INFORMATION ON THE PROCESSING OF PERSONAL DATAThis notice describes the processing of personal data relating to visitors and users of the FinburgH website (www.finburgH.com, the “Site”), as well as to those who subscribe to newsletters or mailing lists, fill in forms, take part in events, activities and initiatives promoted through the Site, submit applications, or otherwise send requests to FinburgH (collectively, the “Users”). FinburgH may update this notice from time to time to reflect future changes to the Site, the services offered, or the communication channels used. In the event of material changes, FinburgH will publish a notice on the Site and/or, where appropriate, send an email communication to inform Users of the changes and to manage any requests to exercise rights under applicable data protection law.1. DATA CONTROLLERThe data controller is FinburgH, represented by Ekaterina Demianova, CEO, with professional domicile in Milan (MI), Italy, email demianova@finburgh.com, VAT no. 14241100966 (“FinburgH”).2. DATA COLLECTED2.1 Data provided by Users The personal data collected through the Site are the data provided by Users when filling in the forms available on the Site, registering for newsletters, mailing lists, events or initiatives, submitting applications, or sending requests to FinburgH using the contact details indicated on the Site. The data collected may include Users’ identification and contact details (for example, name and surname, company, email address, telephone number), personal data contained in communications and requests sent to FinburgH, data contained in CVs or cover letters, as well as any additional information necessary to respond to and manage the specific request made by the User. Users are invited to provide only updated, relevant and non-excessive data in relation to the purposes of the processing. If Users need to provide personal data relating to third parties, they are responsible for complying with applicable legal requirements and for ensuring that such third parties are properly informed about the communication of their data to FinburgH and the related processing. Any unnecessary data may be deleted or anonymized.2.2 Browsing data Each time a User accesses the Site, the systems and technological infrastructure used to operate it may automatically record technical browsing data, such as the IP address or domain name of the device used, browser and device information, requested pages or resources, date and time of access, duration of the visit, and other similar technical information. Such data are processed for the proper functioning, management and security of the Site, for the detection and resolution of technical issues, for the preparation of aggregate statistical information on the use of the Site, and, where necessary, to ascertain responsibility in the event of cyber incidents or unlawful use. 3. PURPOSES OF THE PROCESSINGUsers’ personal data (“Data”) may be processed for the following purposes.3.1 Subscription to the newsletter or sector mailing listsThe data collected when a User completes the newsletter subscription form or requests to receive sector specific email communications or to be included in mailing lists to which the User has been invited or has requested access (for example, name and surname, company, email address) may be processed in order to send informational and promotional communications concerning FinburgH’s activities, updates, insights, invitations to events and/or conferences organized, promoted or sponsored by FinburgH, also in collaboration with third parties, or in which FinburgH professionals participate as speakers. Providing the Data is necessary to complete subscription to and use of the newsletter or mailing list service. Therefore, if the User refuses or fails to provide the requested Data, FinburgH may be unable to activate the newsletter or mailing list service. The User may unsubscribe from the newsletter or mailing list service at any time by following the procedure indicated at the bottom of each communication or by sending a specific request to FinburgH using the contact details indicated in section 7 below. The legal basis for this processing is the provision of the service requested by the User, FinburgH’s legitimate interest in providing ongoing updates on developments and initiatives that may be relevant to its clients or potential clients, and, where required by applicable law or by the communication channel used, the User’s consent. Such legitimate interest is considered compatible with the rights and freedoms of data subjects, as the processing concerns ordinary contact data and is limited to communications that may reasonably be relevant to the User’s professional interests.3.2 Registration for events, related follow-up and optional subscription to the FinburgH newsletter The Data collected (for example, name and surname, company, email address) through the completion of registration forms for events advertised on the Site or on online platforms through which such events are promoted or managed (for example LinkedIn or webinar/event platforms) may be processed for: (i) the User’s participation in the requested event and the receipt of any follow-up materials or communications connected with it; and (ii) the sending of the FinburgH newsletter, if the User has given consent through the dedicated checkbox or other equivalent opt-in mechanism made available during registration.3.2.1 Participation in events and sending related follow-up communicationsEvents may be organized and/or sponsored by FinburgH, including together with third parties, or may feature FinburgH professionals as speakers. In this context, the Data may be disclosed to public and private entities involved in the organization and management of the relevant event and/or to providers of ancillary and necessary services (for example, speakers, event staff, communication providers, webinar platforms, venue managers, or other operational suppliers). Such entities will process the Data, as the case may be, either as independent data controllers or as data processors appointed by FinburgH pursuant to a specific written mandate. Providing the Data is necessary to complete registration for the event. Therefore, if the User refuses or fails to provide the requested Data, the User may be unable to participate in the event. The legal basis for this processing is the performance of pre-contractual and contractual measures adopted at the User’s request, compliance with related legal obligations, and, with regard to the sending of follow-up 2 communications related to the event, FinburgH’s legitimate interest in promoting its expertise and activities in the areas covered during the event. This legitimate interest is considered compatible with the position and reasonable expectations of Users, since it is reasonable to assume that those who register for an event are interested in receiving follow-up communications related to the topics addressed in that event. If the User participates in events and/or activities organized and/or sponsored, in whole or in part, by parties other than FinburgH and the User has given the relevant consent where required, the Data may also be disclosed to such third parties, which will act as independent data controllers in accordance with the privacy notices that they will make available to Users within the applicable legal timeframes. Any such consent is optional: failure to provide it will not prevent participation in the event. Any consent given may be withdrawn at any time by writing to the contact details indicated in section 7 below, without affecting the lawfulness of the processing carried out before withdrawal.3.2.2 Sending the FinburgH newsletterIf the User has given consent, during registration for events through the Site or through online platforms, to receive the FinburgH newsletter, the Data collected in connection with participation in such events may also be processed in order to send the FinburgH newsletter by email. Consent is optional. Failure to provide it will not prevent the User from participating in the event. Any consent given may be withdrawn at any time by writing to the contact details indicated in section 7 below, without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal. The processing described in this paragraph is not necessary for participation in the events promoted on the Site, and any withdrawal of consent and/or objection to receiving such communications will have no negative consequences for the User.3.3 Management of spontaneous applicationsThe Data collected through the completion of recruiting / career forms made available on the Site (for example, name, surname, telephone number, email address, CV and any message or cover letter) will be processed for the sole purpose of assessing the candidate’s profile and, where relevant, carrying out any subsequent interview or selection activities. Providing the Data marked as mandatory in the relevant form is necessary in order to process the candidate’s request. Failure to provide such Data may therefore prevent FinburgH from reviewing the candidate’s professional profile and from evaluating the possibility of establishing any form of collaboration or employment relationship. Providing the data contained in the message or cover letter is optional, and failure to provide them will not in itself prejudice the candidate’s application. The legal basis for this processing is the implementation of pre-contractual measures adopted at the User’s request and compliance with related legal obligations.3.4 Responding to User requestsThe Data may also be processed in order to respond to requests that Users send through contact, request, booking or other forms available on the Site, or through the contact details indicated on the Site, including email and other communication channels. For this purpose, it is necessary for Users to provide the contact details required to receive a reply. Without such Data, FinburgH may be unable to respond to the request. The legal basis for this processing is the implementation of pre-contractual and contractual measures adopted at the User’s request and compliance with related legal obligations.4. METHODS OF PROCESSINGThe Data will be processed using manual, electronic and telematic tools by FinburgH personnel and collaborators authorized to process the Data and/or by companies or service providers expressly appointed, where required, as data processors, to whom FinburgH has given suitable operating instructions, including with particular regard to the adoption of appropriate technical and organizational security measures. The updated list of data processors appointed by FinburgH is kept by the data controller and may be requested using the contact details indicated in section 7 below.5. DATA RECIPIENTSThe Data may be communicated and transferred to the categories of recipients indicated in the description of the purposes and methods of processing above, including, where relevant, hosting and IT providers, newsletter and communication service providers, providers supporting the organization and management of events or recruiting activities, professional advisers, and competent authorities where required by law. To the extent strictly necessary to achieve the purposes of the processing (and on the basis of the same legal grounds), the Data may also be transferred abroad, for example:- in the case of events or initiatives taking place outside Italy;
- in the case of requests concerning foreign jurisdictions or international operations;
- where service providers or platforms used by FinburgH are located outside Italy or outside the European Economic Area.
Where Data are transferred outside the European Union to countries that do not benefit from an adequacy decision of the European Commission, and therefore do not guarantee an adequate level of protection of personal data, such transfer will take place only in accordance with applicable law and subject to appropriate safeguards, including, where relevant, the execution of standard contractual clauses approved by the European Commission or the use of another lawful transfer mechanism or derogation.6. RETENTION PERIODThe personal data collected and processed by FinburgH, for the purposes identified in section 3 above, may be retained in a form that allows identification of the User for the period necessary to achieve the relevant purposes and, in particular: • for the processing described in sections 3.1 and 3.2.2, namely the sending of the FinburgH newsletter or mailing list communications, for a period of 24 (twenty-four) months from subscription or from the collection of consent, renewable for further 24-month periods if the User does not unsubscribe or otherwise withdraw consent; • for the processing described in section 3.2.1, namely participation in events advertised on the Site, for the duration of the event and for the following 6 (six) months; • for the processing described in section 3.3, namely the assessment of spontaneous applications, for a period of 12 (twelve) months from receipt of the application; • for the processing described in section 3.4, namely the response to requests from Users, for a period of 12 (twelve) months from the last contact. 4 The Data may be retained for longer periods where necessary to comply with legal obligations or to protect FinburgH’s rights, until the expiry of the relevant limitation periods.7. USER RIGHTS AND CONTACT DETAILSThe User may, at any time and to the extent applicable: (i) obtain confirmation as to whether or not personal data concerning the User are being processed; (ii) request access to such personal data; (iii) request rectification, erasure, or restriction of processing; (iv) object to the processing or withdraw any consent given, without affecting the lawfulness of processing based on consent before its withdrawal; (v) receive the personal data provided to FinburgH in a structured, commonly used and machine-readable format and, where applicable, request that such data be transmitted to another data controller; and (vi) lodge a complaint with the Italian Data Protection Authority or bring a claim before the competent judicial authority. Requests to exercise the above rights must be sent to demianova@finburgh.com Requests regarding the recipients of the Data, as well as requests for clarification about this notice, may also be sent to the same contact details.8. LINKS TO OTHER WEBSITESThis privacy notice is provided exclusively with regard to Data collected through the Site and for the purposes identified in section 3 above, and does not apply to any other websites, pages, platforms or environments that may be accessed through links, widgets or integrations available on the Site (for example, social networks or third-party platforms). Such external websites or platforms may process personal data as independent data controllers and in accordance with their own privacy notices, which Users are encouraged to consult.