Information on personal data processing pursuant to Articles 13 and 14 of EU Reg. No. 679/2016

BAM! Strategie Culturali Società Cooperativa a Responsabilità Limitata collects and uses your personal data when you browse or use the online services on bamstrategieculturali.com.

By personal data we mean any information that can be used to identify you as an individual.

The purpose of this policy is to provide you with a clear and detailed explanation of how, when and why we collect and use your data. It is designed to give you a simple and transparent explanation of our data protection policy and to show you how to exercise your rights effectively.

This information refers only to data processed by BAM! Strategie Culturali Soc. Coop. through this website and does not concern other websites, platforms or social network pages that may be accessed via links on the website: in these cases, it is always necessary to refer to the information available on the respective pages.

This information may be subject to changes and variations over time, so please consult this page regularly in order to keep up to date with the processing of your personal data.

 

CONTENTS:

  1.                 Who is the data controller?
  2.                 When do you collect my data?
  3.                 What data will you process?
  4.                   For what further purposes can you use my data?
  5.                 With whom will you share my data?
  6.                 How will you process my data?
  7.                   Are my data processed outside Europe?
  8.                 How long will you keep my data?
  9.                   Links to third-party sites and social media networks
  10.             What are my rights and how can I protect my privacy?
  11.               Can I file a complaint?
  12.               Possible modifications
  13. Who is the data controller for my data?

Since BAM! Strategie Culturali Soc. Coop, VAT Reg. No. 03201521204, determines the means and purposes of the personal data processing involved in the use of this website, it is the Data Controller.

You can contact the Data Controller by writing to the following addresses:

–        by post: BAM! Strategie Culturali Soc. Coop, via Marconi n. 45, Bologna, Postcode: 40122, Italy;

–        email: hello@bamstrategieculturali.com;

–        certified email: bamstrategieculturali@pec.it.

  1.   When do you collect my data?

BAM! Strategie Culturali Soc. Coop. will collect the information provided directly by you:

  •       when you log in and browse the website;
  •       when sending questions or comments through the sections or contacts designed for this purpose;
  •       when requesting assistance regarding our projects and/or services;
  •       if you apply to work with us;
  •       if you subscribe to the newsletter service.
  1.   What data will you process?

When you browse and use the services on the BAM! Strategie Culturali Soc. Coop website, the following types of data may be processed:

  1. a) Navigation data

Certain personal data whose transmission is implicit in the browsing of the websites, including but not limited to data traffic and concerning location, weblog and other communication data for possible billing purposes or concerning the resources you access through your device, are acquired by the computer systems that enable them to function properly. Although this information is not collected in order to be associated with identified Data Subjects, it may allow users to be identified by its very nature and through processing and association with data held by third parties. For example, this includes the IP addresses or domain names of the computers used by users who connect to the website, the unique addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and browser used.

  •         Purpose of processing: to enable you to use the website safely and correctly;
  •         Lawful basis of the processing: the legitimate interest of BAM! Strategie Culturali Soc. Coop. in the proper functioning of the website and secure browsing, duly balanced with the rights of the Data Subject (Art. 6, paragraph 1, letter f, GDPR).

 

  1. b) Requesting information or quotes via the relevant sections

You can contact us via the contact form (https://www.bamstrategieculturali.com/contatti/) or using the contact details provided on the website to request information or assistance, including with regard to individual services available on the website; this entails the subsequent acquisition of the data you have provided us (first name, last name, email address, telephone number and the information contained in the message) and, of course, it means that you allow us to reply to you using the contact details you provided us with at the time of your request.

  •         Purpose of processing: to ensure adequate support for your needs and to respond to your requests;
  •         Lawful basis of the processing: the provision of the service you have requested (Article 6, paragraph 1, letter b, GDPR).
  1. c)   Work with us

You can contact us to apply for open positions by filling in the appropriate form in the “Work with us” section (https://www.bamstrategieculturali.com/lavora-con-noi/), thereby authorising the Data Controller to process your personal data for the aforementioned purpose. To this end, you will be asked to provide identification data (full name) and a contact email address, and you will also need to share a file containing your CV with us, as BAM! Strategie Culturali Soc. Coop requires this information to assess your application.

The provision of this data is only compulsory for the submission of an application, and it is therefore up to individual candidates to decide whether to proceed with the submission of their curriculum vitae: refusal to do so will result in the inability to use the service, without further consequences.

Consent to data processing is not necessary, pursuant to Article 111bis of Legislative Decree no. 196/2003 (the so-called Data Protection Act, as amended by Legislative Decree no. 101/2018) and Article 9, paragraph 2, letter b) of the GDPR, when the processing concerns data contained in curricula voluntarily submitted by candidates for the purposes of potential employment/collaboration, even where the data in question fall within the particular categories provided for by Article 9 of the GDPR (for example, in the event that the data in question must be known due to the employment relationship being established, with particular reference to whether the candidate belongs to protected categories or the need to carry out pre-employment medical examinations). At the time of any interview, interested parties will be provided with all additional information on the processing of their personal data.

The data will be kept for the period necessary to evaluate your request and, in any case, for a maximum period of two years. In addition, you can ask for your submitted data to be erased at any time by sending a special request to the Data Controller.

  •         Purpose of processing: to provide the service requested by the Data Subject and to assess the application received for potential employment;
  •         Lawful basis of the processing: executing the contractual relationship to which the Data Subject is party (Article 6, paragraph 2, letter b GDPR).
  1. d)     Sending marketing communications in the context of legitimate interest and soft spam

In some cases, we may use the email address provided by the user for the provision of the Data Controller’s services to send certain promotional communications, even without requesting the user’s prior consent. This processing will be carried out in compliance with the provisions of Article 6, letter f) of the GDPR and Article 130, paragraph 4 of Legislative Decree 130/2003. In greater detail, users are informed of the processing activity through this information notice and always have the right to object, simply and free of charge, to this processing: in fact, every communication from the Data Controller contains a reference to this information and indications on how to request an end to processing (by opting out), either by contacting the Data Controller or by directly selecting the appropriate link provided at the bottom of each message.

  •       Purpose of processing: to inform you about products similar to those you have previously purchased, and which may be of interest to you;
  •       Lawful basis of the processing: the regulatory provision of Article 130, paragraph 4, Legislative Decree 196/2003 that legitimises the sending of communications regarding services similar to those already purchased (Article 6, paragraph 1, letters c and f, GDPR).
  1. e) Newsletter

The newsletter is emailed to those who explicitly request it by completing the appropriate form on the website with their email address and authorising BAM! Strategie Culturali Soc. Coop to process their personal data for the aforementioned purpose. The service is only provided if the user explicitly and unequivocally consents (by ticking the appropriate box on the website) and the provision of data is only compulsory for the purpose of receiving the newsletter. Refusal will make it impossible to use the service, without further consequences.

The newsletter service is provided via the Brevo platform (formerly Sendinblue), operated by the company Sendinblue SAS, with head office at 106 Boulevard Haussmann – 75008, Paris, France, registration number 498 019 298; email: privacy@sendinblue.com and dpo@sendinblue.com. For further information, please read the Privacy Policy – https://www.brevo.com/it/legal/privacypolicy/.

In any case, to stop receiving the newsletter, simply select the unsubscribe link at the end of each email or send a specific request to the email address hello@bamstrategieculturali.com. The subscription cancellation process is partially automated, so further newsletters may be received after this request, although no later than 72 hours after the subscription cancellation request, when these newsletters had already been scheduled to go out prior to receiving the cancellation request.

  •         Purpose of processing: to send email communications to the interested party relating to BAM! Strategie Culturali Soc. Coop. services, news and updates on related topics, as well as offers and promotions reserved for subscribers to the service;
  •         Lawful basis for processing: the consent of the Data Subject (Article 6, paragraph 1, letter a, GDPR).
  1. f)       Cookies

What are cookies? A cookie is a small text file that stores brief information about your browsing on a particular website and is installed on your device when you log in. Each cookie contains various data (e.g., the name of the server it comes from, a numeric identifier, etc.), may remain in the system for the duration of a session (until the browser is closed) or for long periods, and may contain a unique identifier.

When you visit the website again, they will be redirected to the website that generated them (first-party cookies) or to those provided by third parties that can recognise them (third-party cookies). BAM! Strategie Culturali Soc. Coop. would like to reassure you about the security of the cookies on its website: they do not damage your device in any way, but they will speed up your browsing, providing you with a better experience.

What are they used for? Cookies are used for different purposes depending on their type: some are strictly necessary for a website to work properly (technical cookies), while others optimise its performance to offer a better user experience or enable the acquisition of statistics on website usage, such as analytics cookies, or allow personalised advertising to be displayed, such as profiling cookies.

The BAM! Strategie Culturali Soc. Coop website may use both cookies that do not require your consent for their installation (such as technical cookies) and cookies that require your prior consent before they can be used (such as profiling cookies). This information is shown in the banner displayed when you open the website and in the cookie settings panel that is always available on the website.

In greater detail, the following cookies may be activated on the website:

  1. Technical cookies (which do NOT require your consent):

These cookies are necessary for the website to work and allow you to access its functions (so-called navigation cookies) or to authenticate yourself during the session.

We also use functional cookies, which allow us to store your preferences and settings, thereby improving your website browsing experience.

To ensure their functionality, these cookies are generally not deleted when the browser is closed. However, they have a predefined duration (generally up to a maximum of 2 years) and are automatically deactivated after this period. These cookies and the data they collect will in no way be used for any further purposes.

Technical cookies are installed automatically when you access the website or to activate certain functions (e.g., by selecting the “remember me” option). You can decide to disable them at any time by changing your browser settings, although this may lead you to experience some problems viewing the website.

  •       Purpose of processing: to ensure the proper functioning and security of the website;
  •       Lawful basis of the processing: the legitimate interest of BAM! Strategie Culturali Soc. Coop. in the proper functioning of the website and secure browsing, duly balanced with the rights of the Data Subject (Article 6, paragraph 1, letter f, GDPR).
  1. Analytical cookies (which may NOT require your consent if anonymised)

These cookies track the choices made on the website and data relating to users’ online browsing (e.g., pages viewed, time spent on a page, etc.) in order to carry out statistical analyses, normally in an anonymous and aggregate form. If users are traceable and identifiable through these analyses, these tools may only be used with your consent.

When the following circumstances apply

–        the IP address was duly anonymised;

–        the information obtained with analytical cookies refers to a single computer resource (website, app, etc.) and is used only in an anonymous and aggregate form;

–        the cookie provider does not combine the information with other processing and does not pass it on to third parties,

complete anonymisation of the data collected is guaranteed and even cookies falling into this category can be activated without the need for user consent, precisely because the data processed cannot be linked to any identifiable user.

  •       Purpose of processing: to have statistics on user behaviour on the website, based on aggregated and anonymised data.
  •       Lawful basis for processing: as appropriate:

– the legitimate interest of BAM! Strategie Culturali Soc. Coop. in optimising website performance and improving the services provided through the website, duly balanced with the rights of the Data Subject (Article 6, paragraph 1, letter f, GDPR);

– the user’s consent (Article 6, paragraph 1, letter a, GDPR), which is freely given and revocable at any time, via the cookie banner or by following the instructions below and in the Cookie Policy link.

  1. Profiling and marketing cookies (which require your CONSENT):

This website also uses profiling and third-party cookies, the installation of which is subject to your prior consent given via the banner or managed at any time via the Cookie Policy that is always accessible via the appropriate button on the website.

Profiling cookies may comprise several categories, including advertising profiling, retargeting or social media cookies.

  •       Advertising profiling cookies: these create a user profile that allows you to view advertising content in line with the preferences you expressed when browsing the website;
  •       Retargeting cookies: these are created in order to send you advertising content related to products you have purchased or viewed on the website and in which you have expressed interest;
  •       Social media cookies: this website installs cookies relating to social media network plug-ins. These cookies are managed directly by third parties and enable the display of advertisements in line with your preferences.

When you access the website, a banner will inform you of the presence of profiling and retargeting cookies and, through it, you will be able to decide whether to consent to their installation, with the option to select the individual cookies you wish to install.

You may, however, revoke your consent at any time, without affecting your ability to visit the website and enjoy its contents.

The installation of profiling, retargeting, analytical and social media cookies, including any other activity linked to them, is managed through third-party services. For more information and to activate or deactivate these cookies, you can access the information provided directly by the third-party companies: the relevant list is available in our Cookie Policy.

The user is informed both through the short information notice (banner displayed until consent is given or denied) and through our Cookie Policy, which we invite you to read carefully for all other information on the cookies used on the website and for information on how to disable them.

  •       Purpose of processing: to analyse the user’s browsing behaviour in order to present personalised advertising;
  •       Lawful basis for processing: the user’s consent (Article 6, paragraph 1, letter a, GDPR), which is freely given and revocable at any time, via the cookie banner or by following the instructions below and in the Cookie Policy link.
  1. Social media plugins

The website includes some buttons that send the user to the Data Controller’s social media profiles. Only after clicking on these buttons, some cookies may be activated by the third parties that manage the social media networks for marketing and profiling purposes. The website Data Controller does not manage these tools directly but informs you of the possibility that they may be activated by using the website functions. For more information, including on how to disable these cookies, please read the social media networks’ privacy policies:

 

When you access the website, a banner will inform you of the possible presence of profiling and retargeting cookies and, through it, you will be able to decide whether to consent to their installation, with the option to select the individual cookies you wish to install.

You may, however, revoke your consent at any time, without affecting your ability to visit the website and use its contents.

The installation of profiling, retargeting, analytical and social media cookies, including any other activity related to them, is managed through third-party services. For more information about the use (or not) of these cookies by the website, and about their activation or deactivation, you can access the information provided directly by the third-party companies: the relevant list is available in our Cookie Policy.

Disabling via browser

Please note that at https://www.youronlinechoices.com/uk/ you can not only learn more about cookies, but also check the installation of many cookies on your browser/device and, where supported, disable them too.

Commonly used browsers (e.g., Internet Explorer, Firefox, Chrome, Safari) also accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: this function is generally and widely supported.

Cookies can therefore be easily disabled or deactivated by accessing the options or preferences for the browser in question, and third-party cookies can also usually be blocked. Generally speaking, these options will only apply to that browser and on that device, unless options to merge preferences on different devices are active. Specific instructions can be found on the options or help page of the browser itself. Disabling technical cookies, however, may affect the full and/or proper functioning of several websites, including this one.

As a rule, most browsers used today:

  •       offer the “Do not track” option, which is supported by some (but not all) websites. Thus, some websites may no longer collect certain browsing data;
  •       offer the option of anonymous or incognito browsing: this means that no data will be collected in the browser and no browsing history will be saved, but browsing data will nevertheless be collected by the operator of the website visited;
  •       allow stored cookies to be deleted in whole or in part, but on a new visit to a website they are usually installed if this possibility is not blocked.

Please see the following links to the support pages of the most widely used browsers (with instructions on how to disable cookies on those browsers):

  1.   For what further purposes can you use my data?

Your personal data may also be used for the purpose of:

  1. a)       complying with legal obligations and requests from public or government authorities;
  2. b)     managing any disputes or litigation and thus defending the rights of BAM! Cultural Strategies Soc. Coop., both in and out of court.

In such cases, the lawful basis for processing will be:

–          for point a), the fulfilment of a legal obligation;

–          for point b), the legitimate interest of the Data Controller in the protection of its rights, provided that it is appropriately balanced, on a case-by-case basis, with the rights of the Data Subject.

  1.   With whom will you share my data?

In accordance with the purposes indicated in the previous section, the staff of BAM! Strategie Culturali Soc. Coop. may be assigned to process your data in order to provide you with the services, information or support requested.

Therefore, access to your personal data will be expressly authorised by the Data Controller, which, should it be necessary, may appoint the subjects it uses for the provision of services and for activities falling within its competence as Data Processors pursuant to Articles 28 and 29 of the GDPR.

In this regard, we must point out that:

–        the newsletter service is provided via the Brevo platform, operated by the company Sendinblue SAS, based at 106 Boulevard Haussmann – 75008, Paris, France, registration number 498 019 298; email: privacy@sendinblue.com and dpo@sendinblue.com;

–        the list of cookie providers is available in the Cookie Policy;

We would also like to remind you that the list of Data Processors is available from the Data Controller, from whom you can request it using the contact details given above.

Users’ data shall under no circumstances be passed on to third parties except where the nature of the services rendered requires it, or where, by virtue of a legal obligation or in the presence of its legitimate interest, the Data Controller needs to communicate them to the competent judicial or supervisory authorities.

  1.       How will you process my data?

Your personal data will also be processed with the aid of electronic means for the time strictly necessary to achieve the purposes for which it was collected.

BAM! Strategie Culturali Soc. Coop. will take the necessary technical and organisational measures to prevent the loss, unlawful or incorrect use of data, as well as to prevent any form of unauthorised access by third parties.

Therefore, BAM! Strategie Culturali Soc. Coop. will guarantee the security of your personal data by limiting the number of people who will be allowed access to the servers or databases and by putting in place protection systems to avoid the risk of cyber attacks.

  1.       Will my data be processed outside Europe?

The data processed by BAM! Strategie Culturali Soc. Coop. is kept in servers located in Italy.

However, some providers of cookie services are based in countries outside Europe, particularly the United States, as also expressly mentioned in our Cookie Policy.

In such cases, personal data may also be transferred to servers located in the United States: in these cases, compliance with the safeguards provided for and required by the adequacy decision adopted by the European Commission on 10 July 2023 concerning personal data transferred from the EU to US companies and their adoption by the relevant provider will always be verified. Therefore, all necessary precautions will be taken to guarantee the best possible protection of personal data by basing such transfer: a) on adequacy decisions of third-party recipients expressed by the European Commission; b) on adequate guarantees expressed by the third-party recipient pursuant to Article 46 of the Regulation; c) on the adoption of binding corporate rules and, in particular, by preparing technical and IT security measures that best protect personal data and the rights of the Data Subjects, as provided for by the GDPR and European legislation.

  1.   How long will you keep my data?

BAM! Strategie Culturali Soc. Coop. will process your personal data for the time reasonably necessary to achieve only the purposes listed above, which can be consulted in the “What data will you process?” section, or for the storage periods laid down by the relevant legislation. In addition:

– data relating to your CV and application will be kept for two years;

– data used for sending the newsletter will be kept until you request cancellation;

– data used for soft-spam communications will be kept until you request erasure or for two years from the last time you expressed interest in BAM! Strategie Culturali Soc. Coop. (for example, by contacting us through the website);

– you can find information on the deletion of data processed via cookies in our Cookie Policy.

At the end of the storage period, your personal data will be deleted or irreversibly anonymised.

  1.   Links to third-party sites and social media networks

The website may contain links to and from our partners’ websites, as well as to advertisers and social media networks. Please note that the Data Controller assumes no responsibility for any personal data that may be collected through these websites and the use of their services and that, if you follow a link to any of these websites, you are invited to consult the privacy policies pertaining to each external party with respect to the website.

  1.   What are my rights and how can I protect my privacy?

In relation to your personal data and in compliance with the GDPR, BAM! Strategie Culturali Soc. Coop. informs you that you have the right to request:

  •       access to your data;
  •       modification and rectification of any errors in our databases relating to your data;
  •       the erasure of your data if they are held in the absence of the legal prerequisites;
  •       the restriction of the processing of your data;
  •       opposition to data processing;
  •       data portability.

Forms and more information are also available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924.

 

The following table provides a detailed explanation of how to exercise your rights:

 

YOUR RIGHT HOW CAN YOU EXERCISE IT?
Access You can ask:

●        For confirmation of any processing involving your personal data;

●        To have a copy of your data;

●        To be provided with other information about your personal data that is not already in this policy.

 
Rectification You can request the rectification of inaccurate or incomplete personal data.

Before proceeding with rectification, we will check the accuracy of the data in our files.

 
Erasure /

Right to be forgotten

 You can request the erasure of your personal data, but only if:

●        Keeping them is no longer necessary in relation to the purposes for which they were collected;

●        You have revoked your previously given consent (where processing is based on consent);

●        The processing was carried out unlawfully;

●        It is necessary to comply with a legal obligation to which BAM! Strategie Culturali Soc. Coop. is subject (in relation to an order from an Authority).
Restriction You can ask for your personal data to be restricted, but only if:

●        Their accuracy has already been disputed;

●        They are no longer necessary for the purposes for which they were collected, but there is a legal challenge regarding their use;

Following your request for restriction, the use of your personal data is, however, permitted when:

●        Your consent is still in place;

●        It is necessary to take or fight legal action;

●        To protect the rights of another natural or legal person involved in the processing.

 
Portability You can request a copy of your personal data in a structured, readable and commonly used format.

 
Objection You can object at any time to the processing of personal data concerning you when:

●        the basis for the lawfulness of the processing is the legitimate interest of the Data Controller;

●        personal data are processed for direct marketing purposes, including profiling insofar as it is related to such direct marketing.

When you object:

●        to processing for direct marketing purposes, personal data will no longer be processed for such purposes;

●        in the event of a legitimate interest on the part of the Data Controller, processing may continue only if the Data Controller demonstrates the existence of compelling legitimate grounds for proceeding with the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.

It is also possible to exercise the right of objection by automated means using specific methods, such as those made available on the personal page on the website and in emails (cancellation links).

BAM! Strategie Culturali Soc. Coop. guarantees that any request concerning your rights will be answered within thirty days of receipt.

  1.   Can I file a complaint?

You have the right to file a complaint with the Personal Data Protection Authority if you believe that the processing carried out by BAM! Strategie Culturali Soc. Coop. does not comply with the requirements of European Regulation no. 679/2016 and national legislation.

In Italy, the competent authority is the Garante per la protezione dei dati personali, whose contact details can be found at http://www.garanteprivacy.it/.

More information and the sample document to be used for the complaint can be found here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 .

In addition, if the prerequisites set out in Articles 78 and 79 of the GDPR are met, you have the right to bring an action before the competent court.

  1.   Possible modifications

The information we are providing you with now may change over time, when processing activities change, when the data collected changes, when legislative or regulatory changes occur, or when technological developments occur. We therefore advise you to periodically consult this Privacy and Cookie Policy, which is always updated on this page.