Privacy policy

pursuant to Art. 13 Regulation (EU) 2016/679 (GDPR)

Strategica Group S.p.A. (VAT 07002270960), a company specialized in management consulting activities in the Risk Management sector, registered office in 20123 - Milan (MI), Via Giacomo Leopardi no. 7, as Data Controller pursuant to and for the purposes of the Regulation (EU) 2016/679 (hereinafter also "GDPR" or "legislation"), recognizes the importance of the fundamental right to protection of natural persons with regard to the processing of personal data. Therefore, by virtue of the aforementioned legislation, the processing of personal information of the data subjects will be carried out and protected in accordance with principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, accountability and, in any case, in accordance with the provisions of the GDPR. Access to and use of the website http://www.strategicagroup.com/ confers the status of User on the visitor to the website and implies full and unreserved acceptance by the same of the following conditions of use. In case of non-acceptance, please do not use the website http://www.strategicagroup.com/.
 
1.    DATA CONTROLLER
The Data Controller is Strategica Group S.p.A. (C.F./P.I. 07002270960), ), in the person of its pro tempore legal representative, registered office in 20123 - Milan (MI), Via Giacomo Leopardi no. 7. The Data Controller can be contacted at the following e-mail address: privacy@strategicagroup.com

2.    PURPOSE AND LAWFULNESS OF PROCESSING
The personal data acquired through the site will be processed, in accordance with the GDPR, pursuant to the different lawful basis - legislative, contractual, consensual or for the pursuit of a legitimate interest - for the following purposes:

• for the provision of services, including responses to requests from interested parties and Users; on this point, please note that the optional, explicit and voluntary sending of e-mails, also via the “Contact us- become a customer”, by its very nature entails the subsequent acquisition of the sender’s e-mail address;
• to allow data subjects to be registered in company records, both in paper and electronic format;
• to manage and maintain the aforementioned company records;
• for the conclusion and execution of contracts;
• for the fulfilment of pre-contractual, contractual and tax obligations deriving from existing relationships, as well as managing the necessary communications connected to them;
• for the fulfilment of obligations deriving from mandatory rules, both national and European;
• for the exercise of a legitimate interest as well as a right of the data controller (i.e., the right of defence in court, the protection of credit positions, the ordinary internal operational, managerial and accounting needs);
• for marketing and promotional activities as well as the sending of newsletters, communications, including commercial ones, information circulars, invitations to events, subject to the consent of the parties concerned.

In the event the processing is carried out for purposes other than those mentioned above, further and specific consent will be requested to the interested parties.
 

3.    RECIPIENTS OF PERSONAL DATA
The policy herein describes the management methods of the website http://www.strategicagroup.com/(hereinafter “the Site”), aiming at identifying, as recipients of the personal data processing, the subjects with whom Strategica Group S.p.A., for any reason, maintain relationships or contacts, or to whom otherwise provides personal data, for the purposes and under the further conditions of this statement. Personal data can, specifically, be communicated to all the companies that are part of Strategica Group S.p.A., Strategica Risk Consulting S.r.l., Strategica Insurance Management S.r.l., Valore Sicuro S.r.l. and Vaance S.r.l. -as well as to third parties appropriately designated “Responsible for the treatment" and provided with suitable guarantees pursuant to the law.
It is understood that the personal data of the interested parties may be freely disclosed to third parties, such as Law Enforcement, whenever this is permitted by law or required by an order or provision of a competent authority

4.    PERSONAL DATA RETENTION PERIOD
The personal data of the data subjects will be stored as long as is reasonably necessary to fulfil the relevant purposes envisaged in paragraph 2), as well as for the time during which the Data Controller is subject to storage obligations for tax and/or accounting purposes or for other purposes determined by relevant legal and regulatory obligations, both national and EU. Please note that specific security measures are observed to prevent the loss of personal data, unlawful or incorrect use of the same and unauthorized access, in accordance with the provisions of the GDPR.
Furthermore, in order to ensure that your personal data are always accurate, updated, complete and relevant, we invite you to report any changes to the e-mail address privacy@strategicagroup.com    
As regards access tracks, these are stored for the duration of six months.

5.    RIGHTS OF THE DATA SUBJECT
Data subjects have the right to exercise the following rights recognized by the GDPR at any time, if the legal requirements exist, by contacting the Data Controller at the e-mail address privacy@strategicagroup.com:

• to request and obtain confirmation as to whether or not personal data concerning him or her are being processed;
• where personal data concerning him or her are being processed, to request and obtain access to their personal data;
• to request and obtain, without undue delay, the rectification of inaccurate personal data concerning him or her, as well as the integration of incomplete personal data;
• to request and obtain, without undue delay, upon the occurrence of one of the conditions provided for in Article 17(1) GDPR, the erasure of personal data concerning him or her, except as provided for in Article 17(3) GDPR;
• to request and obtain, in the cases provided for by Article 18(1) GDPR, the restriction of processing of their personal data;
• to object at any time to the processing of their personal data, in the event of special situations concerning him or her. Specifically, in the event of opposition, personal data will no longer be processed, unless there are compelling legitimate grounds for processing that override the interests, rights, and freedoms of the data subjects or for the assessment, exercise or defence of a legal claim;
• to obtain the portability of their personal data, i.e., the right to receive the personal data from the Data Controller in a structured, commonly used and machine-readable format and request their transmission to another Data Controller, without hindrance;
• where consent is required for the processing of personal data, to withdraw the consent already given, limited to cases where the processing is based on the data subject's consent for one or more specific purposes or in the case of processing of special categories of data (i.e., data revealing racial origin, political opinions, religious beliefs, state of health or sex life, etc.). Processing based on consent and carried out prior to the revocation of such consent does not affect and, therefore, retains its lawfulness.

In any event, we ask you not to send or communicate so-called special categories of personal data through the site or by any other means. For the purposes of the GDPR, "special categories of personal data" means any data capable of revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. Finally, data subjects have the right to lodge a complaint with the Italian Data Protection Authority (Autorità Garante per la protezione dei dati personali), where they consider that their rights under the GDPR have been infringed, in accordance with the procedures indicated on the website of the Italian Data Protection Authority itself, accessible at www.garanteprivacy.it

6.    CONSEQUENCES OF FAILURE TO PROVIDE PERSONAL DATA
The provision of personal data is compulsory for the purposes referred to in paragraph 2), letters a) to g) and failure to provide such data involves the impossibility of reaching the conclusion of contracts and the inability to provide the services requested.
The provision of personal data is optional for the purposes referred to in paragraph 2), letter h) and failure to provide such data makes it impossible to pursue them.

7. DATA PROCESSED
We process the following categories of personal data:

• Personal data - information you provide to us regarding the place and date of birth, education or professional situation.
• Contact details - information relating to the name, fiscal code, address, telephone number, mobile number, email address, professional or personal, name and public data of the company where you are employed.
• Interests - information you provide us about your interests, including products / services provided by our companies
• Data on social networks: information that you publicly share on a social network, or that is part of your profile on a social network and that you have allowed third parties to share with Strategica Group.
• Use of the website: like all websites, this site also makes use of log files in which information collected in an automated manner is stored during user visits. The information collected could be the following: internet protocol (IP) address; type of browser and device parameters used to connect to the site; name of the internet service provider (ISP); date and time of visit; web page of origin of the visitor (referral); possibly the number of clicks.