Privacy

In compliance with the obligations under Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (the "GDPR"), we hereby inform you that illuminem S.r.l. ("illuminem" or “us”) with registered office in Vicolo Sozomeno 2, 51100, Pistoia (PT), Tax Code and VAT No.02040550473, registered with the Companies' Register, REA No. 607886, PEC illuminem@pec.it, as data controller, will process your personal data, which may be collected by us, provided by you and/or communicated to us by other entities, during the navigation and use of our website https://saleshub.illuminem.com/ (the "Website").
The processing of the data you have freely provided or otherwise collected during your navigation on the Website will be carried out in compliance with the personal data protection regulations in force. In particular, the processing will be based on the principles of fairness, lawfulness and transparency. The data will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed and will be collected and recorded only for the purposes indicated in this notice.

This privacy notice applies to broadly three categories of individuals:

• Our Website visitors: where we collect browsing data, such as IP addresses through “cookies”;
• Our Subscribers: where we collect browsing data and the data provided to us in the context of creating an Account on our Website; and
• Various individuals whose information has been either sourced by ourselves or provided to us by our data partners.

When you browse our Website, certain information about the device you use to access the Internet is transmitted to us with the help of various technologies, commonly referred to as “cookies”. This is true even if you don't have an Account with us and even where you haven't purchased a Subscription.
If you are a Website visitor, we will usually collect the following personal information: IP address; general location (e.g. state), data related to browsing on the Website; browser and device information; information that you provide, collected via cookies, pixel tags and other technologies, without disclosing your identity; information that has been aggregated in such a way that it no longer reveals your specific identity.
Such personal information is processed for the following purpose(s): to display our Website, to ensure its proper functioning, to ensure its security and to improve it (on the basis of analytics).
In order to process such personal information, we rely on the following legal base(s): when the processing is in connection with ensuring the proper functioning of our website(s) it is necessary for the pursuit of our legitimate interests, that are to deliver a running and safe online presence (art 6.1.f. GDPR); when the processing is in connection with improving our Website, it is subject to your consent when required by law (art 6.1.a. GDPR), or where that is not required, it is necessary for the pursuit of our legitimate interests, that are to improve our online services (art 6.1.f. GDPR).
To exercise your choice for non-essential cookies, please use the banner on the Website.

Illuminem Sales Hub is B2B service for sales lead generation in the sustainability area. If you wish to subscribe for our services, we'd need to ask you for some basic contact and payment details. We also ask new Subscribers to respond to a short survey about the company they work for.
If you are a Subscriber visitor, we will usually collect the following personal information: full name, professional email address, job title, payment details, and your responses to our onboarding survey about the company you work for.
Such personal information is processed for the following purpose(s): to onboard you as a new customer (we need to know who our customers are), to take payment from you (so we can provide our services) and to manage our commercial relationship with you (so we can contact you and ensure a satisfactory customer experience).
In order to process such personal information, we rely on the following legal base(s): taking steps to enter into a contract with you and later, performing the of the contract between us and you (art 6.1.b GDPR).

In order to provide our service, we gather information about decision makers in the sustainability area. Such decision makers are usually employees in companies tasked with responsibilities around furthering the company's sustainability agenda and maturity. Such personal information is public and is either collated by ourselves or by our partners (e.g. companies such as RocketReach). To understand more about RocketReach’s database, please read this article. To opt out from RocketReach’s database, please visit this link. When it comes to such information, we will usually collect the following personal information: your name, location, job title, job seniority, career history, education, employer name, and contact details such as professional email and phone number. All this information is collected only in so far as available publicly online or provided by RocketReach. Such personal information is processed for the following purpose(s): the information is processed for the purpose of collating it and presenting it to our Subscribers for their lead generation (e.g. direct marketing) purposes. We contractually ask our Subscribers to comply with applicable data protection law when using this information. In order to process such personal information, we rely on the following legal base(s): the processing is necessary for the pursuit of our legitimate interests, that are to deliver our services to our Subscribers (art 6.1.f. GDPR).
When it comes to such information, we will usually collect the following personal information: your name, location, job title, job seniority, career history, education, employer name, and contact details such as professional email and phone number. All this information is collected only in so far as available publicly online or provided by RocketReach.
Such personal information is processed for the following purpose(s): the information is processed for the purpose of collating it and presenting it to our Subscribers for their lead generation (e.g. direct marketing) purposes. We contractually ask our Subscribers to comply with applicable data protection law when using this information.
In order to process such personal information, we rely on the following legal base(s): the processing is necessary for the pursuit of our legitimate interests, that are to deliver our services to our Subscribers (art 6.1.f. GDPR).

The processing of the personal data referred to in the preceding paragraphs is carried out mainly with the aid of electronic and computerised tools suitable to grant the security and confidentiality of such data.

Personal data about Website visitors and Subscribers may be disclosed by illuminem solely and exclusively for the purposes indicated and where necessary, to the following categories of subjects: suppliers of services such as website hosting, data analysis, payment processing, information technology and the use of related infrastructures, customer service, email delivery, auditing and other services; consulting firms, law firms, accountants; companies controlling and/or affiliate to illuminem, sellers of sustainability solutions.
Personal data may also be communicated, where requested, to the competent judicial authorities, public administrations and supervisory and control authorities.
Personal data shall not, however, be disclosed to unspecified subjects. Illuminem, as data controller, also reserves the right to transfer your personal data to third countries. Transfers of data outside the European Economic Area are subject to a special regime under applicable law, and will only be made to countries that ensure an adequate level of protection of personal data, on the basis of an adequacy decision by the Commission or where adequate safeguards have been adopted (including the standard contractual conditions provided by the European Commission), provided that the data subjects have effective rights of action and remedies.
The above applies equally to personal data about individuals listed on Sales Hub. In addition, we disclose such data to our Subscribers, as described above.

Your data will be stored, in accordance with the provisions of the relevant legislation in force, for a period of time not exceeding that necessary to achieve the purposes for which they are processed. The criteria for determining the period of data retention take into account the period of permitted processing and the applicable regulations on taxation, statute of limitation periods and legitimate interests that constitute the legal basis of the processing. When the processing is based on your consent, your data may be stored until the consent is revoked. At the end of the retention period, the data will be deleted, aggregated or anonymised.
Website visitor data is usually stored for no longer than 2 years after their last visit to our Website.
Subscriber data is usually stored for no longer than 7 years after a Subscription is cancelled.
Personal information of individuals listed on Sales Hub is usually stored until it becomes outdated.

Applicable law grants to you specific rights, including the right to request from the data controller:

• confirmation as to whether or not your personal data are being processed and, if so, to obtain access to it (right of access);
• the rectification of inaccurate personal data, or the integration of incomplete personal data (right to rectification);
• the erasure of the data, if one of the grounds listed in article 17 of the GDPR applies (right to erasure);
• to restrict the processing of your personal data, if one of the grounds provided for in article 18 of the GDPR applies (right to restriction of processing);
• to receive the personal data you have provided in a structured, commonly used and machine-readable format, and to transmit them to another data controller (right to data portability);
• to no longer process your personal data, on grounds relating to your particular situation (right to object).
• You have the right to withdraw your consent to the processing of your personal data for marketing purposes, at any time, without affecting the lawfulness of the processing based on consent before the withdrawal.

To exercise your rights, you can write to illuminem S.r.l., Vicolo del Sozomeno 2, 51100, Pistoia, or send an email to info@illuminem.com.
Please note we may need to ask you for additional information before processing requests if we need to verify the identity of the individual who submitted them.
Without prejudice to any other administrative or jurisdictional remedy, data subjects also have the right to lodge a complaint with a supervisory authority if he/she considers that the processing of his/her personal data is carried out in breach of the GDPR.
The contact details of the supervisory authorities in Europe are provided herein.

Version published on 5th June 2024.