DIGITAL PRIVACY POLICY

The purpose of this document is to provide maximum transparency regarding the information and data collected through this website (the “Site”) and the way in which such information/data are processed. This document does not apply to information collected through channels other than those indicated.
This document describes how Ad Artem s.r.l. manages its websites and digital channels with respect to the processing of personal data relating to customers/users/visitors who access them.
For individual processing activities related to specific channels and/or activities, Ad Artem s.r.l. refers to the detailed information available on Ad Artem s.r.l website.

Privacy Policy
This document is made available to customers/users/visitors (“Data Subjects”) – also pursuant to Article 13 of the European Regulation 2016/679 on the protection of personal data (“Regulation” or “GDPR”), Legislative Decree 30/06/2003 no. 196 (“Privacy Code”), and subsequent amendments and integrations – by Ad Artem s.r.l., with its registered office and administrative office at Via Lanzone 13, Milan, tax code and VAT number 11033950152, in its capacity as Data Controller (“Controller”) of your personal data.
The purpose of this document is to provide maximum transparency to Data Subjects regarding the information collected through the website and the way such information/data are processed. This document does not apply to information collected through channels other than those indicated.

Types of Data Processed
The Site presents informative and interactive content to Data Subjects; therefore, during site navigation, Ad Artem s.r.l. may acquire information about the visitor, as described below:

Browsing Data
The IT systems and software procedures used to operate the Site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, type of browser used, operating system, domain name and addresses of websites from which access was made, information about the pages visited by users within the site, access time, time spent on each page, internal path analysis, and other parameters related to the user’s operating system and IT environment.

Additional Data
- In addition to the above, any personal data provided by the visitor through the Site are also processed, for example:
- by filling out a form to request a quote and/or information on the services offered and/or a contact request;
- by writing to the email addresses indicated on Ad Artem s.r.l. site to request information;
- by accessing a reserved area and/or a service;
- by filling out a form to submit their CV;
- by filling out a form to receive Ad Artem s.r.l. newsletter and marketing communications;
- by filling out a form to register for one of Ad Artem s.r.l. initiatives.

Purpose of Processing
The data provided are processed for the following purposes:
- To provide the requested service/performance, manage the contracts entered into with the Data Subject, fulfill administrative, accounting, tax, and legal obligations connected to the execution of the service and/or performance. These activities are necessary for the fulfillment of contractual obligations and do not require specific consent from the Data Subject.
- To monitor user experience on the platforms and services offered by Ad Artem s.r.l. and ensure the proper functioning of the web pages and their content. The processing carried out for this purpose is based on the Controller’s legitimate interest.
- To provide commercial and/or promotional information and/or for marketing activities, including sending advertising material related to services and/or activities of the Controller, through any means (telephone, email, SMS, social media, possibly also via specialized companies, etc.).
For these latter purposes, the processing of the Data Subject’s data is based on their specific consent.

Type of data processed and sharing or transfer of personal data
The data collected from the Data Subject are personal and not special (the “Data”).
- For the performance of Ad Artem s.r.l. activities and for the purposes indicated in this document, your Data may be transferred to the following recipients:
- company personnel (employees, collaborators, consultants, etc.);
- service providers supporting Ad Artem s.r.l. activities (e.g., IT suppliers, cloud service providers, database providers, consultants);
- Public Administrations for legal purposes or Tax Agencies;
- any other public and/or private entity to whom Data communication is necessary in relation to the purposes indicated above.
Ad Artem s.r.l. will not transfer Data to countries outside the European Union/European Economic Area (EEA), i.e., to so-called “third countries.” Such transfers to third countries may include all processing activities mentioned above.

Protection of personal data
Ad Artem s.r.l. has adopted and continuously implements adequate technical and organizational measures to ensure an appropriate level of security and confidentiality of the Data.
These measures take into account, among other things, the state of the art, implementation costs, the nature of the data, and the risks of processing.
The goal is to protect the Data from accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and other forms of unlawful processing.
Furthermore, when managing your personal data, Ad Artem s.r.l. (i) collects and processes Data that are adequate, relevant, and not excessive, as required to meet the purposes described above; and (ii) ensures that such personal data remain up-to-date and accurate.

Data retention period
- Ad Artem s.r.l. will retain Data only for the time necessary to achieve the purpose for which they were collected and received, or to comply with legal or regulatory requirements, without prejudice to the Data Subject’s right to object to data processing and/or request deletion.
- The retention period is determined by the time necessary for the use of the Data, as well as any additional period required to fulfill legal obligations.
- After this period, the Data Subject’s Data will be removed from Ad Artem s.r.l. active systems.

Data subject rights under applicable law
The rights of the Data Subject concerning the Data processed by Ad Artem s.r.l. are as follows:
- Right to rectification: The Data Subject may obtain the correction of their Data. Ad Artem s.r.l. takes all reasonable measures to ensure that the Data it holds are accurate, complete, up to date, and relevant, based on the most recent information available.
- Right to restriction: The Data Subject may obtain restriction of the processing of their personal Data where: (i) they contest the accuracy of the Data processed by Ad Artem s.r.l.; (ii) the processing is unlawful and the Data Subject requests restriction rather than deletion; (iii) Ad Artem s.r.l. no longer needs to process the Data of the Data Subject.
- Right of access: The Data Subject may request information from Ad Artem s.r.l. regarding the Data stored about them, including details on which categories of Data the Controller holds or controls, for what purpose they are used, where they were collected, and to whom they may have been disclosed.
- Right to data portability: Upon request by the Data Subject, Ad Artem s.r.l. will transfer the Data to another Controller, where technically possible, provided that the processing is based on the Data Subject’s consent or is necessary for the execution of a contract.
- Right to erasure: The Data Subject may obtain from Ad Artem s.r.l. the deletion of their personal data where: (i) the Data are no longer necessary for the purposes for which they were collected or otherwise processed; (ii) the Data Subject has the right to object to further processing and exercises this right; (iii) the Data have been unlawfully processed.
- Right to object: The Data Subject may object at any time to the processing of the Data; the Controller will refrain from further processing unless it demonstrates compelling legitimate grounds for processing that override the interests, rights, and freedoms of the Data Subject or for the establishment, exercise, or defense of legal claims.
- Right to lodge a complaint: In the event of a breach of current privacy laws, the Data Subject may lodge a complaint with the competent authorities.
The Data Subject’s rights may be limited where the Controller’s processing is necessary to comply with legal obligations or to establish, exercise, or defend a legal claim.

Changes to this Privacy Policy
Any future changes or additions to the processing of Data as described in this Privacy Policy will be notified through the usual communication channels used by Ad Artem s.r.l. (telephone, website, email, etc.).

Data controller and contact point
The Data Controller is Ad Artem s.r.l., headquartered at 20123, Milan, Via Lanzone, 13.
For any information regarding your Data or to exercise your rights, the Data Subject may contact the following email address: info (at) adartem.it