Pursuant to Regulation (EU) 2016/679 (“GDPR”), the American Chamber of Commerce in Italy (“AmCham Italy”) provides this Privacy Notice concerning the processing of personal data in connection with participation in the MilanoAI Manifesto and browsing the MilanoAI.org website.

1. Data Controller

The Data Controller is American Chamber of Commerce in Italy – AmCham Italy, with registered office at Via Cesare Cantù 1, 20123 Milan, Italy, represented by its pro tempore legal representative (“Data Controller” or “AmCham Italy”).

For any request or clarification concerning the processing of personal data, AmCham Italy may be contacted at privacy@amcham.it.

2. Personal Data Processed

In connection with participation in the MilanoAI Manifesto, AmCham Italy processes the personal data provided by the data subject through the participation request submitted by email.

In the case of participation in an individual capacity, the following data may be processed:

• first and last name;
• place and date of birth;
• city and country of residence;
• email address;
• mobile telephone number, if voluntarily provided.

In the case of participation by a legal entity or other organization, the personal data of the individual representing such entity or organization may be processed, including, in particular, first and last name, position, and email address.

When browsing the MilanoAI.org website, browsing and website usage data may also be processed through cookies and other tracking technologies, as described in Section 11 below.

3. Purposes of the Processing

The personal data collected in connection with participation will be processed by AmCham Italy for the following purposes:

a) Adherence to and participation in the MilanoAI Manifesto

Collection, registration, and management of participation in the MilanoAI Manifesto, as well as carrying out activities related to the purposes and commitments set out in the Manifesto.

b) Possible publication on MilanoAI.org

Subject to specific and separate consent, information relating to supporters of the Manifesto may be published on the MilanoAI.org website.

Any consent to publication does not automatically result in the publication of the relevant data, which remains subject to the discretionary assessment of AmCham Italy.

4. Legal Basis for Processing

The legal basis for the processing referred to in Section 3(a) above is the data subject’s consent, pursuant to Article 6(1)(a) of the GDPR.

Consent to the processing of data for this purpose is necessary in order to participate in the MilanoAI Manifesto. Without such consent, it will not be possible to complete the participation process.

The legal basis for any publication referred to in Section 3(b) above is specific and optional consent.

Failure to provide consent to publication will in no way affect participation in the Manifesto.

5. Provision of Data

The provision of the data necessary to identify the participant and manage participation is necessary to enable AmCham Italy to register and manage participation in the MilanoAI Manifesto.

Providing a mobile telephone number is optional.

Consent to the publication of the participant’s data on the MilanoAI.org website is optional, and failure to provide such consent will not prevent participation in the Manifesto.

6. Methods of Processing

Personal data are processed using manual, computer, and electronic means, in accordance with procedures strictly related to the purposes set out above and in compliance with the principles of lawfulness, fairness, transparency, data minimization, and confidentiality established by the GDPR.

AmCham Italy adopts appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of personal data and to prevent their loss, unlawful or improper use, and unauthorized access.

7. Disclosure and Dissemination of Data

Personal data processed in connection with participation will not be disclosed to third parties, except where this is necessary to comply with legal obligations or to enable parties acting on behalf of AmCham Italy, duly appointed as data processors pursuant to Article 28 of the GDPR, to perform technical or organizational activities necessary for the management of the website and data.

The personal data of an individual participant, or of the individual representing a participating entity, may be disseminated through publication on the MilanoAI.org website exclusively where the specific consent referred to in Section 3(b) above has been provided, and subject to AmCham Italy’s discretionary assessment regarding publication.

8. Data Retention Period

Personal data will be retained for the period necessary to manage participation and carry out activities related to the MilanoAI Manifesto and, in any event, no longer than necessary to achieve the purposes for which the data were collected, except where applicable legal obligations require further retention.

If consent to the processing for the purposes referred to in Section 3(a) is withdrawn, AmCham Italy will cease the relevant processing and delete the personal data processed on the basis of such consent, without prejudice to any legal obligations requiring their retention.

If only consent to publication is withdrawn, participation in the Manifesto will remain valid and the first and last name of the individual, or the corporate name of the legal entity, will be removed from the MilanoAI.org website, where previously published.

9. Withdrawal of Consent

The data subject may withdraw consent at any time by contacting AmCham Italy at privacy@amcham.it.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Withdrawal of consent to the processing necessary to manage participation will result in the inability to continue participating in the MilanoAI Manifesto.

Withdrawal of consent to publication only will result solely in the non-publication or, where publication has already occurred, removal from the website of the first and last name of the individual or the corporate name of the legal entity, without affecting participation in the Manifesto.

10. Data Subject Rights

• The data subject may exercise at any time the rights provided for under Articles 15 et seq. of the GDPR and, in particular, the right to:
• obtain confirmation as to whether or not personal data concerning them exist and access such data;
• obtain the rectification of inaccurate data or the completion of incomplete data;
• obtain, in the cases provided for by applicable law, the erasure of personal data;
• obtain restriction of processing in the cases provided for by the GDPR;
• receive the personal data provided to the Data Controller in a structured, commonly used, and machine-readable format, where the relevant conditions are met;
• withdraw consent at any time;

lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).

To exercise their rights or request information concerning the processing of personal data, data subjects may contact privacy@amcham.it.

11. Cookies and Other Tracking Technologies

The MilanoAI.org website uses cookies and other tracking technologies to ensure its proper functioning and, where user consent is required, for the following purposes.

a) Traffic Analytics Tools

The website may use analytics tools to collect information about website usage, measure traffic and performance, and obtain statistical data concerning users’ browsing activities.

Where the use of such tools involves cookies or other identifiers that are not strictly necessary for the operation of the website, their use is subject to the user’s prior consent.

b) Marketing and Social Tracking Tools

The website may use marketing tools and tracking technologies connected to social media platforms, which may enable the monitoring of users’ interactions with the website and the use of such information for marketing purposes and to measure related activities.

The activation of such tools is subject to the user’s prior consent.

Users may provide or refuse their consent to the various categories of cookies and tracking technologies through the relevant banner displayed upon their first access to the website and may subsequently modify or withdraw their choices at any time.

Refusal of non-essential cookies and tracking technologies does not affect the ability to access and browse the MilanoAI.org website.

12. Consent

I declare that I have read this Privacy Notice and consent to:

☐ the processing of my personal data for the management of my participation and for carrying out activities related to the purposes of the MilanoAI Manifesto.

Consent is required in order to participate in the Manifesto.

☐ the possible publication of the first and last name of the individual or the corporate name of the legal entity on the MilanoAI.org website in the list of Manifesto supporters.

Consent to publication is optional, and failure to provide such consent will not affect participation in the Manifesto. Any publication remains subject to the discretionary assessment of AmCham Italy.

☐ the use of traffic analytics tools.

☐ the use of marketing and social tracking tools.

Providing these consents is optional. Failure to provide consent does not affect access to or browsing of the MilanoAI.org website. Consents provided may be modified or withdrawn at any time through the cookie settings available on the website.