PRIVACY POLICY

PRIVACY POLICY 

  1. Data controller
  2. Warning
  3. Authorized persons within the company involved in data processing
  4. Data processors/ recipients of the data
  5. Navigation data processed
  6. Data subjects
  7. Personal data processed
  8. Purposes and legal basis of data processing
  9. Data retention period
  10. Optional/mandatory nature of the provision of data
  11. Data transfer abroad
  12. Rights
  13. Right to object
  14. Complaint
  15. Withdrawal of consent
  16. Updates and revisions

 

  1. Data controller

RMMusic S.r.l. (“Company”), information about which is provided in the “Contact” webpages of the Company’s websites www.riccardomuti.com, www.riccardomutioperacademy.com and www.riccardomutimusic.com (“Websites”) is committed to protecting personal data in accordance with (a) Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”) as well as (b) applicable Italian legislation on personal data protection (“National Data Protection Laws”).

  1. Warning

This Privacy Policy is related to processing activities carried out in the course of the Company’s ordinary activities and through the following websites:

The website riccardomuti.com is the official website of the Maestro Riccardo Muti (“Maestro”), and is aimed at reporting the activity of the Maestro and the initiatives, also of a business nature, connected to his professional and artistic image. The website presents and, at the same time, refers to the website dedicated to the “Riccardo Muti Opera Academy” project and to the website “Riccardo Muti Music”. To subscribe to the newsletter, personal data are collected through a registration form.

The website riccardomutioperacademy.com is referred to the “Riccardo Muti Italian Opera Academy” project, aimed at teaching the Italian opera repertoire to young conductors, singers and opera coaches/assistant conductors, in the presence of the public. Data subjects’ personal data are collected or received in order to allow data subjects to receive information and/or to access to the Academy programs;

The website riccardomutimusic.com is referred to the e-commerce activity and, in particular, to the marketing of books, publications and gift ideas as well as the Maestro’s concerts and performances in audio and video format (CD, DVD, vinyls/LP) and to the use of on demand streaming services (“Streaming”). For convenience, all goods that are tangible (such as, CD, books and gift ideas) are hereinafter defined as “Products” and so differentiated from the Streaming of digital contents. In this context, personal data are collected in order to allow the purchase of one or more Products, the registration to the newsletter and/or the use of Streaming services.

  1. Authorized persons within the company involved in data processing

Personal data are processed by persons in charge of the processing, who have been appropriately instructed.

  1. Data processors/ recipients of the data

Data can be disclosed to data processors who process data based on previous agreements with the Company. Data processors may belong to the following categories:

  1. suppliers of implementation, management, assistance and maintenance services applied to the IT infrastructure;
  2. suppliers of Streaming system;
  3. suppliers of software, CRM, applications and hardware and related technical support/maintenance services;
  4. accounting and tax consultants;
  5. workplace safety consultants;
  6. banks/credit institutions;
  7. legal consultants;
  8. couriers and transport services;
  9. communication consultants/agencies.

In addition, data may be disclosed to third parties, acting as independent data controllers, such as for example:

  1. public authorities;
  2. certification entities and bodies;
  3. subjects to whom disclosure is mandatory by law.

The Company provides specific information on data processors and recipients, at the request of the data subject.

  1. Navigation data processed

Information about processing of navigators’ personal data, which are collected and processed by the Company through the use of cookies during navigation on the Company’s Websites, can be found on each website of the Company in the “Cookie Policy”, to which data subject may refer.

  1. Data subjects

1) Visitors: any person accessing and using the Websites, also when surfing, for any reason whatsoever, as simple reader or navigator;

2) Customers (including potential customers): consumers who set up an account on the Company’s Websites and purchase Products or use Streaming services; subjects acting for professional aims; representatives of customers – legal persons – that have business relationships with the Company;

3) Candidates: young musicians who participate in the selection process related to the “Riccardo Muti Italian Opera Academy” project, which includes training and study programs concerning the Italian opera repertoire;

4) Supporter/ Public/ Listener/Under 16 and related accompanying person: natural persons who observe rehearsals organized by the Academy, for the entire period of the same as established in the timetable.

5) Partner/Sponsor/Entity: a natural person, who directly or on behalf of a legal person, observes rehearsals of the events organized by the Academy and acts as a sponsor, with the aim of being mentioned in any communication material;

6) Suppliers (including potential suppliers): either natural persons or representatives of legal entities, that have business relationships with the Company.

  1. Personal data processed

The consumers’ personal data being processed consist of common data, such as, for example, the name and surname, telephone number, email address, shipping address, billing address, tax code, VAT number, payment details and order history.

The Candidates’ and Supporter/Public/Listener/Under 16 and related accompanying person’s as well as Partner/Sponsor/Entity’s personal data being processed consist of common data, such as, for example, the name and surname, registered name of the entity, tax code, VAT number, date of birth, place of birth, residence, telephone and mobile number, telefax number, email address, copy of identity document (passport for non-EU citizens), bank account details and/or data relating to the credit card, photographs, biographies and other related material.

With specific reference to Candidates, in addition to the personal data listed above, the Company – as regards to the selection process of the “Riccardo Muti Italian Opera Academy” project – may process the following data: qualifying title/graduation, place and date of the achievement and score.

With specific reference to the Listener, in addition to the personal data listed above, the Company may process personal data contained in the document concerning the enrolment at the conservatory/music school or in other document that certifies the enrolment (libretto) – in order to allow the payment of the reduced rate, as students – required by the Company to listeners students.

With specific reference to the representatives of legal persons – acting as customers or suppliers of the Company – personal data being processed consist exclusively of common data, such as for example, name and surname of the contact person and/or legal representative or owner, name or registered name of the entity, tax code, VAT number, legal and tax domicile, complete contact details, physical address and telephone (also mobile phone) numbers, telefax, certified email and email address and in general information necessary for the performance of contract obligations, such as bank account details and/or data relating to the payment/collection system.

  1. Purposes and legal basis of data processing

The Company shall process personal data for the purposes and legal basis as stated below:

(a) managing the sale transactions between consumers and the Company, necessary to buy products and use Streaming services through the Company’s Websites, to complete/formalize the purchase order, to make payments, to send products and invoices. The sale transactions include also consumers’ registration on the Company’s Websites, setting up the account, as well as return management and products warranty.The data processing is necessary for the performance of a contract or to take steps prior to entering into a contract as well as to comply with legal obligations.
(b) establishing and performing pre-contractual and contractual relationships with Supporter/ Public/ Listener/adult accompanying person of Under 16 and Partner/Sponsor/EntityThe data processing is necessary for the performance of a contract or to take steps prior to entering into a contract as well as to comply with legal obligations.
(c) establishing and performing pre-contractual and contractual relationships with customers (not consumers) and suppliers (including potential ones), as well as replying to precontractual queries (for example, quote requests).The data processing is necessary for the performance of a contract or to take steps prior to entering into a contract as well as to comply with legal obligations.
(d) unless objection is made by the Company’s data subjects involved (“Opt-out”), the email address of Customers as well as of Candidates and data subjects belonging to the categories of Supporter/Public/Listener/Under 16 and related accompanying person and of Partner/Sponsor/Entity is processed in order to send commercial communications about the Company’s products/services similar to those already provided, subject to a previous commercial relationship (“Soft spam”).The data processing, in case of soft spam, is based on the legitimate interest of the Company.
(e) sending to email addresses of customers and of representatives of customers and suppliers (including potential ones) newsletters and commercial/promotional/informative communications regarding the Company activity.The data processing is based on consent, until withdrawal of consent.
(f) sending to email addresses of candidates, provided by them, communications regarding the selection process related to the “Riccardo Muti Italian Opera Academy” project; sending to email addresses of data subjects belonging to the categories of Supporter/Public/Listener/ Under 16 and the related accompanying person and of Partner/Sponsor/Entity – provided by any of the above data subjects – communications regarding the attendance at the rehearsals, organized by the Academy.The data processing is based on consent, until withdrawal of consent.
(g) using (also for business reasons, including for informational and promotional purposes) photographs and audio/video recordings made during the Company’s events, showing the selected Candidates as well as any data subjects belonging to the categories of   Public, Listener, Under 16 and the related accompanying person and of Supporter through the relevant publication and sharing of said photographs and audio/video recordings on the Company’s Websites and social channels.As far as the Public is concerned, the legal basis for the processing is the legitimate interest and in this case the processing is carried out according to the information provided at each event or previously communicated. In the other cases, the data processing is based on consent, which is expressed on a .pdf form, downloadable from the Academy website.

Having regard to the Under 16, the processing is made in accordance with the legal provisions established for the protection of minors.

 

  1. Data retention period

Personal data of consumers, used for the purposes of sale transactions, registration on websites and setting up a customer-account, are processed as long as any consumer decides to avail itself of the services provided by the Company through the Websites. The Company will cancel, at the consumer’s request, the consumer’s personal data which are not necessary to comply with legal obligations (for example, invoice data, data related to the product warranty) and/or to exercise the right of defence and to manage/resolve the dispute.

Personal data of Candidates considered eligible and, therefore, admitted shall be kept without time limitation, as they are mentioned on materials of events and are stored for internal use. The personal data of not-admitted Candidates are retained for the entire duration of the selection process, unless otherwise provided.

Personal data of data subjects belonging to the categories of Public/Listener, Under16 and related accompanying person are retained for the entire duration of rehearsals, unless otherwise provided.

Personal data of Supporter (name, surname and nationality) shall be kept without time limitation, as said data, collected upon prior consent, are mentioned on the communication materials stored internally for archiving purposes and for internal use. A list of Supporters and of their email address is retained for internal archiving purposes and with the aim of memorizing said data to support future events.

Personal data of customers and suppliers of the Company (non-consumers) are retained for the entire duration of the contractual relationship and are then cancelled ten years and six months after the termination of the same for defensive purposes, unless there is an objection/dispute, in which case the data will be kept for the time necessary to exercise the right of defence and to manage/resolve the dispute.

The data processed for the purposes referred to in point (d) of paragraph 8 are retained until the Opt-out has been exercised by data subjects.

Personal data used for the purpose of sending newsletters and commercial/promotional/informative communications regarding the activity of the Company are retained until the withdrawal of consent by data subjects and then are cancelled from Company’s databases and lists.

  1. Optional/mandatory nature of the provision of data

The provision of data by data subjects is necessary to allow the Company to fulfil its legal obligations as well as its contractual obligations or to respond to pre-contractual requests. Any refusal to provide personal data, in whole or in part, will not allow the Company to respond to the request, to perform the contract and/or to comply with legal obligations.

  1. Data transfer abroad

Currently, the Company has no intention to transfer personal data to third countries extra EU. In any case, the transfer – if any – will take place only after verification of compliance with the provisions contained in articles 44 and following of the GDPR and, in particular, upon the previous communication concerning the extra EU country in question and the appropriate safeguards according to the GDPR provisions.

  1. Rights

To exercise the rights provided for by applicable National Data Protection Laws and the GDPR (articles 15 et seq.), data subjects may contact the Company or Company’s data processors if any, in particular, in order to access their personal data, request the rectification, updating, cancellation or limitation of said data, as well as to request the portability of said data; the Company may be contacted using contact details as set out above.

  1. Right to object

With the same procedures described above, data subjects may object, in whole or in part, to the processing of their personal data, where the relevant legal basis is constituted by the legitimate interest of the Company, pursuant to and for the purposes of the provisions of Article 21 of the GDPR.

  1. Complaint

Any data subject who believes that the processing of data concerning him or her is in violation of the GDPR, in accordance with the provision of article 77 of the GDPR, may lodge a complaint with a supervisory authority where the data subject usually lives or works or with a supervisory authority where the alleged infringement has occurred.

  1. Withdrawal of consent

Having regard to the purposes as set out above in points (e), (f) and (g) of paragraph 8, the consent can be withdrawn by data subjects at any time. Once a withdrawal of consent has been expressed, the data in question will be cancelled from the Company’s databases and lists.

  1. Updates and revisions

The Company reserves the right to modify and/or update the Privacy Policy, also taking into account any subsequent additions and/or amendments to national and/or EU legislation regarding the protection of personal data or consequent to any new purposes of data processing that may arise. For this reason, the Privacy Policy is published with a progressive identification number and the month of publication, starting from the April 2020 version, which bears the number “00”. The new versions of the Privacy Policy will replace the previous ones and will be valid, effective and applied starting on the date of publication on the Company’s Websites or the date of communication to the data subjects.

Riccardo Muti Italian Opera Academy