Protecting your personal information is a core value of our business. From this page we provide you with information that may help you understand how we protect your privacy and control the use of your information.
This policy covers the processing of your personal data carried out through our website www.modefinance.com (the "Site") or otherwise in connection with the purchase and use of our products and services.
For any further information on the privacy policies observed by Modefinance S.r.l. in relation to the processing for commercial information purposes, we invite you to consult our dedicated page.
We process your data in compliance with Regulation (EU) No 2016/679 (General Data Protection Regulation, "GDPR") and we provide you with this notice in accordance with articles 13 and 14 of the GDPR
In this policy we tell you in a simple and detailed manner:
In this section we list the persons to whom you can refer to in order to exercise your rights:
This is the entity that decides why and how your personal data are processed and sets up the organisational security measures to protect your privacy.
The data controller is Modefinance S.r.l. who can be contacted at:
Data controller
Modefinance S.r.l.
AREA Science Park, Building A,
Padriciano 99, Trieste
privacy@modefinance.com
Please remember to include your name, e-mail/postal address and/or telephone number(s) so that your request can be handled correctly.
The company Modefinance has appointed a Data Protection Officer (DPO): this is the person in charge of overseeing compliance with the legislation on the processing of personal data and responding to your requests for clarification on how we process your data.
The DPO is also the person appointed by the company to respond to your requests to exercise your right of access and other rights under the GDPR. You can contact him by writing to the following contact details:
Data Protection Officer
Studio legale Avv. Paolo Vicenzotto,
Corso Giuseppe Garibaldi 4 G – Pordenone
EMAIL: dpo@studiolegalevicenzotto.it
Please remember to include your name, e-mail/postal address and/or telephone number(s) so that your request can be handled correctly.
Personal data is any information with which you can be identified, directly or indirectly, if you are a natural person.
We collect and use your personal data in order to enter into and perform your contract with Modefinance and when you visit, consult, request or use Modefinance's services and/or products (including those available on this Site.
In some cases we may also collect your personal data from other TeamSystem group companies or public databases.
Types of data we collect:
★ Contact and access identification data
Such as first name, surname, username, e-mail address, postal address, telephone number, as well as a copy of your ID, where required by applicable law.
★ Product data
Such as data relating to products supplied to you under licence and/or services subscribed to by you, including information contained in documents managed through the product or service, as well as what is required to comply with legal obligations (e.g. compilation of transaction log required by current legislation on the conduct of business information activities).
★ Billing and payment data
Such as VAT number, tax code, address, if applicable, and company name.
★ Browsing data
Such as connection data, IP address (1), domain names and other parameters relating to your browser and operating system.
★ Usage Data
Meaning information generated in the context of the use of products or services purchased by you, such as log data (2), data relating to licences, installations and configurations, data relating to registrations made, or interaction and transaction processes.
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(1) The IP address is the equivalent of the postal address but related to your device (PC, mobile phone, tablet). So a unique address that identifies a unique device
(2) Log data are files that store information on the operation of devices and, above all, records of errors and problems
In this section we explain to you the purposes for which we use your data, i.e. the purpose of the processing.
We also tell you whether you have an obligation to provide us with the data, what happens if you do not want to provide us with the data and how long we keep the data.
These are the purposes for which we process your data:
IN SHORT
★ Are you obliged to provide us with your data?
Yes, without them we cannot provide our services/products.
★ What happens if you do not provide us with the data?
We will not be able to perform the contractual relationship and provide you with the services or products you have requested us.
★ Is your consent necessary to process your data?
Your consent is not required.
★ On what legal (basis) grounds do we process your data?
Processing is necessary in order to perform the contract you have concluded with us, to handle your requests or to carry out the activities necessary to conclude a contract with us and to fulfil an obligation imposed on us by law.
★ How long do we keep your data?
For a period equal to the duration of the provision of the services you have requested and for 10 years thereafter (period in which the statute of limitations for any contractual liability accrues). Except in cases where retention for a later period is necessary for litigation, requests by competent authorities or under applicable law.
Here we describe the different contractual and legal purposes in more detail:
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(3) A webinar is an educational or information session whose participation takes place remotely via an Internet connection.
(4) A chatbot is an instant electronic conversation (chat) that takes place between you and an artificial intelligence (bot).
IN SHORT
★ Is your consent necessary to process your data?
Your consent is not required.
★ Can you object to these processing operations?
You can object to processing carried out for reasons related to your particular situation, in the manner indicated in the section 'What are your rights and how can you exercise them'. In this case, we will not process your data for this purpose, except where we can demonstrate an overriding legitimate reason or the exercise or defence of a right under Article 21 of the GDPR.
★ On what legal grounds do we process your data?
The processing is based on the legitimate interest of the Data Controller, provided for in Article 6, paragraf 1), letter f) of the GDPR. In accordance with the GDPR, we have carried out a thorough balancing of interests with the aim of protecting and guaranteeing your privacy and fundamental rights.
★ How long do we keep your data?
For a period equal to the duration of the provision of the services you have requested and in accordance with the principle of minimisation. Except in cases where:
Here we describe in more detail the different purposes of service improvement and other non-consent-based purposes:
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(5) see above
(6) Anonymisation is a technique whereby personal data can no longer be traced back to a specific person
IN SHORT
★ Are you obliged to provide us with your data?
No, you are not obliged to.
★ Can you object to processing?
You can object at any time to the processing of your data for direct marketing purposes, including profiling if related to such direct marketing.
★ What happens if you do not provide us with data?
We will not process your data for these purposes without any consequences with regard to your contractual relationship with us and the use of our services.
★ Is your consent required to process your data?
Yes, your consent is required, with the exception of the purpose indicated under p.
★ On what legal grounds do we process your data?
We process data on the basis of your prior consent. The only exception relates to the purpose indicated in letter p: in this case the processing is carried out in accordance with Article 130, paragraph 4 of Legislative Decree no. 196/2003 ("Privacy Code") and subsequent amendments and additions, without prejudice to your right to object to the processing.
★ Modification of choices and withdrawal of consent
If you change your mind, you may at any time change the consent given for marketing purposes in the manner indicated in the section "What are your rights and how you can exercise them". In any case, if you no longer wish to receive our marketing communications, you can use the unsubscribe link available at the bottom of our marketing communications received by e-mail. In these cases, we will keep the minimum personal data necessary to register your opt-out and avoid contacting you again.
★ How long do we keep your data?
For a period of 24 months from the date of termination of the contractual relationship regarding the products/services provided or the date of the last contact with you. By last contact we mean, for example, participation in a Modefinance event, use of a product or service provided by Modefinance or the opening of a newsletter. This does not affect your right to revoke your consent at any time.
Here we describe the different marketing purposes in more detail:
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(7) Interconnection consists in using several databases in connection with each other. For instance, data contained in one database can be automatically updated in the event of changes to data contained in a second database
(8) See above
We may share your data with other parties who carry out activities related to our products or services. When sharing your data we respect the principles of purpose and minimisation (9) set out in the GDPR.
The parties to whom we disclose data are: third party service providers and consultants of ModeFinance with reference to activities in the IT, technology, accounting, administrative, legal, banking and insurance sectors. Subject to your consent, the data may also be passed on to TeamSystem and/or network of business partners for the purpose of sending marketing communications and other promotional initiatives through automated communication tools and for the purposes indicated.
The subjects to whom we disclose your data, process them, as appropriate, as autonomous data controllers, data processors or persons in charge of processing. For a complete list of the entities that process data as data processors, please write to us at privacy@modefinance.com
★ Do we transfer your data abroad?
Your personal data may be freely transferred within the European Union. If, for the purposes indicated, Modefinance needs to transfer your personal data outside the European Union, to countries not considered adequate by the European Commission (e.g. United States), Modefinance will take the necessary measures to protect your personal data. We will do this in compliance with the legal guarantees, in accordance with the applicable legislation and in particular Articles 45 and 46 of the GDPR.
If you wish to receive further information about the guarantees in place and would like to request a copy of them, you may contact the Data Protection Officer at dpo@studiolegalevicenzotto.it
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(9) The purpose principle requires that personal data be processed for specified, explicit and legitimate purposes
Your personal data are processed by Modefinance by means of electronic and manual systems according to the principles of fairness, loyalty and transparency and by protecting your confidentiality by means of technical and organizational security measures to ensure an adequate level of security.
These processing operations take place at Modefinance's head office and/or at the offices of external data processors who carry out the processing on behalf of Modefinance.
For more information on cookies and tracking tools used on the site and the related processing of your browsing data, you can consult our cookie policy here.
You have control over your data. Here we list the rights you have in respect of the processing of your personal data:
★ Right of access
You can receive confirmation of the existence of your personal data and have access to its content.
★ Right of correction
You can update, amend and/or correct your personal data.
★ Right to be forgotten and right to limitation
You can request the deletion or restriction of the processing of your personal data processed in breach of the law, including data whose retention is not necessary for the purposes for which the data was collected or otherwise processed. This is subject to an overriding public interest or our legal obligation to retain the data.
★ Right to object
You can object to processing, including profiling. This is subject to the case where there is an overriding legitimate reason for Modefinance to continue the processing.
★ Right to withdraw consent
You may revoke your consent to marketing activities if you have previously given it.
★ Right to complain
You can lodge a complaint with a supervisory authority in the Member State where you normally reside, work or where the alleged infringement has occurred. In Italy, the supervisory authority is the Garante per la protezione dei dati personali (10). This is without prejudice to any other administrative or judicial remedy.
★ Right to data portability
You can receive an electronic copy of the personal data related to you. You have the right to transfer this data to a different service provider if Modefinance processes the data on the basis of your consent or on the basis that the processing is necessary to provide you with the requested services and if the data is processed by automated means.
To exercise your data protection rights as set out above at any time and free of charge, you may contact the Data Protection Officer by sending a request to dpo@studiolegalevicenzotto.it
We will respond to your requests within 30 (thirty) days of receipt, subject to an extension of 60 (sixty) days, taking into account their complexity and number.
In any case, you have the right to lodge a complaint with the Supervisory Authority of the country where you live or work (for Italy, the Garante per la Protezione dei Dati Personali) in the form and manner provided for by current legislation. Likewise, you have the right to appeal to the competent judicial authority for the protection of your privacy rights.
When contacting us, be sure to include your name, e-mail, postal address and/or telephone number to ensure that your request can be handled properly.
★ What happens in the event of your death?
If you are not a legal person, in the event of your death, Article 2-terdecies of the Privacy Code applies: these rights relating to your personal data may be exercised by those who have an interest of their own, or who act as your proxy, or for family reasons worthy of protection.
You may expressly prohibit – under the conditions laid down in the aforementioned Article 2-terdecies – some of these rights from being exercised by these persons by sending a written declaration to the Data Controller, at the contact details you can find in the "About us and how you can contact us" section of this notice. You may also revoke or amend this declaration at a later date in the same manner.
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(10) The website of the Data Protection Authority is www.garanteprivacy.it
We may also change this policy as a result of regulatory changes.
We will notify you in advance of any changes to the policy.
The updated policy text will be available at https://www.modefinance.com/en/privacy-policy
For all enquiries relating to this privacy policy you may contact the Data Controller at the following addresses:
Data Controller
Modefinance S.r.l.
AREA Science Park, Building A,
Padriciano, 99 -Trieste
privacy@modefinance.com
Please remember to include your name, e-mail/postal address and/or telephone number(s) so that your request can be handled correctly.
Last update: 16 May 2022
Below are the articles mentioned in the document with their relative simplification:
| Article | Description |
| Art. 13 GDPR | Information to be provided to the data subject
Establishes the information that the data controller must provide to the data subject, i.e. the person to whom the data relate, when obtaining his data |
| Art. 14 GDPR | Information to be provided to the data subject
Establishes the information that the data controller must provide to the data subject, i.e. the person to whom the data refer, when obtaining his/her data |
| Art. 130 paragraph 4 DL 196/2003 ("Privacy Code") | Promotional communications without the consent of the data subject
If the data subject has provided the data controller with his e-mail address in connection with the sale of a service or product, then the data controller may send the data subject promotional or market research communications even without his consent. The communications must relate to products or services similar to those sold and the data subject always has the right to object to these communications. |
| Art. 45 GDPR | Transfer on the basis of an adequacy decision
Establishes that personal data may be transferred to foreign states or international organisations if there is an adequate level of data protection, as decided by the European Commission.This article also defines the requirements on the basis of which this decision is made. |
| Art. 46 GDPR | Transfer subject to adequate safeguards
Personal data may be transferred to foreign states or international organisations if the data controller has established appropriate safeguards to protect the data. |
| Art. 6, paragraf 1), letter f) GDPR | Lawfulness of processing based on legitimate interest
The processing of personal data is lawful if it is necessary for the purposes of the legitimate interest of the data controller or a third party, provided that this interest is not overridden by the interests or fundamental rights and freedoms of the data subject |
| Art. 21 GDPR | Right to object
The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of his or her personal data when it is based on the pursuit of a legitimate interest. In the event of an objection, the data controller must refrain from further processing the personal data unless it can demonstrate the existence of compelling legitimate grounds which override the interests, rights and freedoms of the data subject or for the exercise or defence of a legal claim. |