MINT Privacy Policy
Dear User,
This privacy policy is provided not only to comply with legal obligations relating to the protection of personal data – Regulation (EU) 2016/679 (hereinafter “GDPR”), Italian Legislative Decree (D.Lgs.) No 196/2003, as updated by D.Lgs. 101/2018 (or “Data Protection Code”) and significant orders issued by the Data Protection Authority – but also because MINT S.p.A (hereinafter also “MINT” or the “Company”) believes that the protection of personal data is a fundamental value of its activities and wishes to provide all information which can help you to protect your confidentiality and control the use you make of your personal data when navigating the mint.ai website (hereinafter the “Website”).Personal data are information relating to an identified or identifiable natural person defined “data subject” (hereinafter also “User”), including for example name, surname and navigation data.

1. DATA CONTROLLER

The Data Controller is MINT S.p.A., in the person of its legal representative, with its registered office via Ripa di Porta Ticinese 113, 20143 - Milan, Italy (“Company” or “Data Controller”).

2. DATA PROTECTION OFFICER

Due to the processing activities carried out, the Data Controller has deemed it necessary to appoint a Data Protection Officer, who can be reached by writing to the email address dpo@mint.ai.

3. SOURCE AND TYPES OF DATA PROCESSED, PURPOSE OF THE DATA PROCESSING AND LEGAL BASIS

The processed personal data is collected mainly on the User’s device when navigating on the Website or using the services made available by the website. This privacy policy analyses the personal data processed in the different sections of the Website and governs exclusively the processing of personal data on the Website and not any other websites the User may be redirected to. The data collected by the Website are processed mainly using electronic means, with software and IT procedures suited to guaranteeing the technical and IT security measures (e.g. the implementation of the https transmission protocol to transfer information entered in the Website).

In order to allow you to use the Website and its services, including the possibility ask for a demo of our products, get a product tour and contact us (collectively, “Services”), the Data Controller needs to collect and process some of your personal data.

Data voluntarily shared by the user

To allow you to use the Services, the Data Controller needs to collect your name, your business email address, your job title, your company and the annual media spend (optional).

The optional, explicit, and voluntary sending of mail involves the collection of your name, your surname, your email address, as well as other personal data included in the requests you submit.

PURPOSE
This purpose includes the possibility to ask for a demo of our products, get a product tour and contact us through the Website.

LEGAL BASIS
The legal basis for the purpose above is to take steps at the request of the data subject prior to entering into a contract (Art. 6 (1) (b) of the GDPR).

NATURE OF THE PROVISION
The provision of your personal data for the purpose above is optional. Failure to authorize its processing would make it impossible to respond to the User's request. 

DATA RETENTION PERIOD
Regarding data voluntarily shared by the User, MINT not beings able to predetermine accurately their retention period, the Data Controller commits as of now to inspire its processing to the principles of adequacy, accuracy, and minimization of data, as required by the GDPR, checking annually the need for its retention. This, except in the case where it is necessary to maintain such data to fulfill regulatory obligations, or to ascertain, exercise or defend a right in court.

Browsing data

The computer systems and software procedures used for the Website operations acquire, during their normal functioning, some personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of computers used by Users who connect to the Website, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters regarding the operating system and computer environment.

PURPOSE
This data, necessary for the use of the Website, is processed for the sole purpose of obtaining statistical information on the use of the Services (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.) and to check the correct functioning of the Services offered.
The navigation data does not persist for more than one year and is deleted immediately after their aggregation, except for the possible need to ascertain crimes by the judicial authorities. 

LEGAL BASIS
The legal basis for the purpose above is the legitimate interest of MINT (Art. 6 (1) (f) of the GDPR) to maintain the security of the Website and ensure that this is not used in a way which may harm the rights of others or as a channel for the commission of crimes or fraud (see recital 47 of the GDPR). 

NATURE OF THE PROVISION
The provision of your personal data for the purpose above is mandatory. Failure to authorize its processing would make it impossible to use the Services of the Website. Furthermore, failure to authorize its processing would make it impossible to guarantee network and information security.

DATA RETENTION PERIOD
The navigation data and that is acquired through the use of the Website will not be kept for more than one year.

Subscribe MINT’s Newsletter

In the Website homepage there is a box that permit to the user to submit a request for subscription to the promotional newsletter relating to the MINT’s products. This section collects the email address of the User. 

PURPOSE
Subscription to the MINT’s newsletter.

LEGAL BASIS
Consent of the User (Art. 6 (1) (a) GDPR) having entered e-mail address in the specific box. This consent is expressed by clicking the button “SIGN UP” and can be withdrawn at any time, without compromising the lawfulness of the processing performed prior to withdrawal, following the instructions given in the “Rights of the data subject” section or clicking the button “Unsubscribe” at the bottom of each newsletter sent.

NATURE OF THE PROVISION
The provision of your personal data for the purpose above is optional. Failure to authorize its processing would make it impossible for the Users to subscribe the MINT’s newsletter.

DATA RETENTION PERIOD
Until withdrawal of consent by the User.

Chatbot

The Website includes the possibility of using a CHATBOT that can be used to provide assistance and support with respect to the User's questions and the handling of the User's business requests.

PURPOSE
This purpose includes the possibility make a question relating to our products, get a product tour and contact us through the Website.

LEGAL BASIS
The legal basis for the purpose above is to take steps at the request of the data subject prior to entering into a contract (Art. 6 (1) (b) of the GDPR).

NATURE OF THE PROVISION
The provision of your personal data for the purpose above is optional. Failure to authorize its processing would make it impossible to respond to the User’s request made by CHATBOT. 

DATA RETENTION PERIOD
Regarding data voluntarily shared by the User via CHATBOT, MINT not beings able to predetermine accurately their retention period, the Data Controller commits as of now to inspire its processing to the principles of adequacy, accuracy, and minimization of data, as required by the GDPR, checking annually the need for its retention. This, except in the case where it is necessary to maintain such data to fulfil regulatory obligations, or to ascertain, exercise or defend a right in court.

Technical Cookies

Technical and session cookies are used. They are small text files containing a certain amount of information exchanged between your terminal or browser and the Website, which allow it to function correctly and to be used. This kind of cookie is mandatory for the correct use of the Website and no consent is required to allow this kind of cookies.

Analytics Cookies

The Website uses first and third-party analytics cookies. The analytics cookies are used to collect information on the use of the Website, in aggregate form, in particular on the number of Users and how they visit the Website itself, also providing anonymous statistical analysis in order to improve the use of the Website and make the content more interesting and relevant to the Users’ desires.

To view links to the privacy policies of third parties, disable all or some of the mentioned cookies, please refer to the following link. This type of cookie is optional and consent is mandatory to allow installation of this kind of cookies.

Profiling Cookies

The Website uses first and third-party profiling cookies. These cookies are not essential, but they help to personalize and improve your experience on the Website. For example, they help us to know and remember your preferences and show you relevant, personalized adverts. They also allow us to limit the number of times each ad is shown, measure the effectiveness of the ad campaign, remember your visit, and share the data we collect with third parties such as advertisers. This type of cookie is optional and consent is mandatory to allow installation of this kind of cookies.

The deletion of these cookies, therefore, although it does not affect the use of the Website, may nevertheless result in a limitation of certain functionalities.

To view links to the privacy policies of third parties, disable all or some of the mentioned cookies, please refer to the following link.

Options regarding the use of cookies by the Website via browser settings.

The provision of all cookies can however be disabled by changing the settings of your browser. It should be noted, however, that intervening on these settings could make the Website unable if you block the cookies that are essential for the provision of our Services. In any case, each browser has different settings for disabling cookies. Below you will find links to instructions for the most common browsers: Apple Safari, Google Chrome, Microsoft Internet Explorer, Mozilla Firefox, Opera.
In addition, your personal data may also be disclosed to our employees, provided that they are previously appointed as acting under the authority of the Data Controller pursuant to Article 29 of the GDPR.

5. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The Data Controller may transfer your personal data to third countries outside the European Union, for the purpose of providing you the Services through the Website. Such transfer is always subject to an adequacy decision, under article 45 of the GDPR, or to the Standard Contractual Clauses, under article 46 of the GDPR. For more information about the rules for transferring data to countries outside the European Union, including the mechanisms on which we rely, you can visit the European Commission’s website here. To request a copy of the Standard Contractual Clauses signed by the Data Controller you can send an email to privacy@mint.ai.

6. AUTOMATED DECISION-MAKING PROCESSING

The Data Controller does not use automated decision-making processes without your consent, including profiling as referred to in Article 22 paras. 1 and 4 of the GDPR.

7. DATA SUBJECTS’ RIGHTS

Regarding the processing of your personal data, you, as a data subject, have the right to withdraw your consent at any time and to obtain from the Company access to your personal data. You may also request the Company to rectify or erasure your personal data. Furthermore, you have the right to obtain the restriction of the processing of personal data concerning you, as well as the right to data portability. In addition to the above, you have the right to object at any time, on grounds relating to your situation, to the processing of your personal data carried out pursuant to Article 6 para. 1, letter e) or f), including profiling on the basis of these provisions, as stated in Article 21 of the GDPR. In addition, where your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data relating to you carried out for such purposes, including profiling insofar as it is related to such direct marketing.

Finally, you have the right to lodge a complaint with a supervisory authority or take legal action if you believe that the processing of your data is in breach of the GDPR. To exercise any of your rights, you may contact the Data Controller, in the person of the legal representative, by addressing a communication to the registered office at Via Lodovico il Moro 25, 20143 – Milan, Italy, or by sending an email to privacy@mint.ai.