Privacy Policy

SSC collects personal data you provide to us directly and during its business activities, including in connection with some client services. We also collect personal data on certain areas of the Sites when you send your request to us, register for SSC's newsletters, sign up for conferences and events. The personal data collected varies and may include information that you provide, such as your name, mailing address, e-mail address, telephone number.

We may also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect may include IP address, source URL, device identifier, web browser, and browsing information collected through cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively "Cookies and Other Tracking Technologies") on our Sites. We may also automatically collect information about how you use the Sites, such as what you have searched for and viewed on the Sites. The information automatically collected may be associated with a unique identifier as well as with any other personal data you have provided.

SSC may also collect personal data about you from third parties, such as data brokers or aggregators or social media, in the course of its business activities including in connection with some client services. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine this data with existing information we have about you or use it independently, for the purposes of our benchmarking and data analytics activities (e.g., analysis of recruiting practices across an industry, detecting fraud patterns in connection with financial transactions, foot traffic in retail environments). We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like SSC, in compliance with applicable law.

SSC uses your personal data to fulfil your requests for information, process your requests to participate in conferences and events, personalize content that you view or receive on the Sites, evaluate and improve our services, distribute newsletters and alerts to you, recruit and evaluate job applicants, analyse the Sites' performance and functioning, publish your letters to the editor or comments, prevent fraud, enforce our terms of use, comply with all applicable laws and corporate reporting obligations, enforce Strategia & Sviluppo's agreements, and accomplish other purposes you may initiate or request. In some situations, the collection of personal data may be required for the operation of the Sites, or we may use it in the course of our business activities, including in connection with some client services, for example, to provide certain services or products such as our benchmarking products. We may combine and/or analyze personal data to evaluate and offer content and services most relevant to you. We may keep any of your personal data on file and use it to contact you.

SSC uses your personal data for profiling based on your interactions with us, on your searches, profile data and preferences, and other content provided to us in order to: (i) tailor your experience; (ii) allow operation of SSC algorithm that uses an automated decision-making process.

SSC and its service providers may use first and third party Cookies and Other Tracking Technologies, including web beacons, to manage our Sites and our services and collect analytics about how you use them. Please refer to our Cookie Policy for more details regarding our use of Cookies and Other Tracking Technologies.

Our Sites do not track you by collecting personal data about your online activities over time and across third party websites or online services. Accordingly, we do not alter our data collection and use practices in response to "do not track" signals transmitted from web browsers.

Lawful basis: necessary in order to execute the service agreement between SSC and you.

Our processing of your personal data for the purposes mentioned above is based:

· in part, on our legitimate interests in promoting and protecting Strategia & Sviluppo, building and maintaining relationships. recruitment, and providing our services;

· in part, on your consent, for example if you register for our newsletters or alerts, or for business purposes that support web operations such as understanding and enhancing the quality of your experience on our web-sites;

· in part, to comply with the law, when certain information is necessary to satisfy our legal or regulatory obligations.

Contact you by email, social media, or other available means of: (i) obtaining your opinions through surveys or questionnaires and providing information on our Services; (ii) marketing communications through social media platforms (such as Facebook or Google).

Building profiles based on your preferences and characteristics (on the basis of information you provide, on your Platform interactions that are automatically recorded by SSC, information obtained from third parties and on your search history) for the purposes of sending targeted promotional and marketing messages as well as other information that we think may be of interest to you.

Contact you in relation to matters of public interest or other events in connection with your ability to use our Services. This may include an invitation to attend an exhibition or other type of campaign in the public interest.

Manage referral programmes, prizes, surveys, sweepstakes or other promotional activities or sponsored events.

Measure the performance of our email marketing campaigns (e.g. by analysing open and click rates), tailor, measure and improve our advertising.

Lawful basis: your explicit consent provided prior to processing.

Contact you by email, phone, SMS, MMS, push notifications, messaging systems (e.g. WhatsApp), social media, ordinary post or other available means to provide you with marketing offers relating to products or services you have previously purchased (soft spam).

Lawful basis: legitimate interest of the data controller.

The provision of data for the above purposes is optional, however failure to provide such data will prevent SSC from sending you marketing communications in the manner and within the limits established above.

SSC processes your personal data by electronic and automated means, in paper form and by manual means, through subjects specifically authorised by SSC. These subjects process the data using technical and organisational security measures that protect your personal data and keeps it confidential.

Some of the key security measures SSC uses to protect your personal data are:

- provision of specific instructions to authorised data processing staff;

- delivery of ongoing training to authorised data processing staff;

• system access control;
• encrypted data storage;
• encrypted data transmission;
• firewall and antivirus;
• pseudonymised data.

SSC will retain your data while applying appropriate technical and organisational security measures for pre-established periods of time or, in any case, for periods that can be determined based on specific processing and storage procedures. Your personal data will be automatically and securely erased by SSC at the end of the retention period in accordance with our data retention and erasure rules.

Personal data collected in the course of SSC business activities, including in connection with some client services, as well as on the Sites may be transferred from time to time to SSC subsidiaries and affiliates and their personnel across our global organization, as well as to our third party service providers located throughout the world, including in countries where the local law may grant you fewer rights than you have in your own country. Additionally, the Sites may be viewed and hosted by SSC and our third party service providers anywhere in the world. Where required by law, we have put in place legal mechanisms designed to ensure adequate data protection of your personal data that is processed by SSC subsidiaries, affiliates and third party service providers, including the transfer of your personal data to countries other than the one in which you reside. If you would like more information about these legal mechanisms, which may include the EU's Standard Contractual Clauses, please contact us at the address below. By using any of the Sites and providing information on any of them, you voluntarily consent to such trans-border transfer and hosting of such information.

SSC will not intentionally disclose or transfer (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to third parties without your consent or as otherwise permitted by law, whether for such third parties' own marketing purposes or otherwise, except as follows. SSC may provide access to your personal data to third party service providers engaged by SSC to provide services related to the Sites as well as related to Strategia & Sviluppo's business activities, including in connection with some client services, in the manner agreed upon in our client services agreements. We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Policy and protects the confidentiality, availability, and integrity of your personal data.

We also may share your personal data with third party service providers who perform services and functions on our behalf to support our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

· If we are required to do so by law or legal process;

· To law enforcement authorities or other government officials;

· When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;

· If disclosure is necessary to protect the vital interests of a person;

· To enforce our Terms of use;

· To protect our property, services and legal rights;

· To prevent fraud against Strategia & Sviluppo, our subsidiaries, affiliates and/or business partners;

· To support auditing, compliance, and corporate governance functions; or

· To comply with any and all applicable laws.

In addition, we may disclose or transfer your personal data in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

You should be aware that whenever you publicly disclose information online, that information could be collected and used by others. SSC is not responsible for any action or policies of any third parties who collect information that users publicly disclose in any such forums on the Sites.

SSC may provide links to third party websites or information as a service to our users. If you use these links, you will leave the Sites. Such links do not constitute or imply an endorsement, sponsorship, or recommendation by SSC of the third party, the third party website, or the information contained therein, and SSC shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

The Sites may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube, with Strategia & Sviluppo.

By associating your social network account with SSC you give us permission to access information that you have made available in your public profile for that social network account. The information available in your public profile varies based on the social network and your settings, but may include your email address, real name, profile picture, gender, and location. We use the information we receive from your social network account in accordance with the social network's terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with SSC and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

If you would like to disconnect a social media account from us, refer to the settings of that social network account and its provider.

The Sites are not designed for or directed at children 16 years of age or younger, and SSC does not intentionally collect or maintain personal data about anyone under this age.

Where granted by applicable law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

If you would like to make a request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact us at info@strategiaesviluppo.com. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

In addition, and where granted by local law, you have the legal right to lodge a complaint with a competent data protection authority.

If you have registered for SSC newsletter or alerts, or you receive invitations to survey or events from SSC and you prefer not to receive future email communications from us, please follow the instructions at the bottom of the page of a single newsletter or write to info@strategiaesviluppo.com to unsubscribe from all SSC communications.

By using the Sites, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our Sites.

If you have any questions about our Privacy Policy or if you would like to communicate with our EU Data Protection Officer or the Data Privacy Team, please contact us at:

SSC S.r.l.
11 via Molino delle Armi
Milano, MI 20100
info@strategiaesviluppo.com