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Privacy Notice for contest participants

pursuant to Art. 13 and 14 of Regulation (EU) 2016/679 – GDPR

1. Data Controller

Fondazione Altagamma, located in Via Monte Napoleone 9, 20121 Milan, Italy, represented by its Legal Representative pro tempore, is the Data Controller for the personal data of participants in Contests directly promoted by Fondazione Altagamma (hereinafter the “Controller”).
Contact: altagamma@altagamma.it

2. Source of Personal Data

The personal data processed are provided directly by the data subject upon participation in the Contest.

3. Categories of Data Processed

The Controller will process the following data, in accordance with the participation modalities set out in the Official Rules:

  • identification and biographical data (first name, last name, date of birth);
  • contact details (address, phone number, email);
  • any data contained in communications with the organizer;
  • images of the participant contained in photographs submitted via email to the Controller to complete participation in the Contest, which may also be used for promotional purposes as set out in point 4(g);
  • additional images or video recordings, only if requested by the Official Rules, subject to consent;
  • additional data required by the Official Rules.

4. Purposes of Processing and Legal Basis

Personal data are processed for the following purposes:

a) Contest management

Participation in the Contest, verification of eligibility requirements, selection of winners, award and delivery of prizes, management of communications with participants.
Legal basis: Art. 6(1)(b) GDPR – performance of a contract to which the data subject is party.

b) Management of in-store events

Transfer of the list of registered participants to the boutiques hosting the initiative’s events, for the sole purpose of managing and organising such events (attendance tracking). The boutiques are not authorised to use such data for any purpose other than those indicated above.
Legal basis: Art. 6(1)(b) GDPR – performance of a contract to which the data subject is party.

c) Compliance with legal obligations

Fulfilment of obligations under applicable regulations governing the Contest in the US and Italy, including tax, administrative and accounting requirements.
Legal basis: Art. 6(1)(c) GDPR – compliance with a legal obligation.

d) Handling of disputes, claims or legal proceedings

Legal basis: Art. 6(1)(f) GDPR – legitimate interest of the Controller.

e) Controller’s marketing

Sending of promotional communications, subject to express consent.
Legal basis: Art. 6(1)(a) GDPR – consent of the data subject.

f) Third-party marketing (Members and Partners of Fondazione Altagamma)

Transfer of personal data to the Members and Partners of Fondazione Altagamma – companies representing the excellence of Italian craftsmanship and creativity, listed at https://altagamma.it/members/ and https://altagamma.it/partners/ – so that they may send promotional communications regarding their products and services, acting as independent data controllers.
Legal basis: Art. 6(1)(a) GDPR – consent of the data subject.

g) Use of submitted photographs for promotional purposes

Photographs submitted by participants may be used by Fondazione Altagamma for promotional purposes related to the “Icons of Italy” initiative and Fondazione Altagamma’s activities, including on digital channels and editorial materials. By accepting the Official Rules, participants assign all rights to the submitted photographs and acknowledge their potential use for such purposes.
Legal basis: Art. 6(1)(b) GDPR – performance of a contract to which the data subject is party (acceptance of the Official Rules).

5. Processing Methods

Personal data are processed using both manual and electronic tools, in compliance with the principles of lawfulness, fairness, transparency, data minimisation and security set out in the GDPR. Appropriate technical and organisational measures are in place to ensure the security and confidentiality of the data.

The Contest landing page is hosted on the Fondazione Altagamma website. For information on the use of cookies and other tracking technologies on the website, please refer to the website Privacy Policy and Cookie Policy.

6. Communication and Recipients of Data

Personal data may be disclosed to:

  • third-party service providers instrumental to the management of the Contest (e.g. hosting providers, couriers, IT suppliers), appointed where necessary as Data Processors pursuant to Art. 28 GDPR or authorised to process data;
  • competent authorities, in fulfilment of legal obligations;
  • tax and legal advisors;
  • travel agencies/tour operators for prize delivery; IT companies and cloud providers;
  • the Members and Partners of Fondazione Altagamma – companies representing the excellence of Italian craftsmanship and creativity, listed at https://altagamma.it/members/ and https://altagamma.it/partners/ – acting as independent data controllers, solely where the data subject has given consent as referred to in point 4(f);
  • the boutiques hosting the events, for the sole purpose of attendance tracking, limited to participants who have registered via the online form.

An updated list of data recipients is available upon request by contacting the Controller at the details provided in point 1.

7. Disclosure of Data

Participants’ data will not be publicly disclosed.

8. Transfers to Third Countries

Data may be processed on servers located in third countries (e.g. the United States) through cloud services. In such cases, transfers will be carried out in compliance with Arts. 44 et seq. GDPR, with entities adhering to the EU-US Data Privacy Framework or through Standard Contractual Clauses (SCCs) approved by the European Commission.

The data of participants who have given consent as referred to in point 4(f) will also be transferred to the Members and Partners of Fondazione Altagamma – companies representing the excellence of Italian craftsmanship and creativity, listed at https://altagamma.it/members/ and https://altagamma.it/partners/ – which will process them as independent data controllers. Such transfer is based on the explicit consent of the data subject pursuant to Art. 49(1)(a) GDPR. Consent may be withdrawn at any time, without prejudice to the lawfulness of processing carried out prior to withdrawal.

9. Data Retention

Personal data are retained for the period necessary for the management of the Contest and, thereafter, for the period required by applicable law, including administrative and tax retention obligations. Data processed for marketing purposes will be retained until consent is withdrawn.

10. Nature of Data Provision

The provision of data is necessary to participate in the Contest and receive any prizes. Refusal to provide data will make participation impossible. Consent to processing for promotional purposes is optional and does not affect the right to participate in the Contest.

11. Data Subject Rights

The data subject may exercise at any time the rights provided under Arts. 15–22 GDPR, including:

  • right of access;
  • right to rectification;
  • right to erasure;
  • right to restriction of processing;
  • right to data portability;
  • right to object;
  • right to withdraw consent, where given.

Requests may be submitted to the Controller at the contact details provided in point 1. The data subject has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), which has jurisdiction over the Controller, pursuant to Art. 77 GDPR (Piazza Venezia 11, 00186 Rome – www.garanteprivacy.it – garante@gpdp.it).

12. Automated Decision-Making

The Controller does not carry out processing based on automated decision-making or profiling activities.

13. Updates to this Privacy Notice

This notice may be updated in the event of regulatory or organisational changes.

14. Website Privacy Policy and Cookie Policy

This notice applies specifically to the “Icons of Italy” Contest. For information on the processing of personal data carried out in the context of the Fondazione Altagamma website, as well as on the use of cookies and other tracking technologies, please refer to the website Privacy Policy and Cookie Policy.