Last Update: 23rd May, 2020
1. Scope of this document
2. Categories of personal data
We collect and process the following data about you:
2.1. Information you give us
You may provide us information when you use our website, access its contents and/or use our services, by filling in forms on the website, when you enter into any of our promotions and/or initiatives, when you write to or correspond with us by e-mail or otherwise. The information you give us may include:
- mandatory information required to register for the services we provide on our website or to access other services provided by us, including your name, surname, email address and password. When you subscribe to our services, we could ask you for further mandatory information such as your postal address. SHN will not be able to provide you with the services offered on our website if the mandatory information is not provided, consequently you will not be able to register to our website and/or subscribe to our services or access any contents;
- correspondence between you and us;
- purchase data, including the type of contents or services you subscribed to.
2.2. Information we collect automatically
3. Purposes of processing and legal basis
We collect and process your personal data for the purposes and legal bases as listed below:
- To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you requested from us, including to allow you to access contents and guides; to pursue this purpose we do not collect your consent since the processing of your personal data is necessary for the performance of our mutual contractual obligations.
- To send you, in accordance with applicable laws and where required, with your consent, marketing materials and information necessary to facilitate the service and to make you suggestions and recommendations about goods or services related to our services that may interest you.
4. Categories of recipients and transfer
4.1. For the purpose of providing you with the requested services we may share your personal data with:
- our authorised employees and/or collaborators and our third-party service providers which process your personal data on our behalf and under our instructions for the purposes described here in above acting as data processors, such as those providing us with IT and email services;
- our business partners who are social media platforms when it is explicitly requested by you (e.g. when you share information generated from our website onto those platforms), when using social media authentication methods;
- competent authorities when we are required to do so by the current law or it is necessary to defend our rights or property or the rights or property of any third party.
In the event that SHN sells or buys any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets; if SHN or all or part of its assets are acquired by a third party, in which case personal data held by it about its members will be one of the transferred assets.
4.2. SHN is based in Italy, EU and transfer data to suppliers who are based in the USA and are Privacy Shield certified. Should data need to be transferred to any other non-EU/EEA country, SHN will adopt relevant safeguards to ensure that the transfer is carried out in compliance with the applicable privacy legislation, in particular the provisions of the GDPR.
5. Data retention
Data are processed mainly by automated systems (e.g. with the use of electronic supports and procedures) only for the time strictly necessary for achieving the purpose for which such data are collected and, in any case, in full compliance with applicable laws and regulations.
6. Data Protection Rights
SHN is committed to give you the appropriate control of your own personal data. In particular, you have the following rights in connection to your personal data.
- Right of access: you have the right to obtain from us the confirmation as to whether or not personal data concerning you are being processed. Moreover, you can request a copy of your data, within reasonable limits.
- Right to rectification: you have the right to obtain the rectification of inaccurate personal data concerning you.
- Right to erasure: you have the right to obtain the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay for one or more reasons described in article 17 of GDPR.
- Right to restriction of processing: you have the right to obtain restriction of processing when one of the conditions described in article 18 of GDPR occurs.
- Right to object: you have the right to object to the processing of your personal data, at any time, where the basis for that processing is either legitimate interests of controller unless there are legitimate reasons for proceeding with the processing that prevails over your own, for example for the exercise or our defense in court.
- Right to data portability: you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
- Right to revoke your consent: if you gave us your consent, you can always ask us for its withdrawal.
Moreover, we inform you that you have the right to lodge a complaint with a supervisory authority, set up to protect fundamental rights and freedoms in connection with the processing of personal data.
To exercise these rights, obtain the updated list of data processors, report problems or ask for clarification on the processing of personal data you can write to the following email address: [email protected] or contact the Data Controller at the postal address indicated above.