Privacy Policy Statement for Processing Personal Data – Newsletter

Privacy Policy Statement pursuant to Art. 13 of EU Regulation No. 2016/679 (“Regulation”)

The Data Controller, Sugarmusic S.p.A., with registered office at Galleria del Corso 4, Milan, [Italy], informs you that your Personal Data are processed for managing and sending newsletters. The legal basis for processing your data for this purpose is your consent [Art. 6(1)(a) of the Regulation]. You may withdraw the consent you have provided and object to such processing at any time in an easy and free manner, also by writing to: Your Personal Data may be shared with natural persons authorized by the Data Controller to process the Personal Data to perform their work task (e.g. employees and system administrators, etc.); services suppliers (such as consultants, etc.) who typically act in their role as Data Supervisors pursuant to Art. 28 of the Regulation; subjects, institutions or authorities to whom it is mandatory to disclose your Personal Data in virtue of legal provisions or orders from the authorities. The up-to-date and complete list of Data Supervisors is available on the Data Controller’s website and in any case may be requested from the Data Controller as indicated above. With regard to the possible transfer of the Data to third-party countries, the Data Controller informs you that the processing will be carried out according to one of the methods allowed by the law in force, such as for example consent by the Data Subject, the execution of a contract concluded between the Data Subject and the Data Controller or the execution of pre-contractual measures implemented on request by the Data Subject; the conclusion or execution of a contract stipulated between the Data Controller and another natural or legal person in favour of the Data Subject; the implementation of standard clauses approved by the European Commission, the selection of subjects belonging to international programmes for the free circulation of data (e.g. EU-USA Privacy Shield) or operating in countries considered to be secure by the European Commission. More information is available from the Data Controller by sending a request to the contacts above. Pursuant to Articles 15 of the Regulation, as integrated and amended, you have the right to request, at any time, access to your Personal Data, the rectification or the erasure thereof, the restriction of the processing in the cases set forth by Art. 18 of the Regulation, to obtain the data concerning you in a format that is structured, common and readable by an automated device, in the cases set forth by Art. 20 of the Regulation. You have the right, at any time, pursuant to Art. 7 of the Regulation, to withdraw the consent you have provided; to make a complaint to the competent Supervisory Body pursuant to Art. 77 of the GDPR (Data Protection Authority) pursuant to Art. 77 of the Regulation should you feel your data have been processed contrarily to the legislation in force. Pursuant to Article 21 of the GDPR, you can object to your data being processed by sending in a request highlighting the reasons justifying the objection: the Data Controller reserves the right to assess the request, which will not be accepted if legitimate binding reasons exist for continuing with the processing which prevail over your interests, rights and freedoms. Requests are to be made in writing and sent to


Version 2 Date 20 January 2020



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