PRIVACY POLICY FOR THE PROCESSING OF PERSONAL DATA

This privacy policy, provided pursuant to Article 13 of the EU General Data Protection Regulation 2016/679 (“GDPR”), contains information regarding the processing of users’ personal data provided while browsing or when completing forms available on the website (hereinafter the “Website”), as further described below.

The Data Controller

The details of the Data Controller, including contact information, are specified within the Website.

Personal Data Processed

  1. a) Browsing Data

The IT systems and software procedures used to operate the Website may collect, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to be associated with identified individuals, but by its very nature could, through processing and combination with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of devices used by users connecting to the Website, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response provided by the server (successful completion, error, etc.), and other parameters relating to the user’s operating system and IT environment.

These data are used solely to obtain statistical information on the use of the Website and to verify its correct operation, to ensure the proper delivery of the various functionalities requested by the user, and to establish liability in the event of potential cybercrimes affecting the Website or third parties.

With regard to personal data collected through cookies, please refer to the Cookie Policy.

  1. b) Other Data Voluntarily Provided by the User

The Data Controller may also process additional personal data such as, for example, first name, last name, email address, telephone number, payment details, and any other information voluntarily provided by the user, for instance when completing forms available on the Website.

Purposes and Legal Bases of Processing

Personal data will be processed for the following purposes:

  1. to enable browsing on the Website and provide the requested web services and functionalities;
  2. where applicable, to manage and respond to information/support requests submitted through the contact channels available on the Data Controller’s Website (including those managed through artificial intelligence systems, such as chatbots used to respond to requests and virtual assistants that enable the recording and transcription of telephone interactions);
  3. where applicable, to create a restricted area within the Website;
  4. where applicable, to provide a service, including the possibility to request a quotation or make a booking (also managed through artificial intelligence systems);
  5. where applicable, to enable the completion of the purchase process for products and services offered by the Data Controller.

The legal basis for the above-mentioned purposes is: the performance of a contract to which the user is a party or the implementation of pre-contractual measures taken at the user’s request. In such cases, the provision of personal data is necessary. Failure to provide the required data may result in the inability to establish the contractual relationship.

Personal data may also be processed for additional purposes, such as:

  1. to verify the proper functioning of the Website and web services and to ensure an adequate level of Website security;
  2. where applicable, to send newsletters/informative communications relating to updates, news, and initiatives concerning the services offered through the Website;
  3. to establish, exercise, and defend a right in judicial or extrajudicial proceedings.

The legal basis for the above-mentioned processing activities is the legitimate interest of the Data Controller. Should the user wish to exercise the right to object, limited to purpose no. 7, they may use the opt-out link available in the footer of each of the aforementioned communications.

Finally, personal data will be processed for the following purposes:

  1. to comply with legal and regulatory obligations and with requests from competent authorities.

The legal basis for the processing is the legal obligation to which the Data Controller is subject. The provision of personal data for this purpose is necessary to enable compliance with legal and regulatory obligations and with requests from competent authorities.

Furthermore, where applicable, personal data may also be processed for the purpose of sending commercial communications and promotional materials relating to all services and products offered by the Data Controller. Such communications may be carried out through automated contact methods (e.g., SMS and email).

This processing is based on the user’s consent, which may be withdrawn at any time. The provision of personal data and the related consent is optional. However, failure to provide the data for this purpose will prevent the Data Controller from pursuing the aforementioned purposes.

Personal Data Retention Period

The Data Controller retains personal data for the period necessary to achieve the purposes for which they were collected or for any other legitimate related purpose, in accordance with the principle of storage limitation set out in Article 5(1)(e) of the GDPR.
Where personal data are processed for two different purposes, the Data Controller retains such data until the purpose with the longer retention period has ceased. Thereafter, the Data Controller will proceed to anonymize, aggregate, or delete the data.

In general, the user’s personal data processed for purposes no. 1 to 7 are retained for the entire duration of the contractual relationship and, limited to the personal data strictly necessary in accordance with the GDPR principle of storage limitation, for no longer than 10 years following the termination of the relationship, without prejudice to cases where, for example, the retention of data for a longer period is required due to potential disputes, requests from competent authorities, or applicable legislation.

Data processed for the purpose of fulfilling legal obligations are retained for a period equal to the retention period prescribed by law for each specific type of data.

Where it is necessary to process data for the purpose of legal protection, such data will be retained for the period during which any claims and/or legal actions may be pursued under applicable law, namely for the entire duration of any pre-litigation and litigation proceedings, until the expiry of the applicable time limits for filing appeals.

Data processed for the purpose of sending commercial communications and promotional materials are retained for 24 months from the date consent is collected, or, where applicable, for a shorter period if the user withdraws consent.

Categories of Data Recipients

The Data Controller may disclose personal data to external parties acting as independent data controllers or processing personal data as data processors. In the latter case, the Data Controller regulates such processing activities through a data processing agreement pursuant to Article 28 of the GDPR, by which the Data Controller provides the data processor with specific instructions regarding the processing of personal data.

Personal data may be disclosed to the following categories of recipients, including:

  • • individuals, companies, or professional firms providing support, assistance, and/or consultancy services, for example in accounting, administrative, or legal matters, relating to the provision of requested services, with reference to specific processing activities;
  • • banks and credit institutions;
  • • third-party companies providing artificial intelligence systems used in the delivery of the various services available on the Website;
  • • entities, bodies, or authorities to which the disclosure of data is mandatory pursuant to legal provisions or orders issued by competent authorities.

Should the user wish to receive further information regarding the list of recipients, they may submit a request to the Data Controller’s email address.

Transfer of Data Abroad

If, for the purposes indicated above, the Data Controller needs to transfer personal data outside the European Union to countries for which the European Commission has not issued an Adequacy Decision, the Data Controller undertakes to adopt and ensure appropriate levels of protection and safeguards, including contractual safeguards, in accordance with applicable regulations.
These safeguards may include the execution of standard contractual clauses pursuant to Article 46(2)(c) of the GDPR, potentially supplemented by additional technical, legal, and organizational measures necessary to ensure that the level of protection of personal data is equivalent to that guaranteed within the European Union.
Should the user wish to receive further information regarding the safeguards implemented and request a copy thereof, they may submit a request to the Data Controller’s email address.

Rights of the Data Subject

Pursuant to Articles 15–22 of the GDPR, the data subject may exercise their rights at any time by submitting a request to the Data Controller’s email address.
In particular, the user may access their personal data and request access, rectification, and deletion of data (where there is no longer any legal basis for processing by the Data Controller), or request restriction of processing concerning them, or object to processing, except where this would make it impossible to continue the contractual relationship for processing activities and data necessary for such purposes, and with the exception of data whose processing may be necessary to establish, exercise, or defend a right in judicial proceedings or to comply with legal obligations.
To modify or delete only the data stored on the systems providing this Website, the user may complete the form available at the following link.

The user also has the right to lodge a complaint with the Supervisory Authority.

 

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COOKIE POLICY

This Website uses technical cookies (i.e., necessary cookies) and, with your consent, analytical and profiling cookies, which may be used by us and by third parties. These cookies are respectively used to enable certain essential Website functionalities, obtain performance measurements of the Website, or provide you with promotional information aligned with your interests.

 

To accept, reject, or select cookies based on their purposes, please use the controls available in the cookie management banner popup.

 

In particular, to find out which cookies are installed through this Website and express your preferences regarding their use, select the “Details” option, where you can also view the individual cookies issued for each category.
To select your preferred purposes, use the relevant checkbox in the banner and click on “Customize” to confirm your preferences.

 

Your preferences will be recorded in a dedicated cookie consent management platform (the “CMP”), developed in accordance with the principles of applicable data protection legislation and relevant guidelines, in order to allow users to exercise their choices in a granular manner.
The CMP allows users to grant or refuse consent to different types of cookies, which are identified and classified according to the purposes for which cookies are issued and used, making their recognition easier and more immediate.

 

You may withdraw or modify the consent previously provided at any time by clicking on the relevant access icon to the CMP, which will be displayed on the Website.
This icon will appear in the bottom-left corner once you have expressed your preferences through the pop-up banner displayed when you access the Website.

 

The cookies used on this Website fall into the categories described below.

What are Cookies

Cookies are small text files that are automatically placed on the user’s computer within the browser. They contain basic information about Internet browsing and are recognized by the browser each time the user visits the Website.
Below are details regarding the cookies installed by this Website, along with instructions on how to manage cookie preferences.

What are Cookies Used For

Cookies are useful because they allow users’ browsing preferences to be stored and the Website to be customized according to their needs, improving the overall browsing experience.
For example, cookies can make use of the Website more immediate and enable certain functionalities. Cookies may allow users to avoid entering the same information multiple times during a visit.
In certain cases, cookies can also ensure that online advertisements displayed to users are more suitable or relevant to their interests.
Some cookies are necessary for the correct operation of the Website or useful for providing a personalized browsing experience; in such cases, disabling them may compromise certain Website functionalities.
Furthermore, cookies allow advertisements to be published on the Website, either directly or through third parties, that are aligned with users’ interests, inferred based on their online activities and browsing habits.

Which Categories of Cookies Are Used on the Website

1 – Technical Cookies, also known as Necessary Cookies

The technical cookies described below do not require consent and are therefore installed automatically upon access to the Website.

 

– Cookies necessary for operation: cookies that allow the Website to function correctly while also enabling users to have a functional browsing experience. For example, they keep the user connected during navigation, preventing the Website from requesting login credentials multiple times when accessing subsequent pages.

 

– Statistical and Audience Measurement Cookies: cookies that help understand, through data collected in anonymous and aggregated form, how users interact with the Website by providing information about the sections visited, the time spent on the Website, and any malfunctions.

 

Per esempio, in alcuni casi i cookie di Google Analytics utilizzati da questo sito, sono stati resi anonimi e quindi sono equivalenti a cookie tecnici.

2 – Functional Cookies

This category includes cookies that allow the Website to remember the preferences selected during browsing, such as language settings.
These cookies are only issued upon the user’s request and with the user’s prior consent.
The user is free to provide consent for the installation of functional cookies and withdraw it at any time through the CMP, without affecting the ability to access the Website and use its content. However, if the user does not consent to these cookies, the use of certain functionalities may be affected.
You can access the CMP at any time through the icon available on the Website, where you will find a summary of the consents provided, which you can modify by clicking on the “Modify Consent” button.
A screen will then open allowing you to update your preferences by selecting the categories of interest. Through the “Details” button, you can view which functional cookies are issued on the Website, their purposes, and their duration.
Once you have made your choice, click on the “Customize” button to confirm your preferences.

3 – Analytical Cookies

Cookies in this category are used to collect statistical information, in non-aggregated form, about how users access and use the Website and how they browse through it.
As required by applicable regulations, the installation of third-party analytical cookies requires the user’s prior consent.
If you provide consent to the installation of analytical cookies, the Data Controller will record such consent through a specific technical cookie. This makes it possible to avoid displaying the cookie banner again during future visits to the Website.
You can access the CMP at any time through the icon available on the Website, where you will find a summary of the consents provided. You can modify your preferences by clicking on the “Modify Consent” button; a screen will then open allowing you to update your choices by selecting the categories of interest.
Through the “Details” button, you can view which analytical cookies are issued on the Website and obtain all the necessary information.
Once you have made your choice, click on the “Customize” button to confirm your preferences.

4 – Profiling Cookies

Profiling cookies are used to group users into homogeneous categories based, for example, on their preferences. These cookies may be used, among other things, to send advertising messages consistent with the user’s online behavior and browsing interests.
In accordance with applicable regulations, users’ prior consent is required for the installation of profiling cookies.
The user is free to provide consent for the installation of profiling cookies and withdraw it at any time through the CMP, without affecting the ability to access the Website and use its content.
If the user provides consent to the installation of profiling cookies, the Data Controller will record such consent through a specific technical cookie. This makes it possible to avoid displaying the cookie banner again during future visits to the Website.
Profiling cookies are installed by the Data Controller and by third parties acting as independent data controllers for the processing of personal data (third-party cookies).
You can access the CMP at any time through the icon available on the Website, where you will find a summary of the consents provided. You can modify your preferences by clicking on the “Modify Consent” button; a screen will then open allowing you to update your choices by selecting the categories of interest.
Through the “Details” button, you can obtain further information about the third parties installing profiling cookies, the individual cookies issued, and their duration.
Once you have made your choice, click on the “Customize” button to confirm your preferences.

Furthermore, by accessing the page http://www.youronlinechoices.com/it/le-tue-scelte, users can learn more about behavioral advertising and disable or enable cookies from the companies listed that work with website operators to collect and use information useful for the delivery of advertising.

Please remember that you can also manage your cookie preferences through your browser.

Detailed instructions for managing cookies by users on the most commonly used browsers are provided below.
Browser manufacturers may update or modify the references to the links below from time to time; therefore, users are advised to always check the instructions provided by the manufacturers of the browsers they use in order to understand how to configure cookie settings.

 

If you are using the Edge browser

 

If you are using the Firefox browser

 

If you are using the Safari browser

 

If you are using the Google Chrome browser

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