Privacy Policy

1. About us

This notice is made available to you by DEBORAH GROUP SRL with registered offices in Viale Solferino 7, 20121 Milan (Italy), in its capacity as the Data Controller of your personal data also pursuant to Article 13 of European Regulation 2016/679 on the protection of personal data (“Regulation” or “GDPR”) and Italian Legislative Decree 30/06/2003 no. 196 (“Privacy Code”), as amended and supplemented by Italian Legislative Decree no. 101/2018, and subsequent amendments and additions.
The purpose of this Information Notice is to inform you of the methods used to process your personal data.

2. Type of data processed

The website offers informative and occasionally also interactive content. When browsing, www.deboramilano.com may, therefore, acquire information about visitors in the following ways:

Browsing data

During normal operation, the IT systems and software used to operate this website acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols. This information includes: IP addresses, type of browser used, operating system, domain name and addresses of websites accessed or exited, pages visited, time accessed, time spent on each page, internal path analysis and other parameters relating to the user’s operating system and computer environment.

Additional data categories

Visitors may provide other categories of personal data through the website, such as:

  • by writing to e-mail addresses indicated on our website to request information (info@deborahgroup.com – contact us);
  • by filling in a form to receive our newsletter and marketing communications;

3. Purpose of processing

Data provided by visitors is processed for the following purposes:

  • to improve the user experience when browsing our platforms, products and services and to ensure the correct functioning of web pages and content. The processing of data for these purposes is necessary to pursue a legitimate interest of the Controller;
  • to send commercial communications on promotions and/or offers, in the interest of the Controller; processing for these purposes requires the specific consent of the user.

4. Sharing and transfer of personal data

Data collected by deboramilano.com is shared only for the above purposes; your personal data will not be shared with or transferred to third parties other than those indicated in this Privacy Policy.
In the course of our activities and exclusively for the purposes listed in this Privacy Policy, your personal data may be transferred to the following categories of recipients:

  • company staff;
  • service providers (e.g. IT system providers, cloud-based service providers, database providers and consultants);
  • Public Administrations as required by law;
  • any public and/or private entities to whom it may be necessary to communicate your personal data for any of the above-mentioned purposes.

The latest list of Data Processors is available at the registered offices of the Controller and will be provided upon written request.

deboramilano.com may be required to transfer your personal data to countries outside the European Union/European Common Area (EEA), to so-called “third countries”. Such transfers to third countries may include all of the data processing activities described above.
This Privacy Policy also applies to the transfer of data to third countries where the level of data protection is different from that of the European Union: personal data will only be transferred to third countries after informing you and, if required, receiving your consent. Any transfer of data to countries other than those for which the European Commission has taken an adequacy decision shall take place on the basis of agreements containing standard contractual clauses adopted by the European Commission or other appropriate safeguards in accordance with applicable law.

5. Protection of personal data

deboramilano.com has adopted appropriate technical and organisational measures to provide an adequate level of security and confidentiality for personal data.
These measures take into account:

  • state-of-the-art technology;
  • implementation costs;
  • the nature of the data;
  • data treatment risk.

The purpose of the aforesaid measures is to protect personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorised disclosure or access, and other unlawful forms of processing.
In addition, when managing your personal data, deboramilano.com:

  • collects and processes personal data that is adequate, relevant and limited to what is necessary to fulfil the above purposes, and
  • ensures that such personal data is kept up-to-date and accurate.

6. Data retention

Without prejudice to your right to object to the processing of your personal data and/or request its deletion, deboramilano.com will only retain your personal data for the time necessary to achieve the purpose for which it was collected and received, or to comply with legal or regulatory requirements.
When the data retention period expires, your personal data will be removed from deboramilano.com’s live systems.

7. Your legal rights

You have the following rights in relation to the personal data processed by deboramilano.com:

  • RIGHT TO RECTIFICATION. You can rectify personal data concerning yourself or communicated to us by you. deboramilano.com makes reasonable efforts to ensure that the personal data in its possession is accurate, complete, up-to-date and relevant, based on the most recent information available;
  • RIGHT TO RESTRICTION. You may restrict the processing of your personal data if:
    • the accuracy of the personal data in question is contested during the period in which deboramilano.com must verify such accuracy;
    • the processing is unlawful and you request the data processing to be restricted or your personal data to be deleted;
    • deboramilano.com no longer needs to keep your personal data but you need the data to ascertain, exercise or defend your rights in court; or
    • you object to the treatment while deboramilano.com is checking whether its legitimate motives prevail over yours.
  • RIGHT TO ACCESS. You may ask deboramilano.com for information on the personal data stored about you, including information on which categories of personal data deboramilano.com owns or controls, for what purpose the data is used, where it was collected (if not directly from you), and to whom the data may have been communicated;
  • RIGHT TO DATA PORTABILITY. At your request, deboramilano.com will transfer your personal data to another Data Controller, if technically possible, provided that the processing is subject to your consent or necessary for the fulfilment of a contract.
  • RIGHT TO ERASURE. You may ask deboramilano.com to erase your personal data if:
    • personal data is no longer required for the purposes for which it was collected or otherwise processed;
    • you are entitled to object to further processing of your personal data and exercise your right to object;
    • your personal data has been processed unlawfully.
      Unless the processing is necessary to satisfy legal or statutory obligations or to establish, exercise or defend legal claims.
  • RIGHT TO OBJECT. You may object to the processing of your personal data at any time, provided that the processing is not based on your consent but on the legitimate interests of deboramilano.com or of third parties. In such cases deboramilano.com will no longer process your personal data unless it can provide evidence of compelling legitimate reasons, an overriding interest in the processing or in the assessment, or the exercise or defence of a legal claim. Should you object to the processing of your personal data, please specify whether you wish to delete your personal data or to restrict its processing.
  • RIGHT TO LODGE A COMPLAINT. In the event of an alleged breach of applicable privacy laws, you may file a complaint with the competent authorities in your country or in the place where the alleged breach occurred.

8. Changes to this privacy policy

Any future changes or additions to the processing of personal data as described in this Privacy Policy will be notified through the usual communication channels utilised by deboramilano.com (e.g. through the website).

9. Data Controller and/or Data Protection Officer

To exercise your rights under Art. 15 et seq. of the GDPR, please contact the Data Controller, DEBORAH GROUP SRL with registered offices in Viale Solferino 7, 20121 Milan (MI). Tel +39 0371461400 E-mail privacypolicy@sodalisgroup.com

The Officer responsible for the protection of your personal data is Dr. Stefano Modena. E-mail stefano.modena@assiteca.it.