Mill & Partner GmbH (“Millé Milano”), in its quality of owner and operator of the https://www.millemilano.com website (“Millé Milano Website”) is aware of the importance of protecting the personal Data and, in its quality of Data Controller, informs users (“Data Subjects”) that personal Data collected through navigation on Millé Milano website will be processed in compliance with applicable legislation. When using the services offered by the site (filling out contact forms, etc.) the Data Subject will receive specific information regarding the further processing of personal Data made by Millé Milano.
Pursuant to Article 13 of Regulation (EU) no. 2016/679 (“Regulation”), Millé Milano provides the following information.
Types of Data collected, purpose and legal basis of processing.
Millé Milano processes the following Data related to Data Subjects (“Data”):
The computer systems and software procedures used to operate the Millé Milano Website acquire, during their normal operation, some personal Data whose transmission is implicit in the use of Internet communication protocols. This category of Data includes IP addresses or domain names of the Data Subjects’ terminals that connect to the site, the MAC (Media Access Control) addresses, the addresses in the URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to forward the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and parameters related to the operating system and to the Data Subject computer environment. These Data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The Data could be used to ascertain responsibility in case of hypothetical computer crimes against the site. The legal basis that legitimises said processing is art. 6(1)(b) of the Regulation, allowing the Data Subject to use the service requested. The same Data may also be used to fulfil legal obligations or requests of the judicial Authority. The legal basis that legitimises said processing is art. 6(1)(c) of the Regulation, as the processing is necessary to fulfil a legal obligation to which the Data controller is subject.
Data provided voluntarily by the Data Subject
Following the voluntary sending of e-mail messages to the e-mail addresses on the site, Millé Milano may process the sender's e-mail address and the additional personal Data contained in the message to respond to requests made by the Data Subject. The legal basis that legitimises said processing is art. 6(1)(b) of the Regulation, as to provide the requested service to the Data Subject. The same Data may also be used to fulfil legal obligations or requests of the judicial Authority. The legal basis that legitimises said processing is art. 6(1)(c) of the Regulation, as the processing is necessary to fulfil a legal obligation to which the Data controller is subject.
Data retention period
Personal Data collected and processed when browsing the Millé Milano Website will be kept for the entire period of service providing and, in any case, deleted or rendered anonymous within 7 days. Personal Data sent voluntarily by Data Subjects through the tools on the site will be deleted after providing the service requested or having responded to them and in any case within the maximum period of 6 months from the end of this activity, with the exception of those required to comply with fiscal, accounting and administrative regulations or to fulfil other legal obligations and to document the activities carried out.
Modalities for Data processing
The personal Data will be collected, saved and processed with electronic tools and will be stored both electronically and on paper, organised in a database, and on any other type of appropriate support. Specific security measures are followed to prevent Data loss, illicit or incorrect use and unauthorised access. The processing of personal Data carried out by Millé Milano does not involve automated decision-making processes.
The provision of navigation Data is necessary to grant the requested service (navigation on the site) and therefore mandatory to this purpose: the failure to communicate or provide personal Data by the Data Subject will result in the impossibility for Millé Milano to allow navigation on the site. The provision of Data for further purposes is optional: failure to communicate or provide Data, in such cases, will not affect the Data Subject, but may result in the inability to provide the Data Subject with the feedback required.
Communication of Data
Personal Data may be disclosed to: subjects who are entitled and have the interest to access personal Data by law or secondary or community legislation; Controller’s internal staff; companies, associations or professional offices that provide services and activities on behalf of the Controller as Data Processor for the fulfilment of legal obligations, as well as for every organisational and administrative need necessary to provide the services requested. The details of the Data Processors are listed in an updated list available at Millé Milano (to be requested at the addresses indicated in point 9). Personal Data will not be disseminated.
Data transfer abroad or to international organisations
Millé Milano is a Swiss Company and for this reason Data are transferred to Swiss. For this purpose, Millé Milano informs that the abovementioned transfer is made in accordance with art. 49, par. 1 let. b) of the Regulation, since the transfer is necessary to perform the service requested.
Link to sites or services of third parties
Data Subject’s rights
The Data Subjects may at any time exercise their rights provided for in the Regulation, including:
- to request information on: (i) the origin of the Data; (ii) the purposes and methods of processing; (iii) the logic applied in the event of the use of electronic devices; (iv) the details of the Controller and of the Processors.
- to obtain: (i) access to, the updating of, or the rectification or integration of the Data; (ii) the erasure, anonymisation or blocking of Data unlawfully processed; (iii) limitation of the processing of Data; (iv) a copy of the Data in standard format.
- to object, in whole or in part, to the processing carried out:
- for the purposes of scientific, historical or statistical research, even if pertinent to the collection purpose, if such opposition is based on reasons related to their particular situation;
- for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller or to pursue the legitimate interest of the Controller or of a third party;
- for the purpose of sending promotional materials, advertising and direct marketing;
- to revoke, at any time, the consent given and on the basis of which the processing has been allowed, without affecting the lawfulness of the processing already carried out on the basis of the consent given before revoking said consent. In the event that they believe that the processing of their Data is against the law, the Data Subjects may submit a complaint to the supervisory authority of the Member State of their habitual residence or work, or to the place in which the alleged violation occurred. The Supervisory Authority can be contacted using the details provided on its own website.
Data controller - Contact details
The Data Controller is Mill & Partner GmbH, Grosse Kirchgasse 4, 5507 Mellingen, Switzerland, in the person of the legal representative pro tempore. To exercise the rights listed above, the Data Subject may make a request using the e-mail account [email@example.com].
Millé Milano retains the right to update this personal Data processing policy.