INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 (“GDPR”)
Last update 2026/02/27
The ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA, with registered office in Via Oldofredi Ercole 23, 20124 Milan, Tax Code and VAT No. 08192390964 (the “Controller”), in its capacity as data controller, hereby informs you, pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”), that your personal data will be processed for the purposes and under the conditions described below.
- Categories of Personal Data and Source of the Data
The Controller processes common personal data (identification and contact details such as name, surname, professional role/qualification, organisation, professional or personal email address), collected:
- directly from the data subject or provided by the member organisation within the membership relationship (institutional contacts);
- during subscription or participation in events, initiatives, working groups or Strategic Communities of the Association;
- through online subscription forms for newsletters or events (e.g., AFIL website; Google Forms).
- Purposes of the Processing and Legal Bases
Processing is carried out for purposes of information, engagement, dissemination and institutional communication relating to the Association’s activities, events, initiatives, projects and services, in line with the Association’s statutory purposes.
The applicable legal bases are:
- a) Legitimate interest of the Controller (Art. 6(1)(f) GDPR)
Applicable to:
- representatives of member organisations,
- institutional contacts provided by the member organisation,
- representatives participating in working groups, strategic communities or associative activities.
The Controller sends institutional and informational communications relevant to the membership relationship. The data subject may exercise the right to object at any time through the opt-out/unsubscribe function available in each newsletter.
- b) Soft spam – Art. 130(4) Italian Privacy Code
Applicable to representatives of former members who previously participated in AFIL activities or subscribed to AFIL newsletters or initiatives.
The Controller may send communications similar to those previously received, without prejudice to the data subject’s right to object at any time via opt-out/unsubscribe.
- c) Consent of the data subject (Art. 6(1)(a) GDPR)
Applicable to individuals (members’ representatives or non-members) who voluntarily subscribe to the newsletter via the website or online forms, or who expressly request newsletter subscription when registering for events.
Consent may be withdrawn at any time via opt‑out/unsubscribe.
- Methods of Processing and Retention Periods
Data are processed in accordance with the principles of lawfulness, fairness, transparency and minimisation, using electronic, digital and – where necessary – paper‑based tools, and applying appropriate technical and organisational measures.
Newsletter sending and management are carried out using dedicated platforms and online subscription forms hosted on AFIL’s websites or event registration systems.
Personal data are retained until withdrawal of subscription or objection (opt‑out/unsubscribe), with immediate deactivation of the address from mailing systems and complete deletion within 24 months of the last interaction.
No automated decision‑making processes, including profiling, pursuant to Article 22(1) and 22(4) of Regulation (EU) 2016/679, are carried out as part of the processing activities described.
- Access to Personal Data
Data may be accessed exclusively by:
- personnel of the Controller expressly authorised and appropriately trained;
- external processors providing newsletter management, website hosting, cloud services, communication tools or IT support;
- additional suppliers acting on behalf of the Controller for the purposes indicated.
- Disclosure of Personal Data
Pursuant to Articles 6(1)(b) and 6(1)(c) GDPR, and therefore without requiring explicit consent, the Controller may disclose your data to judicial authorities and to any entities to whom disclosure is mandatory by law for the fulfilment of institutional or legal obligations. These entities will act as independent controllers.
Personal data processed for the purposes described in Article 2 will not be disseminated.
- Data Transfers
Personal data may be transferred, for the purposes described in this notice and for storage or archiving needs, within the European Union or to third countries.
In all cases, the Controller ensures that any transfer outside the EU complies with applicable legal requirements.
- Nature of Data Provision and Consequences of Refusal
Providing personal data is optional.
Failure to provide data or exercising the opt‑out/unsubscribe option will make it impossible to receive further communications from the Controller, without affecting any other form of relationship or participation in the Association’s activities.
Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.
- Data Subject Rights
As a data subject, you may at any time exercise your rights under Articles 15–22 GDPR. These include: the right to obtain confirmation of whether personal data concerning you are being processed; access to your data; information on purposes, categories of data, recipients (including third-country recipients), retention periods, and data sources; information on automated decision-making, including profiling.
Where applicable, you may exercise the rights to rectification, erasure, restriction, portability, objection, and the right not to be subject to automated decision‑making.
You also have the right to lodge a complaint with the Supervisory Authority and, in the event of damage arising from a GDPR breach, to seek compensation under Article 82 GDPR.
- Exercising Your Rights
You may exercise your rights at any time by sending a registered letter with return receipt to:
AFIL – Associazione Fabbrica Intelligente Lombardia, c/o Innovhub, Via Giuseppe Colombo 83, 20133 Milan (MI), or an email to: direzione@afil.it .
- Controller and Processors
The data controller is ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA, Via Oldofredi Ercole 23, 20124 Milan, Tax Code and VAT No. 08192390964. The updated list of data processors is available at the Controller’s registered office.
Milano ASSOCIAZIONE FABBRICA INTELLIGENTE LOMBARDIA