Information on the processing of personal data
Pursuant to Article 13 of Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR)
1. Data Controller
The Data Controller responsible for the processing of personal data is:
S-Squared
Via Cornelio Tacito 12
Milan, Italy
Represented by Stefano Salis
Email: [Insert privacy contact email]
For any questions regarding this Privacy Notice or the processing of personal data, users may contact the Data Controller using the email address indicated above.
2. Personal Data Processed
When users visit the website or contact S-Squared, the following categories of personal data may be processed:
- Identification and contact details: name, surname, email address, telephone number and other contact details provided by the user.
- Professional information: company name, job title, professional role and other information relating to the user’s professional activities.
- Communication data: information contained in messages, enquiries, requests or other correspondence sent to S-Squared.
- Technical and browsing data: information relating to the user’s device, browser, IP address, access logs and interactions with the website, where collected through the website’s technical infrastructure or cookies and similar technologies.
Users are encouraged not to provide unnecessary personal or sensitive information when contacting S-Squared.
3. Purposes and Legal Bases of Processing
Personal data is processed for the following purposes:
A. Responding to enquiries and requests
Personal data provided through email or other communication channels is processed to respond to questions, requests for information, business enquiries and other communications.
Legal basis: taking steps at the request of the data subject prior to entering into a contract, where applicable, or the legitimate interests of the Data Controller in managing and responding to incoming communications.
B. Managing professional relationships and business opportunities
Personal data may be processed to assess potential collaborations, discuss licensing opportunities, establish professional contacts and manage business relationships.
Legal basis: taking steps prior to entering into a contract, performance of a contract, where applicable, or the legitimate interests of the Data Controller in developing and maintaining professional relationships.
C. Fulfilling legal obligations
Personal data may be processed where necessary to comply with legal, regulatory or administrative obligations applicable to the Data Controller.
Legal basis: compliance with a legal obligation to which the Data Controller is subject.
D. Website operation, security and maintenance
Technical data may be processed to ensure the security, availability and proper functioning of the website, prevent misuse and troubleshoot technical issues.
Legal basis: the legitimate interests of the Data Controller in maintaining a secure and functional website, subject to the rights and freedoms of users.
E. Website analytics and cookie-related activities
Where applicable, personal data may be processed to analyse website traffic, understand user interactions, improve website performance and manage cookie preferences in accordance with the Cookie Policy.
Legal basis: the legitimate interests of the Data Controller where permitted by law, or the user’s consent where required by applicable legislation.
4. Nature of the Provision of Personal Data
Providing personal data when contacting S-Squared is voluntary. However, failure to provide the information necessary to handle an enquiry may prevent the Data Controller from responding or following up on the request.
Where processing is based on consent, users may choose whether to provide that consent and may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal.
5. Methods of Processing
Personal data is processed using electronic and organisational tools appropriate to the purposes described in this Privacy Notice.
Processing is carried out in accordance with applicable data protection legislation and with appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure or destruction.
Personal data is accessed only by individuals authorised to process it or by service providers acting on behalf of the Data Controller, where necessary for the purposes described above.
6. Recipients of Personal Data
Personal data may be disclosed, where necessary and for the purposes set out in this Privacy Notice, to the following categories of recipients:
- IT, website hosting and technical support providers;
- email and communication service providers;
- professional advisers and consultants, where necessary;
- competent public authorities, where disclosure is required by law;
- other service providers involved in the management of professional relationships or business activities, where necessary and lawful.
Such recipients process personal data in accordance with applicable data protection legislation. Where required, service providers acting as data processors are appointed in accordance with Article 28 of the GDPR.
Personal data is not made publicly available except where required by law or where the user has expressly requested or authorised such disclosure.
7. International Transfers of Personal Data
Where personal data is transferred to countries outside the European Economic Area (EEA), such transfers are carried out in accordance with the GDPR.
Appropriate safeguards are implemented where required, including an adequacy decision adopted by the European Commission or suitable sa