PRIVACY POLICY

Section 1. General Provisions

1.1.This Privacy Policy (hereinafter — the “Policy”) forms an integral part of the Agreement (public offer) for the provision of services (clause 1.15 of the Agreement). Terms used in the Policy have the meanings given to them in Section 1 of the Agreement.

1.2.The Policy has been drawn up in accordance with Regulation (EU) 2016/679 (hereinafter — the “GDPR”) and Legislative Decree of the Italian Republic No. 196/2003 and explains which personal data of the Client are processed, for what purposes, on what legal basis, to whom they are transferred and for how long they are stored.

1.3.The services are not intended for persons under the age of 21. The Agency does not knowingly process the data of such persons.

Section 2. Controller of Personal Data

2.1.The controller of the Client’s personal data is the Contractor (the person to whose account the Client has paid for the Package):

2.1.1.Yuliia Lysenko, entrepreneur;

2.1.2.Liudmyla Slobodianiuk, entrepreneur.

2.2.Yuliia Lysenko and Liudmyla Slobodianiuk are independent controllers. Each of them is responsible for the processing of personal data only of those Clients with whom she has concluded an Agreement. Before the Package is paid for, the controller of the data received at the first contact is the one of them who conducts the correspondence with the Client.

2.3.E-mail address for matters relating to the processing of personal data: milanalove.info@gmail.com. In the request, the Client states the name of the Contractor.

Section 3. What Data Are Processed

3.1.The Agency processes the following categories of the Client’s personal data:

3.1.1.identification and contact data: first name, surname, date of birth, e-mail address, telephone number, country and city of residence, citizenship;

3.1.2.questionnaire data: height, weight, marital status, children, education, occupation, interests, criteria for the search for a partner;

3.1.3.photographs and a short description of the Client, links to social networks;

3.1.4.correspondence with the Agency and the Agency Specialists, feedback on Candidates and introductions;

3.1.5.payment data: amount, date and method of payment, payer’s details;

3.1.6.documents provided by the Client voluntarily or at the Agency’s request for verification (clauses 6.3 and 6.4 of the Agreement).

3.2.If the Client voluntarily provides information about his religious beliefs or health (for example, in the search criteria), such data are processed only with his explicit consent (Article 9(2)(a) GDPR).

3.3.A criminal record certificate is processed only if it is provided by the Client, only for identity verification and the safety of Candidates, and only to the extent permitted by Article 10 GDPR and applicable national law. The certificate and its content are not transferred to Candidates.

Section 4. Purposes and Legal Bases of Processing

4.1.The Client may withdraw consent at any time by sending a letter to milanalove.info@gmail.com. Withdrawal of consent does not affect the lawfulness of processing before the withdrawal. If withdrawal of consent makes verification impossible, clauses 6.4 and 7.8.6 of the Agreement apply.

4.2.The Agency does not take decisions based solely on automated processing, including profiling, which produce legal effects for the Client (Article 22 GDPR). Candidates are selected by the Agency Specialists.

Section 5. To Whom the Data Are Transferred

5.1.The Agency transfers the Client’s personal data only to the extent necessary for the relevant purpose:

5.1.1.to Candidates — Profile data: first name, age, photographs, height, weight, country and city of residence, citizenship, occupation, interests, short description. The Client’s contact details are transferred to a Candidate only after mutual interest has been confirmed;

5.1.2.to the Agency Specialists (matchmakers, translators), as well as to other persons if they are engaged in the performance of the Agreement — to the extent necessary for the provision of the services. They act on the instructions of the Contractor and are obliged to keep the data confidential (Article 28 GDPR);

5.1.3.to providers of technical services: e-mail, messengers, video communication, cloud storage;

5.1.4.to banks and payment services — for receiving payments and making refunds;

5.1.5.to the Contractor’s accountant — for tax records;

5.1.6.to public authorities — in cases provided for by law.

5.2.The Agency does not sell the Client’s personal data and does not transfer them to third parties for advertising.

Section 6. Transfer of Data outside the European Economic Area

6.1.Candidates and some of the Agency Specialists are located in Ukraine and other countries outside the European Economic Area (EEA). The European Commission has not adopted an adequacy decision in respect of Ukraine.

6.2.Transfer of Profile data to Candidates is necessary for the performance of the Agreement concluded at the Client’s request (Article 49(1)(b) GDPR).

6.3.Transfer of data to the Agency Specialists outside the EEA is carried out on the basis of the standard contractual clauses approved by Commission Implementing Decision (EU) 2021/914 (Article 46(2)(c) GDPR).

Section 7. Retention Periods

7.1.If personal data are necessary to protect the Agency’s rights in pre-trial or court proceedings, they are stored until the dispute is finally resolved.

7.2.On expiry of the retention periods, the data are deleted or anonymised.

Section 8. Rights of the Client

8.1.The Client has the right to:

8.1.1.obtain information about the processing of his data and a copy of the data (Article 15 GDPR);

8.1.2.rectify inaccurate data (Article 16 GDPR);

8.1.3.request erasure of the data (Article 17 GDPR);

8.1.4.restrict processing (Article 18 GDPR);

8.1.5.receive his data in a structured format (Article 20 GDPR);

8.1.6.object to processing based on legitimate interest (Article 21 GDPR);

8.1.7.withdraw consent (Article 7(3) GDPR).

8.2.A request is sent to milanalove.info@gmail.com. The Contractor replies within one month of receipt of the request (Article 12(3) GDPR). In order to reply, the Contractor may request confirmation of the Client’s identity.

8.3.The right to erasure does not apply to data that the Contractor is obliged to store by law or that are necessary to protect its rights (Article 17(3) GDPR).

Section 9. Data of Third Parties

9.1.If the Client transfers data of third parties to the Contractor (for example, photographs with children or information about a former spouse), he confirms that he is entitled to transfer them.

9.2.The Client may not disclose or publish the data of Candidates received by him in the course of performance of the Agreement (Section 5 of the Rules).

Section 10. Data Protection

10.1.The Contractor takes organisational and technical measures to protect personal data: restriction of access, secure accounts, confidentiality obligations of the Agency Specialists.

10.2.In the event of a personal data breach likely to result in a high risk to the Client, the Contractor notifies the Client without undue delay (Article 34 GDPR).

Section 11. Amendment of the Policy

11.1.The Agency may amend the Policy by publishing a new version on the Website. The Agency notifies Clients with Agreements in force of material amendments by e-mail.