ART. 1 - DURATION OF THE PROGRAM
1.1 The ViaMilano Program is valid from 01/02/2019 until 31/12/2020.
1.2 SEA reserves the right to extend the duration of the Program upon expiry.
ART. 2 - TERMS AND CONDITIONS OF PARTICIPATION
2.1 Participation in the Program is subject to compliance with all the clauses and conditions set out in the following regulations and is free of charge.
2.2 Any private individual aged 18 or over at the time of registration may become a Program Member.
2.3 A card is required to participate in the Program. The card is available in digital format as detailed in paragraph 2.5 and can also be obtained from participating outlets and information desks displaying the ViaMilano Program sticker at Milan Linate and Milan Malpensa airports. The card may also be valid for future promotions. The card allows the holder to collect electronic points instantly. To use the points and claim rewards, the card must be registered for the Program and matched to the Holder’s details. The card is personal and non-transferable. To complete membership, participants must also have an email address to receive the account to access the reserved area as well as a valid home address.
2.4 Any Member who signed up to the previous Program shall participate in the 2018 version automatically, without prejudice to their right to request cancellation. Members shall be entitled to withdraw from the Program at any time. Prior to cancellation, Members shall be guaranteed the opportunity to claim any rewards to which they are entitled owing to the number of points they have collected. Any leftover points that are not used up shall be cancelled and may not be recovered.
2.5 Registration in the Program may take place according to the following procedures:
online, at milanomalpensa-airport.com/en/shop-dine/fidelity-card as well as via the Milan airports’ digital ecosystem (milanolinate-airport.com, milanomalpensacargo.eu, viamilanoeshop.eu, Captive portal WiFi),
with the help of staff at the information desks displaying the ViaMilano Program sticker at Milan Linate and Milan Malpensa airports to complete the pre-registration at milanomalpensa-airport.com/en/shop-dine/fidelity-card, or to carry out all the operations directly on site,
when using other services connected to the Program, by completing the appropriate registration form available at the authorised points.
via the free mobile “Milan Airports” app for the iOS and Android operating systems.
2.6 A Member joins the Program by means of the procedures set out above with the “ViaMilano Program” profile. However, an SEA Club Member (for information firstname.lastname@example.org) joins with the exclusive “Club SEA ViaMilano Program” profile.
2.7 All cards are personal, non-transferable and usable by the Holder only. Each Cardholder guarantees the accuracy of all the information provided, is the only person responsible therefore and, consequently, is obligated to update their profile at milanomalpensa-airport.com/en/shop-dine/fidelity-card, in the event of any changes.
2.8 A Personal Code is assigned to each Member. The card must be produced when making a purchase in order that the relative points may be credited and, if requested, when collecting rewards.
2.9 The personal digital ID code of each Member is matched to an account to which the accumulated points shall be credited. The Cardholder shall receive a confirmation message by email, at the address indicated thereby, with the information required to complete the registration, for all the Program registration procedures referred to in Art. 2.5.
Using the ViaMilano Program account (login and password), it is possible to register directly on the SEA Portal. Therefore, a Member need only sign up to the ViaMilano Program to access the SEA, Milan Linate and Milan Malpensa websites as a registered user. The Cardholder is the only person responsible for keeping their password secret. A request can be made for the reissue of the password via the dedicated function on the APP or milanomalpensa-airport.com/en/shop-dine/fidelity-card.
2.10 Upon registration, the Member shall be asked to accept the contents of the regulations including the personal data protection provisions pursuant to the provisions of EU Regulation 2016/679 and the Italian legislation in force. At the same time, the data subject shall give consent to the processing of their personal data including for the dispatch of communications on new developments, initiatives and promotions reserved for members, covered by the program. The Member may also give separate consent to the processing of their data for promotional, commercial and marketing purposes, as well as for the dispatch of airport information and commercial promotional communications regarding SEA services via its communication channels, such as post, email, sms and/or mms (“Direct Marketing”), as indicated in Article 10 below.
2.11 In addition, the data subject may give separate consent to the processing of their personal data for profiling activities including by way of example only the processing of data relating to their interests, preferences and consumer choices for statistical and market analysis activities (“profiling”) as indicated in Article 10 below, for the purpose of recognising the data subject, comparing and rationalising the data contributed to the site with that communicated on other occasions and being able to send airport information and/or promotional communications selected on the basis of all the data supplied.
2.12 SEA reserves the right to exclude the Member from the Program if the information supplied thereby is found to be false. Exclusion from the Program shall involve the immediate cancellation of all the unused points accumulated so that no further Rewards may be claimed. In the event of the improper use of the card, in particular, for Reward Points accumulated for purchases made by a person other than the Cardholder, SEA reserves the right to cancel the registration of the Cardholder and cancel the points accumulated. A Member who has been excluded or removed from the Program, in accordance with the procedures above, shall also lose the opportunity to access the services on the SEA Portal and receive the relative newsletters.
2.13 If the card is lost, stolen or damaged, the Cardholder shall be bound to inform SEA promptly via the SEA Milan Airports Information Centre +39 02 23 23 23 or by sending an email to email@example.com requesting that the card be blocked and quoting their Personal Code. SEA shall arrange for the suspension of the card and provide the Member with instructions for obtaining a new card. However, SEA shall not be responsible for any fraudulent use of the lost or stolen card. Replacement of the card shall not change the status of the Member in terms of benefits and points acquired up to that time.
3 - ACCESS TO RESERVED AREA
3.1 Members may consult the Rewards Catalogue in the reserved area accessible using the login and password for the Milan Malpensa and Milan Linate websites and the Milan Airports APP and view the rewards available depending on the points accumulated in their Reserved Area accessible via their account.
3.2 Members may also access their Reserved Area to:
view, amend or delete their data as well as revoke or change their consents
view the points balance (this balance may be updated later than the time of purchase). The points balance shall be deemed final 60 (sixty) days after the transaction has taken place
claim rewards and/or benefits
ART. 4 - ACCUMULATING POINTS FOR REWARDS
4.1 Members of the Program can accumulate points in any of the following ways:
1) buying products and services from the retail points at the airport, participating in the campaign,
2) buying SEA airport services at Milan Linate and Milan Malpensa airports (ViaMilano Parking, ViaMilano Lounge, ViaMilano FastTrack) using the Telepass service at participating ViaMilano Parking car parks, after entering the code on their Telepass device in their user profile;
3) online purchases of SEA products or services (ViaMilano Parking, Fast Track, VIP Lounges) in section Viamilanoeshop.eu which can be accessed from the Milan Linate and Milan Malpensa websites. SEA may also allow points to be collected for online purchases of other products and services from third parties accessible from SEA websites, after giving the relevant information;
4) points exchange with the loyalty programs of external partners, according to rules to be published;
5) accessing services or buying products from external partners.
SEA may, after notifying the Members of the Program accordingly, change the points collection methods indicated above.
SEA, may offer additional benefits for specific product categories, without affecting the rights of the Participants. These additional benefits will be offered for limited periods according to strict criteria and may include:
the opportunity to accumulate additional points or bonus points,
discounts on points bands,
the possibility of redeeming points in conjunction with payment (points + cash value) to claim items or prizes from special catalogues. SEA will advertise these additional benefits appropriately, in good time,
access to any discount and promotional conditions at the airport outlets and with external partners. These conditions cannot be used in conjunction with others already offered by the same partner or outlet. Promotional rates will not allow points to be accumulated, unless expressly indicated; in this case, any maximum ceiling / amount permitted will be indicated,
access to any promotions offered via SEA’s online communication tools, such as but not limited to newsletters, surveys and quizzes,
the possibility of obtaining additional rewards and benefits created specifically on the basis of the actions of each Member. In order to be able to enjoy these additional rewards and benefits, the Member will have to produce their boarding pass to use one of the SEA products and/or services (for example only: ViaMilano Parking car parks, Fast Track or VIP Lounges), as well as their ViaMilano Program card. The rewards and benefits that can be obtained will not allow points to be accumulated, unless expressly indicated; in this case, any maximum ceiling / amount permitted shall be indicated. During the course of the Program, SEA may define other initiatives, including for different reasons from those provided for in these Regulations, that will be communicated in due time on the SEA communication channels.
4.2 Only purchases made by the Owner of the card will give the right to collect points.
4.3 SEA may check at any time that the points collected, and the total points balance, conforms to the Regulations of the Program. Further checks may be carried out when the prize is claimed, and the Participant may be asked to produce receipts confirming the purchases. In order to prove the points collected, the Participant is required to keep the receipts for any purchases made at the participating retail point for 60 (sixty) days after the date of purchase.
4.4 SEA may decide not to credit the points collected if there is sufficient reason to suspect that one or more claims is attempted fraud, or does not comply with these Regulations. Any irregular and/or unjustified use of the cards and the points collection procedures described in these Regulations will entitle SEA to immediately block the cards on which irregular and/or unjustified points have been collected, and any prizes claimed will not be delivered. Any points that are found to be irregular and/or unjustified will be definitively cancelled and the related actions are liable for prosecution. Irregular and/or unjustified collection of points may include: collecting points in an amount or at intervals that, although within the maximum limits permitted for points collection, are clearly beyond the capability of the Participant who was entitled to make the purchases. Cards used in this way will be suspended, the Participant will be excluded from the Program and will lose the right to claim Prizes.
4.5 The points accumulated by each Participant will be credited to a personal statement of account, which will contain updated details of the points collected and used. The statement of account can be viewed in the reserved area, which can be accessed by using the login and password for the Milan Linate and Milan Malpensa websites, and the Milan Airports app.
4.6 Points will be awarded as follows:
ViaMilanoProgram profile: 10 points for each euro spent.
Club SEA ViaMilano Program profile: 12 points for each euro spent.
4.7 A minimum purchase value of €5.00 (five euros) will apply. Purchases below that value will not give the right to the collection points. For purchases above the threshold, the full amount spent will be included in the calculation of points credited, apart from cases in which different rules apply.
4.8 To obtain the automatic crediting of points, the Participant must provide the retailer with the physical or digital ViaMilano Program card at the retail point, so that the points can be recorded and credited.
4.9 Points collected from the online purchase of SEA products and services (ViaMilano Parking, Fast Track, VIP Lounges) which are then cancelled by the Participant within 14 days from the date of purchase will be deducted from the Participant’s points total.
4.10 For every car or van hired at the hire points participating in the Program at Milan Linate and Milan Malpensa Airports, with a maximum of 400 points per purchase.
4.11 Points will not be awarded for cars or vans hired at corporate rates pre-agreed between the hire company and the corporate client. Points will not be awarded for online bookings made on the websites of third-party hire companies. If the booking is cancelled, no points will be awarded.
4.12 Points will not be awarded for purchases made using restaurant vouchers/meal vouchers of any kind, except for vouchers expressly authorised and/or issued by SEA.
4.13 The tax receipts for the products purchased must be kept until the date on which SEA definitively accredits the points. This will automatically take place within 60 (sixty) days from the date of purchase. The two-colour system on the online statement of account allows the Participant to differentiate between the points accredited and those collected but not yet accredited.
4.14 Until the time of definitive accreditation, the points collected may be randomly checked by SEA to prevent fraud.
4.15 Participants who are checked by SEA will receive an email communication asking them to provide a copy of tax receipts for their purchases. The Participant’s card will be suspended until SEA personnel has completed the investigation.
If no response is received from the Participant (SEA will send up to three communications) any cards that have been blocked for more than 6 (six) months will automatically be deleted or cancelled after that time and the points collected will also be cancelled at the same time. If the card is suspended the Participant will not be able to collect points or claim prizes. If the Participant does not produce the required documentation within 90 days from receipt of the notification of suspension, he or she will be excluded from the Program and will lose the right to claim Prizes.
If the Participant is suspended, he or she will be unable to take part in any other prize competitions. If the investigations show that the card is not irregular, SEA will credit the points collected during the period of suspension. If a Participant is suspended more than once following an investigation, SEA may exclude the Participant from the Program regardless of the result of the first check.
4.16 Points will not be awarded for purchases of products in the following categories:
pharmaceuticals and over-the-counter medicines,
lottery tickets, scratch cards or betting tickets,
prepaid telephone cards and TV subscription cards,
newspapers and magazines.
4.17 Failure to present the card at the time of payment will mean that no points will be collected and they cannot be credited at a later date.
4.18 The Participant may not sell or exchange the points or prizes in any way.
4.19 Transfers of points between different cards in the Program are not permitted.
4.20 The Participant may not falsify or alter any details regarding his or her participation in the Program nor issue any false or misleading declarations or details for the purposes of gaining undue advantages in the Program.
4.21 Points may not be traded or converted into cash.
4.22 Point circulated by the Participant will be registered in the statement of account which is available in the reserved area, by entering the login and password for the Milan Malpensa and Milan Linate airports, and on the Milan Airports app. SEA may, at its discretion, this regard or delete any points that have been credited erroneously, and will notify the Participant.
4.23 During the campaign, based on specific promotional and/or marketing campaigns, the Promoter may apply more favourable conditions for certain categories of participant based on predetermined requirements. This may include the possibility of awarding additional bonus points, over and above the basic system. Participants will be informed of these opportunities in the relevant communications (Presidential Decree 430/2001 as amended).
ART. 5 - REWARDS
5.1 According to SEA’s own estimates, a total jackpot of around €50,000 (fifty thousand/00) excluding VAT will be distributed with regard to this Program. Under the terms of Art. 7 of Pres. Dec. No. 430 of 26/10/2001, a deposit of 20% of the total value of the rewards that it is assumed will be delivered has been paid.
5.2 The list of prizes can be viewed in the reserved area, which can be accessed by using the login and password for the Milan Linate and Milan Malpensa websites, and the Milan Airports app.
5.3 The prizes may consist of:
vouchers for purchases at airport retail points at Milan Linate and Milan Malpensa, and for airport services (ViaMilano Parking),
access to airport services (e.g.: ViaMilano Fast Track, ViaMilano Lounge),
other prizes as advertised on the SEA channels: these can be viewed in the reserved area, which can be accessed by using the login and password for the Milan Linate and Milan Malpensa websites, and the Milan Airports app.
5.4 SEA reserves the right to:
include “extra” rewards in the catalogue for limited periods with dedicated redemption terms, notifying all Members thereof in advance via all the communication channels stipulated;
change the amount (€) of any Vouchers in the catalogue, notifying all Members thereof (in advance) via all the communication channels stipulated.
ART. 6 – CONVENTIONS OFFERED BY OTHER PARTNERS
6.1 In addition to the rewards initiative, participation in the ViaMilano Loyalty Program will provide access to a series of special offers from other Partners participating in the Program. The list is available on the SEA channels.
6.2 The special offers may be enjoyed following registration for the program or the obtainment of a specific number of points. Irrespective of the points used, the Member shall retain access to the special offers corresponding to their highest number of points collected for the entire duration of their participation in the Program.
6.3 The updated list of special offers from partners participating in the Program could change over time including as a result of the expiry of the offers from the Partners.
6.4 SEA reserves the right to introduce additional gifts, services or benefits for participants to extend the range of opportunities proposed. Members shall be notified of any such opportunities on the SEA channels in due time.
6.5 SEA declines all responsibility in relation to the special offers from the Partners participating in the Program.
6.6 SEA reserves the right to develop specific agreements with Partners for participation in the ViaMilano Program rewards initiative that may include points being credited.
ART. 7 - CLAIMING AND COLLECTING PRIZES
7.1 Depending on the type of prize (Article 5), a Participant may claim a prize according to the procedure described in the prize catalogue which can be found in the reserved area, accessed using the login credentials for the Milan Malpensa and Milan Linate websites, and the Milan Airports app.
7.2 Rewards claimed shall be collected according to the following procedures:
for prizes in the Voucher category, the Participants should visit one of the retail points/stores taking part in the Program and inform the retailer that they wish to use the Voucher by showing the bar code, or by accessing the website directly. Vouchers can be requested and used at the time of purchase. Vouchers are non-cumulative. Only one voucher may be used, per purchase. For higher amounts, the difference will be payable by the Participant and the retailer will credit the points for the purchase while deducting the points for the issue of the Voucher. For example, a purchase to the value of €45 (forty-five euros) with the issue of voucher for €15 (fifteen euros) will result in points being credited to the value of €30 (thirty euros). The retailer will then issue confirmation that the points have been allocated;
for e-commerce vouchers, the code must be input on the e-commerce website. A voucher can be used to buy goods or services at the same time it is issued. Therefore, a participant is required to make a purchase of a value which is equal to or higher than the value of the voucher. Vouchers are non-cumulative. Only one voucher may be used, per purchase. For higher amounts, the difference will be payable by the Participant and the retailer will credit the points for the purchase while deducting the points for the issue of the Voucher. For example, a purchase to the value of €45 (forty-five euros) with the issue of voucher for €15 (fifteen euros) will result in points being credited to the value of €30 (thirty euros). The retailer will then issue confirmation that the points have been allocated;
for prizes in the “Airport Services” category, Participants can select the desired service from the list in the reserved area accessible using the login credentials on the Milan Malpensa and Milan Linate websites and the Milan Airports app. The selected service will then be authorised, under the conditions available with the prize;
the other prizes can be collected in accordance with the detailed procedure contained in the reserved area, which can be accessed by using the login and password for the Milan Linate and Milan Malpensa websites, and the Milan Airports app;
for some of the prize categories, the Participant’s financial contribution can be paid when the prize is claimed, on the e-commerce platform on the SEA websites;
once the prize has been collected, no exchange or refund of any kind is permitted, except for reasons attributable to SEA.
7.3 Vouchers cannot be used for the categories of goods not included in the points collection scheme. These categories are listed in para. 4.16 of these Regulations.
7.4 Prizes that have been stolen, lost, destroyed or which have expired cannot be reissued.
7.5 If the Participant is unable to use his or her prize, no cash alternative is available.
7.6 The prizes are personal and may not be used by anyone other than the requesting Participant.
7.7 The Participants can access the prizes until 30 (thirty) days after the Program ends, therefore until 31/01/2019. During the campaign, based on specific promotional and classical marketing campaigns, SEA may apply more favourable conditions for certain categories of participant based on predetermined requirements. SEA will inform interested parties of these opportunities, through its own advertising channels.
7.8 SEA may introduce other opportunities for the collection of certain prizes, under certain conditions, for limited periods. Participants will be suitably informed of these campaigns on the SEA advertising channels.
7.9 If the prize required by the Participant is no longer available, it will be replaced with a prize of equal or higher value, of the same type. In certain cases, SEA reserves the right to contact the Participant directly to inform them of this.
7.10 SEA offers Participants using ViaMilano Program prizes the opportunity to obtain additional prizes and benefits specifically tailored to each Participant’s purchasing behaviour. SEA will promptly inform participants of how to obtain these opportunities, through its own advertising channels.
ART. 8 - RULES OF CONDUCT; PENALTIES
8.1 The Participant’s participation in the Program is subject to compliance with all the conditions and rules of conduct contained in these Regulations.
8.2 Participants must not act in an abusive, disrespectful or inappropriate manner towards the employees of SEA or Partners of the Program, nor act inappropriately inside the areas made available to the Participants or refuse to follow the instructions of SEA employees or the employees of a Partner.
8.3 SEA may, at its discretion, exclude a Participant from the Program, and without affecting the existing rights of the Participant, cancel any points collected but not yet used at the time of the exclusion, and cancel any prizes previously obtained but not yet used, if he or she does not respect all the conditions of these Regulations and/or if his or her conduct does not conform to the Regulations, or to the terms and conditions of SEA or one of its Partners, or to any other applicable provision or rule.
8.4 Participation in this promotion requires acceptance of the conditions in these Regulations.
8.5 Prizes will only be awarded after the necessary checks have been carried out by the Organisers who may check at any time that the person entitled to the prize has duly complied with the Regulations. Any attempted fraudulent use of the Program materials represents a criminal offence (theft and fraud) which may be prosecuted and made the subject of legal proceedings.
ART. 9 - WITHDRAWAL FROM THE PROGRAM
9.1 The Cardholder is free to withdraw from the Program at any time. Withdrawal must be notified to SEA by registered post or by email, sent to firstname.lastname@example.org. In both cases, to allow SEA to check the entitlement of the person requesting withdrawal from the Program, the personal code, date of birth and email address on the ViaMilano Program system, will be requested.
If no prize is claimed when withdrawing from the Program, the points collected will be lost. A Participant who has decided to withdraw from the Program will also lose the right to access the services on the SEA website and to receive newsletters.
ART. 10 - PERSONAL DATA PROCESSING AND PRIVACY NOTICE
10.1 All personal data provided voluntarily by the data subjects when registering for the ViaMilano Program and/or during the use of the Services, including via the SEA Portal, shall be processed by SEA – under the terms of Articles 4, no. 7) and 24 of EU General Data Protection Regulation (GDPR) 2016/679 of 27 April 2016, as well as the Italian legislation in force.
Personal data processing means any operation or set of operations carried out with or without the use of automated processes, applied to personal data or sets of personal data, even if such data is not registered in a databank, such as collection, registration, organisation, structuring, storage, processing, selection, blocking, adaptation or amendment, extraction, consulting, use, communication via transmission, distribution or any other form of provision, comparison or interconnection, limitation, cancellation or destruction.
As the data controller, SEA shall ensure that the personal data is processed in accordance with the principles of need, legality, fairness, quality of data and proportionality. In each case, the data shall be processed using procedures that ensure its confidentiality by means of electronic, manual or printed instruments; it shall be compared, classified and calculated using lists or directories. In any case, the data shall be processed in accordance with the minimum security measures to guarantee the confidentiality of the subject whose personal data is concerned and prevent the risk of access to such data by unauthorised third parties. Therefore, SEA shall carry out the relative data processing, under the terms of the GDPR and Italian legislation in force, for the purposes set out below.
10.2 (Aims and legal basis of data processing) Data shall be acquired and processed in accordance with the rules established by the GDPR and the Italian legislation in force for the following purposes with the consent of the data subject:
(i) to manage the participation of the Member in the Program, attribute the rewards and other benefits connected to participation in the Program and the holding of the card to the Member as well as provide the relative correlated services in accordance with the methods provided for in these Regulations as well as via the dispatch of communications on new developments, initiatives and promotions reserved for members, covered by the program (“Primary Aims”)
(ii) Direct Marketing (see under point 10.6)
(iii) Profiling (see under point 10.6)
10.3 (Communication and distribution of personal data for the pursuit of the Primary Aims of data processing). Data may be communicated to third parties when communication is mandatory according to the law, including therein the prevention/repression of any unlawful activity. With reference to Article 13, paragraph 1, clause (e) of the Regulation and Italian legislation in force, the data may be communicated for the pursuit of the Primary Aims only to employees/ co-workers/consultants of the Company as well as third-party service providers within the framework of the Program and with which the Company cooperates for the pursuit of the Primary Aims. The updated list of external data processors is available at the Company’s head office. The data shall not be distributed or personal data disclosed to the public or, in any case, to an indeterminate number of persons.
10.4 (Data storage periods) Personal data shall be processed throughout the duration of the Program and for subsequent versions thereof and shall be stored after the expiry and/or withdrawal by the Member for administrative purposes only (and not for the purposes of Profiling and Direct Marketing) for a period not exceeding three months (without prejudice to any specific legal obligations regarding the storage of accounting documentation and except for the storage of the Member’s data for a period not exceeding one year, in any case, for the purposes of permitting the Member to benefit from a reward in view of the points accumulated). In each case, personal data shall be stored for the purposes of Profiling or Direct Marketing for a period not exceeding twelve and twenty-four months respectively as from registration, except for the actual conversion of the data into an anonymous form to prevent identification of the data subjects, including indirectly or by associating other databanks.
10.5 Personal data that does not need to be stored for the purposes for which it has been processed and, in any case, on the expiry of the storage deadlines referred to above, shall be deleted or converted into an anonymous form by SEA and the third parties to which it may have been communicated for the above-mentioned purposes.
10.6 (Mandatory or optional provision of data) Primary Aims. Provision of the personal data required in the Program registration form marked by an asterisk (*) is optional but necessary for the Member’s full participation in the Program and for the initiatives connected therewith as well as for the fulfillment of statutory obligations.
Any refusal to provide the personal data requested, in full or in part, including during the execution of the Program may only give rise to the inability of SEA or third-party service providers within the framework of the Program to execute the Program in full or perform the obligations deriving therefrom correctly.
The omission or partial or inaccurate provision of personal data other than that marked by an asterisk (*) shall have no consequence in relation to the Member’s inclusion or participation in the Program and shall not prevent them from registering for or using the services on the SEA Portal.
Direct Marketing Aim. In order to proceed to the processing for the purposes of Direct Marketing specific, separate, express, documented, prior and entirely optional consent must be acquired mandatorily.
By providing consent to data processing for Direct Marketing purposes, the data subject acknowledges specifically the promotional, commercial and marketing aims of the data processing in a broad sense (including the consequent administrative and managerial activities) and expressly authorises this data processing under the terms of Art. 6, paragraph 1, clause (a) of the GDPR and in accordance with the Italian legislation in force.
If the data subject does not intend to give consent to data processing for Direct Marketing purposes, the Company shall be unable to carry out the relative data processing. Failure to provide consent to data processing for Direct Marketing purposes shall not lead to any interference and/or consequence with respect to any other business, contractual or other type of relations in existence with the user.
Profiling. It is possible that for Direct Marketing purposes and to improve the services, the Company shall process so-called “profiling” data. For this processing and the purposes of complete information, reference is made to the definition referred to in Art. 4, paragraph 1, No. (4) of the GDPR: “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”.
In order to proceed to profiling, it is mandatory to obtain specific and separate consent. If the data subject does not intend to give consent to processing for Profiling purposes, the Company shall be unable to carry out the relative data processing. The data subject is free to provide data processing consent for Direct Marketing purposes and not for additional consent for Profiling purposes. Should the data subject not intend to provide consent to data processing for Profiling purposes, the Company shall have no Profiling information and the data collected shall be processed solely and exclusively for Direct Marketing purposes by the Company, if the data subject has given consent thereto. The data processed for Profiling and the relative authorised profiles shall not be subject to any distribution.
10.7 In each case, even if the data subject has given consent to authorise the Company to pursue all the aims indicated in the points above, they shall remain free to revoke them at any time.
As required by Art. 21 of the Regulation, it is stated specifically and separately that a data subject shall be entitled to object to the processing of their personal data for these purposes at any time and that if the data subject objects to the data processing, the personal data may no longer be processed for such purposes.
10.8 (Transfer of personal data to Countries not belonging to the European Union) The data collected and processed shall not be transferred to companies or other entities outside the European Community.
10.9 (Data controller)
The ID of the data controller is as follows:
Società per azioni Esercizi Aeroportuali S.E.A., having its registered office in Segrate (Milan) – 20090 – at Milan-Linate Airport
10.10 (Data Protection Officer (DPO)
The Data Protection Officer may be contacted, including for the exercise of the rights of the data subjects in accordance with Articles 15-22 of the Regulation, by sending an email to email@example.com.
10.11 (Data subject rights)
Data subjects shall be entitled to exercise the rights referred to in Articles 15 to 22 of European Regulation 2016/679 reproduced below in relation to data processing. Exercise of the rights is not subject to any restrictions in terms of form and is free of charge.
Pursuant to Articles 15 to 22 of European Regulation 2016/679, data subjects shall be entitled to obtain the correction, integration or deletion of their personal data from the data controller(so-called Right To Be Forgotten); they shall also benefit from the right to obtain the restriction of the data processing and right to the portability of the data, right to object to the processing of the personal data, including profiling and, finally, the right to complain to the Ombudsman.
ART. 11 - REFERENCE TO LAWS; CONFLICT OF LAWS
11.1 For all matters in these Regulations not expressly stipulated or governed, refer to the relevant legal and statutory regulations applicable with particular reference to Pres. Dec. No. 430 of 26/10/2001, (published in Official Gazette No. 289 of 13/12/2001), containing "Regulations on the organic revision of the system of competitions and prize promotions, as well as gambling initiatives under the terms of Art. 19, paragraph 4, of Law No. 449 of 27/12/1997".
11.2 In the event of any conflict between the provisions of these Regulations and those of said legislation, the latter shall prevail.