Data Controller

Method and place of processing of the collected data

Processing methods
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers) may have access to the Data. hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the processing
The Owner processes Personal Data relating to the User if one of the following conditions exists:
• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties. However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place
The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner. The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data. In case of higher protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Owner by contacting him at the opening details.

Retention period
The Data are processed and stored for the time required by the purposes for which they were collected. Therefore:
• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of processing the collected data
The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User and Statistics. To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
• Contact the User Mailing list or newsletter (this Application) Personal data collected: name and surname, email.
• Statistics The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
• Google Analytics (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.

User rights
Users can exercise certain rights with reference to the Data processed by the Data Controller. In case of higher protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out which rights are applicable in your case and how to exercise them.

In particular, the User has the right to:
• withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
• oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
• verify and ask for rectification. The User can verify the correctness of their Data and request its updating or correction.
• obtain the limitation of the processing. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation. Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

Applicability of the higher level of protection
While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data. This higher level of protection is always guaranteed when the treatment:
• it is performed by a Data Controller based in the EU; or
• concerns Personal Data of Users located in the EU and is functional to the offer of goods or services for consideration or free of charge to such Users; or
• concerns Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users to the extent that such behavior takes place within the Union.

Further information on the treatment

Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information
At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance
For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, which are files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests
This Application does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes. contact number held by the Data Controller. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)
Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data
This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference the sequence of the pages consulted, the parameters relating to the operating system and the IT environment of the User.

Cookies
Small portion of data stored in the User’s device.

Legal references
This privacy statement is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy statement only concerns this Application.

Last modified: May 24, 2018