Privacy Policy

Our website collects some Personal Data from its Users. Data Controller: Martino & Partners srl. Via di Porta Pinciana 6, 00187 – Rome.

Email address of the Data Controller: privacy@martinopartners.com

 

Types of Data Collected

Among the Personal Data collected by our website, either independently or through third parties, there are:

• Usage data
• Cookies
• Last name and first name
• Phone number
• Email

Detailed information on each type of data collected is provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to the collection of the data. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of the website. Unless otherwise specified, all Data requested by our website is mandatory for its proper functioning. If the User refuses to communicate them, it may be impossible to provide the website Service. In cases where our website indicates some Data as optional, Users are free to refrain from communicating such Data without any consequences on the availability of the Service or its operation. Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller. The possible use of Cookies – or other tracking tools – by our website or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through our website and guarantees to have the right to communicate or disseminate them, freeing the Data Controller from any responsibility towards third parties.

Methods and place of processing the collected Data

Martino & Partners adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties involved in the organization of our website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of processing

Martino & Partners as the Data Controller processes Personal Data relating to the User if one of the following conditions applies:

• The User has given consent for one or more specific purposes;

Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply when the processing of Personal Data is subject to European data protection legislation;

• The processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations thereof;
• The processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible to ask the Data Controller to clarify the specific legal basis of each processing and in particular to specify whether the processing is based on the law, required by a contract, or necessary to enter into a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section on details about the processing of Personal Data. The User has the right to obtain information about the legal basis of Data transfers outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as the UN, and about the security measures taken by the Data Controller to safeguard the Data. If any such transfer takes place, the User can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may retain Personal Data for longer until such consent is withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

Purposes of processing the collected Data

The Data concerning the User is collected to allow Martino & Partners to provide its Services, as well as for the following purposes: SPAM protection, Contacting the User, Interaction with social networks and external platforms, and Statistics. For specific information about the Personal Data used for each purpose, the User may refer to the section “Details about the processing of Personal Data”.

Details about the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

SPAM protection

This type of service analyzes the traffic of this website, potentially containing Users’ Personal Data, to filter it from parts of traffic, messages, and content that are recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc. The use of reCAPTCHA is subject to Google’s privacy policy and terms of use. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Contacting the User: Contact Form

By filling in the contact form with their Data, the User consents to its use to reply to requests for information, quotes, or any other kind indicated by the form header. Personal Data collected: last name, email, first name, and phone number.

Interaction with social networks and external platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of our website. The interaction and information obtained through our website are always subject to the User’s privacy settings for each social network. If a service enabling interaction with social networks is installed, it might still collect traffic data for the pages where the service is installed, even when Users do not use it.

LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Google Fonts

Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service.

Statistics

The services contained in this section enable the Data Controller to monitor and analyze web traffic

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, to compile reports on its activities, and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its advertising network. This integration of Google Analytics anonymizes your IP address. The anonymization works by shortening the IP address of the Users within the member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server and shortened within the United States. We use Google Analytics to analyze and regularly improve the use of our website, making the experience more pleasant for users. For the exceptional cases in which personal data is transferred to the USA, Google adheres to the Privacy Shield, https://www.privacy-shield.gov/EU-US-Framework. Your data will be processed within Google Analytics to protect the legitimate interests of Intervox. Third-party information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001. Terms of use: https://www.google.com/analytics/terms/it.html, Privacy Policy: http://google.com/intl/it/analytics/learn/privacy.html, and Privacy Policy: http://www.google.de/intl/it/policies/privacy.

Refusal to collect data

You can prevent the collection and transmission of data generated by your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=it Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Participant in the Privacy Shield.

User Rights

Users may exercise certain rights regarding their Data processed by the Data Controller. In particular, the User has the right to:

• Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.
• Object to the processing of their Data. The User can object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
• Access their Data. The User has the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. The User can verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Under certain circumstances, the User can restrict the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Under certain circumstances, the User can request the erasure of their Data by the Data Controller.
• Receive their Data and have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. The User can bring a claim before their competent data protection authority or take legal action.

Details about the right to object

When Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

How to exercise these rights

To exercise their rights, Users can direct a request to the contact details of the Data Controller provided in this document. Requests are made free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Additional information about Data Processing: Legal Defense

The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Data Controller may be required to reveal Personal Data upon request of public authorities.

 

Additional information about Data Processing: Specific Information

Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

Additional information about Data Processing: Information not contained in this policy

Further information related to the processing of Personal Data can be requested at any time from the Data Controller using the contact details provided.

Response to requests, “Do Not Track”

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor “Do Not Track” requests, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

Martino & Partners, as the Data Controller, reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, within this Application, as well as, if technically and legally feasible, by sending a notification to Users via any contact information available to the Data Controller. Therefore, it is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the legal basis of User consent, the Data Controller shall collect new consent from the User, where required.

Definitions and legal references: Personal Data (or Data)

Personal Data means any information that, directly or indirectly, even in connection with any other information, including a personal identification number, allows for the identification or identifiability of a natural person.

Definitions and legal references: Usage Data

Usage Data is information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the visitor, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device’s operating system and/or the User’s IT environment.

User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject: The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor):  The natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Data Controller, as described in this privacy policy.

Data Controller (or Owner):  The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

Our site:  The hardware or software tool by which the Personal Data of the Users is collected and processed.

Service: The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU):  Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie: Small piece of data stored in the User’s device.

Legal references: This privacy statement is prepared based on multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation). Unless otherwise stated, this privacy policy applies solely to this Application.

Newsletter Information

This information is provided by Martino & Partners S.r.l., in accordance with Article 13 of the EU Regulation no. 2016/679 (General Data Protection Regulation, hereinafter “GDPR”).

Identity and contact details of the data controller

The Data Controller is Martino & Partners S.r.l. (hereinafter “Martino & Partners S.r.l.”), with registered office in Rome, Via di Porta Pinciana 6, email: info@martinopartners.com.

Contact details of the DPO

Martino & Partners srl has appointed a Data Protection Officer (hereinafter “DPO”), who can be contacted at the following email address: privacy@martinopartners.com.

Purpose of the processing of personal data and legal basis of the processing

Personal data is processed based on the legitimate interest of Martino & Partners S.r.l., represented by the need to send stakeholders information about ongoing projects, activities, and initiatives organized throughout the year, in the interest of the recipients themselves.

In any case, if the recipient no longer wishes to receive communications from Martino & Partners S.r.l., they can always request to be removed from the mailing list either by using the “unsubscribe” function present in every communication sent or by making a request to info@martinopartners.com.

Possible recipients or categories of recipients of personal data

The processing of personal data will be carried out by the staff of Martino & Partners S.r.l., mainly through IT and telematic tools, with logic strictly related to the purposes, and in any case, in a way that ensures the confidentiality and security of personal data.

Some processing may also be carried out by the staff of companies connected and/or belonging to the Martino & Partners srl Group or by third parties to whom Martino & Partners S.r.l. entrusts certain activities for the purposes listed in the previous paragraph.

These entities will operate as data processors under Article 28 of the GDPR and will be given appropriate instructions, particularly regarding the adoption of security measures to ensure the confidentiality and security of the data. The complete and updated list of entities designated as data processors is available from Martino & Partners S.r.l. In any case, the data will not be disseminated.

Transfers abroad

Any transfer of personal data outside the European Union will only take place after the adoption of adequate safeguards as provided for by the GDPR.

Personal data retention period or criteria used to determine that period

The provided data will be retained solely for the period during which the service is active and, in any case, no longer than 24 months from the last interaction with the recipient, always subject to the right to object to further processing.

Data subject’s rights

The data subject can exercise a number of rights regarding their personal data. In particular, the GDPR grants the data subject the right to:

1. Request access to personal data, rectification of inaccurate data, and the completion of incomplete personal data;
2. Obtain the deletion of personal data, unless processing is necessary to comply with a legal obligation under national or European Union law or for the establishment, exercise, or defense of legal claims;
3. Obtain the restriction of processing in the cases provided for by Article 18 of the GDPR;
4. When processing is carried out by automated means and based on consent or necessary for the execution of contractual obligations, request data portability, i.e., receive their personal data in a structured, commonly used, and machine-readable format, and have the data transmitted to another controller without hindrance;
5. When processing is based on consent, withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;
6. Lodge a complaint with the competent data protection authority (e.g., in the Member State of their habitual residence, place of work, or place of the alleged infringement).

Martino & Partners S.r.l., as prescribed by the GDPR, undertakes to provide the data subject with information on actions taken concerning a request to exercise their rights without undue delay and, in any case, no later than one month from the receipt of the request.

Nature of providing personal data and consequences of failure to provide

The provision of personal data is naturally optional, with the understanding that, in the absence of such data, Martino & Partners S.r.l. will not be able to send its corporate information and updates.

Last update: September 12, 2023