PRIVACY POLICY

WEBSITE PRIVACY POLICY

Links Management and Technology AG. places this website at the disposal of its users in order to provide information regarding its activities in a free, simple and direct manner. Our aim is to provide information that is up-to-date, accurate and as complete as possible. In any case, our company cannot in any way be held responsible for the accuracy, completeness or quality of the information provided on this website. Any liability for material or immaterial damage resulting from the use or non-use of the information provided or from the use of incorrect or incomplete information is therefore excluded.

This information on the processing of personal data describes the processing of personal data entered or collected on the site www.linksmt.it (‘Site’). The information also describes the processing of personal data, whether entered or collected through competitions, forms, interviews or other channels (e.g. social pages).

Information on the processing of personal data

Links Management and Technology AG. informs that this page describes how the company website (‘Site’) is managed with reference to the processing of personal data of visitors and users consulting it.

The information is given in compliance with Italian and European legislation on the protection of personal data (EU Regulation 2016/679) to those who interact with the web services of the Site and, therefore, does not apply to information collected through channels other than this website.

It does not, therefore, refer to processing carried out through other partner websites of Links Management and Technology AG. that the user may access through links from this website. For such processing, the respective owners will have to provide autonomous information.

Who processes user data

Data controller:

The data controller of the data collected following consultation of this website is LINKS MANAGEMENT AND TECHNOLOGY AG., with registered office at Thurgauerstrasse 54 - 8050 Zürich - CHE-171.175.441-, Telephone: +41 79 248 44 22, Email: info@linksmt.ch.

The Company, in its capacity as Data Controller, has appointed Mr Domenico Busco of Studio Legale Busco & Partners as Data Protection Officer (DPO), who can be contacted at the following addresses dpo@linksmt.it and dpo.linksmt@legalmail.it.

What personal data we collect and why

Personal data means any information about you that allows us to identify you, such as your first name, last name, contact details, telephone number, e-mail address, IP address and information about your access to our website.

We may collect your personal data when you contact us at the telephone numbers indicated, send an e-mail, make requests of various kinds or use social network plug-ins on the Website.

Therefore, following consultation of this Site or use of the services made available through it, the following types of personal data of users may be processed:

a) Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation 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, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and IT 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, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site or third parties: except for this possibility, at present, data on web contacts do not persist for more than seven days.

b) Personal data provided voluntarily by Users

The personal data provided freely and voluntarily by users of this site concern respectively

- those entered in the forms present in certain sections of the site (e.g.: the ‘Careers’ section) or sent by e-mail to the e-mail addresses indicated on the Site, in order to respond to the user's requests.

With the use or consultation of this Site, therefore, Links Management and Technology AG. will process the data of visitors and users in order to

- provide information services about the company's activities (including the organisation of events or shows)

- respond to information and contact requests

- verify the necessary and automatic collection of data relating to interaction with the website;

- allow the interested party to participate in events (through the various channels made available by the Company);

- analysing, on aggregate data, the behaviour of visitors and users or analysing, on aggregate data, the behaviour on the website;

- preventing or detecting fraudulent activity or abuse harmful to the Site.

We will only process your personal data if we have a lawful basis to do so. The legal basis will depend on the reasons why we have collected and need to use your personal data. These reasons include, in some cases, the need to respond to your requests (contractual or pre-contractual purposes, legitimate interest), to comply with certain legal and/or regulatory requirements or to pursue the legitimate interest of the Controller; in other cases, we may need your consent (e.g. opinion polls or market research), in which circumstances we will require it in the form required by law.

Where we obtain data and the nature of providing it (including the consequences of refusing to provide it)

Your data may be collected online when you browse the site or if you send e-mails, faxes or telephone calls to the numbers indicated; in particular, your personal data, e-mail address and, where requested, telephone number are necessary for the pursuit of the purposes indicated above (such as, for example, providing feedback on your requests). If you send your CV, the personal data it contains will be processed pursuant to Art. 111 bis of Legislative Decree 196/03.

Failure to provide the data necessary to respond to your requests may result in the impossibility of providing you with a comprehensive reply or other available services. As the case may be, and if necessary, you will be informed from time to time of the compulsory or optional nature of providing personal data (e.g. to make a specific request). The compulsory or optional nature of the provision of data will be highlighted by means of a notice or an appropriate character to the compulsory information. Finally, please note that failure to provide optional personal data will not entail any obligation or disadvantage.

To whom we communicate/disclose your data

For the purpose of using the online services, as well as to comply with certain legal and/or regulatory requirements or for the legitimate interest of LINKS MANAGEMENT AND TECHNOLOGY AG., your data may be disclosed

- to our employees and internal collaborators (e.g. collaborators and employees specifically authorised to process data, agents or dealers within our territory and belonging to our sales network)

- to third party companies, contractually linked with the Company or other entities that perform activities and services in outsourcing on behalf of the Data Controller (third party technical service providers such as, for example, hosting providers, communication agencies, web platform development and maintenance service providers, providers of development, delivery and operational management services for the technological platforms employed, etc.), appointed where necessary as external Data Processors

- to third parties for whom this is necessary and indispensable (or in any case functional) for the performance of LINKS MANAGEMENT AND TECHNOLOGY AG.'s activities.

Social media: We may use social media plug-ins on our website. Accordingly, data will be shared with the social media service and possibly shared on your social media profile (e.g. Facebook, Twitter, Instagram). Please refer to the privacy policy of these third-party social media providers to learn more about these practices.

Personal data will in any case not be disclosed. This is without prejudice, in any case, to the communication or dissemination of data required, in accordance with the law, by Police Forces, Judicial Authorities, information and security bodies or other public entities for purposes of defence or state security or the prevention, detection or suppression of crimes.

To whom we transfer your data

The management and storage of personal data will take place in Italy and, in any case, within the European Union. Currently the servers used are located within the European territory. The data will not be transferred outside the European Union. It is in any case understood that, should we deem it necessary, we will be entitled to change the location of the servers in Italy and/or the European Union and/or non-EU countries. In this case, we will ensure in advance that the transfer of data outside the EU will take place in compliance with the applicable legal provisions by entering into, if necessary, agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission or only in the presence of other requirements in compliance with the applicable Italian and European regulations.

How long we keep your data

The data collected by the Site during its operation is used exclusively for some of the purposes indicated above and kept for the time strictly necessary to carry out our activities.

We will not retain data for longer than is necessary to fulfill the purpose for which it was processed. In determining the appropriate retention period, we take into consideration the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes by other means.

The data collected by the Site will therefore be retained for as long as is necessary to respond to your requests and, even after termination, to manage any contractual, pre-contractual, administrative or legal obligations connected with or arising from them; this is unless you have given your explicit consent in relation to some of the services offered, because in the latter cases the processing may last until your consent is revoked.

Finally, your personal data may also be kept for as long as permitted by Italian law in order to protect the legitimate interests of the Company (Art. 2947, para. 1 and 3 of the Italian Civil Code).

How we process your data and how we comply with data protection regulations

Personal data are processed by electronic and automated means for the time strictly necessary to achieve the above-mentioned purposes. Specific technical and organisational security measures are observed to prevent data loss, illegal or incorrect use and unauthorised access.

We adopt a set of technical and organisational security measures to ensure the confidentiality, integrity and availability of your data.

We process data in a lawful and correct manner, carried out in accordance with the principle of minimisation.

How we guarantee your rights

Links Management and Technology AG. informs you that according to the new European legislation on data processing, under certain circumstances you have the right

1) to ask for confirmation as to whether or not personal data concerning you is being processed and, if so, to obtain access to that data and to all information relating to the processing;

2) to obtain the rectification and correction of inaccurate personal data and to supplement incomplete data, also by providing a supplementary declaration

3) to obtain cancellation if

- the data are no longer necessary in relation to the purposes for which they were collected or processed

- the data have been processed unlawfully,

- the data must be deleted in order to comply with a legal obligation,

- you have revoked your consent,

- you object to the processing;

4) to obtain the restriction of the processing (and thus to suspend it) when one of the following cases occurs

- if you contest the accuracy of your personal data, for the period necessary for us to verify said accuracy;

- if the processing is unlawful and you object to the deletion of the personal data and instead request that their use be restricted;

- if the personal data are necessary for the establishment or exercise of a legal claim of the data subject;

- if the data subject has objected to the processing, pending verification as to whether our legitimate reasons prevail over yours;

5) to request the transfer of your personal information in electronic and structured form to another party (‘data portability’);

6) to object, in whole or in part, to the processing;

7) to revoke, at any time, the consent given (in these cases, revocation of consent does not affect the lawfulness of processing based on consent before revocation);

Data subjects may contact the Data Protection Officer for all questions concerning the processing of their personal data and the exercise of their rights under this Regulation by sending an e-mail to privacy@linksmt.it or to the PEC dpo.linksmt@legalmail.it.

The right to object to the processing of personal data for marketing purposes can be exercised individually both towards the so-called automated contact methods (e.g. e-mail, SMS, or the other tools used by the Controller), and towards the traditional methods (paper mail and telephone); this right can be exercised to all or part of the indicated methods (e.g. only to communications by paper mail or telephone, or by objecting only to the sending of promotional communications carried out by automated tools such as e-mail, SMS).

Users who believe that the processing of their personal data, carried out through this website, occurs in violation of the provisions of the current legislation on the protection of personal data have the right to lodge a complaint with the Supervisory Authority pursuant to art. 77 of the Regulation, or to take legal action (for further information please visit the website www.garanteprivacy.it).

Changes and updates to this Privacy Policy

Links Management and Technology AG. will take care of modifying or simply updating, in whole or in part, the Privacy Policy of the Site also in consideration of the modification of the laws or regulations that regulate this matter and protect the rights of the users. Users of our services whose data is in our possession will be notified of changes and updates to the Site's Privacy Policy by e-mail and, in any event, will be made available on the Home Page as soon as they are adopted. We therefore ask you to regularly access this section to consult the most recent and updated Privacy Policy.