Privacy Policy

Updated to 21 March 2016

Welcome to Clubhouse Brera, website of Copernico Srl.

Your privacy is very important to us and accordingly we want to inform you of the ways in which we collect and use information about you.

Copernico Srl, the Data Controller, a company belonging to Copernico Holding SpA and based in Milan, Piazza IV Novembre 7, has always been extremely attentive to the handling and protection of personal data of its Clients, Users, Suppliers, Co-workers and all other entities it has a business relationship with. For this reason and in order to assure full compliance with provisions under Legislative Decree 30 June 2003 no. 196, our Company has adopted a specific organizational structure and introduced an appropriate Corporate Privacy Compliance Model.

This Privacy Policy applies to the way in which we use all personal data provided via the functions of the Clubhouse Brera site by email, telephone, messages or postal correspondence.

Copernico Srl furthermore reserves the right to modify or amend this Privacy Policy at any time: you are therefore invited to return to this page frequently in order to check for possible modifications. Your use of the Site and our Services implies acceptance of our Privacy Policy as it is amended from time to time.

Copernico Srl, in thanking you for providing us with your personal data, informs you of the purposes and methods used for processing them, distinguishing between:

Website users

Clients and Suppliers

CV/Resume Management

Your rights and the Persons in charge of data handling/Data Protection Officers

Firstly, we would remind you that in accordance with section 7 of Legislative Decree 196/2003, provided below, you have the right, amongst others, to know what information about you is being held and what it is being used for, and to request its integration, correction or deletion.

To exercise said rights, you may contact the Officer or Person in Charge of processing at the following email address: privacy.officer@coperni.co, or at our company’s postal address.

The complete list of all those responsible for processing personal data, appointed by us, is available by contacting our data processing Officer.

Art. 7 (Right of access to personal data and other rights)

The data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.

The  data subject shall have the right to be informed: a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) of  the  identification  details  concerning  the  data  controller,  data  processors  and  the  representative designated as per Article 5, par. 2; e) of the entities or categories of entities to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

The data subject shall have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that has been unlawfully processed, including data whose retention is unnecessary for the purposes for which it has been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, also as regards their contents, to the entities to whom or which the data was communicated or divulged, unless this requirement proves impossible or involves a manifestly disproportionate effort compared to the right that is to be protected.

The data subject shall have the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even if pertinent to the purpose of collection; b) to the processing of personal data concerning him/her, where this is performed for the purpose of sending advertising material, making direct sales or conducting market or commercial communication surveys.

PRIVACY STATEMENT FOR WEBSITE USERS

This page contains a description of site management methods with regard to the processing of the personal data of users who consult the site. The processing is always based on principles of lawfulness and fairness in compliance with all legislation currently in force.

This privacy policy is also provided in the form of an information notice in compliance with art. 13 of Legislative Decree 196/03 (Italian regulation on the processing of personal data pursuant to Directive 95/46/CE) for those who interact with the web services on this site, for the purposes of protecting personal data, accessible online from www.clubhousebrera.com corresponding to the first page of the official Clubhouse Brera website. The privacy statement applies solely to the Clubhouse Brera site and not to other websites that may be consulted by the user through links. They are independent Owners of processing and therefore you should refer back to the site in question.

This privacy statement is in compliance with the Recommendation no. 2/2001 adopted on 17 May 2001 by the European personal data protection authorities within the Working Party set up under Article 29 of  Directive 95/46/EC, to identify the minimum requisites for the on-line collection of personal data and, in particular, the methods, timing and nature of the information that the data controller must provide for users when they link to web pages, regardless of the purpose of the link.

Processing the data freely provided by you will be performed in accordance with current regulations. In particular, the processing will be done in accordance with principles of fairness, lawfulness and transparency, relevance, completeness and avoidance of excess; the data will be collected and recorded for the purposes in the following point and kept for a period of time strictly necessary for those purposes.

 

Types of data processed, methods of processing, purposes of processing, whether voluntary or not

Net browsing data

In the course of normal operations, the information systems and software procedures that govern the functioning of this website capture some personal data whose transmission is implicit in the use of Internet communication protocols.

Such information is not collected with the intention of linking it to identified or identifiable data subjects, although by its very nature, through processing and association with data held by third parties, it may lead to the identification of users.

This category of data includes IP addresses or domain names of the computers used by visitors to the website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request made, the method used to submit the request to the server, the size of files received by way of response, the numerical code which indicates the status of the response given by the server (successful, error, etc.) as well as other parameters associated with the operating system and the IT environment of the user.

This data is used with the sole aim of extracting anonymous, statistical information regarding the use of the website and to ensure that the latter is operating correctly. It is deleted immediately after processing. The data may be used to ascertain liability in the event of hypothetical cybercrimes against the Site.

 

Data supplied voluntarily by the user

The optional, explicit and voluntary dispatch of emails to addresses indicated on this website will involve the subsequent acquisition of the sender’s email address as well as of any other personal data needed in order to respond to requests and/or supply requested services, together with any other personal information included in the email (and attachments) or in the relevant forms.

The emails received are archived indefinitely in a server protected by appropriate security measures.  The data subject may exercise all his/her rights under Article 7 of the Legislative Decree 196/2003 cited at the beginning of this Privacy Policy and in particular is entitled to know what personal information is being held in the archive and request its cancellation by writing to the Person in Charge at the email address privacy.officer@coperni.co.

When replying to enquiries and/or supplying services requested the data supplied will be handled using informational and network procedures. The supply of personal data is always voluntary and failure to provide such data will merely lead to the impossibility of satisfying requests.

We may disclose your data to one or more specific subjects who are entitled to access said information pursuant to the legal provisions, regulations and/or EU directives regarding data handling and processing. In addition, personal data of users may be communicated to third parties who need to access your data for purposes ancillary to the relationship between you and ourselves, and strictly within the limits required to perform the auxiliary tasks entrusted to them (for example banks).

 

Cookies

Our Cookie Policy is available here.

Profiling

Our Profiling Policy is available here.

Place of data processing and scope of communication or broadcast

The data related to the web services of this site are processed by the Provider, within limits strictly necessary for providing the hosting service, at our organization’s office, only by technical staff responsible for processing and at the Servers of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California, 94043 – USA, or by persons employed to carry out occasional maintenance operations.  Your data may be communicated to parent, subsidiary or affiliate companies in accordance with Art. 2359 of the Italian Civil Code or to companies under common control (joint ventures), for administrative accounting purposes as defined in Art. 34, paragraph 1.3 of Legislative Decree 196/2003, or those involved in the performance of activities of an organizational, administrative, financial or accounting nature, regardless of the nature of the data processed.

Your rights and how to exercise them are given at the beginning of this Privacy Policy.

PRIVACY STATEMENT FOR CLIENTS AND SUPPLIERS

Types of data collected

Copernico Srl processes your personal details and tax data, as well as other personal information normally required to pursue contractual relationships, whether current or future, with our company.

Purpose of data processing

Your data will be processed in connection with contractual obligations, and the consequent fulfilment of legal and fiscal obligations, as well as to permit effective management of financial and business relationships.

Withdrawal of consent to data collection for commercial purposes: opt-out.

Copernico Srl may use the email or postal addresses provided by you to send you its own advertising or direct sales material or to carry out its own market research or commercial communications. Any promotional mailing activity shall be exclusively related to goods and services similar to those forming the object of our contractual relationship. We would remind you that when we collect your personal information and every time we contact you for the above-mentioned purposes, you may express your wish to opt-out simply by contacting our customer feedback officer at the email address privacy@coperni.co, or at our company’s postal address, or by clicking on the “unsubscribe/delete me” links at the bottom of the email sent to you. You will receive immediate confirmation that processing of your data  has been terminated.

Processing methods  

Processing may be carried out either electronically or manually (i.e. on paper) using methods and tools aimed at ensuring maximum security and confidentiality.

Voluntary or mandatory provision of data

As far as regards the data we need to know for the purposes of fulfilling the obligations laid down by law, regulations, EU legislation, or provisions issued by Authorities authorised to do so by law and by supervisory and control bodies, any refusal to provide them will make it impossible to establish or continue the contractual relationship, to the extent to which such data are necessary for performance thereof. As far as regards the data that we are not obliged to know, we will assess your failure to provide them on each separate occasion, and will consequently come to a decision on the basis of the importance to us of the data requested which you failed to provide.

Data disclosure

Access to your personal data is exclusively limited to those appointed by the Company to act as Data Processors or Persons in Charge of Processing, such as managers, directors, accounting, administrative and operational management personnel, or external consultants.   In addition, personal data of users may be communicated to third parties (and by this we mean one or more qualified persons) who need to access your data for purposes ancillary to the relationship between you and ourselves, and strictly within the limits required to perform the auxiliary tasks entrusted to them. Your personal data could be transmitted to holding companies, subsidiaries or affiliates under Article 2359 of the Italian Civil Code, or to joint venture companies, for administrative or accounting purposes as defined by Article 34, comma 1-ter of the Legislative Decree 196/2003, or for purposes connected to organisational, administrative, financial and accounting activities, regardless of the nature of the data handled.  More specifically, these refer to internal organisational operations, activities performed in compliance with contractual and pre-contractual obligations and informational activities, managing work relationships in all phases, keeping accounting records, and implementing legislation on taxation, trade unions, social security and welfare, health and safety at work.

The transfer of information about you, even temporary, to a Country not belonging to the European Union, may take place only if needed for the performance of obligations derived from a contract that you are party to, or to fulfil, before the end of the contract, your specific requests, or for the conclusion or execution of a contract stipulated in your favour.

Your rights and how to exercise them are explained at the beginning of this Privacy Policy.

PRIVACY STATEMENT FOR JOB APPLICANTS

Copernico Srl carries out its staff selection activities with full regard for gender equality and without discrimination against any candidate, in compliance with Laws 903/77 and125/91.

Moreover, your data will be processed and stored with the utmost confidentiality, care and diligence in compliance with Legislative Decree 196/2003 and according to the methods reported below.

Collection and nature of data

Personal data is collected through the submission of Curriculum Vitae by the interested parties. It may be collected either online (emails or attachments to related forms) or on paper.

Purposes of processing

Personal data is collected and processed solely with the purpose of identifying, selecting and assessing candidates.

Voluntary or mandatory provision of data

Provision of personal data and submission of a CV or resume on the part of the interested party is optional: in their absence, however, we will not be able to perform the activities of search, selection and assessment of personnel.

Scope of communication or disclosure of data

Data Processors or persons in charge of processing appointed by our company may have access to your personal data. Moreover, your data may be communicated to third parties who supply specific services or perform related activities instrumental to or in support of the methods and purposes for which you provided your data. Furthermore, your data may be communicated to parent, subsidiary or affiliate companies in accordance with Art. 2359 of the Italian Civil Code or to companies under common control (joint ventures), for administrative accounting purposes as defined in Art. 34, paragraph 1.b of Legislative Decree 196/2003,  or those involved in the performance of activities of an organizational, administrative, financial or accounting nature, regardless of the nature of the data processed.

More specifically, these refer to internal organisational operations, activities performed in compliance with contractual and pre-contractual obligations and informational activities, managing work relationships in all phases, keeping accounting records, and implementing legislation on taxation, trade unions, social security and welfare, health and safety at work.

Data processing and storage

Data processing will be performed in accordance with provisions under art. 11 of Legislative Decree no. 196/2003. Data processing will always be performed by applying logic and procedures strictly correlated to the purposes indicated and that ensure the security and confidentiality of said data itself, through the adoption of suitable measures to impede the alteration, deletion, destruction, unauthorized access or processing that has not been approved or is not in compliance with the purposes for which it has been collected.

Data will be stored in our database for a period of time of no more than two years and, in any case, no longer than the time necessary to manage and monitor the process of research and selection.

Your rights and how to exercise them are explained at the beginning of this Privacy Policy.