INFORMATION PURSUANT TO ART. 13 OF EU REGULATION NO. 679/2016 (“GDPR”)
This Policy describes which of your personal data is collected by JMA Consultants Europe S.p.A. (referred to herein as “we” or “JMAC”), for what purposes and in what manner they are processed. Below you will also find the information you need to exercise your rights under the GDPR.
In general, we collect your information when you create an account on our site to access the restricted area, when you use our services, when you send us emails or messages or call us, when you use our site and our social media. We inform you that the personal data collected during these processes will be processed in order to respond to your requests, to allow you to use the services offered by JMAC and to carry out marketing activities, as indicated below.
- Who processes your data – Data Controller
JMA Consultants Europe S.p.A., with registered office in Via Magenta 42, 20123 Milan, is the data controller of your personal data carried out on this site, necessary to provide you with the JMAC services accessible from our site and, after obtaining your consent, for marketing purposes, according to the scopes and methods indicated below.
- What data we use – type of data processed
To create your JMAC account and provide the services available on the site you requested, as well as to provide assistance, we process your personal data such as name, surname (or nickname), email address.
- Where We Take Your Data – How We Collect Data
Directly from you. For example, if you create an account, post a comment on our social media accounts, ask us a question via email or other communication channels. If you do not give us your details, we will not be able to activate an account for you and we could not provide you with one of the services that you requested. If you do not activate a JMAC account, you may only use only a portion of the services accessible on through the site.
From third parties. For example, if you choose to use social media features to interact with us, the third party’s social media site will, with your prior consent, pass on certain information about you to us. Your activities on our sites may be posted on social media platforms on which you have an account (and for which you have accepted terms and conditions, including those relating to the use of your information).
- Why and how long we process your data – Purpose and legal basis of the processing – Period of data retention
To provide you with the services of our site, to give you information and assistance about JMAC services. The processing of your data is necessary to give you access to JMAC’s website, to respond to your requests and to provide you with assistance when using our services. In particular, creating an account allows you to use different features of JMAC’s website, especially the access to the reserved area and to resources published in that area.
The legal basis for this processing is the provision of JMAC services as well as the execution of any pre-contractual measures you may have requested before activating these services. The retention period of your information is the same as the period of your account activity for using JMAC services. Without your details we cannot give you access to the JMAC services available on our site.
To prevent or control unlawful conduct or to protect and enforce rights. For example, we may use your information to prevent or prosecute infringements of our or third party’s intellectual/industrial property rights or computer crimes or those committed through electronic networks. The legal basis for such processing is JMAC’s legitimate interest to protect its rights and to prevent crimes. The period of data retention is equal to the time reasonably necessary to protect our rights from the moment we become aware of the offence or its potential commission.
To obtain information on the use of the site. When you browse our site, even when you do so without being registered or having logged in, the software procedures and the computer system responsible for operating the web applications acquire, during their normal operation, some data whose transmission is implicit in the communication protocols of the Internet.
This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by the Data Controller or third parties, allow users to be identified.
This category of data includes IP addresses or domain names of devices used by users connecting to the application, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..), sections of the site visited, the type of device used, the country from which you connect and other parameters regarding the operating system and computer environment. JMAC uses this information only to enable you to navigate our site and to carry out the operations normally associated with the use of our website. The legal basis for this processing is JMAC’s legitimate interest in communicating with the public via telematic networks. The period of data retention for information that could potentially allow identification is a few hours from access to our site.
What cookies are. Cookies are small text files that sites visited by users send to their terminals, where they are stored and then retransmitted to the same sites during subsequent visits.
The first time you visit our site, you will be asked to accept (or not to accept) cookies using a banner. You may refuse to accept all or some cookies or you may change your computer settings at a later date to know when you receive cookies or to disable the automatic cookie acceptance feature.
The Website uses the following categories of cookies:
- Technical (or navigation) cookies, which contribute to the functioning of the Website, for example to allow navigation between pages and access to the reserved area of the Website; the legal basis of the treatment underlying the use of these cookies is JMAC’s legitimate interest to provide efficient and well-functioning services to its customers; the storage period of these cookies starts from the date of first access to the Website until they are disabled.
- Functional cookies, which allow you to activate specific features of the Site and store your preferences (such as language), to improve your browsing experience; the legal basis for the treatment underlying the use of these cookies is JMAC’s legitimate interest to provide efficient and well-functioning services to its customers; the retention period of these cookies begins from the date on which they are enabled to the site until they are disabled. The user can accept and disable – to his liking – these cookies using the cookies management tool.
- Analytical cookies, which allow you to acquire statistical information in aggregate and anonymous form, depending on how you navigate, the legal basis for the treatment underlying the use of these cookies is JMAC’s legitimate interest to provide efficient and well-functioning services to its customers; the retention period of these cookies begins from the date on which they are enabled to the site until they are disabled. The user can accept and disable – to his liking – these cookies using the cookie management tool.
Below you will find links explaining how to disable cookies for the most popular browsers (for other possibly used browsers we suggest looking for this option in the help of the software normally available through the F1 key):
Internet Explorer: Click the Tools button and then click Internet Options. Click the Privacy tab and in Settings move the slider up to block all cookies
Google Chrome: Click on the menu in the browser toolbar. Select Settings. Click Show Advanced Settings. In the “Privacy” section, click the Content Settings button. Select “Prevent sites from setting data”.
Mozilla Firefox: Click the menu button and select Options. Select the Privacy panel. Under History Settings – select use custom settings. To enable cookies, mark the Accept Cookies from Sites box; to disable cookies, remove the mark from your entry.
Safari: Click in the menu bar on “Safari”, then on “Preferences”. Now click on “Privacy”, then on “Details” to select the site, then select “Remove”.
Alternatively, you can only disable Google Analytics cookies by using the opt-out add-on provided by Google for the main browsers https://tools.google.com/dlpage/gaoptout?hl=it
- Where your data is processed – Transfer of data
The data processed through our site are processed and stored at the facilities of our suppliers in Italy.
- Who we share your data with – recipients of your personal data
With service providers. JMAC uses third party services (cloud, hosting, site navigation functionality) that operate as data controllers under agreements in accordance with Art. 28 GDPR. These persons shall only acquire such personal data as necessary for the performance of their duties and may use them only for the purposes of performing such services on our behalf or to comply with legal requirements. The updated list of third-party suppliers acting as data processors pursuant to Art. 28 GDPR is available on request from firstname.lastname@example.org.
With judicial or administrative authorities. Where we believe we should do so to comply with a court order or authority, or in order to comply with legal obligations or to judicially protect our rights, or those of third parties, we may disclose your information to the Judicial Authority or to an Administrative Authority of the State or the European Union.
JMAC’s sites, apps and services and products in general are not intended for use by persons under the age of 16, who shall not be required to provide JMAC with any personal data. If JMAC acknowledges that it has collected personal data from users under the age of 16, it will take the necessary steps to delete such information as soon as possible.
- Your rights
In addition to managing your personal data processing preferences in accordance with the previous paragraphs, you can contact JMAC to request access to your personal data, its rectification, cancellation or limitation of processing, to oppose processing and to request the portability of your data; you can also revoke your consent at any time (this will not affect the lawfulness of the processing based on the consent given before the revocation).
When you exercise your right of access, you can request the rectification or cancellation of your data, the limitation of the processing and portability of your data, you can oppose the processing and request not to be subjected to automated processing such as profiling (if ever there will be).
You have the right to lodge a complaint with the Data Protection Authority and to ask data controllers, at any time, for information about the data processors and the subjects in charge of the processing, authorized by the data controllers to process your data.
You can exercise your rights by contacting JMAC via e-mail at email@example.com or by writing to the address above.
Version updated to May 10, 2018