Profiling Policy

Updated to March 21 2016

Introduction and General Terms

Profiling is the analysis and processing of information on Users and Customers in order to divide data subjects into “profiles”, that is, groups sharing increasingly specific forms of behaviour or features, with the goal of univocally identifying individual users (single outs) or terminals and therefore profiles of one or more users of the device.

This form of categorisation is useful for providing increasingly targeted services meeting users’ specific requirements and providing customised advertising.

Authenticated and unauthenticated users

Users of the functions taken into consideration may be divided into those possessing an account created through a registration procedure for “authenticated” access to services (referred to as authenticated users), or using the same functions without authentication (referred to as unauthenticated users).

Copernico Srl performs profiling of personal data of unauthenticated users registered for the Clubhouse Newsletter only.

Profiling Policy

Personal data processing

The Data Controller, Copernico Srl of Piazza IV Novembre 7, Milan, collects your personal data by computer or over the internet and organises the information into databases primarily organised in automated form.

Personal data processed

When you receive our Newsletters, we may retain information on you regarding:

  • The frequency with which you open the newsletter and the date of your most recent activity;
  • The time, date, number and position of your clicks on the newsletter, if any.


Profiling methods and purposes

Your personal data may be collected by behavioural analysis software regarding how you interact with newsletters received. Processing for profiling purposes results in creation of “profiles”, that is, groups sharing the same forms of behaviour or characteristics, in order to send customised advertising Newsletters.

Method of acquiring consent and modulation of choices

The request for consent to data processing for profiling purposes is made when you register to receive our Newsletter or sign our Service Contract. You may make changes to your services or deny your consent by clicking on the link provided every time you receive a Newsletter.

Personal data storage

In compliance with the principle of the purposes of storage of users’ personal data (art. 11, paragraph 1, letter e) of the Code), data used for profiling purposes will be stored in a form which permits identification of the data subject for no longer than necessary for the purposes for which the data was collected and processed. A storage period of no more than twelve months is considered appropriate, at the end of which the data will be automatically deleted or made permanently anonymous.

Your rights and the Data Processors

You may read about your rights and the Data Processors in our Privacy Policy.