal use, some personal data for which the transmission is implicit in the use of Internet communication protocols; it consists in information that is not collected to be associated with identified interested people but, due to their actual nature, could, through processing and associations with data held by third parties, allow identifying users (this category of data includes also IP addresses or names of computers used by users connecting to the site, the URI - Uniform Resource Identifier – addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the reply file, the numerical code indicating the status of the response from the server and other parameters regarding the user’s operating system and the computer environment).

The data are used only to obtain anonymous statistical information on the site usage and to check the correct functioning and are deleted immediately after processing.

The data could be used to ascertain responsibility in case of hypothetical cybercrimes against the website. In any case, data on the web contacts do not persist for more than seven days.It is précised that the browsing data could be used to ascertain responsibility in case of cybercrimes against the PROMOS Portal, in accordance with the enforced procedures at the competent Authorities.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of emails to the addresses listed on this website involves the subsequent acquisition of the sender’s address, necessary to answer requests, and any other inserted personal data.Specific information disclosures will be progressively reported or displayed on the website pages dedicated to particular on demand services and in the electronic communications sent by PROMOS.It is necessary to specify that the processing operations that have been carried out through the different pages of the website concern only shared personal data: therefore the user is invited not to send with their communications data revealing their racial or ethnic origin, religious, philosophical or political beliefs, memberships in political parties, trade unions, associations or organisations of religious, philosophical, political, trade union nature, as well as personal data disclosing health and sex life or information that anyhow qualify as “sensitive data” pursuant to art. 4, paragraph 1, letter d) of the Privacy Code. On the contrary, the corresponding message will be immediately deleted. This involves the impossibility to provide the information requested.

If there is however the intention of sending sensitive data to the Holder (for example a CV containing data related to the civil service or protected categories), please forward the message by fax to the following number: + (39) 02 8515.5227-5394 or to the following email address: privacypromos@mi.camcom.it, with a specific declaration of consent to the processing of the sensitive data included therein. It is informed that, without this declaration, the message that has been received will be destroyed. Without prejudice to what is set down regarding Resumes containing sensitive data, it will be possible to the Resumes – if containing only general data - to the following email address: selezione.promos@mi.camcom.it.

Cookies

For the Cookie policy, in compliance with European law, refer to the following link

COOKIE POLICY

Privacy

REGISTRATION FORM FOR A NEW USER OF THE ON-LINE SERVICES PROVIDED ON THE INTERNET SITE AND FOR THE REGULAR NEWSLETTER MADE BY THE PROMOS INVESTMENT ATTRACTION AREA WITHIN THE INVEST IN LOMBARDY PROJECT. Disclosure for the registration form for a new user of the online services provided on the website and registration for the regular newsletter by the PROMOS Investment Attraction Area - Special Agency of the Milan Chamber of Commerce (hereinafter referred to as "PROMOS ") as part of the Invest project in Lombardy. Pursuant to Article 13 of the Legislative Decree 196 of June 30, 2003, We inform you that personal data provided herein shall be processed in accordance with the mentioned legislation. Such data will be processed through electronic registration and will be used only as follows: a) to register to the site and on-line services provided by the Invest in Lombardy (www.investinlombardy.com), to be identified and authorise your access through personal username and password. This service will be provided by the site’s Member Area, reserved only for members of the Partner Program project: an action program in favour of Lombard service companies and professionals that assist foreign companies investing in Lombardy. b) to be included to the mailing list and to send regular newsletter containing institutional communications (relating to services and initiatives by the PROMOS Investment Attraction Area project in Lombardy also in collaboration with private partners participating in the project, the Chamber of Commerce of Milan or other entities connected to investment attraction, exports, and internationalisation), promotion of certain services in the area, information on all the initiatives and activities (institutional information to the subscribers, events, services, call for bids, information on courses/seminars, meetings, conferences, sending of publications and research papers, updating and training, etc.) promoted by the PROMOS Investment Attraction Area within the Invest project in Lombardy, also in collaboration with private partners of the Invest network in Lombardy. Further information can be offered, subject to your consent, by the other Special Companies of the Chamber of Milan, through automatic systems to share, process and exchange information; in the latter case, the Milan Chamber of Commerce and the Special Agencies (Chamber of Arbitration of Milan, Formaper, Innovhub SSI, Promos) shall each operate as an independent holder of the processing and the service by CCIAA of Milan and other Special Companies shall be provided only after prior consent by the user involved in the processing. The personal data requested and marked with an asterisk (*) are mandatory because necessary to provide the services referred to in the above subparagraphs a) and b). If not provided it will be impossible to obtain the mentioned services. The email addresses (and any other collected data) are stored electronically in databases that are protected by safety systems suited to prevent the loss, misuse, unauthorised access or non-allowed treatments or that do not comply with the purposes of the collection. The processing of the collected data is handled by PROMOS through computerised and telematic tools with logics strictly related to the underlined purposes and, anyhow, in order to ensure the security and confidentiality of the data. To provide and manage the Newsletter, the PROMOS Investment Attraction Area uses the service offered by MailChip (The Rocket Science Group, LLC, 512 Means St., Suite 404-30318 - Atlanta, Georgia) and hereunder mentioned just as “MailChimp”. The collected data is stored on secure MailChimp servers. Pursuant to the MailChimp privacy policy, your data will never be used directly by MailChimp or sold by it to third parties. MailChimp guarantees the confidentiality of the processing with the linked privacy policy that is legally binding. With reference to the registration on the portal referred to at the above point a), it is noted that cookies are not used while surfing the corporate website to transmit personal information, nor are any kind of persistent cookies, or user tracking systems. The use of section cookies is strictly limited to the transmission of identification data necessary to allow the safe and efficient exploration of the site. For the corporate communication or promotional activity referred to at the above point b), carried out through automatic information processing systems aimed at improving the communication process with the users, as well as regularly informing businesses, professionals and privates on the activated initiatives, the personal data of the registered user will be processed by Promos, the Chamber of Commerce of Milan (CCIAA) and other Special Agencies (each acting as an independent data holder) as well as by those specifically appointed as data processors (SiComunica among which, by way of example) with automated and/or manual procedures and only for the purposes for which they are collected (the newsletter and institutional/promotional communications), for the time strictly necessary to provide the service; the data will be deleted immediately if the person concerned withdraws their registration with each holder. The data provided by you, both as a result of the conferment and as the result of voluntary contribution, for the above purposes they will be processed by internal Promos staff employed especially for this purpose (secretariat, administration and information system staff, etc.) and third parties, for which this is necessary and indispensable (or anyhow useful), to carry out the purposes of the processing already indicated; In this regard, it is précised that, to send the institutional/promotional communications through automated processing systems, these data will be communicated and shared with the Chamber of Commerce of Milan (CCIAA) and its Special Agencies, through the technical support of DigiCamere, appointed as head of this processing even for the management of the IT platform that involves the institutional communication service. In any case, the data will not be disclosed. It is possible to exercise your rights towards the data Holder at any time pursuant to Article 7 of the Law Decree 196/03. In particular, you have the right to obtain confirmation from the Holder on the existence of data that may concern you and on their processing treatment, to obtain updating, correction or integration of data, their deletion if collected illegally, and oppose the processing for legitimate reasons. The Privacy Coordinator (Ms. Paola Amodeo) is responsible for the relations, to whom you can refer by sending your request to the following e-mail: privacypromos@mi.camcom.it or to the fax number: + (39) 02-8515.5227 5394. Holder of the data processing is PROMOS Promozione Sviluppo, in the person of its legal representative. For further information on the PROMOS activities, you may view the privacy policy on our website where you can find complete information on the data processing made by us.