PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679 (GDPR)
1. Data Controller
Film Club Distribuzione S.r.l., with its registered office in Rome (ZIP code 00153), Via Raimondo da Capua no. 12, Tax Code and VAT number 13487761002, registered with the Companies Register of Rome under REA no. RM-1451077, with digital domicile at the certified email address legal@filmclubdistribuzione.it, acts as the Data Controller.
As the Data Controller, the Company ensures that all operations involving personal data are carried out in full compliance with Regulation (EU) 2016/679 (“GDPR”), according to the principles of lawfulness, fairness, transparency, and proportionality, and with constant commitment to protecting the fundamental rights and freedoms of the data subjects.
2. Categories of Personal Data Processed
In the course of its activities, the Company may process various categories of personal data, including identification and contact details such as name, surname, email address, and phone number, as well as browsing data collected automatically through access to the website (e.g., IP address, access logs, browser type, and other technical data).
Personal data voluntarily provided by data subjects via email or online forms may also be processed, including any third-party data communicated by the data subject.
The use of the website also involves the processing of technical cookies, anonymized analytical cookies, and third-party cookies, as detailed in the Cookie Policy available on the site.
3. Purposes and Legal Basis of the Processing
The collected personal data are processed to ensure proper website navigation and adequate levels of IT security, based on the legitimate interest of the Controller. The processing also serves the purpose of responding to requests sent by data subjects through forms or email, as part of pre-contractual or contractual measures.
Specifically, personal data provided by the data subject through the contact forms available on the Website are processed exclusively for the purpose of handling and responding to the data subject’s requests and providing the requested information.
Personal data may be processed, subject to the data subject’s prior and optional consent, for the purpose of sending informational, institutional or promotional communications relating to the Data Controller’s activities, should such services be implemented in the future.
Refusal or withdrawal of consent for this purpose shall not affect in any way the ability to browse the Website or to receive responses to requests submitted by the data subject.
Additional purposes include compliance with legal obligations, protection of the Controller’s rights in legal proceedings, and prevention of abuse—also based on legitimate interest under Article 6(1)(f) of the GDPR.
4. Methods of Processing and Security Measures
The data are processed using manual and electronic tools, in compliance with the principles of integrity, confidentiality, and availability.
The Company adopts appropriate technical and organizational measures to protect personal data from unauthorized access, loss, destruction, or unlawful disclosure, in accordance with the provisions, among others, of the GDPR.
5. Recipients of Personal Data
Personal data may be disclosed to duly authorized personnel within the company organization, as well as to external providers offering IT, technology, hosting, or technical and communication support services.
Professionals and consultants engaged for tax, legal, or administrative purposes may also access the data, along with third parties in cases provided by law or following orders from judicial or administrative authorities.
These parties will act, as appropriate, as Data Processors pursuant to Article 28 of the GDPR, in compliance with applicable regulations.
6. Transfer of Personal Data Abroad
Personal data will not be transferred outside the European Economic Area.
If a transfer to third countries becomes necessary, it will only take place in the presence of an adequacy decision by the European Commission or, in the absence thereof, by adopting appropriate safeguards as provided under Chapter V of the GDPR, such as the Standard Contractual Clauses approved by the Commission.
7. Retention Period of Personal Data Collected and Processed by the Controller
Personal data will be retained only for the time strictly necessary to achieve the purposes for which they were collected.
In any case, the retention period may be extended to fulfill civil, tax, or accounting legal obligations.
Personal data processed on the basis of the data subject’s consent will be retained until such consent is withdrawn, without prejudice to the lawfulness of processing carried out prior to withdrawal.
8. Data Subject’s Rights
The data subject may exercise, at any time, the rights recognized by Articles 15 to 22 of the GDPR.
In particular, the data subject has the right to access their personal data, request rectification, erasure, restriction of processing or data portability, and to object—on grounds relating to their particular situation—to processing based on the Controller’s legitimate interest.
Consent may also be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Requests can be sent to the email address legal@filmclubdistribuzione.it.
Lastly, the data subject has the right to lodge a complaint with the Italian Data Protection Authority, following the procedures outlined on the official website www.garanteprivacy.it.
9. Cookie Notice Used by the Controller
This Website uses exclusively technical cookies, in compliance with the principle of data minimization and applicable data protection regulations.
Such cookies are strictly necessary to ensure the proper functioning of the Website and to allow users to navigate its pages and access the requested services. No profiling cookies or tools aimed at collecting personal data for commercial, advertising or marketing purposes are used.
The Website does not employ third-party cookies or analytical cookies, including in anonymized or aggregated form.
Technical cookies may include cookies necessary for session management, access to restricted areas and the storage of user preferences, such as language or display settings. The processing of personal data associated with the use of technical cookies is based on Article 6(1)(b) of the GDPR, as it is necessary for the provision of services expressly requested by the user, as well as on Article 122(1) of the Italian Privacy Code, pursuant to which technical cookies do not require the user’s prior consent.
For this reason, such cookies are activated automatically upon access to the Website, without the use of consent banners or similar mechanisms.
Users may manage cookies through their browser settings, including the ability to limit, block or delete cookies.
Disabling technical cookies may, however, impair the correct functioning of the Website and result in the partial or total unavailability of certain pages or features. Instructions on how to manage cookies can be found in the help section or settings of the browser used by the user.
The information collected through technical cookies is limited to what is strictly necessary for navigation and functionality, such as IP address, browser type, session identifiers and language preferences. Such data is not processed for purposes other than those described above and is not shared with parties outside the Controller’s technical and organizational framework.
Session cookies are automatically deleted when the browser is closed, while any persistent cookies used to store user preferences remain valid for a maximum period of twelve months, unless renewed by a new interaction.
Pursuant to Articles 15 to 22 of the GDPR, data subjects may exercise their rights at any time, including the right to access their personal data, request rectification or erasure, restrict or object to processing and, where applicable, exercise the right to data portability. To exercise these rights or to obtain further information regarding the processing of personal data through cookies, users may contact the Data Controller at the following email address: legal@filmclubdistribuzione.it. Data subjects also retain the right to lodge a complaint with the competent Data Protection Authority should they consider that the processing of their personal data is not compliant with applicable data protection laws.
Should the Data Controller introduce, in the future, cookies or tracking tools other than technical cookies, this Privacy Notice will be promptly updated and, where required by applicable law, appropriate mechanisms for obtaining the user’s consent will be implemented.
The Controller reserves the right to update this notice at any time, including as a result of legal, regulatory or technical developments.
Users are therefore encouraged to periodically review this section in order to remain informed of any updates.
10. Amendments and Updates to This Privacy Notice
This privacy notice may be subject to updates, including as a result of regulatory changes or technological developments.
Any changes will be published on the Company’s website and will become effective from the date of publication. Users are therefore encouraged to periodically review this Privacy Notice in order to stay informed of any updates or changes.
11. Contacts
For any request regarding the processing of personal data, including the exercise of the rights granted by Regulation (EU) 2016/679, the data subject may contact the Data Controller by writing to the email address legal@filmclubdistribuzione.it or by regular mail to the following address:
Film Club Distribuzione S.r.l.
Via Raimondo da Capua no. 12
00153 Rome (RM)
Film Club Distribuzione S.r.l. The Data Controller