PRIVACY POLICY

1. Which company will process Your personal data*?

Infranity SAS with registered office in 6 rue Ménars, 75002 Paris, will process* Your personal data as Data Controller* in accordance with Regulation (EU) 2016/679 (hereinafter the “GDPR”).

If You wish to contact Us, You can use the following contact details:

• Contact@infranity.com

If You wish to submit any questions or exercise a right regarding the processing of Your personal data, You can contact the Company’s Data Protection Officer*, by using the following contact details:

By mail:

• 6 rue Ménars, 75002 Paris, to the attention of the Data Protection Officer/RCCI

By e-mail:                                                         

• Contact@infranity.com

Effective as from 15/10/2021

This Privacy Policy provides users (hereinafter “You” or “Your”) of the website [www.Infranity.com] (hereinafter the “Website”) with the information on the processing of their personal data, collected by the Company by means of the Website, in the context of Your use of the Website and the services available on the Website, under Articles 13 and 14 of the GDPR.

Unless otherwise specified herein, this Privacy Policy does not apply to any other data referred to You, collected by the Company by or through any other means, such as information collected offline and on other websites of the entities of the Generali group that You might access via any link found on the Website.

The Company may provide You with further specific information on the processing of Your personal data, along with the relevant request of consent, if needed. This information may also be provided within other webpages of the Website, in case You should make specific requests to the Company, by providing the latter with Your personal data. Those privacy information notices and consents will be respectively provided and obtained prior to the processing of these further categories of personal data.

The Company cares about the confidentiality, protection and safety of Your personal data. In order to help You in understanding this Privacy Policy, You can find a glossary on the last page of this Privacy Policy, which includes the definitions of the main terms used herein.

We strongly recommend You to carefully read this Privacy Policy before browsing through the pages of the Website.

We may amend this Privacy Policy, from time to time, also as a consequence of any legal or regulatory changes. However, the updated version of this Privacy Policy will always be available on the Website, to be consulted by You.

2. How do We process Your personal data and what is the legal basis for the processing of this data?

The Company will process Your personal data in compliance with the obligations to which the Company is subject to under the GDPR.

The Company will process Your personal data (as better identified in Section 4 below) to pursue the following purposes:

1. Providing the services offered through the Website, including the possibility of obtaining answers to the requests for information or assistance that You should submit to us (hereinafter “Contractual Purposes“);
2. Complying with the obligations set forth by applicable laws, including responding to possible requests submitted to us by governmental authorities and supervisory bodies (hereinafter “Law Purposes“);
3. Carrying out activities functional to the sale of companies or business units, acquisitions, mergers, spin-offs or other operations that may affect the Company, as well as executing such operations;
4. Developing and improving the services offered through the Website, by carrying out statistics on the use of the Website (e.g. analysing the most visited pages, etc.) and checking its functioning; and
5. Establishing, exercising or defending of legal claims;

(the purposes of the processing listed under letters from c) to e) above are hereinafter jointly referred to as “Legitimate Business Interest Purposes”).

Based on the legitimate interests of the Controllers to establish and maintain beneficial and optimal professional relationships with current and prospective clients (Article 6, letter f, GDPR), Your personal data shall be processed by the Controller for the following purposes:

• Inviting You to events, meetings, workshops, roundtables, congresses (including professional training), identified as of specific interest to You, organised and managed by the Controller identified from time to time in the invitations (brochures and/or presentations) that will be previously mailed or delivered to You to allow You to register for the event (hereinafter, respectively, the “Event(s)” and the “Partner(s) in the Event”); executing complementary activities following Your registration for the Event, such as, for example, activities related to the organisation and management of the Event itself; if You attend, using Your personal images that may have been collected in the course of the Event for possible publication on different (paper, tape and/or digital) supports, or through other means of communication or media, including websites, portals and social networks present on the internet;
• Sending You newsletters, publications, studies, survey results, market analyses or analyses of specific industries or businesses, and any other type of professional information material, identified as of specific interest to You, prepared or published by the Controller, independently or in cooperation with other entities identified from time to time in the specific document (hereinafter, the “Publications” and “Publication Partners”, respectively).

Moreover, also on the basis of the legitimate interests of the controller, Your personal data shall be processed without your consent by Infranity for the following purposes:

• carrying out customer relationship management, consisting mainly in tracing and managing the relationships and interactions through the professionals belonging to it, develop with the ‘contacts’ of current and prospective clients, and any other persons/entities with whom/which Infranity have developed business relationships, for the purpose of understanding their needs and expectations, improving services offered, developing new services based on the market’s requirements, as well as growing the business. For those purposes the personal information of ‘contacts’, including Your personal information, will be entered into special data bases owned by or available to the Controllers and will thus be made accessible to Infranity. Where specific obligations of confidentiality or professional secrecy exist, as well as when there are particular reasons of expediency, Your personal information will be made available, depending on the circumstances, solely to Infranity, or solely to the Controllers, i.e., solely to the members of the team of the Controller assigned to the specific professional engagement. In any case, it is agreed that You may be contacted, for customer relationship management purposes, only through the professionals who operate within Infranity with which You have established the main relationship.

In case the Company wishes to process Your personal data for purposes other than the ones listed above, the Company will prior provide You with any required information under the GDPR, and collect Your consent, where needed.

The Company does not process Your personal data only based on automated decision-making processes.

3. Why do We ask You to provide Your personal data?

1. The processing of Your personal data for Contractual Purposes (please see Section 2, let. a), above) is carried out pursuant to Article 6.1, let. b) of the GDPR and is mandatory, given that otherwise We would not be able to allow You to browse the Website or assist You in relation to Your requests. If You don’t want Us to process Your Identification Data (as defined under Section 4, letter a), below), You will not have to send us a request of information.
2. The processing of Your personal data for Law Purposes is mandatory, as it is necessary to enable Us to comply with applicable laws.
3. The processing of Your personal data for Legitimate Business Interest Purposes (please see Section 2, letters from c) to e) above) is based on Our legitimate interests, pursuant to Article 6.1, let. f) of the GDPR, which have been adequately balanced with Your interests and rights, as the processing of Your personal data is carried out only to the extent it is strictly necessary to pursue such purposes. However, You may object to the processing of Your personal data, by following the instructions specified under Section 6 below, unless We have an overriding interest on further processing Your personal data or in case the processing of Your data is necessary to establish, exercise or defend of legal claims.

4. Categories of personal data processed

We will process Your personal data only to the extent necessary to achieve the above-mentioned purposes. In particular, We will process the following categories of personal data referred to You:

1. Data voluntarily provided by You, by submitting to Us any requests for information or assistance by means of the Website or using Our contact details available on the Website. This data might include Your name, surname, address, occupation, job title, employer/associated company, phone number and email address, as well as any other information referred to You that You should provide to Us by requesting information or assistance; (hereinafter jointly referred to as “Identification Data”);
2. Browsing data relating to the use of the services on the Website made by You, such as Your IP addresses or domain names of Your devices, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server and other parameters relating to Your operating system and computer environment (hereinafter jointly referred to as “Browsing Data“). This data is automatically collected by means of the cookies* installed on the Website, in accordance with Our cookie policy, which is available at the following link. The collection of the Browsing Data does not aim at matching this data with You and We process this data in aggregate form. However, We may be able to identify You by means of Your Browsing Data.

5. With whom do We share Your personal data?

The Company will process Your personal data only to the extent that it is adequate, relevant and limited to what is necessary in relation to the purposes indicated under Section 2 above, by means of electronical and telematic tools as well as hard copies, in such a way as to ensure the security, protection and confidentiality of Your personal data.

In pursuing the purposes referred to in Section 2 above, We may disclose Your personal data to the following categories of recipients:

1. Third party suppliers and companies of the Generali group, to the extent that such entities provide assistance or consultancy services to the Company, including but not limited to technological, accounting, administrative, legal and insurance services;
2. Governmental authorities and supervisory bodies whose right to access to Your personal data is set forth by applicable laws; and
3. To possible purchasers of the Company and other entities resulting from mergers or any other operations affecting the Company.

Your personal data will not be disseminated.

6. Where do We transfer Your personal data?

In pursuing the purposes referred to in Section 2 above, We may transfer Your personal data to countries outside the European Economic Area (EEA), by implementing appropriate safeguards, according to Articles 44 et seq. of the GDPR.

If You wish to have further information on the Countries where Your personal data may be transferred to as well as the relevant safeguards in place, You can contact Our Data Protection Officer, by using the contact details above.