Calenti & Partners S.r.l. (hereinafter, for brevity, the “Company” or the “Data Controller”), in its capacity as the Data Controller, wishes to inform you, pursuant to the applicable data protection regulations, including European Regulation 679/2016 on the protection of personal data (the “Regulation”), that the personal data you provide at the time of establishing the relationship and throughout its duration will be processed in compliance with the applicable legislative and contractual provisions for the purposes and in the manner set forth below. In certain circumstances, some data may also be collected from third parties, where necessary and always in compliance with the applicable regulations.

1. Identity and Contact Details of the Data Controller
The Data Controller is Calenti & Partners S.r.l., with its registered office at Via Plinio No. 11, Milan.

2. Categories of Personal Data, Purposes, and Legal Basis of Processing
The Company may process:
- identification and contact data: first and last name or company name, tax code or VAT number, residence or registered office, email address, phone number;
- tax-related data or any other data necessary to process or receive payments.
The personal data mentioned above are processed for the following purposes and on the basis of the following legal grounds:
a. to fulfill obligations arising from the law and/or the existing contract with the Company, to which this notice is attached, and to provide the requested consulting and assistance services; in this case, the lawfulness of processing is based on the necessity of complying with legal obligations related to the establishment and management of the employment relationship (Art. 6.1, letters b and c of the Regulation);
b. management of potential disputes and protection of the Company’s rights; in this case, the lawfulness of processing is based on the necessity of pursuing the Company’s legitimate interest (Art. 6.1, letter f of the Regulation);
For these purposes, your consent is not required.
c. The provided data may also be processed for the purpose of sending newsletters, informational communications, or for marketing purposes; in this case, the lawfulness of processing is based on your consent (Art. 6.1, letter a of the Regulation).

3. Methods of Processing and Nature of Data Provision
Personal data will be processed by the Company using both digital and paper-based systems, in accordance with the principles of fairness, integrity, and transparency as established by the applicable data protection regulations, while safeguarding your privacy and rights through the implementation of appropriate technical and organizational measures to ensure a level of security commensurate with the risk.
The provision and updating of your personal data is mandatory under applicable laws (e.g., tax regulations or others) or for the execution of the contractual relationship. Without such data, it will not be possible to establish or – in certain circumstances – continue the relationship.
The provision of data for the purposes outlined in point 2.c. is optional, and failure to provide such data or the withdrawal of consent to processing will not affect the contractual relationship but will only result in the inability to process the data for the purposes indicated therein.

4. Data Retention
All data relating to you will be stored in compliance with civil and tax obligations (for example, the legal obligation to retain accounting records and additional business correspondence for 10 years) and, in any case, only for the duration of the existing contract. Once the relationship has ended, to protect the Company’s rights, the data will be retained – accessible only when necessary – for a period corresponding to the statute of limitations for any rights you may claim against the Company. This period varies depending on the type of data and any factors that may interrupt or suspend the running of the statute of limitations.
If you consent to the processing of data for the purposes referred to in point 2.c., such data will be retained for a maximum period of 24 months from the date of collection.

5. Data Recipients
Your data will not be disclosed, but, for the purposes indicated above and in compliance with the principles of the Regulation, may be communicated to: the Company’s employees, its collaborators, consultants, and professionals (in particular, by way of example: accountants; communication agencies). In fulfilling legal obligations, those arising from the contractual relationship, or at your request, data may be disclosed to public bodies or public authorities.

6. Data Transfer
Your data will be stored at the Company’s headquarters and on its servers (both located in Italy), as well as on the servers of communication agencies situated within the EU, and, in any case, will not be transferred outside the EU.

7. Data Subject Rights
The data subject may exercise, in relation to the data processing described herein, the rights provided by the applicable data protection regulations, including the right to:
- receive confirmation as to the existence of personal data concerning them and access its content (right of access);
- update, modify, and/or correct their personal data (right to rectification);
- request the erasure or restriction of processing of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction of processing);
- object to processing based on legitimate interest (right to object);
- withdraw consent, where given, without prejudice to the lawfulness of processing based on consent before its withdrawal;
- lodge a complaint with the supervisory authority in the event of a breach of data protection laws;
- receive a copy of the data in electronic format relating to them, provided in the context of the employment contract (e.g., salary data, internal mobility services), and request that such data be transmitted to another data controller (right to data portability).
To exercise these rights, you may contact the Company at any time by sending your request to the following email address: privacy.emaitaly@ema-partners.com, or by registered mail with return receipt to the following address: Via Plinio No. 11, Milan, Italy.