Privacy Policy

Guanxi with registered office at Via Francesco Cigna 96/17, 10155 Turin, Italy (hereinafter only "Guanxi"), in its capacity as Data Controller of personal data pursuant to Legislative Decree 196/2003 as amended - Personal Data Protection Code ("Privacy Code") - and EU Regulation 679/2016 applicable from 25 May 2018 - General Data Protection Regulation ("GDPR") (hereinafter referred to as the "Applicable Legislation"), recognises the importance of the protection of personal data and considers its protection one of the main objectives of its business.

Guanxi informs you that, for the execution of relations with its users, it collects data relating to them, acquired even verbally, directly or through third parties, qualified as "personal data" by the Applicable Legislation.

The latter provides that the data controller is obliged to inform the data subject of what data is being processed and of certain elements qualifying the processing, which, in any case, must be carried out fairly, lawfully, transparently, with purpose limitation and storage, data minimisation, accuracy, integrity and protecting the confidentiality, rights and freedoms of the data subject. 

Before disclosing any personal data, Guanxi invites you to carefully read this privacy policy ("Privacy Policy") which contains important information on the protection of personal data and the security measures taken to ensure confidentiality in full compliance with Applicable Law.

Furthermore, this Privacy Policy:

  • is intended as provided only for the site https://www.guanxi.it/it/ ("Site") and for the Campaign section https://campagna.guanxi.it/  ("Campaign") while it does not apply to other websites that may be consulted through external links;
  • is intended as Information provided pursuant to Article 13 of the Applicable Legislation to those who interact with the Site;
  • complies with Recommendation No. 2/2001 on minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Party.

Definitions and legal references

Personal Data (or Data)

Personal data is any information which, directly or indirectly, including in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.

Data Usage

This is the information collected automatically through this Application (including by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.). The country of origin, the characteristics of the browser and the operating system used by the visitor, the various temporal connotations of the visit (e.g. the time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, the parameters relating to the operating system and the User's IT environment.

User

The individual who uses this Application which, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refer.

Data Processor 

The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Controller, as set out in this privacy policy.

Data Controller 

The natural or legal person, public authority, service or other body that, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

The hardware or software tool through which Users' Personal Data are collected and processed.

Service

The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be deemed to include all the current member states of the European Union and the European Economic Area.

Cookie

Small piece of data stored within the User's device.

Legal references

This Privacy Policy is drafted on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy relates exclusively to this Application.

Index

Data Controller and Data Processor

Personal data subject to processing

Navigation data and Data provided voluntarily

Cookie Policy

Purpose, legal basis, mandatory or optional nature of processing

Recipients

Communication and dissemination

Data retention periods

Rights of the data subject

Amendments to the information notice

Copyright Contents

Further information on processing

1. Data Controller and Processor

In light of Applicable Law, the data controller of the Website is Guanxi with registered office at via Francesco Cigna 96/17, 10155 Turin, Italy. For any information relating to Guanxi's personal data processing, including the list of data processors, please write an email to: privacy@guanxi.it. 

2. Personal data subject to processing

Personal Data" shall mean 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 to one or more characteristic elements of that person's physical, physiological, mental, economic, cultural or social identity. The Personal Data collected by Guanxi is set out in section 3 of this privacy policy.

3. Navigation Data and Data provided voluntarily

The information systems of the Site and the Campaign collect certain Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature could, through processing and association with data held by third parties, allow you to be identified. Among these are the IP addresses or domain names of the devices used to connect you to the Site, the URI (Uniform Resource Identifier) 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 your operating system and computer environment. This data is used to obtain anonymous statistical information on the use of the Site and to check its correct functioning; to allow - given the architecture of the systems used - the correct provision of the various functions requested by you, for security reasons and to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Site or third parties, and is deleted after 7 days.

Data provided voluntarily: 

Through the Website you have the opportunity to voluntarily provide Personal Data such as your first name, last name and email address to subscribe to the newsletter service or to contact Guanxi through the forms. Guanxi will process this data in compliance with the Applicable Legislation, assuming that it relates to you or to third parties who have expressly authorised you to provide it on the basis of an appropriate legal basis legitimising the processing of this data. With respect to such hypotheses, you act as an autonomous data controller, assuming all the legal obligations and responsibilities. In this sense, you hereby grant Guanxi the widest possible indemnity in respect of any dispute, claim, request for compensation for damage caused by processing, etc. that may be received by Guanxi from third parties whose Personal Data has been processed through your use of the Website in violation of the Applicable Legislation. In the areas of the Site dedicated to user registration or certain services, there are specific disclosures that you should review before submitting your data.

4. Cookie Policy

Guanxi collects Personal Data through cookies.Cookies or other identifiers are portions of code placed on the User's device that assist the Owner in providing the Service in accordance with the purposes described. Please consult the relevant Cookie Policy page

5. Purpose, legal basis, mandatory or optional nature of processing

We care about your privacy and also about not sending you information that is not in line with what you are interested in. 

We hate spam as much as you do and we don't like services that are too invasive (a few extra e-mails may arrive in conjunction with the downloading of some ebooks, because we use software that sends e-mails according to your behaviour, HubSpot, and it may happen that some action in sequence sends you one or two extra e-mails). But our communications are related to the number of documents you download, the pages you see and, sometimes, the need for a salesperson to contact you if they think you might be interested in our offer.

This is precisely why Guanxi needs your information. 

We collect it through the forms on almost every page of our site so that we can send you useful information from time to time (new ebooks on related topics or as relevant as possible to what you have seen or downloaded), so that you can subscribe to our monthly newsletter with the latest blog posts on the topics that interest you, and so that we can eventually contact you directly about products or services that we offer, but never in bulk.

In order to grow our company, employing more and more people, we need to find other companies that might need our services. To do this, we adopt the inbound methodology: we present and offer content on our site that we think is useful to our potential customer, to get them to give us their contact details in exchange for access to this valuable content (or for requests for more information). And from there, the contact is fed with other useful information thanks to 'workflows' that send out emails analysing personal data and behaviour.

When you fill out the form, we use cookies that keep track of your browsing (we know which pages are viewed by our users), to find out what topics you are interested in and to be able to align our offer to your interests.

In this way, we then try to understand which contacts could be potential customers: if you fill in a form on our site you could be among them!

You can unsubscribe from our communications at any time. On any marketing email you receive from us, you can click on the link to unsubscribe from our communications or to manage your communication preferences.

As explained above, we always strive to protect and respect your privacy, just as we try never to be intrusive when proposing new content or marketing offers. In short, we will only ever try to get in touch if there is any interest on your part. 

And if not... let us know!

For all intents and purposes, for us the form you fill out is a kind of 'access to service': you become our 'customer' for information material, and we will treat you as such, avoiding mass offers to update products or to propose new services to you. More than 90% of our communications, for those who download forms, are intended to deepen content and to distribute and disseminate culture within the scope of the interest we infer from browsing.

Although we remind you that you can unsubscribe from any type of communication directly from every email you receive, our aim is not to send you spam and continuous advertising: we try to keep a relational contact with you by 'talking' about topics that may interest you. In this way we try to increase our brand awareness and that you think of us when you need the services we provide.

We are not infallible! This means that we may sometimes send you emails with material that is not 100% relevant to your interests. We apologise for this, but the system, as you can imagine, is automated and, no matter how hard we try to keep our communications 'relevant' to your interests, the magic doesn't always work. If it does... help us grow!

Attention: it costs us to produce content (blog or e-learning or ebook).

It costs in terms of man-hours and experience put on the counter 'for free'.

Our aim, as you will have understood, is to sell our services to companies. So the communications we send you are - while respecting your privacy and trying to align ourselves with what you are interested in - an attempt to build your loyalty, to keep you close, to talk to you... so that we can sell what we offer your company when it needs it.

Guanxi Data Processors

The Data Processors (i.e. the people in charge of data management) at Guanxi, are just the employees and operating partners who keep the CRM up to date and running. 

Data Processor is also HubSpot, the SaaS software we use as CRM for data management and processing. HubSpot's servers are located in the United States, and HubSpot inc. adheres to EU guidelines on transferring data outside the European Union.

For quoting, another data processor used by Guanxi is PandaDoc, software that allows easy quoting using pre-set templates. 

Unsubscribing from Guanxi communications

To unsubscribe from receiving communications from Guanxi, Users may address a request to the Holder's contact details indicated in this document.

Requests are filed free of charge and processed by the Owner as soon as possible, in any case no later than one month after receipt.

You may also proceed to modify and unsubscribe from communications to which you are subscribed by clicking on the footer of our emails.

The Personal Data you provide through the Website will be processed by Guanxi for the following purposes:

  1. a) purposes inherent to the performance of a contract to which you are party or to the performance of pre-contractual measures taken at your request (e.g.: request for contact via the Contact form, registration to the newsletter service, access to expressly requested training content, etc.);
  2. b) purposes of statistical research/analysis on aggregate or anonymous data, without therefore the possibility of identifying the user, aimed at measuring the operation of the Site and the performance of users on training courses, measuring traffic and assessing usability and interest
  3. c) purposes relating to the fulfilment of a legal obligation to which Guanxi is subject;
  4. d) purposes necessary to establish, exercise or defend a right in court or whenever the courts exercise their jurisdictional functions;

The lawful basis for the processing of Personal Data for the purposes set out in point a) is the provision of a service or response to a request that does not require consent under Applicable law.

The purpose referred to in point b) does not involve the processing of Personal Data, whereas the purpose referred to in point d) is a lawful processing of Personal Data within the meaning of Applicable law since, once Personal Data is 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 it may make it impossible to respond to your request or fulfil a legal obligation to which Guanxi is subject.

6. Recipients

Your Personal Information may be shared, for the purposes specified in paragraph 3, with

  • persons necessary for the provision of the services offered by the Website including but not limited to the sending of e-mails and the analysis of the operation of the Website who typically act as data processors of Guanxi;
  • persons authorised by Guanxi to process Personal Data who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality; (e.g. employees and contractors of Guanxi); (a. and b. are collectively "Recipients")
  • judicial authorities in the exercise of their functions when required by Applicable law.

7. Communication and dissemination

The data we collect from our members are not disclosed to unspecified persons in any way, including by making them available or consulting them.

On the other hand, the personal data of the data subject may be "communicated" by us, by which term is meant the disclosure of such data to one or more specific persons also by making them available or consulting them, in the following terms:

  • to subjects entrusted within our Structure with the processing of data, and in particular to the employees of the Administration Office,
  • to subjects who can access the data by virtue of a provision of law, or EU regulations, within the limits provided for by law
  • to subjects who need access to the data for purposes auxiliary to the existing relationship, within the limits strictly necessary to carry out the auxiliary tasks entrusted to them (e.g. credit institutions and forwarding agents)
  • to our consultants, to the extent necessary to carry out their duties with us, subject to our letter of appointment imposing a duty of confidentiality and security in the processing of data
  • to other external parties in their capacity as organisers, partners and sponsors in institutional activities relating to courses, meetings, congresses, and any other event to which the data subject participates through Guanxi.

8. Data retention periods

Guanxi will process your Personal Data for the time strictly necessary to achieve the purposes set out in paragraph 3. By way of example, Guanxi will retain your Personal Information for the Guanxi newsletter service until you decide to unsubscribe from the service. Notwithstanding the foregoing, Guanxi will retain your Personal Information for as long as permitted by Italian law to protect its interests (Art. 2947 paragraphs 1 and 3 of the Italian Civil Code). More information about the retention period of your Personal Data and the criteria used to determine this period may be requested by writing to the Data Controller.

9. Rights of the data subject

Within the limits of the Applicable Legislation, you have the right to request from Guanxi, at any time, access to your Personal Data, its rectification or deletion or to object to its processing, the restriction of its processing as well as to obtain in a structured, commonly used and machine-readable format the data concerning you. Requests should be addressed by e-mail to: privacy@guanxi.it In accordance with the Applicable Legislation, you have in any event the right to lodge a complaint with the Personal Data Protection Authority if you consider that the processing of your Personal Data is contrary to the Applicable Legislation.

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

  • Withdraw consent at any time. The User may revoke the consent to the processing of its Personal Data previously expressed.
  • Object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are set out in the section below.
  • Access to your Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • Verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
  • Obtain the restriction of processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • Obtain the deletion or removal of your Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
  • Receive their Data or have them transferred to another Data Controller (portability). The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, on a contract to which the User is party or on contractual measures related thereto.
  • Proposing a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
  • Details of the right to object:When Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they may object to the processing without giving any reason. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise rights: To exercise their rights, Users may address a request to the Controller's contact details indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.

10. Changes to the Policy

This Privacy Policy is effective as of 1 March 2020. Guanxi reserves the right to change or simply update its content, in part or in full, including due to changes in Applicable Law. Guanxi will inform you of such changes as soon as they are introduced and will be binding as soon as they are published on the Website. Guanxi therefore invites you to visit this section regularly to be aware of the most recent and updated version of the Privacy Policy so that you are up to date on the data collected and its use.

11. Copyright

This section provides a policy for the treatment of content on www.guanxi.it. The content of this blog is protected by a Creative Commons "Attribution-NonCommercial-ShareAlike 2.5 Italy" licence.

You may reproduce, distribute, communicate to the public, publicly display, perform, and even modify this work on the condition that you attribute the authorship of the work by expressly mentioning the author and including the direct link to the original content page. You may not use this work for commercial purposes and you must share the work you are using in the same manner. For more information and for the full licence: "Attribution-NonCommercial-ShareAlike 2.5 Italy".

Contents: The contents on the site and in the Campaign area do not represent a newspaper because they are not updated periodically. They cannot therefore be considered an editorial product within the meaning of law no. 62/2001.

The Authors and Guanxi are not responsible for what is published by readers in the comments to each post. Comments considered offensive or damaging to the image or honour of third parties, spam, racist or containing personal data that do not comply with Applicable Law will be deleted. They are also not responsible for the content of linked sites, which may be subject to change over time.

  • Further information on processing

Legal defence

The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory phases of such proceedings to defend against abuses in the use of this Application or related Services by the User. The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

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.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and that may also contain Personal Data, such as the User's IP address.

Legal defence

The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of legal proceedings to defend against abuses in the use of this Application or related Services by the User. The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific Disclosure

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 disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and that may also contain Personal Data, such as the User's IP address.