In accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter “GDPR”), ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) (IMF) (hereinafter “Data Controller”), with registered office at Via Borgonuovo 16, 40125 Bologna (BO), Italy, in its capacity as "Data Controller", hereby informs you that your personal data will be processed in compliance with the above-mentioned legislation in order to safeguard the rights, fundamental freedoms and dignity of natural persons, with particular reference to confidentiality and personal identity. We inform you that, if the activities performed on your behalf should require processing of third-party personal data of which you are the controller, it shall be your responsibility to ensure that you have fulfilled the legal requirements regarding the Data Subjects in order to render its processing by us legitimate.

Origin, purpose, legal basis and nature of the data processed

The personal data, directly provided by you, is processed by ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) for the purpose of providing the service requested by the user and/or from the conclusion of the contract and/or during the execution and/or stipulation of the same.

Third-party personal data communicated to the Company by the user to IMF may also be processed. In this case, the user automatically becomes the data controller and assumes the consequent legal obligations and responsibilities, thus holding IMF harmless against any complaints, claims or applications for damage compensation that the Company should receive from third-party Data Subjects.

In compliance with current legislation on the protection of personal data and without the need for specific consent from the data subjects, the data will be stored, collected and processed by IMF for the following purposes:

fulfilment of contractual obligations, execution and/or conclusion of the contract with the Customer/User and/or management of any pre-contractual measures;

compliance with any legal requirements, tax regulations arising from performance of company business, and obligations related to administrative and accounting activities;

sending, either directly or via third-party suppliers of marketing and communication services, of newsletters and communications for direct marketing purposes by email, SMS, MMS, push notifications, fax, traditional mail or operator-assisted telephone, relating to products supplied by other companies according to Article 130, paragraphs 1 and 2 of Legislative Decree 196/03 (hereinafter "Code") and the provisions of European Regulation 279/2016 on this issue;

communication of Data to third party companies for sending newsletters and communications for marketing purposes through email, SMS, MMS, push notifications, fax, paper mail, telephone with operator pursuant to Article 130 paragraphs 1 and 2 of the Code and other forms of communication permitted by law.

The legal basis for processing for purposes a) and b), above, are Articles 6.1 b) and 6.1 c) of the GDPR.

Provision of the Data for the above-mentioned purposes is optional. However, failure or refusal to provide such Data would make it impossible for the Company to execute and/or conclude the contract and provide the services requested of it.

The legal basis for personal data processing for purposes c) and d) is Article 6.1 a) of the GDPR, since processing is based on consent; it should be noted that the Data Controller may obtain a single consent for the marketing purposes indicated above, under the General Provision of the Italian Data Protection Authority (Garante per la protezione dei dati personali), “Guidelines on Promotional Activities and Combating Spam” of 4 July 2013. Provision of consent to use of the Data for marketing purposes is optional, and if the Data Subject wishes to oppose processing of the Data for marketing purposes using the methods indicated above, as well as revoking the consent provided; s/he may do so at any time with no consequences (aside from no longer receiving marketing communications) by following the instructions found in the “Rights of the Data Subject” section of this Policy.

Finally, it should be noted that, for processing performed for the purposes of direct sending of its own advertising materials or its own direct sales or for performance of its own market research or marketing communications relating to products or services similar to those used by the IMF user, the Company may use email addresses or registered addresses pursuant to and within the limits of Article 130, paragraph 4, of the Privacy Code and Italian Data Protection Authority Provision of 19 June 2008, even without express consent. The legal basis for processing of the Data for this purpose is Article 6, paragraph 1, letter f) of the GDPR, without prejudice to the possibility of opposing such processing at any time by following the instructions found in the “Rights of the Data Subject” section of this Policy.


The Data may be communicated to third parties appointed as Data Supervisors under Article 28 of the GDPR and, in particular, to banking institutions, companies operating in the insurance sector, suppliers of services strictly necessary for performance of company business, to company consultants, where this is necessary for tax, administrative or contractual reasons or due to requirements protected by current standards. The data may also be transferred to third-party companies for commercial and/or marketing purposes.

Your personal data, or personal data of third parties of which you are the controller, may also be communicated to external companies, identified on a case-to-case basis, to which ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) entrusts fulfilment of obligations arising from the assignment received, and to which only data necessary for the activities requested of them shall be transmitted. All employees, consultants, temporary workers and/or any other “natural persons” conducting their business based on instructions received from ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE), under Article 29 of the GDPR, are designated Data Processors. ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) shall issue appropriate operating instructions to any appointed Data Processors or Supervisors, with particular reference to the adoption of and compliance with security measures, in order to guarantee the confidentiality and security of the Data. Indeed, with reference to matters of personal data protection, the Customer is invited, under Article 33 of the GDPR, to report any circumstances or events that could result in a potential “data breach” to ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE), in order to permit immediate assessment and implementation of any actions designed to counter such an event, by notification sent to ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) at the addresses indicated below.

The Data shall not be disclosed.

The ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) has the obligation to communicate the Data to the public authorities upon specific request.

Transfer abroad

Your personal data may be transferred abroad where necessary for management of the assignment received. For processing of any information and data communicated, such parties shall be required to adopt equivalent levels of protection for personal data processing by their employees. In any event, only data necessary for the established purposes shall be communicated, and the regulatory tools provided for in Chapter V of the GDPR shall be applied.

Methods, processing logic and retention period

Your Data shall be collected and recorded in a lawful and correct manner for the above-mentioned purposes, in accordance with the principles and requirements set out in Article 5, paragraph 1 of the GDPR.

Personal data processing shall be performed using manual, computerised and telematic tools with logics strictly correlated to the said purposes and, in any event, in such a way as to guarantee its security and confidentiality.

Your personal data shall be processed by ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE) for the entire duration of the assignment, and also subsequently, in order to exercise or safeguard is own rights or for administrative purposes and/or to fulfil the obligations arising from the applicable pro tempore regulatory and legislative framework, in accordance with the specific legal provisions on data retention.

Rights of the Data Subject

In accordance with and subject to the limits and conditions provided for by the legislation on personal data protection with regard to exercise of Data Subjects’ rights concerning data processing under this Privacy Policy, you, as Data Subject, are entitled to request confirmation as to whether or not your personal data is being processed, access personal data concerning you and request to have it amended or cancelled, and to receive notification of such amendment and cancellation by those to whom the Data may have been transmitted by our Organisation. You also have the right to request restriction of processing in the cases provided for by the regulations, to portability of personal data - provided by you - in the cases indicated by the regulations, to oppose processing of your personal data and, specifically, to oppose decisions regarding it if based solely on automated processing of your personal data, including profiling. If you deem the processing of your personal data to be in breach of the GDPR standards, you have the right to lodge a complaint with the Italian Data Protection Authority under Article 77 of the GDPR.

If you intend to request further information on the processing of your personal data or for the possible exercise of your rights, you can contact Mr. Marco Raspati in writing, by registered letter to be sent to Bologna, at via Borgonuovo No. 16.

Data Controller and Supervisor

According to Article 4 of the GDPR, the Data Controller is the ITALIAN MARKETING FOUNDAITON APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE), in the person of the President of the Association located at Via Borgonuovo 16 - 40125 BOLOGNA (BO), VAT Number: 94169260547 - Tax Code: 94169260547

A full list of the Data Supervisors is available at the association’s registered office or by written request to be sent by registered letter.

Best Regards

The Data Controller

ITALIAN MARKETING FOUNDATION APS (ASSOCIAZIONE DI PROMOZIONE SOCIALE), in the person of the President of the association Mr. Marco Raspati