Newsletter policy statement

1. Data Controller and Data Protection Officer

The Data Controller is Ersel Banca Privata S.p.A., with registered office in Piazza Solferino, 11 - 10121 Turin, in the person of its legal representative pro tempore (hereinafter “Ersel” or the “Data Controller”).

To exercise your rights, listed in Article 6 below, as well as for any other request relating to them and/or to this Policy, you may contact the Data Controller at the following addresses:

• telephone: +39 011 5520111 
• email: privacy@ersel.it

The Data Controller has appointed a Data Protection Officer ("DPO") pursuant to Article 37 of the GDPR, whom you may contact to exercise your rights and receive any other information relating to your rights and/or this Policy, by writing to dpo@ersel.it.

2. Personal data processed, purposes of processing and legal basis

The Data Controller will process your personal identification and contact data (such as first name, last name and e-mail address) directly provided by you by filling in the appropriate data collection forms in the dedicated areas on the Data Controller's website.

Your personal data will be processed for the following purposes: 

(a) sending, by e-mail, Ersel's newsletter; the legal basis for this purpose is the execution of a request by the data subject pursuant to Article 6(1)(b) of the GDPR;

(b) promotion and sales activities for the services and products of the Data Controller and/or of the companies in the Data Controller's Group, including by invitations to events or market research by means of manual (e.g. telephone contact, paper mail, e-mail, etc.) or automated means of contact (e.g. automated e-mail campaigns, SMS, automated telephone contact, instant messaging, etc.); the legal basis for the processing of the data is the provision of your consent, pursuant to Article 6(1)(a) of the GDPR;

(c) promotion and sale of “dedicated” products and services of the Data Controller and/or of the companies of the Data Controller's Group, specifically identified through customer profiling techniques aimed at analysing and forecasting information relating to your preferences, habits, consumption choices, including through the use of automated techniques or systems, also implemented through the enrichment of data with information acquired from third parties (enrichment). The legal basis for this purpose is your consent pursuant to Article 6(1)(a) of the GDPR.

3. Nature of data provision, data retention period and processing methods

For the purpose referred to in Article 3 (a) above, the provision of your personal data is mandatory; your refusal to provide such data will make it impossible for the Data Controller to deliver Ersel's newsletter to you. 

With reference to the purposes set forth in Article 3 (b) and (c) above, the provision of your personal data is optional and your refusal to provide them would not affect your subscription to Ersel's Newsletter, but would only make it impossible for the Data Controller to keep you up-to-date on its products, services and/or initiatives or to develop promotional initiatives for you that are more in line with your profile.

The retention period of your personal data:

• for the purposes referred to in Article 3(a) above, will last until you unsubscribe from the Newsletter service;
• for the purposes set out in Article 3 (b) and (c) above, will last 2 years from the date of issue of the relevant consent or until you decide to revoke your consent;

Processing is carried out in compliance with the requirements of the GDPR, according to the principles of fairness, lawfulness and transparency and the protection of your rights as described therein. The personal data shall be processed through the use of electronic, telematic and paper media, subject to security measures suited to ensuring the privacy of the personal data and preventing undue access by unauthorised entities. 

The Data Controller shall not carry out any automated decision-making processes on your personal data, including profiling as referred to in Article 22(1) and (4) of the GDPR.

4. Disclosure of data

For the pursuit of the purposes described in Article 3 above, the personal data processed will be known to the employees, assimilated personnel and contractors of the Data Controller, who will act as authorised entities for the processing of personal data. 

Furthermore, your personal data may be processed by third parties belonging, by way of example, to the following categories:

• service providers for the management of IT systems;
• providers of external telematic platforms for sending communications;
• advertising agencies or other service providers;
• companies belonging to the Group to which the Data Controller belongs, for the performance of instrumental activities connected with or supporting that of the Data Controller.

The entities belonging to the above-mentioned categories operate, in some cases, as data controllers specifically appointed by the Data Controller in compliance with Article 28 of the GDPR, and in other cases completely autonomously as separate data controllers, it being understood that, in the latter case, the communication of your personal data to such autonomous data controllers would take place solely to pursue the purposes set out in Article 3 above.

The complete and updated list of the entities to which your personal data may be disclosed can be requested by contacting the Data Controller at the address indicated in Article 1 of this Policy. 

Your personal data will not be disseminated.

5. Transfer of personal data outside the European Union

The Data Controller does not intend to transfer your personal data outside the European Union. 

Should such a circumstance become necessary for technical and organisational reasons, such a transfer will in any case be preceded by prior verification of satisfaction of the conditions of legitimacy and of the appropriate guarantees prescribed by Articles 44 et seq. of the GDPR. In such a circumstance, you may request information from the Data Controller about the transfer of your personal data outside the European Union and obtain a copy of the protection measures adopted by making a specific request to the Data Controller via the e-mail address privacy@ersel.it.

6. Data subjects' rights

In relation to the processing described in this Policy, as data subject, you may, under the conditions set out in the GDPR, exercise the rights set out in Articles 15 - 21 of the GDPR, in particular: 

• right of access: the right to obtain confirmation as to whether or not personal data concerning you are being processed and, if so, to obtain access to your personal data – including a copy thereof – and communication of, inter alia, the information referred to in Article 15 of the GDPR;
• right of rectification: the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and/or the integration of incomplete personal data pursuant to Article 16 of the GDPR; 
• right to erasure (right to be forgotten): the right to obtain, without undue delay, the erasure of personal data concerning you, in the cases referred to in Article 17 of the GDPR; the right to erasure does not apply to the extent that the processing is necessary for the performance of a legal obligation or for the performance of a task carried out in the public interest or for the establishment, exercise or defence of legal claims;
• right to restriction of processing: the right to obtain restriction of processing, in the cases indicated in Article 18 of the GDPR;
• right to data portability: the right to receive, in a structured, commonly used and machine-readable format, personal data concerning you provided to the Data Controller and the right to transmit them to another data controller without hindrance, where the processing is based on consent and is carried out by automated means, in accordance with Article 20 of the GDPR. Furthermore, the right to have your personal data transmitted directly by the Data Controller to another data controller if this is technically feasible;
• right to object: the right to object to the processing of personal data concerning you, unless there are legitimate grounds for the Data Controller to continue the processing, pursuant to Article 21 of the GDPR;  
• right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before revocation;
• right to lodge a complaint with the Personal Data Protection Authority, Piazza Venezia n. 11, 00187, Rome (RM).

The above-mentioned rights may be exercised vis-à-vis the Data Controller by contacting the points of contact indicated in Article 1 above. The Data Controller will take charge of your request and provide you with information on the action taken in respect of your request without undue delay and, in any event, no later than one month after receipt thereof.

The exercise of your rights as data subject is free of charge pursuant to Article 12 of the GDPR. However, in the case of requests that are manifestly unfounded or excessive, including by reason of their repetitiveness, the Data Controller may charge you a reasonable fee, in the light of the administrative costs incurred in handling your request, or refuse to grant your request. 

Finally, please be advised that the Data Controller may request further information necessary to confirm the identity of the data subject

The Holder
Ersel Banca Privata S.p.A.