Guanxi, with its registered office at Viale Nuvoli 58/4, 10098 Rivoli (TO), Italy (hereinafter referred to as “Guanxi”), as the Data Controller pursuant to Legislative Decree 196/2003 and subsequent amendments — Personal Data Protection Code (“Privacy Code”) — and Regulation (EU) 2016/679 applicable since May 25, 2018 — General Data Protection Regulation (“GDPR”) (hereinafter collectively referred to as the “Applicable Legislation”) — acknowledges the importance of personal data protection and considers its safeguarding one of the main objectives of its activities.
Guanxi informs that, for the execution of relationships with its users, it collects data related to them, acquired verbally, directly, or through third parties, classified as “personal data” under the Applicable Legislation.
The latter provides that the Data Controller is required to inform the data subject about which data are being processed and certain key aspects of the processing, which must in any case be carried out with fairness, lawfulness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, while safeguarding the confidentiality, rights, and freedoms of the data subject.
Before providing any personal data, Guanxi invites you to carefully read this privacy policy (“Privacy Policy”), which contains important information about the protection of personal data and the security measures adopted to ensure confidentiality in full compliance with the Applicable Legislation.
This Privacy Policy also:
- It applies solely to the website https://www.guanxi.it/it/ (the “Site”) and to the campaign section https://campagna.guanxi.it/ (the “Campaign”) and does not apply to other websites that may be accessed via external links;
- It is intended as the Information Notice provided pursuant to Article 13 of the Applicable Legislation to those interacting with the Site;
- It complies with Recommendation No. 2/2001 concerning the minimum requirements for online data collection within the European Union, adopted on May 17, 2001, by the Article 29 Working Party.
Definitions and Legal References
Personal Data (or Data)
Personal data means any information that directly or indirectly, including in connection with any other information—such as a personal identification number—identifies or can identify a natural person.
Usage Data
Usage Data refers to information collected automatically through this Application (including third-party applications integrated into this Application), such as: IP addresses or domain names of the computers used by the User connecting to this Application; URI (Uniform Resource Identifier) addresses; 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 server’s response status (success, error, etc.); the country of origin; characteristics of the browser and operating system used by the visitor; various timing details of the visit (e.g., the time spent on each page); and details about the path followed within the Application, particularly the sequence of pages visited, as well as parameters related to the User’s operating system and IT environment.
User
The individual who uses this Application and, unless otherwise specified, is the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural person, legal entity, public administration, or any other body that processes personal data on behalf of the Data Controller, as described in this privacy policy.
Data Controller (or Controller)
The natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing personal data, including the security measures related to the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.
This Application
The hardware or software tool through which the Users’ Personal Data are collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this website/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document is intended to include all current member states of the European Union and the European Economic Area.
Cookie
A small piece of data stored on the User’s device.
Legal References
This privacy notice is drafted based on multiple legal frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy notice applies exclusively to this Application.
Index
- Data Controller and Data Processor
- Personal Data Subject to Processing
- Browsing Data and Voluntarily Provided Data
- Cookie Policy
- Purpose, Legal Basis, and Mandatory or Optional Nature of the Processing
- Recipients
- Communication and Disclosure
- Data Retention Periods
- Data Subject’s Rights
- Changes to the Privacy Policy
- Content Copyright
- Additional Information on Processing
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Data Controller and Data Processor
We inform you that GUANXI S.r.l., headquartered at Viale Nuvoli No. 58/4, 10098 Rivoli (TO), VAT number 10366830015, represented by its pro-tempore legal representative, is the Data Controller of your personal data pursuant to EU Regulation 2016/679.
The Data Protection Officer is Attorney Enrico Sinigaglia, phone: +39 049 79845411, email: dpo@guanxi.it.
Personal Data Subject to Processing
“Personal Data” means any information relating to an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to their physical, physiological, mental, economic, cultural, or social identity. The Personal Data collected by Guanxi are detailed in section 3 of this privacy policy.
The IT systems of the Site and the Campaign collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. These are pieces of information not collected to be associated with you personally but which, by their very nature, could—through processing and association with data held by third parties—allow your identification. Such data include IP addresses or domain names of the devices used to connect to the Site; URI (Uniform Resource Identifier) addresses of the requested resources; 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 server’s response (success, error, etc.); and other parameters related to your operating system and IT environment. This data is used to derive anonymous statistical information about the use of the Site and to ensure its proper functioning; to allow—given the architecture of the systems used—the correct delivery of the various functions you request; for security reasons and to ascertain liability in case of hypothetical cybercrimes against the Site or third parties. These data are deleted after 7 days.
Voluntarily Provided Data:
Through the Site, you have the opportunity to voluntarily provide Personal Data such as your name, surname, and email address to subscribe to the newsletter service or to contact Guanxi through the forms. Guanxi will process these data in accordance with the Applicable Legislation, assuming that they refer to you or to third parties who have expressly authorized you to provide them based on an appropriate legal basis that justifies the processing of the data in question. In such cases, you act as an independent Data Controller, assuming all legal obligations and responsibilities. In this regard, you provide the broadest indemnity against any disputes, claims, or requests for compensation for damages from processing, etc., that may be received by Guanxi from third parties whose Personal Data has been processed through your use of the Site in violation of the Applicable Legislation. Specific information is provided in the areas of the site dedicated to user registration or certain services, which the user must review before submitting their data.
Guanxi collects Personal Data through cookies. Cookies or other identifiers are pieces of code placed on the User’s device that assist the Data Controller in delivering the Service for the purposes described. Please refer to the dedicated Cookie Policy page for more information.
Purpose, Legal Basis, and Mandatory or Optional Nature of the Processing
We care about your privacy and also about not sending you information that is not in line with your interests.
We hate spam as much as you do and we’re not fans of overly invasive services (you might receive an extra email or two when downloading an eBook, as we use a software—HubSpot—that sends emails based on your actions. So, sometimes a sequence of actions could trigger one or two additional emails). However, our communications are tied to the number of documents you download, the pages you view, and sometimes to a sales representative reaching out if they think you might be interested in our offer.
That’s why Guanxi needs your information.
We collect them through the forms scattered across almost every page of our site, in order to send you occasional useful information (new eBooks on related topics or as relevant as possible to what you’ve viewed or downloaded), to subscribe you to the monthly newsletter with the latest blog posts on topics that interest you, and to potentially contact you directly about products or services we offer, but never in a mass manner.
In order to grow our company and provide jobs for more people, we need to find other businesses that could benefit from our services. To do this, we adopt the inbound methodology: we present and offer content on our site that we believe is useful to our potential clients, asking for their contact information in exchange for access to this valuable content (or for further information requests). From there, the contact is nurtured with more useful information through “workflows” that send emails based on demographic data and behavior analysis.
When you fill out the form, we use cookies that track your navigation (we know which pages our users view) to discover which topics interest you and to align our offering with your interests.
In this way, we then try to identify which contacts might be potential customers: if you fill out a form on our site, you could be one of them!
You can unsubscribe from our communications at any time. On any marketing email you receive from us, you can click the link to unsubscribe or manage your communication preferences.
As explained earlier, we are always committed to protecting and respecting your privacy, just as we strive to never be invasive when offering new content or marketing offers. In short, we’ll only reach out to you if we believe there’s genuine interest on your part.
And if we’re not… let us know!
For all these reasons, the form you fill out is, for us, a sort of “access to the service”: you become our “client” for informational material, and we will treat you as such, avoiding mass offers for product updates or new services. More than 90% of our communications, for those who fill out forms, are aimed at deepening content and spreading knowledge within the area of interest we infer from your navigation.
Even though we remind you that you can unsubscribe from any type of communication directly from any email you receive, our goal is not to send you spam or continuous advertising: we aim to maintain a relational contact with you, “talking” about topics that might interest you. In this way, we try to increase the awareness of our brand, so that you think of us when you need the services we offer.
We’re not perfect! This means that sometimes we might send you emails with content that isn’t 100% relevant to your interests. We apologize for that, but as you can imagine, the system is automated, and while we do everything we can to keep our communications “relevant” to your interests, the magic doesn’t always work. If that happens… help us grow!
ATTENTION: Producing content (blog posts, e-learning materials, or ebooks) COSTS us.
It costs us in terms of work hours and the expertise shared “for free”.
Our goal, as you may have understood, is to sell our services to businesses. Therefore, the communications we send you are—while respecting your privacy and trying to align with your interests—a way to build loyalty, keep you close, and engage with you… so that we can offer what we provide to your company when it needs it.
- Data Processor of Guanxi
The Data Processors (i.e., the individuals responsible for managing the data) at Guanxi are solely the employees and operational partners who are responsible for keeping the CRM updated and functioning.
The Data Processor also includes HubSpot, the SaaS software we use as our CRM for data management and processing. HubSpot’s servers are located in the United States, and HubSpot Inc. complies with the EU guidelines regarding data transfer outside the European Union.
To create quotes, another Data Processor used by Guanxi is PandaDoc, a software that enables easy quotation through pre-set templates.
- Unsubscribe from Guanxi Communications
To stop receiving communications from Guanxi, Users can send a request to the contact details of the Data Controller provided in this document.
Requests are submitted free of charge and are processed by the Data Controller as quickly as possible, in any case within one month from the receipt.
Users can also modify or unsubscribe from communications by clicking the “unsubscribe” link in the footer of our emails.
The Personal Data you provide through the Website will be processed by Guanxi for the following purposes:
a) Purposes related to the performance of a contract to which you are a party or to the execution of pre-contractual measures taken at your request (e.g., contact request via the Contact form, subscription to the newsletter service, access to expressly requested training content, etc.).
b) Purposes of research/statistical analysis on aggregated or anonymous data, therefore without the possibility of identifying the user, aimed at measuring the functioning of the Site and user performance on training paths, measuring traffic, and evaluating usability and interest.
c) Purposes related to the fulfillment of a legal obligation to which Guanxi is subject.
- d) Purposes necessary to ascertain, exercise, or defend a right in judicial proceedings or whenever judicial authorities exercise their jurisdictional functions.
The legal basis for the processing of Personal Data for the purposes referred to in point a) is the provision of a service or the response to a request that does not require consent pursuant to the Applicable Legislation.
The purpose referred to in point b) does not involve the processing of Personal Data, whereas the purpose referred to in point d) represents a legitimate processing of Personal Data pursuant to the Applicable Legislation since, once the Personal Data are provided, the processing is indeed necessary to comply with a legal obligation to which Guanxi is subject.
The provision of your Personal Data for the purposes listed above is optional, but failure to provide them may make it impossible to respond to your request or to comply with a legal obligation to which Guanxi is subject.
Recipients
Your Personal Data may be shared, for the purposes specified in point 3, with:
- Entities necessary for the provision of the services offered by the Site, including by way of example the sending of emails and the analysis of the Site’s performance, which typically act as data processors on behalf of Guanxi.
- Persons authorized by Guanxi to process Personal Data who have committed to confidentiality or are subject to an adequate legal obligation of confidentiality (e.g., employees and collaborators of Guanxi); (a. and b. are collectively referred to as “Recipients”).
- Judicial authorities in the exercise of their functions when required by the Applicable Legislation.
Communication and Disclosure
The data we collect from our subscribers are not disclosed to unspecified parties in any way, including by making them available or accessible.
The data subject’s personal data may instead be “communicated” by us, with this term meaning the disclosure to one or more specific parties, including by making the data available or accessible, under the following terms:
- To persons within our Organization appointed to process the data, in particular the staff of the Administration Office.
- To persons who may access the data by virtue of legal provisions or EU regulations, within the limits established by law.
- To persons who need access to the data for purposes auxiliary to the existing relationship, strictly limited to what is necessary to perform the auxiliary tasks assigned to them (e.g., credit institutions and shipping companies).
- To our consultants, within the limits necessary to carry out their assignment with us, subject to our letter of engagement imposing the duty of confidentiality and data security;
- To other external parties in their capacity as organizers, partners, and sponsors of institutional activities related to courses, meetings, congresses, and any other event attended by the data subject through Guanxi.
Data Retention Periods
Guanxi will process your Personal Data for the time strictly necessary to achieve the purposes indicated in point 3. By way of example, Guanxi will process Personal Data for the Guanxi newsletter service until you decide to unsubscribe from the service. Without prejudice to the above, Guanxi will process your Personal Data for the period allowed by Italian law to protect its own interests (Art. 2947 paragraphs 1 and 3 of the Civil Code). More information regarding the retention period of Personal Data and the criteria used to determine such period can be requested by contacting the Data Controller.
Data Subject’s Rights
Within the limits of the Applicable Legislation, you have the right to request from Guanxi, at any time, access to your Personal Data, the rectification or deletion of such data, objection to their processing, restriction of processing, as well as to obtain the data concerning you in a structured, commonly used, and machine-readable format. Requests should be sent via email to: privacy@guanxi.it.
Pursuant to the Applicable Legislation, the data subject also has the right to lodge a complaint with the Data Protection Authority if they believe that the processing of their Personal Data violates the Applicable Legislation.
Users may exercise certain rights regarding the Data processed by the Data Controller. In particular, the User has the right to:
- Withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously given.
- Object to the processing of their Data. The User may object to the processing of their Data when it is based on a legal ground 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 obtain information about the Data processed by the Data Controller, specific aspects of the processing, and to receive a copy of the processed Data.
- Verify and request rectification. The User may verify the accuracy of their Data and request its updating or correction.
- Obtain restriction of processing. When certain conditions apply, the User may request the restriction of processing of their Data. In such cases, the Data Controller will not process the Data for any purpose other than storage.
- Obtain deletion or removal of their Personal Data. When certain conditions apply, the User may request the deletion of their Data by the Data Controller.
- Receive their Data or have it transferred to another controller (portability). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on related contractual measures.
- Lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or seek judicial remedy.
Details on the right to object: when Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are informed that, if their Data is processed for direct marketing purposes, they may object to the processing without providing any reason. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.
How to exercise rights: To exercise their rights, Users may send a request to the contact details of the Data Controller provided in this document. Requests are made free of charge and will be processed by the Data Controller as soon as possible, in any case within one month.
Changes to the Privacy Policy
This Privacy Policy has been in effect since March 1, 2020. Guanxi reserves the right to modify or simply update its content, in whole or in part, also due to changes in the Applicable Legislation. Guanxi will inform about such changes as soon as they are introduced, and they will become binding once published on the Site. Guanxi therefore encourages users to regularly visit this section to review the most recent and updated version of the Privacy Policy in order to stay informed about the data collected and its use.
Content Copyright
This section provides information on the processing of the content present on the website www.guanxi.it. The content of this blog is protected by a Creative Commons license ‘Attribution-NonCommercial-ShareAlike 2.5 Italy’.
You may reproduce, distribute, communicate to the public, publicly display, perform, represent, and recite this work, as well as modify it, provided that you give proper attribution to the author by expressly citing them and including a direct link to the original content page. You may not use this work for commercial purposes, and you must share any derivative works under the same license. For more information and the full license text: ‘Attribution-NonCommercial-ShareAlike 2.5 Italy’.
Content: the content present on the website and in the Campaign area does not constitute a newspaper or periodical publication because it is not updated regularly. Therefore, it cannot be considered editorial product pursuant to Law No. 62/2001.
The Authors and Guanxi are not responsible for content posted by readers in the comments on each post. Comments deemed offensive or harmful to the image or reputation of third parties, spam, racist, or containing personal data not compliant with the Applicable Legislation will be deleted. They are also not responsible for the content of websites linked through external links, which may change over time.
Additional Information on Processing
Legal defense
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory phases for their possible initiation to defend against abuses in the use of this Application or related Services by the User. The User acknowledges that the Data Controller may be required to disclose the Data by order of public authorities.
Specific notices
Upon User request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operational and maintenance needs, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.
Information not included in this policy
Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the provided contact details.
Response to ‘Do Not Track’ requests
This Application does not support ‘Do Not Track’ requests.
To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.
Changes to this Privacy Policy
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, on this Application, as well as, where technically and legally feasible, by sending a notification to Users through one of the contact details they have provided. Users are therefore advised to frequently review this page, referring to the date of the last modification indicated at the bottom.
If the changes affect processing activities based on consent, the Data Controller will collect the User’s consent again, if necessary.