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Privacy policy
 

Privacy policy

 

The purpose of this privacy policy is to provide all the information on the processing of personal data carried out by The Ruling Companies S.r.l. when the User navigates and accesses the services of this website "rulingcompanies.com" (as indicated below).


1. Introduction - Who are we?

The Ruling Companies S.r.l. with registered office in Via F.lli Ruffini 9, 20123 Milan, Italy, tax code 04309110965, VAT number 04309110965 and registration number in the Business and Trade register of Milan 1738557 (hereinafter the "Controller"), owner of this website as the controller of the personal data of the users (hereinafter the "Users") browsing and using the services available on the website (hereinafter the "Website") provides below the privacy policy pursuant to Art. 13 of the EU Regulation 2016/679 of 27 April 2016 (hereinafter "Regulation" or "Applicable law").


2. How to contact us?

The Controller takes the right to privacy and protection of personal data of its Users into the utmost consideration. For any information related to this privacy policy, Users may contact the Controller at any time, using the following methods:

  • by sending a registered letter with return receipt to the Controller's registered office in Via F.lli Ruffini 9, 20123 Milan, Italy;
  • by sending an e-mail to: privacy@rulingcompanies.com

The Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Art. 37 of the Regulation.


3. What do we do? - Purpose of the processing

By browsing the Website, the User can consult the content available and learn about the services and initiatives promoted by the Controller; by registering to the Website, the User can subscribe to webinars and training courses available on the Website (hereinafter, jointly, the "Webinars"), download any multimedia materials relating thereto (hereinafter the "Materials"), carry out networking activities in order to keep in touch with other Users registered on the Website and view the Webinars which have been attended by other Users (hereinafter "Networking" and, jointly, the "Service").

In particular,
the User may register on the Website as “manager” (hereinafter the "Manager"). The Manager has the option of registering on behalf of his/her company and registering the company's employees and/or collaborators (hereinafter the "Personnel") to the Website as Users in order to allow them to participate in the Webinars offered to them by the company and, in general, to use the Service. The Manager may be contacted per e-mail by the Controller to send a personal, non-transferable alphanumeric code that enables the Manager to register the Personnel to the Website and thus to access the Webinars and Materials. The Manager undertakes to provide this policy on the processing of personal data to the Personnel when they register their company for the Service offered on the Website.

Alternatively, the User may also register directly as natural person through voluntary membership.
Use of the Service is finalised upon payment of the membership fee..

- Following the registration of the company by the Manager or through voluntary membership, a User may access the Website as "Associate" (hereinafter the “Associate”). Users wishing to access the Website as Associates are required to send an e-mail to the Controller, following the instructions indicated in the section “Verify your e-mail” of the Website. The e-mail address with which the User contacts the Controller will be used for the sole purpose of the profile activation procedure. After the procedure, the Associate will be for all intents and purposes operational on the Website.

- By means of the "Contact us" and "Help" sections (hereinafter, jointly, the "Contact section"), the User may contact the Controller for various purposes such as, indicative but not exhaustive, to obtain more information on the services offered through the Website, to ask the Controller for support, to submit a suggestion or a proposal.

Where possible and indicated within the Website, the User may decide to participate in one of the Webinars available on the Website even without being registered on the Website as "guest" (hereinafter the "Guest").

The User may, using the "Reviews" function, decide to leave an evaluation and/or comment on the Webinars s/he has attended.

Whether the User accesses the Website as Associate, or when registering as Guest, the User will receive, as part of the Service, communications containing reminders and service information regarding the Webinar(s) selected by the Company (or by the same User in case of voluntary membership), if the User is an Associate, or to which the User is subscribed, if s/he is a Guest (hereinafter the "Reminders").
These communications differ from the newsletter, which the User may receive by providing specific, free and optional consent, as better specified in paragraph 4.1 below.

With reference to the activities that may be carried out through the Website, the Controller collects personal data relating to Users. This Website and any services offered through the Website are reserved for persons aged 18 years or older. The Controller therefore does not collect personal data on persons under the age of 18. Upon request of Users, the Controller shall promptly delete all personal data involuntarily collected related to persons under the age of 18.
In particular, User personal data will be lawfully processed by the Controller for the following purposes:

  • a) Contractual obligations and provision of the Service, to enable navigation of the Website or to enforce the terms and conditions of the Service, which are accepted by the User when registering on the Website; fulfil specific requests of the User.
    - The User data collected by the Controller for the sole purpose of browsing the Website include all those personal data whose transmission is implicit in the use of Internet communication protocols, such as: IP addresses used by users connecting to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, log files and other parameters related to the operating system and IT-environment of the User.
    - The User data collected by the Controller when the User registers on the Website as “Manager” include: first name, last name, e-mail address, telephone number, company name, company role, as well as any additional data voluntarily published if the User intends to leave a review through the relevant function. Unless the User gives the Controller specific and optional consent to the processing of his/her data for the further purposes provided for in the following paragraphs, the User personal data shall be used by the Controller for the sole purpose of ascertaining the User identity (also by validating the e-mail address), thus avoiding possible fraud or abuse, and contacting the User for service purposes only (e.g. sending a personal alphanumeric code non-transferable to third parties, which allows the Manager to access the Webinars and Materials).
    - The User data collected by the Controller when the User activates the profile as “Associate” include: first name, last name, e-mail address, company name, as well as all further data voluntarily published if the User intends to leave a review through the relevant function. Unless the User gives the Controller specific and optional consent to the processing of his/her data for the further purposes provided for in the following paragraphs, the User personal data will be used by the Controller for the sole purpose of activating the profile and ascertaining the identity of the User, by validating the e-mail address, thus avoiding possible fraud or abuse, and contacting the User for service purposes only (e.g. sending of Reminders).
    - The User data collected by the Controller when the User registers for a Webinar as "Guest" include: first name, last name, e-mail address, company name, company role, as well as any further data voluntarily published in case the User wishes to leave a review through the relevant function. Unless the User gives the Controller specific and optional consent to the processing of his/her data for the further purposes provided for in the following paragraphs, the User personal data will be used by the Controller for the sole purpose of ascertaining the identity of the User (also by validating the e-mail address), thus avoiding possible fraud or abuse, and contacting the User for service purposes only (e.g. sending of Reminders).

    The User is aware that the information and data provided when registering on the Website may be transmitted by the Controller and made available to other Users, for Networking purposes of the Service offered through the Website. Notwithstanding the provisions of this paragraph, as well as elsewhere in this privacy policy, under no circumstances shall the Controller make User personal data accessible to third parties.
  • b) Contact request and/or information request, the User data collected by the Controller for the purposes of any contact request and/or information request include: first name, last name, e-mail address, as well as any personal information of the User that may have been voluntarily published. The User's personal data will be used by the Controller for the sole purpose of ascertaining the identity of the User, thus avoiding possible fraud or abuse, and contacting the User for service purposes only (e.g. responding to his/her request for information). Notwithstanding the provisions elsewhere in this privacy policy, under no circumstances shall the Controller make the personal data of Users accessible to other Users and/or third parties;
  • c) Fulfilling the User's request, the User personal data collected and processed by the Controller for the purpose of fulfilling the User's request regarding the possibility of leaving a review of the selected Webinar, include: first name, last name, e-mail address, as well as all the User personal information that may have been voluntarily provided by the same within the dedicated box.
  • d) Administrative-accounting purposes, i.e. to carry out activities of organisational, administrative, financial and accounting nature, such as internal organisational activities and activities functional to the fulfilment of contractual and pre-contractual obligations;
  • e) Legal obligations, i.e. to fulfil obligations provided for by law, by an authority, by a regulation or by European legislation.

The provision of personal data for the processing purposes indicated above is optional but necessary, as failure to provide such data will make it impossible for the User to benefit from the Services offered by the Controller on the Website.


4. Further processing purposes

4.1 Newsletter
With the User free and optional consent, some of the User personal data (i.e. e-mail address) may also be processed by the Controller for the purpose of sending the newsletter. Therefore, the User will receive a recurring newsletter from the Controller containing information, updates, news and initiatives concerning the Service offered by the Controller.

Newsletter communications differ from Reminders since these contain information, updates and news regarding the entire Service, and not limited to the Webinar(s) to which the User is subscribed and/or the Webinar(s) selected by the company of which the User is a member (or by the User himself in case of voluntary membership). Receipt of the Reminders is also not conditional on consent, as the User receives them as part of the Service.

If consent is not given, the possibility of using the Service offered on the Website will not be affected in any way.

In the event of consent, the User may revoke it at any time by making a request to the Controller as indicated in paragraph 8 below.

The User may also easily object to further sending of promotional communications by clicking on the relevant link for revoking consent, which is to be found in each e-mail containing the newsletter. Once consent has been revoked, the Controller will show the User a message confirming that consent has been revoked.


5. Legal basis

Contractual obligations and fulfilment of the User's request (as described above in para. 3, letter A): the legal basis is Art. 6, para. 1, letter B of the Regulation, i.e. the processing is necessary for the performance of a contract to which the User is party or for the performance of pre-contractual measures taken at the User's request.

Request for contact and/or information (as described above in para. 3, letter B): the legal basis is Art. 6, para. 1, letter B of the Regulation, i.e. the processing is necessary for the performance of a contract to which the User is party or for the performance of pre-contractual measures taken at the User's request.

Fulfilling the User's request (as described above in para. 3, letter C): the legal basis consists of Art. 6, para. 1, letter B of the Regulation, i.e. the processing is necessary for the performance of a contract to which the User is party or for the performance of pre-contractual measures taken at the User's request.

Administrative-accounting purposes (as described above in para. 3, letter D): the legal basis is Art. 6, para. 1, letter B of the Regulation, i.e. processing is necessary for the performance of a contract to which the User is party or for the performance of pre-contractual measures taken at the User's request.

Legal obligations (as described above in para. 3, letter E): the legal basis is Art. 6, para. 1, letter C of the Regulation, as the processing is necessary to comply with a legal obligation to which the Controller is subject.

Further processing purposes: for the processing relating to the activity of sending the newsletter (as described above in para. 4.1), the legal basis is Article 6, para. 1, letter A of the Regulation, i.e. the provision by the data subject of consent to the processing of his/her personal data for one or more specific purposes. For this reason, the Controller asks the User for specific, free and optional consent to pursue this processing purpose.


6. Processing methods and data retention periods

The Controller will process the User personal data by means of manual and computerised tools, with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data.

The personal data of the Users of the Website will be kept for the time strictly necessary to fulfil the primary purposes illustrated in paragraph 3 above, in particular as long as the User keeps his/her profile/registration on the Website active, or as long as necessary to protect the interests of both the Users and the Controller in civil law.

In the case referred to in paragraph 4.1 above, the User personal data shall be kept for the time strictly necessary to fulfil the purposes set out therein and, in any case, until the User revokes his/her consent.

In any case, any retention periods provided for by law or regulations are unaffected.


7. Scope of data communication and dissemination

The personal data of the Users may be disclosed to the employees and/or collaborators of the Controller in charge of managing the Website and the Users' requests. These subjects, who have been instructed to do so by the Controller pursuant to Art. 29 of the Regulation, will process User data exclusively for the purposes indicated in this policy notice and in compliance with the provisions of the Applicable law.

User personal data may also come to the knowledge of third parties who may process personal data on behalf of the Controller in their capacity as Data processors, such as, by way of example, suppliers of IT and logistical services functional to the operation of the Website, suppliers of outsourcing or cloud computing services, professionals and consultants.

Furthermore, the personal data of Users may be communicated by the Controller, to the extent that this is necessary to perform the Service and/or to comply with legal obligations, to other Users registered on the Website, as well as to other parties to whom the data must necessarily be communicated in order to allow the User to take advantage of the service offered through the Website.

In the event that the User decides to register, on a voluntary basis, as natural person, the payment providers identified for payment of the membership fee may also have access to the User personal data.

Users have the right to obtain a list of any data processors appointed by the Controller and of advertisers by submitting a request to the Controller in the manner indicated in paragraph 8 below.


8. Rights of the parties involved

The personal data of the Users may be disclosed to the employees and/or collaborators of the Controller in charge of managing the Website and the Users' requests. These subjects, who have been instructed to do so by the Controller pursuant to Art. 29 of the Regulation, will process User data exclusively for the purposes indicated in this policy notice and in compliance with the provisions of the Applicable law.

User personal data may also come to the knowledge of third parties who may process personal data on behalf of the Controller in their capacity as Data processors, such as, by way of example, suppliers of IT and logistical services functional to the operation of the Website, suppliers of outsourcing or cloud computing services, professionals and consultants.

Furthermore, the personal data of Users may be communicated by the Controller, to the extent that this is necessary to perform the Service and/or to comply with legal obligations, to other Users registered on the Website, as well as to other parties to whom the data must necessarily be communicated in order to allow the User to take advantage of the service offered through the Website.

In the event that the User decides to register, on a voluntary basis, as natural person, the payment providers identified for payment of the membership fee may also have access to the User personal data.

Users have the right to obtain a list of any data processors appointed by the Controller and of advertisers by submitting a request to the Controller in the manner indicated in paragraph 8 below.


Users may exercise the rights guaranteed to them by the Applicable law by contacting the Controller in the following ways:

  • By sending a registered letter with return receipt to the Controller's registered office in Via F.lli Ruffini 9, 20123 Milan, Italy;
  • by sending an e-mail to: privacy@rulingcompanies.com

The Controller has not identified the figure of the Data Protection Officer (DPO), since it is not subject to the designation obligation provided for in Art. 37 of the Regulation.

Pursuant to the Applicable law, the Controller informs Users that they have the right to obtain information on (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) the identification details of the data controller and data processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of such data in their capacity as data processors or persons in charge of processing.

Furthermore, Users have the right to obtain:
a) access, update, rectification or, where interested, integration of the data;
b) the cancellation, transformation into anonymous form or restriction of data processed in breach of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) certification that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared to the right protected.

In addition, Users have:?
a) the right to withdraw consent at any time, if the processing is based on their consent;
b) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used and machine-readable format);
c) the right to object:

  • i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if they are relevant to the purpose of the collection;
  • ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
  • iii) where personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for that purpose, including profiling insofar as it relates to such direct marketing;

d) if they consider that the processing concerning them is in breach of the Regulation, the right to lodge a complaint with a supervisory authority (in the member state in which they have their habitual residence, in the member state in which they work, or in the member state in which the alleged breach occurred). The Italian supervisory authority is the Data Protection Commissioner, with its head office in Piazza Venezia 11, 00187 Rome (www.garanteprivacy.it).


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The Owner is not responsible for updating all the links displayed in this policy; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by that link.