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Valentina Bandera STUDIO Privacy Policy


Contents:

1. Purpose

2. Data Protection Principles

3. Kind of Information We Hold About You

4. How Is Personal Data Collected

5. How Is Information Used

6. Special Category Personal Data

7. More specific details of how we may use your Personal Data

8. Change of purpose

9. Data Sharing

9.1. How secure is your information with third-party service providers and other entities in our group?

10. Security

11. Cookies

11.1. Use of cookies by Valentina Bandera STUDIO

11.2. Disabling/Enabling all cookies

11.3. More information about cookies

11.3.1. Strictly Necessary Cookies

11.3.1. Perfomance Cookies

11.3.1. Functionality Cookies

11.3.1. Targeting/Advertising Cookies

12. Accuracy

13. Retention

14. Your Rights in Connection With Personal Data

14.1. No fee usually required

14.2. What we may need from you

14.3. Right to withdraw consent

15. Data Protection Manager

16. Changes to this Privacy Notice

17. Contact information


1. Purpose:

Valentina Bandera STUDIO is committed to respect and protect your privacy and the security of your personal data. This policy sets out the basis on which Valentina Bandera STUDO may collect, store and process any Personal Data on you as a result of your use of this website. In accordance with the General Data Protection Regulation (GDPR). Employees, workers, and contractors should refer to our Privacy Notice for Employees and our Privacy Policy (found on our intranet).


Valentina Bandera STUDIO is a “data controller”. This means that we are responsible for deciding how we hold and use Personal Data. We are required under data protection legislation to notify you of the information contained in this Privacy Notice. We may update this Notice at any time.


2. Data Protection Principles

We comply with the GDPR. This says that the Personal Data we hold must be:


- Used lawfully, fairly and in a transparent way.

- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

- Relevant to the purposes we have told you about and limited only to those purposes.

- Accurate and kept up to date.

- Kept only as long as necessary for the purposes we have told you about.

- Kept securely.


3. Kind of Information We Hold About You


Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together follows:


Identity Data includes first name, last name, country of residence, company, and job title.

Contact Data includes address, email address and telephone numbers.

Professional Data includes CVs, and documents related to your qualifications, experience, and role, current salary, eligibility to work in Italy.

Usage Data includes information about how you use our website.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.


In limited circumstances, we may also collect, store and use documents to prove your identification such as a copy of your passport or address, and/or the following “special categories” of more sensitive Personal Data:

- Information about your race or ethnicity, and religious beliefs.

- Information about your health, including any medical condition.

- Information about criminal convictions and offences.

The Personal Data we may collect varies depending upon how it is collected and for what purpose. More specific details are set out below.


4. How Is Personal Data Collected


Personal Data may be collected in the following ways:


a. Information collected by cookies from the use of our website.

When you visit www.valentinabandera.it we may send a ‘cookie’ to your computer. This is a small data file stored by your computer to help improve functionality or tailor information to provide visitors with more relevant pages. For details of the cookies employed by us see Section 11 below.


b. Direct interactions – where you provide information by filling in forms or corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:

- complete an online form to subscribe to our mailing list;

- make business enquiries via email or telephone; and

- enter into a working relationship with us.


c. Third parties or publicly available sources. For example, consultants working with us whose CVs might be sent by their employer for bid documents or so we can assess their suitability for a project.


5. How Is This Information Used


We will only use your Personal Data when the law allows us to, such as:


a. Where it is necessary to perform a contract with you or in order to take steps at your request prior to entering into a contract.

b. Where we need to for compliance with a legal obligation.

c. Where it is necessary for the purposes of our legitimate business interests to run a successful international design studio or third party legitimate interests, and your interests and fundamental rights do not override those interests.


We may also use your Personal Data in the following situations, which are likely to be rare:


a. Where we need to protect your interests (or someone else’s interests).

b. Where it is needed in the public interest.


6. Special Category Personal Data


Special Categories of sensitive Personal Data require higher levels of protection and we will need to have further justification for collecting, storing and using this type of Personal Data, such as:


a. In limited circumstances, with your explicit written consent.

b. Where it is necessary for us to meet legal obligations.

c. Where it is necessary for reasons of public interest.

d. Where it is needed on health grounds, subject to appropriate confidentiality safeguards.


We may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

It is unlikely that we will need to collect or process Special Categories of sensitive Personal Data. Where we do need to, we will notify you and (where required) obtain your consent to the processing.


7. More specific details of how we may use your Personal Data


We have set out in the table below details of the type of data we may collect (by reference to the groups described in Section 3 above), the ways we may use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
To deliver relevant website content to you and to use data analytics to improve our website (a) Identity, (b) Contact, (c) Usage, (d) Marketing and Communications, (e) Technical. Necessary for our legitimate interests (to keep our website updated and relevant and to develop our business)
To send marketing newsletters to you (a) Identity, (b) Contact, (c) Marketing and Communications. Necessary for our legitimate interests (to develop our business)
To invite you to events (a) Identity, (b) Contact, (c) Marketing and Communications. Necessary for our legitimate interests for business development- to strengthen business relations and to market our services
To administer and protect this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity, (b) Contact, (c) Technical. Necessary for our legitimate interests (for running our business, provision of administration and IT services, and network security)
To respond to your new business enquiry as a potential client. (a) Identity, (b) Contact. Necessary for our legitimate interests (for winning and providing design services)
To administer our working relationship with you and your employer (as applicable), such as providing and administering architectural and engineering services to you, and/or collaborating with you to bid for a design project or to provide design services. (a) Identity, (b) Contact, (c) Professional Data. In limited circumstances we might require documents to prove your identification such as a copy of your passport or Special Categories of sensitive Personal Data. In these circumstances we will notify you and where necessary obtain your consent. Performance of a contract with you. Necessary for our legitimate interests (for winning and administering projects and running our business)
To consider and respond to your application to work with us. (a) Identity, (b) Contact, (c) Professional Data, (d) Technical Data. Necessary for our legitimate interests (of recruiting talented employees)and necessary to take steps at your request in anticipation of entering into a contract

8. Change of purpose


We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.


Occasionally we may use Personal Data to send you updates about our business or invites to events. If you prefer not to receive promotional material from Valentina Bandera STUDIO email us at vb@valentinabandera.it and put “unsubscribe” in the subject line together with the name of the publication you wish to unsubscribe from.

Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.


9. Data Sharing


We may share your Personal Data with third parties, including third-party service providers and other entities in the Valentina Bandera STUDIO Group where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest for the purpose of running a successful international design practice in doing so.


For example, we may share your Personal Data with:

a. professional advisors such as lawyers and accountants;

b. processors such as providers of cloud hosting solutions or translation companies;

c. to an auditor, regulator or to otherwise comply with the law.


We may share Personal Data, such as CVs of collaborating design consultants, to clients, potential clients or collaborating designers where this was the purpose of collection.


9.1 How secure is your information with third-party service providers and other entities in our group


All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your Personal Data in line with our policies and the law. We do not allow our third-party service providers to use your Personal Data for their own purposes. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.


10. Security


All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site or eMail; any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.


11. Cookies:


Cookies are small text files that the sites visited by the user send and record on his personal computer or any additional device, including mobile, to be relayed to the same sites at the next visit. Cookies are used for different purposes: for example, to remember the actions and preferences of the user (such as, for example, a login, your preferred language, the font size, other display settings, etc.) So that should not be shown again when you re-visit that site and browse from page to page of it; or to perform computer authentication, monitoring sessions and keep the information of the activities of users accessing a website and may also contain a unique identifier that allows you to track the user's navigation within the site for statistical purposes or advertising. Cookies can be sent from valentinabandera.it, or even from different sites (cd cookies of 'third parties'). Some operations may not be performed without the use of cookies, which in some cases are so technically necessary for the operation of the site.


11.1 Use of cookies by Valentina Bandera STUDIO


Within this website cookies are used to facilitate features and functions which improve your browsing experience. They are also used to measure the performance of the site and the ways in which visitors navigate their way around. The below information details the cookies we use, how to prevent these being written and the impact of doing so on your browsing experience.


11.2 Disabling/Enabling all cookies


You can accept or decline cookies by modifying the settings in your browser. However, you will not be able to use all the interactive features of the site if cookies are disabled.

Most recent web browsers allow control over the cookies saved through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visitwww.allaboutcookies.org.


11.3 More information about cookies


There are four main types of cookies used by websites. These categories are described below, based on the information published in the International Chamber of Commerce Cookie Guide.


11.3.1 Strictly Necessary Cookies - Enable services you have specifically asked for. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies the services you have asked for, like shopping baskets or e-billing, cannot be provided.

11.3.2 Perfomance Cookies - Collect anonymous information on the pages visited. These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

11.3.3 Functionality Cookies - Remember choices you make to improve your experience. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

11.3.4 Targeting/Advertising Cookies - Collect information about your browsing habits in order to make advertising relevant to you and your interests. These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.


The table below explain the cookies we use and why. The information is updated regularly but if a discrepancy is found then please contact us.


Strictly Necessary Cookies:

N/A - None used.

Performance Cookies:

N/A - None used.

Functionality Cookies:

N/A - None used.

Targeting/Advertising Cookies:

cookieAccepted: Stored when you dismiss the cookie policy banner, so that it does not display on every page.


12. Accuracy


We want to make sure that your Personal Data is accurate and up to date. Please contact us if any information we are using is not accurate or up to date.


13. Retention


We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected it or for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.


14. Your Rights in Connection with Personal Data


Under certain circumstances, by law you have the right to:


a. Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

b. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

c. Request the erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.

d. Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

e. Request the transfer of your Personal Data to another party.


If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact the Data Protection Manager in writing.


14.1 No fee usually required


You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.


14.2 What we may need from you


We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.


14.3 Right to withdraw consent


In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Manager or use any unsubscribe link in any email newsletter that you receive. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.


15. Data Protection Manager


We have appointed a Data Protection Manager to oversee compliance with this Privacy Notice. This role is held by Valentina Bandera, who may be contacted on vb@valentinabandera.it.

If you have any questions about this Privacy Notice or how we handle your Personal Data, please contact the Data Protection Manager.


16. Changes to this Privacy Policy


We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.

If you have any questions about this Privacy Notice, please contact the Data Protection Manager


17. Contact information


Requests for further information about this Privacy Notice or about how we process Personal Data can be sent to Valentina Bandera by email to: vb@valentinabandera.it.