Privacy Policy & Coockie Policy

PRIVACY INFORMATION AND COOKIES

PRIVACY POLICY

In accordance with the obligations arising from the national (D.Lgs. June 30, 2003, No. 196 of the Italian Personal Data Protection Code) and European legislation (General Data Protection Regulation (GDPR) 2016/679) and subsequent changes, this website respects and safeguards the users’ and visitors’ privacy, putting in place proportionate measures to not violate the user’s rights. This policy is valid exclusively for the online activity of this website and for the website’s visitors/users. It is not valid for information collected through channels different from this website. The aim of this privacy policy is to offer full transparency about information collected by the website and how it uses it.

Legal basis for the processing.

This website processes data based on consent. With the use or consultation of this website, users and visitors explicitly approve this policy and consent to the processing of their personal data in relation to the modes and purposes hereafter described, including a possible spreading to third parties if necessary for the distribution of a service.

The provision of data and consequently the Consent to the collection and processing of data is optional, the User can negate the consent and can revoke at any time the given consent (through the link in the Contacts page). However, denying consent may make some services impossible to offer and the navigation experience on the website could be compromised.

Starting from May 25th, 2018 (when the GDPR comes into effect), this website will process some data based on the legitimate interests of the data controller.

Purposes and collected data

This website, as it is common in all websites, uses log files in which is automatically collected information during the user’s visit. The collected information could be the following:

- Internet Protocol address (IP);
- type of browser and settings of the device used to connect to the Internet;
- Internet service provider (ISP);
- visit’s time and place;
- HTTP referrer page and exit page;
- possibly, number of clicks.

This information is processed in an automatic way and collected in aggregated form to verify the correct functioning of the website, and for safety reasons (from May 25th, 2018 on, this information will be processed based on the interests of the owner).

For safety reasons (anti-spam filters, firewalls, virus detection), the data recorded automatically can possibly include personal information such as IP address, which can be used, in accordance with the laws in effect, to block damaging activities to the website itself, to other users or otherwise harmful activities or those constituting a crime. This information is never used for the identification or profiling of the user, but only to safeguard the website and its users (from May 25th, 2018 on, such information is going to be processed based on the legitimate interests of the owner).

In the case that the website allows comments, or in the case of specific services requested by the user, the website automatically detects and registers some user’s identification data, including his email address. These data are to be considered voluntarily given by the user when requesting the service. Adding a comment or other information, the user expressly accepts the privacy policy and in particular, he agrees to let the information added be freely shared, also with third parties.

The received information will be used exclusively for the distribution of the service requested and only for the amount of time needed for the distribution of the service. The information that the users of the website deem to make public through services and tools made available to them, are offered consciously and voluntarily by the user, exempting the website from liability regarding any violation of the law. It is the user’s responsibility to verify the authorization of input of personal data for third parties or of content safeguarded by the national and international legislation.

Data collected by the website during its functioning are used exclusively for the aforementioned purposes and preserved for the time strictly necessary for which they have been collected. In any case, the data collected by the website will never be supplied to thirds parties for any reason, unless it is a legitimate request from the legal authorities and in other cases provided for by the law.

The data used for security purposes (block attempts to damage the site) are kept for the time necessary to fulfill the aforementioned purpose.

Processing location

Data collected from the website are processed at the Data Processor’s headquarters, and at the datacenter of the web hosting. Sodalis Group web Hosting, Viale Europa 12, 26855 Lodi Vecchio (Lodi) - eLogic S.r.l., Via Paolo Nanni Costa, 30, 40133, Bologna), which is responsible for the data handling and processing for the owner, is located in the European Economic Area and acts in accordance of European legislation.

 

COOKIE POLICY

This website, as is common for websites, uses cookies, small text files that allow storage of information about the user’s preferences, improvement of the website’s functionality, simplification of navigation, automatic procedures (e.g. log-in, languages) and site analytics.

Session cookies are essential to distinguish between connected users and are useful to avoid giving a requested functionality to the wrong user, in addition to safety reasons like  avoiding cyber attacks on the websites. Session cookies contain personal data and last only for the active session, that is until the browser is closed. For those cookies, consent is not required.

Functionality cookies used by the website are strictly necessary to the use of the website, and they are connected to a direct functionality request from the user (such as log-in), for which consent is not required.

By using the website, the user expressly consents to the use of cookies.

How to disable cookies

Cookies are connected to the used browser and CAN BE DISABLED DIRECTLY FROM THE BROWSER, this way refusing/revoking consent for the use of cookies. Keep in mind that disabling cookies could prevent the proper functioning of the website.

Instructions on how to disable cookies can be found in the following pages:
Mozilla Firefox Microsoft Internet Explorer - Microsoft Edge - Google Chrome - Opera - Apple Safari

Third-party cookies

This website works also as intermediary for third-party cookies, used to offer additional services and functions to visitors and improve the use of the website, like social network buttons or videos. This website has no control over third-party cookies, which are completely managed by third-parties. Consequently, information on the use of the abovementioned cookies, their scopes and the possible disabling process are offered directly by the third-parties on the web pages hereafter indicated.

This website uses cookies from the following third-parties.

  • Google Analytics: is one of Google’s analysis tools that, through the use of cookies (performance cookies), collects anonymous navigation data (IP cut off at the last 8 digits) and unites them with the sole purpose of examining the user’s use of the site, fills reports on the site activities and offers other information, including the number of visitors and the number of pages visited. Google can also transfer this information to third parties when imposed by the law or when third parties have negotiated the information on behalf of Google. Google will not associate the IP address to any other data owned by Google. Data transmitted to Google are going to be deposited in Google’s Servers in the United States. Based on a specific agreement with Google, designated as responsible for data processing, they commit to processing data based on the Owner’s requests (see the end of the disclosure), issued through the software settings. With these settings, advertisement options and data sharing are disabled. Additional information on Google Analytics can be found on Google Analytics Cookie Usage on Websites. The user can selectively disable data collection by Google Analytics installing on their browser the specific Add-On provided by Google (opt out).
     
  • YouTube: a platform owned by Google for video sharing that uses cookies to collect information about users and their navigation devices. The videos uploaded on the website do not convey cookies at the access page, thanks to the setting "privacy enhanced mode (no cookie)" that does not allow YouTube to store information about the visitors unless they voluntarily reproduce the video.

For additional information on the use of data and their processing by Google please look at the information section in the Google Privacy Policy page, and on the page on How Google uses information from sites or apps that use our services

Social Network Plugins

This website integrates social network plugins and/or buttons to allow easy sharing of content on your favorite social networks. These plugins are set to avoid cookies when accessing the page, to safeguard the user’s privacy. Cookies could be set, if anticipated by the social network, only when the user voluntarily and effectively uses the plugin. Keep in mind that if the user navigates while being logged in the social network, the she/he has already accepted the use of cookies transferred to this website when she/he signed up for the social network.

Please refer to the privacy policies of each social network for regulation on storing and usage of information gained through plugins

Facebook - (cookie policy link )
Twitter - (cookie policy link )
LinkedIn - (cookie policy link )
Google+ - (cookie policy link ). 

Data transfer outside EU countries

The website could share some of the collected data with services located outside the European Economic area. Especially Google, Facebook and Microsoft (LinkedIn) through social plugins and Google Analytics. The transfer is authorized on the basis of specific decisions made by the European Union and the Italian Data Protection Authority, specifically the  1250/2016 decision(Privacy Shield - here is the information page of the Italian DPA), for which additional consent is not necessary. The aforementioned companies guarantee their acceptance of the Privacy Shield.

Safety Measures

The website processes user’s data in a legal and appropriate manner, adopting the necessary safety measures aimed at avoiding non-authorized access, spreading, editing or destruction of data. The processing is carried out through telematic and/or IT tools, with management and reasonings directly related to the previously mentioned objectives. In addition to the data controller, in some cases categories of employees involved in website management might have access to the data (administration, marketing department, legal department, system admins) or external subjects (such as third party technical support suppliers, postal couriers, hosting providers, IT companies, communication agencies).

Users’ rights

In accordance with the European Regulation 679/2016 (GDPR) and the national law, the User can, according to use and with the limits envisaged by the current law, exercise the following rights:

  • To request confirmation of existence of personal data about him (right of access);
  • To know the origin;
  • To access and receive communication in an intelligible form;
  • To receive information about the reasoning, uses and processing objectives;
  • To request updates, rectification, integration, erasure, anonymous transformation, or restriction of processed data that is unlawful, including those not necessary for the pursuit of the objectives for which they were collected;
  • In case of processing based on consent, the data supplied by the data controller is to be received, only with the potential supporting party cost, in a structured and legible form from a data processor and in a commonly used format for an electronic device;
  • the right to file a complaint to the Regulating Authority (Italian Data Privacy Authority - link to the Italian Authority page);
  • as well as, more in general, all the rights that are recognized by the existing laws.

All requests need to be addressed to the Data Controller.

In case the data is processed based on legitimate interest, the rights of the persons concerned by the processing are nonetheless granted (excluding the right to portability which is not anticipated in the law), in particular the right to oppose the processing that can be exercised by sending a request to the Data Controller.

Data Controller

The Data Controller in accordance with the current laws is the administrator of the website, (SODALIS GROUP, Viale Europa 12, 26855 Lodi vecchio, Lodi  (MI), email privacypolicy@sodalisgroup.com, telephone (+39 03714621), which shall be reachable through the CONTACT section.

Updates:
This privacy and cookie policy was updated on the 23rd of May, 2018