As of May 25th The General Data Protection Regulation (GDPR) (EU) 2016/679 is applicable, a regulation in EU law on data protection and privacy for all individuals within the European Union.
Impact Hub Milano is committed to GDPR compliance, and we have been working to make sure that we are achieving a high standard in privacy protection. We will be compliant prior to the May 25, 2018 enforcement date and have set-up our Privacy Policy to include GDPR-related specifications.
Below is our Privacy Policy. In addition to this Privacy Policy, Impact Hub Milano also has terms of service.
Privacy & Cookies Policy
Effective Date: May 24, 2018
This Privacy Policy belongs to Impact Hub Srl, formally residing at Via Aosta 4 20155 Milano Italy and registered under Italian Chambre of Commerce number MI-1903563 (Impact Hub Srl).
You can contact us via:
- milan.impacthub.net
- [email protected]
1. INTRODUCTION
1.1 As a consumer you have the right to protection of your personal data. How Impact Hub Milano performs this protection is described in this Privacy Policy. This policy describes the purpose of the registration and which data are recorded in which way. We are committed to safeguarding the privacy of our (website) visitors and Impact Hub Milano members, clients and partners.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of (website) visitors and Impact Hub Milano members, clients and partners; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 We use cookies on our website for the provision of our website and services, as well as for analytics purposes to help us improve our product offering.
1.4 The Impact Hub Milano service incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive some types of emails and what profile information is registered. You can access these controls from your Impact Hub Milano profile on the admin portal and on the Community App. Below each newsletter there is a button to unsubscribe.
1.5 In this policy, “we”, “us” and “our” refer to Impact Hub Milano as a provider.
2. HOW WE USE YOUR PERSONAL DATA
2.1 In this Section 2 we have set out:
- the general categories of personal data that we may process;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name, company name, contact- and address details and data required to process invoices and payments (for example your bank account number). The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website and tools, providing our services, ensuring the security of our online tools, administrative processing of invoices and payments and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our services OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information contained in any inquiry you submit to us regarding services (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent OR your directly communicated interest in the relevant services.
2.5 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your company, your job title or role, your contact details, information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our customer relationships.
2.6 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your payment identification data and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.7 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us.
2.8 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with members and clients.
2.9 We may process information that you provide to us for delivering our services (“service delivery data“). The service delivery data may include information about your personal skills, your company, information related to you as an entrepreneur and the status of your entrepreneurial trajectory. The correspondence data may be processed for the purposes of providing you with our services and supporting you in your entrepreneurial trajectory thru our programmatic activities, courses and/ or events. The legal basis for this processing is consent OR the performance of a contract between you and us.
2.10 We may process any of your personal data identified in this policy for statistical and academic analysis. The data may be processed for the purpose of improving our services, tracking our performance or to advance general scientific knowledge in the field. When we make use of external providers for the analysis of such data we make sure that the data are either available in the public domain already, processed with your consent or anonymized in such a way that an individual subject cannot be identified. The legal basis for this processing is consent OR our legitimate interests, namely advancing the field of social innovation and entrepreneurship.
2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. PRINCIPLES OF DATA PROTECTION
3.1 In this Section 3, we provide information about the principles of data protection that we adhere to.
3.2 Impact Hub Milano will protect the data files so that only the authorized personnel defined by Impact Hub Milano, have access to the file. These Impact Hub Milano authorized personnel may be Impact Hub Milano employees or subcontractors. Impact Hub Milano ensures that all data systems and computer equipment are sufficiently protected with appropriate technical methods, including passwords and personal user IDs.
3.3 If Impact Hub Milano uses third parties for technical maintenance of the data or for support and processing functions, Impact Hub Milano strives to ensure, that the subcontractor can and will protect the registered data as required in accordance with applicable data policies.
3.4 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.5 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. TRANSFER OF YOUR PERSONAL DATA
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 Impact Hub Milano generally has its operations in Italy. Some of our services are provided by the Global Impact Hub association, which resides in Vienna, Austria.
4.3 We employ a number of third party data processors (the most important ones are listed in Section 4.4, the complete list is available upon request). Transfers to these processors will be protected by appropriate safeguards, namely the use of standard data protection clauses and/or the EU-U.S. Privacy Shield. We will take reasonable and appropriate steps necessary to ensure that all third parties engaged as sub-processors are processing the personal information we entrust to them in a manner that is consistent with the requirements of the GDPR.
4.4 Third party processors:
| Processor Name: | Processing Activities: | Data Location(s): |
| Nexudus | Cloud Member and Client Relationship Management Services and Invoice Provider | United Kingdom |
| Impact Hub GmbH | Hosting, Technical, Content and Service Provider | Austria |
| Google, Inc. | Cloud Data and Service Provider | United States |
| Gust | Startup Deal Flow Provider | United States |
| Salesforce | Cloud Collaboration Platform and Member Directory | United States |
| Eventbrite | Cloud Event Services and ticketing | United States |
| Campaign Monitor | Cloud Mailing Provider | Australia, United Kingdom, United States |
| WordPress.org | CMS – Content Management System | The Netherlands |
| Profis | Electronic Invoicing System | Italy |
5. RETAINING AND DELETING PERSONAL DATA
5.1 We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. After this data is no longer necessary, we will delete or anonymize data in our possession within a reasonable time frame, except such data as we determine may be needed to resolve disputes, enforce agreements, and comply with business, technical, or legal requirements related to our business.
6. AMENDMENTS
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We will notify you of significant changes to this policy by email, newsletter or through the Impact Hub Milano software.
7. YOUR RIGHTS
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others, or in circumstances where the retrieval of such data would pose an undue burden on the data processor.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. The contact information of our EU Representative may be found in Section 13.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
8. ABOUT COOKIES
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. COOKIES THAT WE USE
9.1 We use cookies to:
- recognize your browser and user session
- keep track of what pages you have visited
- store your user preferences
- perform analytics to help us make our service better, and to
- assist with administration and security for our website and software
10. COOKIES USED BY OUR SERVICE PROVIDERS
10.1 Our service providers may use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
11. MANAGING COOKIES
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-websitepreferences (Firefox);
- http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies (Internet Explorer);
- https://support.apple.com/kb/PH21411 (Safari); and
- https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
