Privacy Notice for the Use of Chat
On the Jacob Cohen Company website there is a channel for instant communication with real people who can respond during office hours to the requests of website visitors. Pursuant to Regulation (EU) 2016/679 ("GDPR") and the California Consumer Privacy Act (“CCPA”), and pursuant to Art. 13 of EU Regulation 2016/679, Jacob Cohen Company Spa (“the Company” or the “Data Controller”), already communicated or which will be communicated in the future and where the personal data are or will be collected, wishes to inform you that your data may be processed in compliance with the regulations referred to above by the Company in relation to dialogue in the interactive chat.
Data Controller
The Data Controller is Jacob Cohen Company Spa,
with its registered office at Via Vittorio Pisani 20, 20124 Milan.
Privacy Office
May be contacted at the following e-mail address: privacy@jacobcohen.com
May be contacted at the following e-mail address: dpo@consulentegrdr.eu
The updated list of external data processors appointed by the Data Controller in accordance with Article 28 of the GDPR, as well as the individuals authorised to process the data, is available at the Company’s headquarters or upon request to the Privacy Office.
Source of personal data
The personal data are provided directly by the data subject. All personal data collected are processed in compliance with regulations in force and, in any event, with the required confidentiality.
Nature of the collection
For the chat function, the collection of personal data is also required, as the data subjects need to be identified using minimal data; the refusal to provide such personal data will make it impossible to activate the communication via chat. The relative processing does not require the consent of the data subject.
Purpose and legal basis of data processing
The collection or processing of personal data has the sole purpose of adequately meeting obligations connected to the interactive chat function.
Nature of provision and consequences of any refusal
Any refusal to provide minimal identifying personal data shall make it impossible to carry out the operations connected to the interactive chat.
Processing methods
The personal data shall be processed lawfully and fairly and in any event in compliance with the regulations referred to above, using appropriate tools to guarantee its security and confidentiality, and may also be processed by means of IT tools used for saving, managing and transmitting such data. The processing will be carried out, primarily, by the internal organisation of the company under the management and control of the responsible company functions and for the purposes specified previously, as well as by Group companies or third parties, as identified in point 7 below. Personal data shall be stored in a form that makes it possible to identify the data subject for a period of time not to exceed that necessary for the purposes for which the data were collected and processed.
Duration of processing
The personal data processed shall be stored for the time strictly necessary for the fulfilment of the requests expressed in the interactive chat dialogue. The personal data shall be stored only for the time necessary for the purposes for which they were collected, respecting the principle of minimisation pursuant to Article 5, paragraph 1, letter c) of the GDPR.
Recipients of personal data
Without prejudice to the communications made in fulfilment of a legal, regulatory or EU legislative obligation, the communication, also by means of mere consultation, or the provision of your personal data may take place with respect to the following parties:
· entities, supervisory bodies, authorities or public institutions;
· natural persons or legal entities that provide specific services: data processing, logistics and postal services, customer satisfaction surveys, legal, administrative, tax and/or accounting advice, organisation of trade fairs and communication events;
The parties pursuant to point a) operate in their capacity as independent Data Controllers. We assure to you that, in any case, the parties cited will be transferred exclusively, if not aggregated and anonymous personal data, the required and pertinent personal data with respect to the processing purposes under their responsibility. The list of such third parties shall be continuously updated and accessible to you should you request it from our company. The personal data shall not in any case be distributed or transferred to countries outside the EU.
Rights of data subjects
As a data subject, you have the following rights regarding the personal data collected and processed by the Data Controller for the purposes outlined above: (i) the right to access, particularly by requesting confirmation at any time of whether your personal data is held in the Company’s archives and making this information available to you in a clear and intelligible manner, as well as the right to know the origin, logic and purpose of the processing, with an explicit and specific indication of the individuals responsible for processing and any third parties to whom your data may be communicated; (ii) the right to request the updating and rectification of data (except evaluative data), the deletion of superfluous data or their transformation into anonymous form, as well as the restriction of processing and definitive deletion in the case of unlawful processing; and (iii) where applicable, the right to restrict processing and data portability. You also have the right to lodge a complaint with the Data Protection Authority if you believe your rights have been violated under the applicable data protection regulations.
The Data Controller has made it possible for you to submit a request, including your details, to the following address: privacy@jacobcohen.com
