Privacy Policy

Version 1.0 (31 May 2015)

This information (or “privacy policy”) is provided pursuant to art. 13 Legislative Decree 196/2003 (Code regarding the protection of personal data, c.d. “Privacy Code”) and describes how the site is managed www.minardimanagement.com the processing of any personal data acquired in accordance with current legislation.

The site is owned and managed by XXXX (for company data see par. 3). This privacy policy is provided only for this site and not for third-party websites that may be consulted by the user via links.

In any case, XXXX undertakes, to the extent of its competence, to fully comply with the current legislation on the protection of personal data.

 

1. PURPOSE AND METHOD OF TREATMENT

1. Any data acquired, always and in any case in compliance with current legislation, will be processed for institutional purposes, connected and / or instrumental to the provision of access to this site, including any additional services requested by the user; in particular:

a) to execute a service (such as accessing the site with all its features). To this end, the data may be disclosed to third parties whose collaboration XXX may and / or must make use of for the accomplishment of the aforementioned purposes. It is however possible to consult the site without providing any personal data, even if some features may not be available and some services may not be provided, as set out and specified as appropriate also in this privacy policy;

b) to perform, in general, legal obligations;

c) for operational and management needs internal to XXXX and inherent to the services and / or products offered.

2. In case of explicit and optional consent, the data will be processed for marketing and / or commercial promotion purposes, including the sending of printed and / or digital advertising material, relating to the services and / or products offered by XXXX . More details are available in art. 5.

3. The data will be processed lawfully and fairly and used only for the purposes referred to in the preceding paragraphs; for more details, please also refer to art. 5. The data will be processed using suitable tools to guarantee its security and confidentiality and may be carried out with paper tools and / or using automated tools designed to store, manage and transmit the data. The data will be kept for the time prescribed by law.

 

2. NATURE OF DATA CONFERENCE AND CONSEQUENCES OF A POSSIBLE REFUSAL TO ANSWER

1. The granting of consent to the processing of data for the purposes referred to in art. 1, paragraphs 1 and 2, is mandatory exclusively for the purposes indicated in relation to each service, subject to information provided in the manner established by law. In other words, the consequences of any refusal to respond or to give consent are always explicit and are connected to each service rendered: for example, any refusal to the relative treatment can prevent the consultation of the site with all its functions (in the in the case of cookies), the receipt of the newsletter (in the case of the newsletter service) or the receipt of advertising material (in the case of art.1 paragraph 2). Therefore, the user is informed in the manner appropriate to each specific case, but in any case he can consult the website even denying consent to the processing of personal data, where required; in this case, some functionalities or features could be disabled.

3. HOLDER OF THE TREATMENT

Following consultation of this site and the use of one or more services, data relating to identified or identifiable persons may be processed. The owner of their treatment is XXXXX, P.I. XXXX, with registered office in XXXX – XXXX, No. XX and operational headquarters to be strictly referred to in XXXX – XXXX.

 

4. PLACE OF DATA PROCESSING

The treatments connected to the web services referred to on this site are carried out at the operational headquarters of XXXXXX, subject to explicit exceptions, and are only handled by technical staff of XXXX in charge of processing. The site hosting service is provided by Aruba, which guarantees to XXXX, as far as it is concerned, compliance with current legislation. The data acquired via the web, or in any case deriving from web services, may be communicated to the technological and instrumental partners of which the Data Controller uses for the provision of the services requested by users / visitors. XXXX guarantees, in any case, compliance with current legislation to the extent of its competence.

 

5. TYPES OF DATA PROCESSED / SPECIFIC TREATMENTS

Depending on the service rendered, personal data of different types may be processed. The specification relating to each treatment can be consulted in this article. Each interested party is invited, in particular, to read art. 7 (“Rights of interested parties”).

 

5.1 Navigation data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the navigation of the websites. This information is not collected to be associated with identified interested parties; however, by their very nature they could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or domain names of the computers used by users who connect to the site, the URL 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 obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and platform used by the user.

The above data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning; are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site: except for this possibility, the data on web contacts do not currently persist for more than seven days. With regard to cookies, please refer to par. 5.3.
5.2.1 Data provided voluntarily by the user (communications)

The optional, explicit and voluntary sending of communications by means of contact forms on the site or by e-mail to the addresses indicated on this site entails the subsequent acquisition of the data communicated by the sender, including his e-mail address, and the consent to receive any response messages to their requests. Furthermore, requests can be made by telephone at the numbers indicated on the site.

The personal data provided in this way are used for the sole purpose of satisfying or responding to the requests sent and are communicated to third parties only if this is necessary for this purpose.

 

5.2.2 Data provided voluntarily by the user (to receive communications for marketing and / or commercial promotion purposes)

Each interested party can voluntarily provide their personal data to XXXX in order to receive commercial or promotional communications, however named, with both digital and paper communications. In every communication, the interested party is reminded that he can revoke the consent at any time and without formalities. The data is deleted at the request of the interested party.

 

5.3.1 Cookie

What are? Cookies are information stored by the browser when a website is visited with any suitable device (such as a PC, tablet or smartphone). Each cookie contains different data (for example, the name of the server from which it comes, a numeric identifier, etc.), it can remain in the system for the duration of a session (until the browser is closed) or for long periods and can contain a unique identification code.

What are they for? Cookies are used for different purposes depending on their type: some are strictly necessary for the correct functionality of the site (technical cookies), while others optimize its performance to offer a better user experience or allow you to acquire usage statistics. of the site, such as analytics cookies; still others are used to display advertisements, in some cases personalized thanks to the profiling performed (profiling cookies).

Consenso : l’eventuale prestazione del consenso dell’utente viene memorizzata da XXXX, per quanto di sua competenza, mediante un cookie tecnico, avente durata di 12 mesi. The user is informed both through the brief information (banner displayed on the first visit to the site until consent is given or denied, as explained in paragraph 5.3.4. “How to disable cookies?”) And by means of this extended information; furthermore, in paragraph 5.3.3 links to the privacy policies of third parties are indicated, also for the purpose of disabling them (where directly available through them).

How to disable them? It is possible to disable cookies both through the browser settings (par. 5.3.4. “How to disable cookies?”) And through the mechanisms made available by some third parties (par. 5.3.3 “Cookies used on the site”).

 

5.3.2 General types of cookies used on the site

Technical cookies: they are essential for the proper functioning of this site.

Analytical cookies (third party): they are used for the purpose of aggregate analysis of visits to the site, through the use of a third-party service.

 

5.3.3 Cookies used on the site

First party cookies: only technical cookies are used, with the following purposes: a) to memorize the user’s consent to the use of cookies (duration: 12 months);

Third party cookies: This site uses third-party cookies For more information on the cookies mentioned above and for disabling the cookies themselves:

– Google Analytics: http://www.google.com/intl/it_ALL/analytics/learn/privacy.html (for disabling – opt-out): https://tools.google.com/dlpage/gaoptout);

 

5.3.4 How to disable cookies?

Control via browser: Commonly used browsers (eg Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: it is a generally and widely supported function.

Therefore, cookies can easily be deactivated or disabled by accessing the options or preferences of the browser used and generally only third-party cookies can be blocked; in general, these options will only have effect for that browser and on that device, unless options are active to unify preferences on different devices. Specific instructions can be found on the options or help page of the browser itself. Disabling technical cookies, however, can affect the full and / or correct functioning of various sites, including this site.

As a rule, the browsers used today:

– offer the “Do not track” option, which is supported by some websites (but not all). In this way, some websites may no longer collect certain navigation data;

– offer the option of anonymous or incognito browsing: in this way no data will be collected in the browser and the browsing history will not be saved, but the browsing data will still be acquired by the operator of the website visited;

– allow you to delete the cookies stored in whole or in part, but when you visit a website again they are usually installed where this possibility is not blocked.

The links to the support pages of the most popular browsers are indicated (with instructions on disabling cookies on these browsers):

– Firefox (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);

– Internet Explorer (http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies);

– Safari (iOS)( https://support.apple.com/it-it/HT201265 );

– Chrome (desktop: https://support.google.com/chrome/answer/95647?hl=it; Android e iOS https://support.google.com/chrome/answer/2392971?hl=it).

Third party cookies: Third-party cookies can be disabled both in the manner described above and by referring to each third party (following the links indicated in the previous paragraph).

Online tools: it is noted that from the site http://www.youronlinechoices.com/it/ it is possible not only to acquire more information about cookies, but also to verify the installation of numerous cookies on your browser / device and, where supported, also to disable them.

 

5.4 Newsletter

The XXXX newsletter is sent via email to those who explicitly request it, using the form on the site www.minardimanagement.com and thus authorizing XXXX to process their personal data for the aforementioned purpose.

Consent: The provision of data is mandatory only to be able to receive the newsletter: refusal to provide them makes it impossible to use the newsletter service, but there are no other consequences.

Purpose: The personal data provided by users are used for the sole purpose of sending the newsletter and will not be disclosed to third parties.

Mode: The collected data are processed with IT tools. Suitable security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

Cancellation from the service: to stop receiving the newsletter, simply select the unsubscribe link, present at the end of each email, or send a request to giovanni@minardimanagement.com. The cancellation is managed in an automated way, so further newsletters could be received, the sending of which was planned before receiving the cancellation request. XXX is available to provide any clarification on the matter.

 

6. CHANGES TO THE PRIVACY POLICY

This Privacy policy may be modified, also as a result of legislative or regulatory changes, technological developments and the provision of new services or modifications to those already rendered. Therefore, each interested party is invited to periodically consult the XXXX Privacy policy.

7. RIGHTS OF THE INTERESTED PARTIES

The interested party is “the natural person to whom the personal data refer” (Article 4, paragraph 1, letter i, Legislative Decree 196/2003). Each interested party has the right, at any time, to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or correction (article 7 d.lgs. 196/2003). Pursuant to the same article, one has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their processing. At the bottom of this privacy policy, art. 7 d.lgs. 196/2003.

Requests should be sent:

– by e-mail, to the address: giovanni@minardimanagement.com

– by post, XXXXXXX

 

Art. 7 legislative decree 196/2003 (Right of access to personal data and other rights)

1. The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in an intelligible form.

2. The interested party has the right to obtain the indication:

a) the origin of personal data;

b) the purposes and methods of the processing;

c) of the logic applied in case of processing carried out with the aid of electronic tools;

d) the identity of the owner, manager and the representative appointed under Article 5, paragraph 2;

e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents.

3. The interested party has the right to obtain:

a) updating, rectification or, when interested, integration of data;

b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data which need not be kept for the purposes for which the data were collected or subsequently processed;

c) certification that the operations referred to in letters a) e b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right .

4. The interested party has the right to object, in whole or in part:

a) for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;

b) to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.