PRIVACY POLICY
Information on the processing of personal data pursuant to Article 13 of EU Regulation 2016/679
Pursuant to and for the purposes of the provisions of EU Regulation 2016/679 and subsequent amendments relating to the protection of personal data, we inform you of how we process, store, and protect the data you provide when applying for the Venture Building program on the website https://www.vento.ventures/ (hereinafter the "Program").
By completing the aforementioned form, you declare that you have accepted the terms and conditions referred to in the following link.
Privacy is very important to us, and we want you to always feel protected. For this reason, we invite you to read this policy carefully.
By subscribing to the service, you share only the information that allows us to provide the service.
Below we clarify:
1. Who is the Data Controller of your data;
2. What data we use;
3. The purposes for which we process your data;
4. On what legal basis we collect your data;
5. How your data is used;
6. Which data is mandatory and which is optional;
7. How long your data is retained;
8. To whom your data may be communicated;
9. Autonomous data controllers;
10. Data transfer;
11. What your rights are.
1. Who is the Data Controller of your data
The Data Controller of your personal data is Vento S.r.l., in the person of the legal representative pro tempore, VAT No. 12783920015, with registered office in Turin - Via Carlo Francesco Ormea 48, 10125, email: info@vento.ventures, PEC: vento1@legalmail.it.
The Controller reserves the right to appoint a Data Protection Officer (DPO), whose name will be promptly communicated to the data subject.
2. What data we use
When applying for the Program, you will be asked for the following data: Name, Surname, Email, LinkedIn profile.
The Controller does not collect additional categories of personal data beyond those indicated above for the declared purposes and is not responsible for any additional personal information spontaneously provided, even via email and/or telephone.
3. Purposes for which we process personal data
Your personal data will be processed for the following purposes:
1. Applying to the Program in compliance with the Terms and Conditions;
2. Once selected, participating in the Program;
3. Sending you marketing and/or promotional communications;
4. Subscribing you to our newsletter;
5. Fulfilling fiscal, accounting, and administrative obligations, including anti-money laundering;
6. Transferring personal data to Vento's partner companies for recruitment purposes.
4. On what legal basis we collect your data
The legal basis for the processing for the purposes referred to in letters a) and b) of the previous paragraph is the performance of the contract pursuant to Art. 6(1)(b) of EU Regulation 2016/679. The legal basis for the processing for the purposes referred to in letters c), d), and f) is explicit consent pursuant to Art. 6(1)(a) of EU Regulation 2016/679. The legal basis for the processing for the purpose referred to in letter e) is the necessity to comply with a legal obligation pursuant to Art. 6(1)(c) of EU Regulation 2016/679.
5. How your data is used
Your data is collected, recorded, stored, and used for the execution of the service. Your data is processed electronically and stored on databases and servers of Vento S.r.l. Your personal data is protected to minimize the risk of destruction, loss, unauthorized access/use, or use incompatible with the initial purpose of the collection. This is achieved through the application of technical and organizational security measures by Vento S.r.l. Some of the main security measures employed by Vento to protect the personal data of the data subject include:
Specific instructions to Vento personnel authorized to process the data, continuous training of authorized personnel;
- Access control to IT systems;
- Encryption in data storage;
- Encryption in data transmission;
- Firewalls and antivirus;
- Pseudonymization of data.
6. Which data is mandatory and which is optional
Providing personal data for the purposes referred to in letters a) and b) is mandatory, as well as accounting and fiscal data for the purpose referred to in letter e). Failure to provide such personal data will make it impossible to proceed with the execution of the service. Providing personal data for the purposes referred to in letters c) and d) is optional and does not affect the execution of the service.
7. How long your data is retained
The data collected will be retained for the next 3 years and subsequently for legal obligations up to 10 years. Personal data used for sending commercial communications, any profiling, and newsletter subscription will be retained for 24 months from consent acquisition.
8. To whom your data may be communicated
For the pursuit of the aforementioned purposes, your personal data may be communicated/known to the following categories of recipients:
The Controller's collaborators specifically authorized;
Third parties involved in the execution of the provided service or performing technical, organizational, and operational tasks on behalf of Vento.
The third parties to whom personal data may be communicated act as: 1) Data Controllers, i.e., subjects who determine the purposes and means of processing personal data; 2) Data Processors, i.e., subjects who process personal data on behalf of the Controller.
In particular, the data processors are:
Hosting cloud services and infrastructure: Netlify Privacy Policy (netlify.com);
Analytics services:
Google Analytics, Privacy Disclosures Policy - Analytics Help (google.com);
Bryq form Privacy Policy | Bryq Software
TeamTailor Privacy Policy | TeamTailor Software
Tally Privacy Policy | Tally Software
Substack Privacy Policy | Subastack Software
Display of content from external platforms:
Google Fonts, Privacy Policy – Privacy & Terms – Google
Professionals and consultants (e.g., accountants).
9. Autonomous Data Controllers:
- Vento's partner companies;
- Authorities in specific cases to exercise rights and meet specific requests;
- Any other companies in case of merger or acquisition.
10. Data Transfer
Your data may be transferred outside the European Union. The Controller ensures that any transfer of personal data to non-EU countries will be carried out in accordance with the provisions of the GDPR. Personal data will not be disclosed without your prior consent.
11. What your rights are
We illustrate what your rights are so you always have control over your privacy and your information. You can exercise the rights provided for in Articles 15 to 22 of EU Regulation 2016/679 by sending an email to the Data Controller at info@vento.ventures and PEC vento1@legalmail.it.
You have the right to:
1. Have confirmation of the existence or otherwise of your personal data and request that such data be made available to you in a clear and comprehensible manner. In particular, you can request information and, where appropriate, a copy of the origin and category of your personal data, the logic of use, the purposes and methods of processing, the identification details of the Controller and processors, the subjects or categories of subjects to whom your personal data may be communicated or who may become aware of it, the period for which your data will be retained or the criteria used to determine this period, where possible, the existence of an automated decision-making process, including profiling, the logic used, the importance and the expected consequences for you.
2. Obtain without justified delay the update, modification, or rectification of your inaccurate data or the integration of your incomplete data if you have an interest.
3. Obtain the deletion of your data whenever the data is no longer necessary for the purposes for which it was collected or otherwise processed, or when you decide to withdraw consent or oppose the processing, or still when the data is processed unlawfully or deleted to comply with a legal obligation.
4. Obtain the restriction of processing in the event of:
a. Contestation of the accuracy of personal data if you do not prefer to request the modification, update, or rectification of your data;
b. Unlawful processing by the Controller to prevent deletion;
c. Exercise of a right in judicial proceedings;
d. Verification of the possible prevalence of the Controller's legitimate reasons over those of the data subject.
5. Receive, where the processing is carried out by automated means, without hindrance and in a structured, commonly used, and machine-readable format, the personal data concerning you that you have provided to us, with prior consent or under a contract, for transmission to another Controller or – if technically feasible – obtain direct transmission from one Controller to another.
6. Object at any time, in whole or in part:
a. For legitimate and prevailing reasons related to your particular situation, to the processing of personal data concerning you;
b. To the processing of personal data concerning you for marketing purposes.
7. Not be subjected to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you in a similar way.
8. Withdraw consent at any time.
In all the cases mentioned above, if necessary, the Controller will notify the third parties to whom your personal data has been communicated of the possible exercise of your rights, except for specific cases (e.g., when this fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right).
Finally, for the processing referred to in this information, you have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).
This information may be subject to changes. For any updates, we invite you to consult our website and the other channels made available.