Wi-fi detection system Privacy Policy

INFORMATION NOTICE ON DATA PROCESSING ACTIVITIES RELATED TO THE WI-FI DETECTION SYSTEM

Article 13 of Regulation (EU) 2016/679 – General Data Protection Regulation

In the exhibition district of Fiera Milano S.p.A. at Rho, there is a system of antennas/sensors that, when activated, allows the detection of devices with Wi-Fi enabled belonging to visitors ("Data Subjects") present in the same district.

The data acquired through the aforementioned system are processed by Fiera Milano S.p.A. (hereinafter "FM"), as the Controller, in an aggregated and anonymous form for statistical purposes. In particular, the processing is necessary for FM to pursue legitimate interests related to statistical analyses concerning the quantity of visitors in various areas and pavilions of the exhibition district, subject to FM adopting adequate guarantees and organizational and technical measures to reduce any potential risk or impact of the processing on the rights of the Data Subjects (such as minimizing collected data to prevent device tracking, immediate pseudonymization of data, and permanent deletion of pseudonymized data within a short timeframe necessary for their aggregation and processing in a completely anonymous form).

However, Data Subjects can exclude detection by deactivating the Wi-Fi functionality of their device (which excludes the detection of the Wi-Fi signal). The collected personal data (MAC address and device brand) are stored only temporarily, for the strictly necessary technical times (usually 10 seconds) for their immediate pseudonymization (using a hashing technique with the application of a salt that changes every 15 minutes). Pseudonyms of these data are used for calculating the static position of visitors' devices, remaining stored for a short time (usually 20 minutes) before being (i) aggregated for processing in an anonymous form, by displaying areas with different color densities on a map (so-called heatmap), and (ii) permanently deleted.

The system is managed by FM with the assistance of specifically authorized personnel or companies that, as data processors, perform certain organizational and technical activities on behalf of FM, including the system provider, responsible for its technical management. This FM-owned system is completely separate from the Wi-Fi network that allows visitors to connect to the Internet.

Data Subjects, if identifiable, have the right to exercise the rights provided in Articles 15 and following of the GDPR, to the extent applicable to the limited processing of the relevant data, with particular regard to the right to access personal data, obtain essential information about the characteristics of the processing and the balance of interests carried out by FM, correct any inaccurate data, delete or limit the processing if the conditions are met, or object, for specific reasons related to their situation, to the processing necessary for the pursuit of FM's legitimate interests as the Controller.

For any matter related to the processing of personal data and to exercise the aforementioned rights, the Data Subject can contact our company, Fiera Milano S.p.A., as the data controller, with registered office at S.S. del Sempione 28, 20017 Rho (Milan) and legal office at Piazzale Carlo Magno 1, 20149 Milan, email privacy@fieramilano.it, or also contact the Data Protection Officer of Fiera Milano, at the aforementioned postal address and email address: dpo@fieramilano.it. The Data Subject also has the right to lodge a complaint with the Italian Data Protection Authority for the protection of their data and rights.