INFORMATION ON THE PROCESSING OF PERSONAL DATA – PHOTO/VIDEO SHOOTING DURING THE PRIVATE EVENT LOVRÉN IN THE CITY
(art. 13 EU Reg. 2016/679 – GDPR)
1. Data controller
Clinicalfarma Srl VAT No. IT02477590992
Registered office: Via Sant'Ilario 32 A/2 – 16167 Genoa (GE)
2. Processed data
Images and videos that may portray event participants (mainly contextual and group shots; possible shots of setups and moments of the event).
3. Purpose
to) Internal event documentation and reporting (archiving and reporting).
b) Corporate communication of the initiative (publication of content related to the event on the Company's official channels: website, company social media channels, and informational/corporate materials).
Please note: Filming may be done during the event; only a selection of footage may be used for communication purposes.
4. Legal basis
The processing of personal data is based on the Company's legitimate interest pursuant to Art. 6, paragraph 1, letter f) of the GDPR, consisting of documenting and communicating its institutional and corporate communications initiatives, including through event images. This processing is carried out in a proportionate and minimized manner, using contextual images, without focusing on individual participants, in a context for which data subjects can reasonably expect visual documentation, and in compliance with their fundamental rights and freedoms.
5. Processing methods and data minimization measures
The Company adopts organizational and technical measures to reduce the impact on data subjects, including:
· preference for contextual and group shots;
· avoid, as far as possible, recognizable close-ups;
· be careful not to associate images with particular information (art. 9 GDPR) or potentially prejudicial circumstances;
· On-site reporting: participants can inform staff of their desire not to appear in recognizable images;
· editorial selection prior to any publication, with the exclusion of content that is not consistent with these rules and of people who have expressed opposition/dissenting opinion (where identifiable);
· Specific measures for minors: the Company avoids recognizable footage; if incidentally present, the content is not used for publication and/or blackout measures are adopted.
6. Data recipients
The data may be processed by:
- authorized internal personnel;
- suppliers who provide photo/video, post-production, content management, and digital communication services, appointed as Data Processors pursuant to Art. 28 GDPR;
- social media platforms (e.g., Meta, LinkedIn, etc.), which operate as independent data controllers for the processing related to the operation of their respective platforms.
7. Transfers outside the EU
Posting on social media platforms may involve transfers to non-EU countries, according to the mechanisms indicated by the platforms (e.g., Standard Contractual Clauses or other applicable instruments). Further information is available in the platforms' privacy policies.
8. Conservation
The images/videos are stored:
- for corporate communication purposes: for a period not exceeding 24 months from the date of the event;
- For internal archiving/documentation: for a period not exceeding 24 months unless longer retention is required for protection in the event of disputes and/or legal obligations.
9. Rights of data subjects and objection (Article 21 GDPR)
Interested parties may exercise the rights set forth in Articles 15–22 of the GDPR.
In particular, they may object to processing based on legitimate interest (Article 21 GDPR) for reasons related to their particular situation.
These rights may be exercised by sending a detailed communication to the following address [email info@clinicalfarma.it].
The Company will process the request and, where technically and organizationally feasible, will adopt appropriate measures (e.g., exclusion from the selection process, non-publication, removal from channels under the Data Controller's control).
10. Use of the image (art. 10 cc – arts. 96–97 lda)
Any use of the image must be consistent with the event and not harmful to the honor, reputation, or dignity of the interested party. In the event of justified reports or requests, the Company will evaluate exclusion/removal from the channels under its control, within technical limits.
11. How to report "I don't want to appear"
During the event: please contact the staff.
Alternatively, write to privacy@clinicalfarma.it
The report will be considered both during the filming phase (where possible) and during the selection/publication phase (exclusion of contents where identifiable).