Methods of Processing

The Controller processes Users Personal Data adopting all the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Data are managed through digital and/or telematic instruments, with organization methods strictly related to the indicated purposes. In addition to the Data Controller, in certain cases, Data could be accessible to other categories of subjects, involved in the management of the website (administrative, commercial, marketing or legal personnel and system administrators) or external subjects (as technical service suppliers, post carriers, hosting providers, IT companies, communication agencies) appointed by the Controller, when necessary, as Responsible for their processing. The updated list of Managers may always be requested from the Data Controller.

Legal basis of the processing

The Controller shall process Personal Data relating to the User in the event that one of the following conditions is met:

• The data subject has given consent to the processing of his/her personal data for one or more specific purposes. Note: In some jurisdictions, the Controller may be authorised to process Personal Data without the User’s consent or any other of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary for performing tasks carried out in the public interest or in the exercise of official authority vested in the controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party;

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.

Location

All Data is processed at the Controller’s operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller. The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the location of processing, the User may refer to the section that describes in detail the processing of Personal Data.

The User has the right to obtain information about 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 the UN, and about the security measures taken by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him at the contact details given at the beginning of the policy description.

Retention period

All Data are processed and stored for the time required for the purposes for which they were collected.

Therefore

• Personal Data collected for purposes related to the execution of a contract between the Controller and the User will be retained until the execution of such contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such time as such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Data Controller. 

When processing is based on the User’s consent, the Controller may retain the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in accordance with a legal obligation or following a specific order by an authority.

At the end of the retention period the Personal Data will be deleted. Therefore, any right of access, deletion, rectification and portability of the Data may no longer be exercised.

Purpose of Data Processing

User Data is collected to enable the Data Controller to provide its Services, as well as for the following purposes: Tag Management, Statistics, Contacting the User, Interaction with social networks and external platforms, Managing contacts and sending messages, Managing User databases, Interaction with online survey platforms, Advertising, Remarketing and behavioural targeting, Viewing content from external platforms, Protection from SPAM, Performance testing of content and functions (A/B testing) and Registration and authentication.

To obtain further detailed information on the purposes of Data processing and on the Personal Data specifically relevant for each purpose, the User can refer to the relevant sections of this document.

Rights of the Data Subjects

Users may exercise certain rights with regard to the Data processed by the Controller.

In particular, the User has the right to:

• Revoke consent at any time. The User may revoke their consent to the processing of their Personal Data as expressed above.
• Oppose the processing of their data. The User may object to the processing of their Data when it takes place 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 Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• Verify and request correction. The User may verify the correctness of their Data and request that it be updated or corrected.
• To obtain processing limitation. When certain conditions are met, the User may request that the processing of his/her Data be limited. In this case, the Data Controller will not process the Data for any other purpose other than their storage.
• Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User may request the Controller to cancel his/her Data.
• Receive their Data or have them transferred to another Controller. The User has the right to receive their Data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer to another Controller without hindrance. This provision is applicable when the Data is processed by automated means 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.
• To lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest by the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they may object to the processing without giving any reason. To find out if the Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

How are rights exercised

In order to exercise the User’s rights, Users may address a request to the Controller via the contact details indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.

Cookie Policy

This application makes use of Cookie. For further information or for an extended viewing of the policy, The User may consult the Cookie Policy.

Right to undertake legal proceedings

The User’s Personal Data may be used by the Controller in court or in the preparatory stages for possible legal proceedings against abuse in the use of this Application or related Services by the User. The User declares to be aware that the Controller may be obliged to disclose the Data by order of the public authorities.

Specific information

Upon the User’s request, 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 operation and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e. files that record interactions and may also contain Personal Data, such as the User’s 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 whether any third party services used support “Do Not Track” requests, the User is encouraged to consult the third parties own privacy policy.

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, where technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please consult this page regularly, referring to the date of the last change indicated at the bottom of the page.

If the changes involve processing operations for which the legal basis is the User’s consent, the Controller will seek the User’s consent again, if necessary.

Definitions and legal references

Last modified: 01 May 2021