Privacy Policy
Excellera Advisory Group, in its capacity as Data Controller, intends to provide information to any persons whose data may be processed within the scope of the activities described, pursuant to art. 14 of Regulation (EU) 2016/679 (hereinafter “Regulation”).

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

1. Categories of personal data
As part of the strategic consultancy and political intelligence activities carried out for its clients (hereinafter “Activities”), the Company may process: i) personal identification data (for example, name, surname, date and place of birth), contact details and contact information (for example, e-mail address) of the interested parties; ii) data relating to training, the 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 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 the performance of strategic consulting and political intelligence, which are central activities for the business of Excellera Advisory Group.

The processing of data of a common nature is therefore carried out in accordance with Art. 6, para. 1, letter f) of the Regulation.
Interested parties have the right to object to such processing at any time by writing to dataprotection [at] Excellera Advisory Group, subject 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 Regulation will be processed by the Company pursuant to art. 9, par. 2, letter. e) of the Regulation, and therefore only when made manifestly public by the parties concerned.

3. Categories of subjects to whom the personal data may be communicated and purposes of communication
The Owner may communicate the personal data collected and processed in the context of its activities to external companies that offer the Owner management or information technology services. These companies will process personal data in their capacity as data processors.

Furthermore, the Data Controller may communicate the personal data of the interested parties to subjects in the interest of whom the Company carries out its activities. These subjects will process the personal data in their capacity as independent data controllers.

The list of data processors can be requested by writing to dataprotection [at] Excellera Advisory Group.

There is no provision for any form of dissemination of data collected to indeterminate subjects.

4. Duration of treatment
The personal data indicated above will be processed by the Owner for the time strictly necessary to carry out the activities described above. If no longer necessary, the data collected will not be subject to further storage.

5. Transfer of data outside the European Union
The data processed by the Company will be transferred outside the European Union by service providers that the Holder uses. This transfer, where applicable, will be regulated with the service providers through the use of standard contractual clauses adopted by the European Commission in Decision 2010/87/EU and any subsequent amendments or, alternatively, on the basis of a decision of adequacy by the Commission and/or any other instrument permitted by the relevant legislation. In particular, in cases where the supplier is located in the United States, personal data will be transferred according to the Privacy Shield.

Interested parties may obtain information on where the data were transferred and a copy of such data by writing to dataprotection [at] Excellera Advisory Group.

6. Rights of data subjects
In accordance with the current regulations, the interested parties may exercise the following rights:

1. request and obtain information about the existence of their personal data at the Company and about the processing of data by the Owner and obtain access to such data;
2. request and obtain the modification and/or correction of their personal data;
3. request and obtain the cancellation – and/or limitation of the processing – of their personal data if the data or information is not necessary – or no longer necessary – for the purposes above, then after the period of retention indicated in the preceding paragraph.

Such requests may be addressed to the Owner by writing to dataprotection [at] Excellera Advisory Group.

Interested parties under the current rules may submit any complaints regarding the processing of their personal data to the Guarantor for the protection of personal data.