The Data Controller is:
The Coorps Srl
VAT No. 14382640960
Registered office: Via Borghetto, 3 – 20122 Milan – Italy
Contact email: info@thecoorps.com
2. Types of data processed
For newsletter subscription and management, the Data Controller processes the following categories of personal data:
personal and/or identifying data (e.g. first and last name, if requested in the form);
email address;
any additional information that the data subject may voluntarily provide in free text fields;
usage data related to interaction with newsletters (e.g. email opens, link clicks) collected through standard tracking systems of email marketing tools.
3. Purpose of processing and legal basis
Personal data will be processed for the following purposes:
a) Newsletter subscription and delivery containing updates, informational content and – where applicable – promotional/commercial communications related to the Data Controller's services and/or initiatives.
Legal basis: explicit consent of the data subject (Art. 6, para. 1, letter a) GDPR).
b) Compliance with legal obligations to which the Data Controller is subject.
Legal basis: compliance with legal obligations (Art. 6, para. 1, letter c) GDPR).
c) Possible judicial protection of the Data Controller's rights.
Legal basis: legitimate interest of the Data Controller (Art. 6, para. 1, letter f) GDPR).
The provision of data for the purpose referred to in letter a) is optional, but necessary to receive the newsletter: failure to provide it will result in the inability to complete the subscription.
4. Processing methods
Data processing is carried out using predominantly electronic and digital tools, in compliance with the principles of lawfulness, fairness and transparency set out in the GDPR, adopting adequate technical and organisational measures to ensure the security and confidentiality of the data.
No automated decision-making processes are carried out that produce legal effects on the data subject or that similarly significantly affect them. Any analysis of newsletter interactions is carried out in aggregate form or in any case not in a manner that leads to automated decisions with such effects.
5. Data retention period
Personal data will be retained for the time necessary to pursue the purposes indicated above, in particular:
for the purpose of sending newsletters, until consent is revoked by the data subject or until a request to be removed from the mailing list is made;
in any case, after a period of [e.g. 24 months] from the last significant interaction with the communications sent (email opens, link clicks), the Data Controller may evaluate the deletion or further minimisation of the data, unless contrary legal obligations exist.
After the retention period, the data will be deleted or irreversibly anonymised.
6. Communication and transfer of data
Data may be processed by persons authorised by the Data Controller (internal staff) and by third parties acting as Data Processors pursuant to Art. 28 GDPR, such as, by way of example:
email marketing and mailing list service providers;
IT, hosting and system maintenance service providers;
consultants and professionals (within strictly necessary limits).
Data will not be disclosed to the public.
Should data be transferred outside the European Economic Area (EEA), such transfer will take place in compliance with Articles 44 et seq. GDPR, for example to countries covered by an adequacy decision of the European Commission or on the basis of Standard Contractual Clauses, in any case adopting adequate safeguards to protect data subjects.
7. Rights of the data subject
As a data subject, the user may exercise at any time the rights provided for by Articles 15–22 of the GDPR, including, by way of example:
right of access to personal data;
right to rectification of inaccurate data or completion of incomplete data;
right to erasure of data ("right to be forgotten") in the cases provided for by law;
right to restriction of processing;
right to data portability, where applicable;
right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
right to object to processing for reasons related to their particular situation, in the cases provided for by Art. 21 GDPR.
To exercise these rights, the data subject may send a request to the Data Controller at the email address: info@thecoorps.com
The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) (www.garanteprivacy.it) if they believe that the processing of data is in violation of current legislation.
8. Methods of withdrawing consent to the newsletter
The user may withdraw consent to data processing for newsletter delivery at any time:
by clicking the unsubscribe link at the bottom of each email received; and/or
by sending an explicit request to the Data Controller's email address indicated in this notice.
Following the withdrawal of consent, the email address will no longer be used for sending newsletters, without prejudice to any further retention permitted or required by law.
9. Processing of minors' data
The newsletter is not aimed at minors under 14 years of age. Should the Data Controller become aware that personal data of minors has been collected without the consent of the person exercising parental responsibility, they will proceed to delete such data.
10. Updates and amendments
The Data Controller reserves the right to modify or update, in whole or in part, the content of this notice, including in consideration of changes in legislation. Updated versions will be made available in the same section/page where this notice is published.