Pursuant to Article 13 of the Legislative Decree 196 of 30 June 2003 “Code in the Matter of Protection of Personal Data” (hereinafter the “Italian Privacy Code”) and to Article 13 of the Regulation (EU) 2016/679 containing provisions for the protection of natural persons with regard to the processing of personal data and for the free movement of such data (hereinafter the “GDPR”), we hereby provide you with information regarding the processing of your personal data collected via the website www.mbeglobal.com (hereinafter the “Website”).
- Data controller
Personal Data collected via the Website will be processed by MBE Worldwide S.p.A., with registered office at Viale Lunigiana 35/37 - 20125 Milano (IT) - Fiscal Code/VAT No. 05393070965 in its quality of data controller (hereinafter the “Controller”).
- Categories of Personal Data processed
The following Personal Data may processed via the Website: name, surname, email, mobile, country and city (hereinafter the “Personal Data”).
- Purposes of processing Personal Data
The Controller will process your Personal Data for to the following purposes:
- registration to the Website;
- to reply to enquiries made via the Website relating to the possible affiliation as a franchisee or as a master licensee;
- to send you, by any means of communication (fax, e-mail, text message, multimedia messaging service, paper-based mail, operator-assisted phone calls), advertising material and literature of a promotional nature or in any case involving commercial solicitation pertaining to services, products or discounts offered by the Controller, as well as for conducting studies and surveys of the market, and elaborating related statistics.
- Legal basis for processing Personal Data
The legal basis for processing your Personal Data for the purposes as per Section 3, a. and b. above is the performance of the contract consisting in the provision of the Website’s services and/or your request of information on how to become a franchisee or a master licensee.
The legal basis for processing your Personal Data for the purposes as per Section 3, c. above is your specific consent.
The provision of your Personal Data for the purposes as per Section 3, c. is optional and failure to do so will have the sole consequence of making it impossible for the Controller to send you advertising and promotional messages and to conduct market research.
If you have given consent authorizing the Controller to pursue the purposes as per Section 3, c. you will notwithstanding remain free to revoke at any time such consent and/or to object to the processing of Personal Data for the aforementioned purposes, by sending without any formalities a clear written communication to that effect to the addresses as specified in Section 10 below.
- Modalities of processing of Personal Data
Personal Data will be processed by means of both manual and IT devices.
- Recipients of Personal Data
To fulfil the purposes as set out in Section 3 above your Personal Data may be communicated by the Controller to:
(i) employees, agents or collaborators of the Controller who are located within the territory of the European Union;
(ii) subsidiaries or associated companies, which - currently - include Sistema Italia 93 S.r.l., MBE Spain 2000 SL, MBE Deutschland Gmbh, MBE France S.a.r.l., MBE Poland Sp.zo.o;
(iii) subjects located within the territory of the European Union of whom or which the Controller avails itself for marketing activities;
(iv) third parties, including entities located outside the European Union, with which the Controller has a relationship of master franchising;
(v) third parties, located within the territory of the European Union, with which - from time to time - commercial partnership agreements and/or common initiatives, campaigns and projects will be developed;
(vi) persons, companies or professional offices located within the territory of the European Union that engage in activities of assistance and consultation in accountancy, administrative, legal, tax and financial matters;
(vii) subjects, bodies or authorities to whom or which the communication of your Personal Data is mandatory by virtue of provisions of law or orders issued by authorities.
The subjects or categories of subjects to whom or which Personal Data may be communicated process your Personal Data in the capacity of data processors, autonomous data controllers or joint data controllers.
The complete list of the data processors of the Controller is available at its registered office; for more information, you may apply in writing at the addresses specified in Section 10 below.
- Transfer of personal data extra EU
In case your enquiry relates to a possible affiliation as a franchisee or as a master licensee in a country located outside the European Union your personal data may be transferred outside the European Union.
- Retention of Personal Data
In application of the principle of proportionality, the Controller will:
(i) retain your Personal Data, as per the purposes of Section 3, a. and b. for the time necessary for the provision of the Website’s services and for the time necessary to manage your request of information on how to become a franchisee or a master licensee;
(ii)retain your Personal Data, as per the purposes of Section 3, c. for a period not longer than twenty-four months from the time of their recording, save for anonymization which prevents, even indirectly or in aggregate with other databases, the identification of the data subject.
The Controller has implemented suitable mechanisms for automatic erasure of Personal Data, including to any third party to whom or which such data may be communicated.
- Rights of the data subject
Pursuant to Article 7 of the Italian Privacy Code, as well as pursuant to articles 13(2)(b) and (d) as well as Articles from 15 to 22 of the GDPR, we inform you that:
a) you have the right to apply to the Controller in order to have access to your Personal Data, to rectify or delete the same or restrict the processing as well as to object to such processing, or to revoke consent, in addition to the right to portability of the data;
b) you have the right to lodge a complaint with the “Garante Privacy” (national privacy authority), following the procedures and instructions published on the official website of the same national privacy authority at www.garanteprivacy.it;
c) any rectification or deletion or restriction on processing done at your request, unless it proves to be impossible or entails a disproportionate effort, will be communicated by the Controller to each of the recipients to whom or which your Personal Data have been transmitted. Upon request, the Controller may communicate such recipients to you.
Your applications for the exercise of such rights shall be addressed in writing to the Controller at the addresses as specified in Section 10 below.
The exercise of the rights is not subject to any formal restriction and is free of charge.
For ease of reference, we reproduce below the text of Article 7 of the Italian Privacy Code:
Art. 7. Right of access to personal data and other rights
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, even if not yet recorded, and to the communication thereof in intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing if carried out with the help of electronic means;
d) of the identification data of the data controller, data processors and designated representative pursuant to Article 5.2;
e) of the subjects or categories of subjects to whom or which the personal data may be communicated or that may become aware of them in the capacity of designated representative in State territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the following rights:
a) to obtain the updating, the rectification or, when he/she has an interest in it, the supplementation of the data;
b) to obtain erasure, anynomization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) to obtain certification to the effect that the operations as per letters a) and b) have been brought to the attention, including as to the contents thereof, of those to whom or which the data have been communicated or disseminated, unless this requirement proves impossible to fulfil or involves a manifestly disproportionate effort with respect to the right that is to be safeguarded.
4. A data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, when it is carried out for the purpose of sending advertising material or direct sale or else for conducting market research or commercial communication surveys.
For more information about the provisions contained in Articles from 15 to 22 of the GDPR, click on the following link:
- Contacts for the exercise of the rights of the data subject and for further information
With respect to the exercise of your rights in relation to the purposes as per Section 3.2 above and/or to obtain any type of information you may need in relation to the Controller pursuant to this Privacy Notice, you can send a written communication to MBE Worldwide S.p.a. with registered office at Viale Lunigiana 35/37 - 20125 Milano (IT) - Fiscal Code/VAT No. 05393070965 Tel. +39 02 67625777 - Fax +39 02 67625778 or an email to firstname.lastname@example.org.
- Changes to this privacy notice
This privacy notice will be valid as of the date indicated below. Any changes to this privacy notice will be detailed on this page in order to ensure that you are fully aware of what Personal Information is collected and how it used.
Latest update: 29th May 2018