PRIVACY POLICY
ICG Insurance Consulting Group SpA with registered office in via Nizza, 53 Rome (RM) (hereinafter, the “ Company ”), as the data controller, undertakes to protect the user’s privacy. This Privacy Policy (” Privacy Policy “) applies only to the site icgnet.it (hereinafter the ” Site “).
Please read the Privacy Policy carefully before using the Site.
1 – The Site
The main purpose of the Site is the presentation of the Company’s services and products through the provision of information and descriptions to users.
This document describes the methods of collection, use and sharing of personal data that the Company obtains as a result of the use of the Site by users.
Since the Company reserves the right at any time to extend or reduce the functionality of the Site and to modify the services and / or products offered, the Privacy Policy may be updated at any time by the Company, which will notify users and to visitors to the Site of any changes made.
Considering that the Site could allow access to websites owned and operated by the Company or by third parties, it is specified that this Privacy Policy does not apply to said websites and that, in particular, the Company is not responsible for the protection of personal data from such third parties.
2 – Data processed
2.1 – Data provided voluntarily by the user.
The Company may collect the following personal data provided voluntarily by the user:
- name and surname of the user
- your email address
- company name
- other information provided by the user in the contact form .
2.1 – Navigation data.
The navigation data includes all data collected automatically through the Site and concern, for example, the types of actions that the user carries out on the Site and the way in which the user is using the Site. The navigation data are used exclusively to obtain anonymous statistical information on the use of the Site and to check its regular functioning. These data could also be used in order to ascertain responsibility in the event of any computer crimes against the Site or to protect the rights of the Company.
3 – Purpose and legal basis of the processing
Purpose 3.1 – The Company processes the user’s personal data to provide the services and / or products requested by the user, to respond to or satisfy a user’s request, including registration to ensure and manage participation in initiatives, events or promotions to which the user has chosen to join. Legal basis 3.1.1 – The Company processes the data for these purposes to execute a contract and / or pre-contractual measures adopted at the request of the user. |
| Purpose 3.2 – The Company processes the user’s personal data to send the user promotional information regarding services and / or products of the Company and / or third parties, to send invitations to events of the Company and / or third parties and to carry out market surveys , through automated tools (e.g. via email) and non-automated (paper mail, telephone with operator), without prejudice to the possibility for the user to oppose the sending of such communications at any time even being able to select with which tools to be contacted or less. Legal basis 3.2.1 – The Company processes the data for these purposes only with the prior consent of the user, specifically acquired at the time of the collection of personal data for this purpose. |
| Purpose 3.3 – The Company processes the user’s personal data for communication to our commercial partners for its own marketing purposes carried out through automated (e.g. email) and non-automated (paper mail, telephone with operator) tools, as autonomous owners of the treatment. The user has the right to withdraw his consent at any time. Legal basis 3.3.1 – The Company processes the data for these purposes only with the prior consent of the user, specifically acquired at the time of the collection of personal data for this purpose. |
| Purpose 3.4 – The Company processes the user’s personal data to ensure that the Site is updated and meets the needs of users, to analyze, review and improve the products or services offered on the Site, to provide users with a browsing experience of the Site user-friendly, to ensure compliance with the terms of use of the Site, the safety of the Site and its users and to protect the rights and / or assets of the Company. The information used for this purpose will remain strictly anonymous and will not be used to identify any user nor will it be aggregated with users’ personal data. Legal basis 3.4.1 – The Company processes the data for these purposes to pursue its legitimate interest in protecting its assets, its business and its rights. |
| Purpose 3.5 – The Company processes the user’s personal data to fulfill obligations deriving from law, regulations or community legislation. Legal basis 3.5.1 – The Company processes the data for these purposes to fulfill a legal obligation. |
4. Nature of the provision of data and consequences of any refusal
Providing data for the purposes referred to in points 3.1 , 3.5 is necessary and a refusal by the user makes it impossible for the Company to perform its contractual obligations and provide the user with the requested features, services and information. as specified above. The provision of data for the purposes referred to in point 3.4 is automatic and implicit in the Internet transmission protocols.
Providing data for the purposes referred to in points 3.2 and 3.3 is optional and any refusal by the user will have no consequence on the provision to the user of the services, features and information requested through the Site.
5. Recipients of the data
5.1 – Third party service providers.
The Company shares users’ personal data with third party service providers who will act as data processors in order to make it possible to use the Site and / or receive services through the Site. By way of example, such third parties may include professionals, even in associated form, who provide technical, commercial or administrative consultancy to the Company for the pursuit of their business and the purposes described in this document, companies that deal with the management or maintenance of the IT infrastructure on which the Site is based, agencies specialized in the management of promotional and marketing services in the name and on behalf of the Company.
5.2 – Third parties in compliance with a legal obligation or to protect the rights of the Company.
The communication of personal data of users can take place towards institutions, law enforcement agencies, judicial, administrative, regulatory or public security authorities, in the context of a legal or administrative procedure, or in order to fulfill a legal obligation. o protect one of our rights, even in court.
5.3 – Third parties in the case of corporate transactions.
The communication of personal data of users may take place in the face of events such as mergers, company (or branch) transfers or other extraordinary transactions in which the Company may have to share information with potential buyers or counterparties and their consultants. .
5.4 – Third party business partners.
With the user’s consent, we can communicate the personal data of users to our business partners to pursue the purpose referred to in point 3.3 .
6. Data of minors
The Company does not intentionally collect or store personal data of individuals under the age of 18, nor does it intentionally allow such minors to use the Site.
Users under the age of 18 are requested not to register on the Site and not to provide personal data.
7. Transfer abroad
The Company may need to transfer users’ personal data abroad to provide services to the user and to pursue the other purposes indicated in this Privacy Policy. Before proceeding with the transfer of data outside the European Union, it will adopt suitable precautions, including contractual ones, provided for by the applicable privacy legislation, in order to guarantee the protection, security and confidentiality of the personal data being transferred (for example, will adopt the Standard Contractual Clauses provided by the European Commission).
8. Data retention
The Company keeps the personal data of users for the time strictly necessary to provide the services or to achieve the purposes for which the data were collected, or in compliance with legal obligations. For example, the Company retains the personal data necessary for the exercise of our right of defense in the event of legal disputes, such as personal data relating to a contract or the provision of a service, up to a maximum of 10 years from the conclusion of the service. of the service and / or supply of the product, on the basis of the ordinary limitation period provided for by the Civil Code.
After this deadline, the personal data will be deleted or made anonymous.
In the event that the Company has collected personal data based on the user’s consent and no longer has any other valid legal basis to continue with their treatment, if the user subsequently denies his consent, the Company will delete the personal data concerned by such revocation. Notwithstanding the foregoing, the Company retains the personal data of users collected in accordance with this Privacy Policy for the marketing purposes referred to in point 3.2 for a period not exceeding 2 years from their collection and for the purpose of anonymous profiling of the target referred to in point 3.4 for a period not exceeding 12 months from their collection.
After this deadline, the data will be deleted or made anonymous.
9. Data security
The Company undertakes to protect the security of the user’s personal data and complies with the security provisions provided for by the applicable legislation in order to avoid data loss, illegitimate or illicit use of data and unauthorized access to the same. The information systems and computer programs of the Company are configured in such a way as to minimize the use of personal and identification data, which are used only when necessary for the pursuit of the specific purposes pursued from time to time as indicated in this Privacy Policy. The Company uses advanced security technologies and procedures aimed at promoting the protection of users’ personal data; for example, personal data are stored on secure servers located in controlled access locations. You can help the Company to update and keep your personal data correct by notifying us of any relative changes, for example, to your e-mail address.
10. Privacy rights
The user has the right to access, rectify or delete the data stored by the Company concerning him, as well as the right to oppose, or limit, certain types of treatment (including the right to withdraw his consent to the treatment previously provided), as well as to receive personal data concerning him in a structured format, commonly used and readable by an automatic device (right to data portability). The user can revoke the consent at any time and the revocation of the consent does not affect the lawfulness of the processing based on the consent before the revocation. Finally, the user has the right to lodge a complaint with a competent Supervisory Authority. The exercise of the above rights has no costs but in the event that the Company considers the exercise of privacy rights by the user manifestly unfounded or excessive, the Company reserves the right to charge the requesting user a reasonable contribution. expenses for processing the request. To exercise your privacy rights, as well as to request any information or clarification regarding this Privacy Policy, the user can contact the Company at the following address: privacy@icgnet.it .