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Newsletter Policy

Notice pursuant to Art. 13 EU Regulation 2016/679 for the Processing of Personal Data

Data Controller

We inform you that, in accordance with EU Regulation 2016/679 (infra: “Regulation”), your Personal Data will be processed by Creazioni Artistiche Musicali - C.A.M. s.r.l con sede in Galleria del Corso, 4 - 20122 Milano (MI), as data controller ("Data Controller”).

Purpose, legal basis and voluntary nature of the processing

The Data Controller will process your personal data (art. 4.1 of the Regulations) specifically your first name, last name and e-mail address, for the following purpose: 

Sending via automated tools (e-mail, push notifications, SMS) of newsletters and promotional and marketing communications about the Owner's products and initiatives, including communications aimed at conducting market research and participation in prize shows and events.

It should be noted that the Data Controller collects a single consent for the marketing purposes described herein, pursuant to the General Provision of the Guarantor for the Protection of Personal Data “Guidelines on Promotional Activities and Countering Spam” of July 4, 2013; if, in any case, you wish to object to the processing of your data for marketing purposes performed by the means indicated herein, as well as to revoke the consent given; you may do so at any time by contacting the Data Controller at the contact details indicated in this notice, without affecting the lawfulness of the processing based on the consent given before revocation.

The legal basis of processing for the above purposes refers to the expression of consent by the data subject to the processing of his or her personal data (Art. 6.1.a of the Regulation).

The provision of your Personal Data is voluntary; no consequences are foreseen in case of your refusal.

Recipients of personal data 

Your Personal Data may be shared with:

persone persons authorized to process your Personal Data in accordance with Articles 29 and 32(4) of the Regulations and 2-quaterdecies of the Privacy Code (e.g., employees of the Company who must process your Personal Data by reason of their job duties, system administrators;

subjects who, in the provision of services in favor of the Company, process data on behalf of the Company itself and typically act as Data Processors (e.g., contracting companies in the case of entrusting work, even partial, to external companies; third parties involved in the management of information systems and web platforms; third-party collaborators that the Company uses for specific services of a technical and/or organizational nature - such as IT service providers, external collaborators and consultants; companies belonging to the Group; etc.). For a complete and updated list of Data Processors, write to privacy@sugarmusic.com 

entities and authorities, which normally act as autonomous Data Controllers within the meaning of Article 4(7) of the Regulation, to which it is mandatory to communicate your Personal Data in accordance with the regulatory provisions applicable to the Company or by virtue of contractual obligations or in execution of pre-contractual measures.

 

With regard to the possible transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the modalities allowed by the applicable law, such as the consent of the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures adopted at the request of the Data Subject; the conclusion or execution of a contract concluded between the Data Controller and another natural or legal person in favor of the data subject; the adoption of Standard Clauses approved by the European Commission; the selection of entities operating in countries considered safe by the European Commission. You can get more information, upon request, from the Data Controller at the contacts above.

How your personal data will be processed 

In relation to the stated purposes, the processing of personal data is carried out using manual, computer and telematic tools with logic strictly related to the purposes themselves and, in any case, in such a way as to ensure the security and confidentiality of the data, in addition to compliance with the specific obligations enshrined in the law.

Data retention

Your Personal Data will be kept only as long as necessary for the purposes for which it is collected, respecting the principle of minimization set forth in Article 5(1)(c) of the GDPR. In particular, Your Personal Data will be kept for 24 (twenty-four) months. 

More information is available from the Data Controller.

I suoi diritti privacy (ex artt. 15 e ss. del Regolamento)

You have the right to request from the Company, at any time, access to your Personal Data, its rectification or erasure, the restriction of processing, and to receive the data concerning you in a structured, commonly used, and machine-readable format in the cases provided for under Article 20 of the Regulation.

We also inform you that you have the right to object ex art. 21 of the Regulation, for legitimate reasons, to the processing of your data, for example you may object at any time to the sending of direct marketing with automated tools (sms, mms, email, push notifications, fax) and not (paper mail, telephone with operator); moreover, it remains without prejudice to the possibility of exercising this right in part, that is, in this case, objecting, for example, only to the sending of promotional communications carried out by automated tools. 

At any time you may revoke ex art. 7 of the Regulation, the consent already given, without affecting the lawfulness of the processing carried out prior to the revocation of consent.

Requests should be addressed in writing to the Data Controller at the following address.: privacy@sugarmusic.com 

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Data Protection Authority), pursuant to Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to applicable law.

(Version 1 of 30th January 2025)