- 1.Data Controller and contact details
The Data Controller is Fabrizio Crestani, C.F. CRSFRZ87T17C957T, hereinafter also “Data Controller” or only “Controller”.
- Personal data subject to processing
The personal data processed by or through the Website are the following:
- Navigation data
The computer systems and software procedures used to operate the website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. These personal data are not collected to be associated with identified data subjects, but, considering their nature and intrinsic characteristics, they could, through processing and association with data held by third parties, enable users to be identified. This category of data includes, for example, IP addresses, domain names of the computers used by users who connect to the website and the addresses in the Uniform Resource Identifier (URI) notation of the requested resources. This data is used for the sole purpose of obtaining aggregate or anonymous statistical information on the use of the website itself and to check its correct functioning, in order to identify anomalies and/or abuses. These data are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes or at the request of the Public Authority.
- Data provided on a voluntary base
The “Contacts” section of the Website contains the Data Controller’s contact details (telephone number and e-mail). The User, through these contact details, may contact the Controller and voluntarily provide personal data such as, for example:
- personal identifying data (e.g., first and last name);
- personal data useful for the purpose of re-contacting the User (e.g., e-mail address, telephone number, country and, if applicable, company to which the User belongs);
- the additional personal data provided by the User when contacting the Controller.
The Data Controller shall process personal data in compliance with the Applicable Law, assuming that they refer to the User or to third parties who have expressly authorised the User to provide them or whose personal data that the User was entitled to provide. With respect to these assumptions, the User undertakes to indemnify and hold harmless the Data Controller from any dispute, claim or request for compensation for damage caused by the processing of personal data that may be received from such third parties.
- Cookies and other tracking tools
- Purposes and legal basis of the processing
The following table provides the purposes and legal basis concerning the processing of the above-mentioned personal data:
|Providing feedback to any inquiries sent on a voluntary base by the User using the Data Controller’s contact details available on the “Contacts” section of the Website.||The implementation of pre-contractual measures taken at the User’s request and/or the contract to which the User is a party [art. 6 (1)( b), of the GDPR].|
|Complying with legal obligations to which the Data Controller is bound, included to respond to any requests to exercise the User’s rights as data subject under current data protection legislation.||The compliance with legal obligations to which the Data Controller is bound [Article 6(1)(c) of the GDPR].|
|Verifying any fraudulent or illegal use of the Website and ensure its security and functionality in the interest of the Users and the Data Controller.||The legitimate interest of the Data Controller and the Users themselves to prevent or identify any fraudulent or otherwise illegal use of the Website [art. 6(1)(f) of the GDPR].|
|Carrying out research/statistical analysis on aggregate or anonymous data, without therefore being able to identify the User, to measure traffic and assess usability and interest with respect to the Website.||The legitimate interest of the Controller to verify the usability and the appeal of the Website [art. 6(1)(f) of the GDPR].|
|Ascertaining, exercising, or defending legal claims or whenever courts are acting in their judicial capacity.||The legitimate interest to ascertain, exercise, or defend legal claims or whenever the courts are acting in their judicial capacity [art. 6(1)(f) of the GDPR].|
- Consequences of failure to provide personal data
The provision of data by the User is subject to the User’s willingness to contact the Data Controller and, therefore, optional. Nevertheless, failure to provide them, in whole or in part, may result in the impossibility of providing feedback to any requests for information and/or requests to exercise the User’s rights as a data subject.
- Methods of personal data processing
Personal data are processed with manual and/or paper-based and/or computer-based and/or telematic instruments and/or supports, in any case in such a way as to guarantee their security and confidentiality. To this end, the Data Controller has adopted and implements security measures, both technical and organisational, appropriate to the level of risk related to the processing of personal data carried out.
In particular, the Website functionality is provided on HTTPS encrypted connection and personal data are collected, filed, and stored on secure servers, protected by firewalls, and physically located within the European Union.
- Recipients of personal data
The personal data of the User may be shared, for the purposes described above, with:
- employees or other types of collaborators of the company authorized by the Data Controller to process those personal data pursuant to and for the purposes of Article 29 of the GDPR and Article 2-quaterdecies of the Privacy Code and who have received specific instructions on how to process the data in accordance with the Applicable Law;
- companies, consultants, or professionals who may be entrusted with the installation, maintenance, updating of the Site (for example, web agencies) and, in general, with the management of the hardware and software of the Owner, included hosting providers and cloud computing services providers that act as data controllers pursuant to and for the purposes of art. 28 of the GDPR;
- Public Authorities to whom, in their capacity as independent data controllers, it is mandatory to disclose the personal data of the User by virtue of legal provisions or orders of the authorities;
- law firms, associated firms, consultants, or professionals (e.g., legal consultancies) who may be appointed to support the Data Controller in order to ensure the correct fulfilment of the legal obligations with which he is required to comply; the ascertainment, exercise or defence of a right in court or whenever the jurisdictional authorities act in their judicial capacity.
- Transfers to non-EU countries and/or international organisations
Personal data voluntarily provided by the User to the Controller won’t be transferred to countries and/or international organizations outside the European Economic Area.
- Period of retention of personal data
The User’s personal data or provided by the User will be kept for a period not exceeding the one necessary for the pursuit of the purposes indicated above and for which they are processed.
In particular, personal data will be kept for the period necessary to provide feedbacks to any requests for information received and, in any case, for a period not exceeding 3 months from the moment the user provided those personal data.
- Rights of the data subject
We inform the User that, as the data subject, he/she is entitled:
- to receive confirmation as to whether or not his/her personal data are being processed and, if so, to obtain access to them and to a range of relevant information, including, by way of example, information concerning : a) the purposes of the processing; b) the categories of personal data that are subject to processing; c) the entities or categories of entities to whom or which the personal data have been or will be communicated; d) the storage period of the data or, if that is not possible, the criteria used to determine that period; e) the source of the personal data, if they have not been provided by the User;
- to request and obtain the updating of personal data, the rectification of inaccurate data or, when needed, the integration of incomplete data;
- to request and obtain the erasure of personal data if: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) the User objects to the processing carried out on the basis of a legitimate interest of the Controller and there is no overriding legitimate reason to continue the processing; c) the personal data have been processed unlawfully; d) the personal data must be erased by the Controller in compliance with a legal obligation;
- to request and obtain the restriction of processing in the event of: (a) contestation of the accuracy of his/her personal data for the time necessary for the Data Controller to carry out the requested verifications; (b) unlawful processing of data by the Data Controller, if the User objects to the deletion of the data and instead requests the restriction of its use; (c) ascertainment, exercise or defence of a right of the User in court, although the Data Controller no longer needs the data for the purposes of processing; (d) awaiting the outcome of the verification as to whether the Data Controller’s legitimate reasons prevail over those of the data subject;
- in cases where the processing of personal data is based on a contract and is carried out by automated means, to request and receive in a structured, commonly used and machine-readable format his/her personal data and, if technically feasible, to obtain the direct transmission of them by the Controller to another controller;
- to object, in whole or in part, on legitimate grounds relating to the User’s particular situation, to the processing of personal data concerning the User, even though they are relevant to the purpose of collection;
- to file a complaint with the Italian Data Protection Authority pursuant to Article 77 of the GDPR and Articles 140-bis et seq. of the Privacy Code.
The Data Controller shall inform each of the recipients to whom the User’s personal data have been transmitted of any rectification, cancellation and/or restriction of processing carried out, except when this proves impossible or involves a disproportionate effort.
- Ways of exercising rights of the data subject
As a data subject, the User and/or the third party on whose behalf the User has provided the data may at any time exercise the above-mentioned rights by contacting the Data Controller at the contact details listed above.
To file a complaint with the Data Protection Authority, the User may use the forms made available on the relevant website.