B) for direct marketing based on the user’s account, for the delivery of communications, newsletters and promotional and business information, market research or other product research and direct sales, information material, for the assessment of customer satisfaction, for commercial and advertising material or material concerning events and initiatives, by the Data Controller: by automated means such as e-mail, SMS (Short Message Service) or other, as well as by telephone calls via operator and paper mail.
LAWFULNESS: personal data shall be processed in compliance with the lawfulness conditions pursuant to art. 6 of EU Reg. 2016/679:
– upon prior consent and until data subject’s objection to the processing for marketing purposes; – with reference to the user’s account, for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject can reasonably expect at the time and in the context of the collection of the personal data that processing for that purpose may take place (recital 47).
The Controller sends newsletters and promotional materials through systems that generate reports, in order to compare and improve the outcomes of such communications. Thanks to such reports, the Data Controller shall be able to know, for instance: the number or readers, the number of opened messages, the number of single clicks and of clicks; the devices and operating systems used to read the communication; details on the activities of individual users; details of sent, delivered and undelivered and of forwarded emails. All these data are used to compare and improve, if necessary, the outcome of the such communications.