Privacy Policy
Privacy Notice pursuant to Articles 13 and 14 of Regulation (EU) 2016/679
Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the “Regulation”), CAMINSCHI srl hereby provides its customers, including potential customers, as well as third parties in general (e.g., delegates, legal representatives, etc.) who come into contact with it on behalf of or under mandate from customers, including potential customers (the “Data Subjects”), with the information required by law regarding the processing of their personal data (“Personal Data”).
1. Data Controller and Data Protection Officer
MADALINA CAMINSCHI (tax code/VAT number 14577840961), with registered office at Via San Francesco d’Assisi, 15 – 20122 Milan (MI), Italy, represented by its legal representative pro tempore, is the entity that processes the Data Subjects’ data and, for legal purposes, is considered the Data Controller of the Personal Data.
In this capacity, it is responsible for ensuring the application of appropriate organizational and technical measures to protect personal data in compliance with applicable regulations.
MADALINA CAMINSCHI has appointed a Data Protection Officer (DPO) responsible for ensuring compliance with privacy protection regulations. The DPO can be contacted for matters relating to the processing of Personal Data at the following address: info@madalinacaminschi.com
2. Methods of Collecting Personal Data
The Personal Data processed by the Data Controller may be collected directly from the Data Subject, including through remote communication technologies used by the Controller (e.g., websites, smartphone and tablet applications, call centers, etc.).
3. Categories of Personal Data Processed
The Personal Data processed by the Data Controller may include, by way of example:
i. Browsing data (e.g., IP addresses or domain names of the computers used by users connecting to the website, request time, method used to submit the request to the server, the numerical code indicating the status of the response given by the server, and other parameters relating to the operating system and browser used by the user, logs);
ii. Identification data (e.g., first name, last name, tax code, address, date and place of birth, nationality);
iii. Contact data (e.g., landline and/or mobile phone numbers, email address);
iv. Profiling and marketing data (e.g., interests and preferences);
v. Other data attributable to the categories listed above.
4. Purposes and Legal Basis of Processing
Personal Data, where the relevant conditions apply, will be processed for the following purposes.
Website registration and management of contact requests and/or requests for information material
The processing of the Data Subject’s personal data is carried out to perform activities related to website registration, where applicable, and to manage requests for information, contact requests, and/or the sending of informational material, as well as to fulfill any related obligations.
The legal basis for this processing is the performance of services related to registration, information or contact requests and/or the sending of informational material, as well as compliance with legal obligations.
Providing data is optional; however, failure to provide the data will make it impossible for the Controller to fulfill the requested service.
Contract performance
Personal Data will be processed for the management of the contractual relationship (for example, billing services, payment management, or handling complaints submitted to us) and for the provision of services requested through the website.
The legal basis for this processing is the performance of contractual obligations and compliance with legal obligations.
Providing data is optional; however, refusal to provide such data will make it impossible for the Controller to provide the requested services.
Compliance with legal obligations, defense of rights, and fraud prevention
Personal Data will be processed to comply with legal obligations, as well as to establish, exercise, or defend a right of the Controller and/or to defend against claims by third parties, both in judicial and extrajudicial proceedings.
In particular, the Controller may process Personal Data to comply with accounting and tax obligations and to comply with orders issued by judicial authorities aimed at preventing and prosecuting crimes.
The legal basis for this processing is the legitimate interest of the Controller, balanced against the rights and freedoms of the Data Subject.
Promotional activities regarding services/products similar to those already purchased
Personal Data may be processed for the purpose of sending communications related to promotions and offers for services/products of the Controller that are identical or similar to those already purchased by the Data Subject, unless the Data Subject initially objected or objects to such processing in subsequent communications.
The legal basis for this processing is the legitimate interest of the Controller to promote products or services that may reasonably be of interest to the customer, taking into account the balance of rights between the Controller and the Data Subject.
The Data Subject has the right to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them for this purpose.
Promotional activities relating to services/products offered by CAMINSCHI srl
Personal Data will be processed, subject to specific consent, for the sending of promotional communications and offers regarding the Controller’s services/products through traditional methods (e.g., postal mail, telephone calls with an operator) and/or automated methods (e.g., email, SMS, MMS, fax, prerecorded calls).
The legal basis for this processing is the consent given by the Data Subject, which may be withdrawn freely at any time without affecting the lawfulness of processing carried out prior to the withdrawal.
Failure to provide consent will make it impossible to use the related services but will not affect the contractual relationship with the Controller.
Marketing relating to products or services of CAMINSCHI srl partners
Personal Data will be processed, subject to specific consent, for the sending of promotional communications and offers relating to services/products of MADALINA CAMINSCHI’s commercial partners, through traditional methods (e.g., postal mail, telephone calls with an operator) and/or automated methods (e.g., email, SMS, MMS, prerecorded calls).
The legal basis for this processing is the consent given by the Data Subject, which may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
Failure to provide consent will make it impossible to use the related services but will not affect the contractual relationship with the Controller.
Profiling
The processing of Personal Data, including location data and socio-demographic data acquired during the provision of electronic communication services and from public sources, may be carried out, subject to specific consent, for profiling purposes.
This includes analyzing transmitted data and purchased services/products in order to provide advertising messages and/or commercial proposals aligned with the preferences expressed by users.
This activity will be carried out in aggregated and anonymized form, through the implementation of models for analyzing customer data using statistical algorithms, predictive models, and aggregations only for the time strictly necessary for the purposes pursued.
In any case, Personal Data will not be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning the Data Subject or similarly significantly affect them.
The legal basis for this processing is the consent given by the Data Subject, which may be withdrawn at any time.
Failure to provide consent will make it impossible to use the related services but will not affect the contractual relationship with the Controller.
5. Recipients of Personal Data
The collected Personal Data may be communicated to entities acting as independent Data Controllers or Data Processors, depending on the circumstances, for the purposes described above and in compliance with legal obligations.
In particular, Personal Data may be made available to:
- parties responsible for carrying out activities related and instrumental to processing (archiving service providers, IT service providers, social media management companies, marketing companies, insurance companies, banking institutions);
- commercial partners of CAMINSCHI srl;
- public administrations, authorities, and other entities in compliance with legal obligations.
Personal Data will not be disclosed to the public.
6. Transfer of Data to Third Countries
Personal Data are stored in archives located within the European Union.
Where necessary to achieve the declared purposes, the Data Subject’s data may be transferred abroad to countries or organizations outside the European Union that guarantee an adequate level of protection as determined by the European Commission, or on the basis of other appropriate safeguards such as Standard Contractual Clauses adopted by the European Commission or the Data Subject’s consent.
The Data Subject has the right to obtain a copy of the data transferred abroad and the list of countries/organizations to which the data have been transferred by writing to:
7. Data Retention Period
Data will be stored in a form that allows identification of the Data Subject for a period not exceeding the time necessary to achieve the purposes for which they were collected, taking into account the laws applicable to the activities and sectors in which the Controller operates.
Once the retention period has expired, the data will be deleted or anonymized unless further retention is necessary to comply with obligations (e.g., tax and accounting obligations) that remain even after termination of the contract (Art. 2220 Italian Civil Code) or to comply with orders from public authorities and supervisory bodies.
The duration of cookies used on the website can be consulted in the Cookie Policy below.
In the event of litigation, the retention period may be extended up to 10 years after its resolution.
8. Processing Methods
Processing will be carried out by authorized personnel who need access to the data to perform their duties, using electronic tools and in accordance with principles of lawfulness and fairness, in order to safeguard the confidentiality and rights of the Data Subject in compliance with applicable legislation.
Profiling related to marketing (analysis of habits and consumption choices) is carried out through an automated process aimed at studying and analyzing behavioral profiles and characteristics of the customer base to optimize promotional activities for products and services.
9. Rights of the Data Subject
The Data Subject has the right to request from the Data Controller:
i. confirmation as to whether or not personal data concerning them is being processed and, if so, access to the data (right of access);
ii. correction of inaccurate personal data or completion of incomplete data (right to rectification);
iii. deletion of personal data where one of the conditions set out in the Privacy Regulation applies (right to erasure);
iv. restriction of processing where one of the cases provided by the Regulation applies (right to restriction);
v. to receive the personal data provided to the Controller in a structured, commonly used, and machine-readable format and to transmit those data to another controller (right to data portability);
vi. to object at any time, in whole or in part, to processing carried out for the legitimate interests of the Controller and for marketing or profiling purposes (right to object);
vii. to withdraw consent to the processing of personal data at any time, without affecting the lawfulness of processing based on consent before withdrawal.
Consent given for marketing activities using automated contact methods (e.g., SMS, MMS, fax, phone calls, email, web applications) also extends to traditional contact methods (postal mail or phone calls with an operator).
Similarly, opposition to marketing carried out through automated methods also extends to traditional methods. The Data Subject may still choose to consent or object to only one of the two methods.
To exercise their rights, the Data Subject may send an email to:
or send a written communication to the Data Controller at the registered office of CAMINSCHI srl.
The Data Subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or with the supervisory authority in the EU Member State where the alleged violation occurred, pursuant to Article 77 of the Regulation, and to seek judicial remedies pursuant to Articles 78 and 79 of the Regulation.
10. Cookies
Information regarding the use of cookies can be found at the following link: link