Who we are
Throughout this document, “we”, “us’, “our” and “ours’ refer to Milano Ventures Ltd., a limited liability company incorporated in Ireland, also trading as: Wornex International (Ireland), NEXUS-International Broadcasting Association (NEXUS-IBA), International Public Access Radio (IPAR), Irish Radio Relay Service (IRRS), Italian Radio Relay Service (IRRS), European Gospel Radio (EGR). We provide cloud (Internet), media and broadcasting services worldwide.
What is the General Data Protection Regulation (GDPR)?
The General Data Protection Regulation (‘GDPR’) applies from 25 May 2018 and significantly changes data protection law in Europe, strengthening the rights of individuals and increasing the obligations on organisations. The GDPR is designed to give individuals (defined in the GDPR as: “natural persons”) more control over their personal data. (A copy of the GDPR is available here).
The key principles under the GDPR are lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality, and accountability (Article 5 of the GDPR).
Your rights under the GDPR
Under GDPR data subjects have increased rights. The data subject rights are:
- The right to be informed (Articles 12 – 14 of the GDPR);
- The right to access information (Article 15 of the GDPR);
- The right to rectification (Articles 16 & 19 of the GDPR);
- The right to erasure (Articles 17 & 19 of the GDPR);
- The right to data portability (Article 20 of the GDPR);
- The right to object to the processing of personal data (Article 21 of the GDPR);
- The right of restriction (Article 18 of the GDPR);
- Rights in relation to automated decision making, including profiling (Article 22 of the GDPR).
For customers using our services
- The security, speed and reliability of your data and services come first;
- We promptly notify you if we detect a breach of our own security that may compromise your data;
- You have full control of your data and software that you install. You are also responsible for keeping any software up-to-date to avoid any security breach to your data;
- Our data centres are mainly located in Europe and USA, and we may offer a local presence to some customers with data centres in other parts of the world;
- We operate a resilient, highly available infrastructure that consists of secure networks, servers and data centres connected and controlled by our WorldDirector global load balancing technology.
How we use your information and your data
We understand that your privacy and the security of your information are very important to you. Milano Ventures is committed to keeping your information private.
Using our website
- number of people who visit the website;
- date and time of visits;
- number of pages viewed;
- amount of time spent on the website;
- popular sections of the website
Subject to your device settings and consents, we may also collect information about your device, your location and whether or not you are a user or client of Milano Ventures. This information is anonymous, and no attempt is or will be made to identify visitors without their consent.
The search facility on our website is an internal search function and only returns information that appears on the website. We do not track or retain user activity when customers use this facility.
Personal Information You Provide To Us
Unless you agree, otherwise any, information gathered in respect of requests of information is retained by Milano Ventures for the purpose of answering to your requests or for providing products or services that you have requested to you or your organisation. We may analyse your information using automated means to:
- help us understand your needs and develop our relationship with you;
- to help us to offer you products and service information we believe will be of interest to you.
We ask for personal information when verifying your identity as a legitimate, registered user of our services, or when signing up for a service or product provided by Milano Ventures.
All information provided to us by you will be treated with the utmost confidentiality by all applicable legislative and regulatory standards. If you ever decide that you no longer wish us to keep or use information or you want the information to be revised or updated, please feel free to contact us. We will remove or amend the information as appropriate by applicable legislative and regulatory requirements. Removal of certain or all information may fail to answer to any request, or delay, suspension or termination of services rendered to you or delay or failure in the delivery of any product that you have ordered.
Calling our Helpdesk
Milano Ventures may collect Calling Landline Identification (CIL) or any other information on the origins of a call as an additional security measure to identify and verify whether callers are spammers, prospective or registered clients of Milano Ventures before we can provide assistance or any information to them. We do not record or retain phone conversations.
Any emails sent to us are recorded and forwarded to the relevant department and may be assigned a ticket number to track processing of each request. The sender’s email address will remain visible to all staff tasked with dealing with the query. Please be aware that it is the sender’s responsibility to ensure that the content of their emails is within the bounds of the law. All unsolicited material of a criminal nature will be reported to the relevant authorities and blocked.
Making a complaint to us
When we take on a complaint, a file is generated. This will usually contain personal information about the complainant and any other individuals involved in the complaint. We will only collect personal information that is necessary to investigate the complaint.
We will usually have to disclose the complainant’s identity to whomever the case is against. We will try to facilitate a complainant who wishes to remain anonymous, but if a case proceeds it is inevitable that the identities of both parties are revealed. This is to ensure fairness in the legal process.
If sensitive personal data organization for a complaint, appropriate measures will be taken to ensure that it is safely processed. The information contained in complaint files will be kept in line with our retention policy. This means that information will be held for six years from the last date of action on file. It will be kept in a secure environment and available only to those who need to access it.
Registering as a client or user
When a business or individual is required to register with Milano Ventures, (i.e., when subscribing to any service or buying a product or service online), a record of their registration is created. All information requested on original registration shall hereafter be referred to as “Registration Information”. Such record is accessible only to Milano Ventures, to our outsourced accounting firms, our designated Tax Agents, our Company Secretary and those who legitimately need such records to comply with laws and regulations.
Such records may also be available to our outsourcing partners to deliver any service or product that you have ordered (i.e. in case of domain name registration we must send personal and company data to each domain name registry or their reseller). Registration Information will not be available to third parties unless specified above, and unless you have agreed to release this information to third parties, i.e. for marketing purposes.
We do not retain manual registration records. Registration files may also contain personal data in case of individuals, sole traders, or to identify contacts with whom Milano Ventures will interact to answer each customer or user request.
In the case of an organisation, applying to become a client it must provide names and descriptions of the principals, officers, directors and partners and secretary if appropriate and any other information which Milano Ventures may require.
In the case of an individual applying to become a client, he or she must give the name, residence, business profession or other occupation of the applicant and any other information which Milano Ventures may require.
If you or your organisation provides any information that is untrue, not accurate or incomplete or Milano Ventures has reasonable grounds to suspect that such information is not current, incomplete or inaccurate, then Milano Ventures has the right to suspend or terminate your or your organisation’s services and/or not to deliver services or products ordered.
This Registration Information will be retained by the Milano Ventures for no longer than as is necessary, i.e. to comply with tax or other provisions of law or to continue to provide product or services on a regular basis. Unless you or your organisation has agreed to the use of the Registration Information for direct marketing purposes by Milano Ventures, Milano Ventures agrees to use the Registration Information only for the purpose of supplying products or services to you or your organisation.
If you or your organisation has agreed to the use of Milano Ventures for direct marketing purposes, it may opt out in writing at any time.
Reporting a Breach of Data Protection
We take Breach Notifications from organisations who are self-reporting a lapse in Data Protection, or from individuals whose own personal data has been disclosed without their consent. We only gather such information as is necessary to investigate and take action in a case. Breach report material is stored in electronic format for six years from the last date of action on file. It will be securely stored and available only to those who need to access it.
Access to personal information
If you ever decide that you no longer wish us to keep or use information or you want the data to be revised or updated, please feel free to contact us. We will remove or amend the information as appropriate under applicable legislative and regulatory requirements.
In any case, unless we are obliged to retain personal data because of an existing contract or by law or tax reasons, your personal data will be deleted after 36 months since we last heard from you.
To exercise your rights as an individual or natural person under the GDPR, as summarised above, the individual concerned should apply in writing to email: email@example.com. You should also include any additional details that would help to locate your information – for example, a personal account number or additional email addresses. You will be asked to send us evidence of your identity and address. This is to make sure that personal information is not given to the wrong person.
You can prove your identity with any of the following:
- A valid passport;
- A current identity card;
- A current driving licence with your photo.
Evidence from our data processing or provided by you should prove that you were in the European Union, as per article 3 of the GDPR (Territorial Scope), when your personal data was processed by us.
Chatbox services are provided by Smartupp. Your personal data might be collected by 3rd parties, such as Smartsupp.com, s.r.o., VAT ID CZ0366868 or us. Smartsupp acts as Data Processor on behalf of the website owner who is the data controller. Smartsupp is GDPR compliant. You can find information about Smartsupp personal data privacy and processing here. Processing of your personal data is necessary to provide you customer service if you interact with us using our chatbox.
This means that may still collect some personal data when you use the chat box on our site, and we are responsible for this data. By using Smartsupp as a Data Processor when they provide chat box services, we pass some personal data to Smartupp for processing.
Disclosure of personal information
When providing our services to you, we may share your information with:
- Your authorised representatives;
- Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii) you ask us to share your information;
- NEXUS-International Broadcasting Association, a non-profit organisation, based in Milan, Italy.
- Service providers who provide us with support, telecommunication, broadcasting and cloud services;
- Domain registration providers or domain registrars, when you register an Internet domain name through us;
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities;
- Credit reference/rating agencies;
- Third parties in connection with a sale or purchase of assets by us: persons making an enquiry or complaint; debt collection agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, examiners, Official Assignee for Bankruptcy and equivalent in other jurisdictions;
- Trade associations and professional bodies, non-statutory bodies and members of trade associations;
- Business or joint venture partners.
Third parties to whom we may disclose information may also include organisations such as An Garda Síochána (meaning “the Guardian of the Peace” or Irish Police) or the Office of the Revenue Commissioners (Irish Tax office).
Updates and Changes to our Privacy Statement
This is a live document, under regular review, and may change without notice from time to time. This policy was last updated on May 24, 2018.
How to contact us
If you require exercising your rights according to the GDPR, please contact us by email at firstname.lastname@example.org.