Privacy Policy

Cattaneo Zanetto Pomposo & Co. Srl., with registered office in Milan, Largo Richini 6 (hereinafter also “ Company ” or “ Owner ”), is a company that operates in the sector of institutional relations and lobbying . Among others, the Company offers its clients strategic consultancy and political intelligence services in which context it may have an interest in acquiring and processing personal data concerning individuals who hold public and institutional positions, opinion leaders and public figures.

Cattaneo Zanetto Pomposo & Co Srl, as Data Controller, intends to provide information to any subjects whose data could be processed in the context of the activities described, pursuant to art. 14 of Regulation (EU) 2016/679 (hereinafter ” Regulation “).

In particular, this information illustrates the purposes and methods with which the Company collects and processes the personal data of interested parties, what the interested parties’ rights are and how they can be exercised.

1. Categories of personal data

As part of the strategic consultancy and political intelligence activities carried out in favor of its clients (hereinafter ” Activities “), the Company may process: i) personal identification data (for example, name, surname, date and place of birth), contact details and information (for example, e-mail address) of the interested parties; ii) data relating to the training, political or institutional positions held and the professional and/or political experience of the interested parties.

Furthermore, if relevant and under the conditions described below, the Company may process data relating to the political opinions or membership of political parties of the interested parties as well as further data belonging to the particular categories referred to in the art. 9 of the Regulation.

2. Purpose and legal basis of the processing

The personal data collected by the Company will be processed on the basis of a legitimate interest of the same in carrying out strategic consultancy and political intelligence activities , which constitute central activities for the business of Cattaneo Zanetto Pomposo.

The processing of data of a common nature is therefore carried out pursuant to art. 6, par. 1, letter. f) of the Regulation.

Interested parties have the right to object to such processing at any time by writing to dataprotection [ at ] cattaneozanetto.it, without prejudice to the existence of prevailing interests of the Company pursuant to art. 21 of the Regulation.

The data belonging to the particular categories referred to in art. 9 of the Regulations will be processed by the Company pursuant to art. 9, par. 2, letter. e) of the Regulation; therefore, exclusively when made manifestly public by the interested parties.

3. Categories of subjects to whom personal data may be communicated and purposes of communication

The Data Controller may communicate the personal data collected and processed as part of its activities to external companies that offer management or IT services to the Data Controller. These companies will process the personal data as data controllers.

Furthermore, the Data Controller may communicate the personal data of interested parties to subjects in whose interests the Company carries out the Activities. These subjects will process the personal data as independent data controllers.

The list of data processors can be requested by writing to dataprotection [ at ] cattaneozanetto.it.

The personal data being processed will never be published, displayed or made available/consulted by indeterminate subjects.

4. Duration of treatment

The personal data indicated above will be processed by the Data Controller, pursuant to art. 5, paragraph 1 of the Regulation, for the time strictly necessary to carry out the activities described above and therefore:

1. for subjects who hold public/institutional positions, for the duration of the assignment, after which the data collected will not be subject to further storage;
2. for subjects who do not hold public/institutional positions, for the period of time during which the interested party can be considered to be a public subject/ opinion leader for the purposes of the Data Controller’s political intelligence activities , after which the data will not be subject for further conservation.

5. Transfer of data outside the European Union

The data processed by the Company will be transferred outside the European Union by service providers used by the Data Controller. This transfer, where appropriate, will be regulated with the service providers through the use of standard contractual clauses adopted by the European Commission with Decision 2021/914/EU and any subsequent amendments or, alternatively, on the basis of an adequacy decision of the Commission and/or any other instrument permitted by the relevant legislation. In cases where the supplier is located in the United States, personal data will be transferred according to the EU-US Data Privacy Framework, if the supplier has adhered to it.

Interested parties will be able to obtain information on the place where the data has been transferred and a copy of such data by writing to dataprotection [ at ] cattaneozanetto.it.

6. Rights of interested parties

In compliance with current regulations, interested parties may exercise the following rights:

1. request and obtain information regarding the existence of personal data at the Company and regarding the data processing carried out by the Data Controller as well as obtaining access to such data;
2. request and obtain the modification and/or correction of your personal data;
3. request and obtain the cancellation – and/or limitation of processing – of your personal data if it is data or information that is not necessary – or no longer necessary – for the aforementioned purposes, therefore after the retention period indicated in the previous paragraph has elapsed ;
4. object to the processing at any time in the cases provided for by law.

Such requests may be addressed to the Data Controller by writing to dataprotection [ at ] cattaneozanetto.it.

Interested parties pursuant to current legislation may submit any complaints regarding the processing of their personal data to the Guarantor for the Protection of Personal Data (Piazza Venezia, 11, 00187, Rome, guarantor [ at ] gpdp.it, protocol [ at ] pec.gpdp.it).