Data Controller

Definitions and Legal References

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in combination with any other information, including a personal identification number, can identify or make identifiable a natural person.

Usage Data

This includes information collected automatically through this Website (also by third-party applications integrated into this Website), such as: IP addresses or domain names of the computers used by the User to connect to this Website, URI addresses (Uniform Resource Identifier), request time, method used to forward the request to the server, file size received in response, numerical code indicating the response status from the server (success, error, etc.), the country of origin, browser and operating system features used by the visitor, various time-related aspects of the visit (e.g., time spent on each page), and details related to the navigation path followed within the Application, with particular reference to the sequence of pages viewed, parameters related to the operating system, and the User’s computing environment.

User

The individual who uses this Website, who, unless otherwise specified, is the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal entity, public authority, or any other body that processes personal data on behalf of the Data Controller, as described in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of processing personal data and the tools used, including the security measures related to the functioning and use of this Website. Unless otherwise specified, the Data Controller is the owner of this Website.

This Website (or Application)

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Website as defined in its terms (if available) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union in this document shall be extended to all current member states of the European Union and the European Economic Area.

Cookies

A small portion of data stored within the User’s device.

Legal References

This privacy policy is drafted based on multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies solely to this Website.

Types of Data Collected

Among the Personal Data collected by this Website, either independently or through third parties, are: Cookies, Usage Data, first name, last name, email, username, and website.

Complete details about each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.

Unless otherwise specified, all requested Data by this Website is mandatory. If the User refuses to provide such Data, it may be impossible for this Website to provide the Service.

In cases where this Website indicates some Data as optional, Users are free to refrain from providing such Data without affecting the availability or operation of the Service.

Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

The potential use of Cookies – or other tracking tools – by this Website or by third-party service providers used by this Website, unless otherwise specified, is aimed at providing the Service requested by the User, as well as the additional purposes described in this document and in the Cookie Policy, if available.

The User is responsible for third-party Personal Data obtained, published, or shared through this Website and guarantees that they have the right to communicate or disseminate them, holding the Data Controller harmless from any liability towards third parties.

Methods and Location of Data Processing

Processing Methods

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

Legal Basis for Processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

• 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 legal basis specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on Personal Data protection;
• The processing is necessary for the performance of a contract with the User and/or 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 performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible to request the Data Controller to clarify the legal basis of each processing and, in particular, to specify whether the processing is based on the law, a contract, or is necessary to conclude a contract.

Location

Data is processed at the Data Controller’s operational offices and at any other location where the parties involved in the processing are located. For more information, contact the Data Controller.

The User’s Personal Data may be transferred to a country different from the one where the User is located. To obtain more information on the location of the processing, the User can refer to the section related to details on 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 public law organization or one established by two or more countries, such as the UN, as well as about the security measures adopted by the Data Controller to protect the Data.

If any of the transfers described above occur, the User can refer to the respective sections of this document or request information from the Data Controller by contacting them at the details provided above.

Retention Period

Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

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

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 retain the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

After the retention period, Personal Data will be deleted. Therefore, once this period expires, the rights to access, deletion, rectification, and data portability will no longer be exercisable.

Purposes of Processing the Collected Data

The User’s Data is collected to allow the Data Controller to provide their Services, as well as for the following purposes: Statistics, Contacting the User, Commenting on content, Displaying content from external platforms, Interacting with social networks and external platforms, Protection from SPAM, Managing User databases, and Interacting with live chat platforms.

For more detailed information on the purposes of processing and the Personal Data 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:

Commenting on Content

Commenting services allow Users to post and publicly share comments regarding the content of this Website.
Users, depending on the settings decided by the Data Controller, may leave their comments anonymously. If among the Personal Data provided by the User is the email address, it may be used to send notifications about comments on the same content. Users are responsible for the content of their comments.
If a third-party comment service is installed, it is possible that, even if Users do not use the comment service, the service collects traffic data related to the pages where the comment service is installed.

Direct Comment System (This Website)

This Website has its own content comment system.

Personal Data collected: last name, email, first name, website

Interaction with live chat platforms

This type of service allows interaction with live chat platforms, managed by third parties, directly from the pages of this Website. This allows the User to contact the support service of this Website or for this Website to contact the User while navigating its pages.
In case a live chat platform interaction service is installed, it is possible that, even if Users do not use the service, it may collect Usage Data related to the pages where it is installed. Additionally, live chat conversations may be recorded.

Interaction with social networks and external platforms

This type of service allows interaction with social networks, or with other external platforms, directly from the pages of this Website.
The interactions and information collected by this Website are subject to the User’s privacy settings related to each social network.
In case a social network interaction service is installed, it is possible that, even if Users do not use the service, it may collect traffic data related to the pages where it is installed.

“Share” button and Facebook social widgets (Facebook, Inc.)

The “Share” button and Facebook social widgets are services for interacting with the Facebook social network, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Location of processing: USA – Privacy Policy.

“Pin it” button and Pinterest social widgets (Pinterest)

The “Pin it” button and Pinterest social widgets are services for interacting with the Pinterest platform, provided by Pinterest Inc.

Personal Data collected: Cookies and Usage Data.

Location of processing: USA – Privacy Policy.

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are services for interacting with the Twitter social network, provided by Twitter, Inc.

Personal Data collected: Cookies and Usage Data.

Location of processing: USA – Privacy Policy.

Protection from SPAM

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, to filter it from traffic, messages, and content recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is an anti-spam service provided by Automattic Inc.

Personal Data collected: Various types of Data as specified in the service’s privacy policy.

Location of processing: USA – Privacy Policy.

Statistics

The services in this section allow the Data Controller to monitor and analyze traffic data and track User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses Personal Data, collected anonymously on this site, to track and examine the use of this Website, compile reports, and share them with other services developed by Google.
Google may use Personal Data, collected anonymously on this site, to contextualize and personalize ads on its advertising network.

Personal Data collected: Cookies and Usage Data.

Location of processing: USA – Privacy Policy – Opt Out.

Displaying content from external platforms

This type of service allows displaying content hosted on external platforms directly from the pages of this Website and interacting with it.
In case such a service is installed, it is possible that, even if Users do not use the service, it may collect traffic data related to the pages where it is installed.

Google Fonts (Google Inc.)

Google Fonts is a font display service managed by Google Inc. that allows this Website to integrate such content into its pages.

Personal Data collected: Usage Data and various types of Data as specified in the service’s privacy policy.

Location of processing: USA – Privacy Policy.

Gravatar (Automattic Inc.)

Gravatar is an image display service managed by Automattic Inc. that allows this Website to integrate such content into its pages.
Please note that if Gravatar images are used for comment systems, the commenter’s email address (or parts of it) may be sent to Gravatar, even if they are not registered with this service.

Personal Data collected: Usage Data and email.

Location of processing: USA – Privacy Policy.

YouTube Video Widget (Google Inc.)

YouTube is a video content display service managed by Google Inc. that allows this Website to integrate such content into its pages.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy.

Newsletter

The website features a Newsletter exclusively for our customers, who periodically receive notifications and/or service communications via email.

For the provision and management of the Newsletter, the service offered by SendinBlue (SendinBlue, 55 rue d’Amsterdam, 75008 Paris, France) is used, and the collected data are stored on the service provider’s secure servers.

According to SendinBlue’s privacy policy, the data will never be used directly by SendinBlue or sold to third parties. SendinBlue uses properly authorized operators for service maintenance, and in exercising this function, they may have access to your data.

The guarantees provided by the privacy policy of SendinBlue.

User Rights

Users can exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

• revoke consent at any time. The User can withdraw the consent for the processing of their Personal Data previously given.
• object to the processing of their Data. The User can object to the processing of their Data when it is based on a legal basis other than consent. Further details about the right to object are provided in the section below.
• access their Data. The User has the right to obtain information about the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
• obtain the restriction of processing. When certain conditions are met, the User can request the restriction of processing of their Data. In such cases, the Data Controller will not process the Data for any purpose other than their storage.
• obtain the deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Data Controller.
• receive their Data or have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format, and where technically feasible, to have them transferred without hindrance to another controller. This provision applies when the Data is processed by automated tools, and the processing is based on the User’s consent, a contract to which the User is a party, or related contractual measures.
• file a complaint. The User can file a complaint with the competent data protection authority or seek judicial remedies.

How to exercise rights

To exercise the User’s rights, Users can send a request to the contact details of the Data Controller provided in this document. The requests are free of charge and will be processed by the Data Controller as soon as possible, in any case within one month.

Further information on processing

Defence in legal proceedings

The User’s Personal Data may be used by the Data Controller in legal proceedings or in preparatory stages for its possible initiation to defend against misuse of this Website or its associated Services by the User.

The User acknowledges that the Data Controller may be required to disclose Data by order of public authorities.

Specific notices

At the User’s request, in addition to the information provided in this privacy policy, this Website may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance needs, this Website and any third-party services it uses may collect system logs, which are files that record interactions and may contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Additional information regarding the processing of Personal Data can be requested at any time from the Data Controller using the contact details.

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. Please regularly check this page, taking as reference the date of the last modification shown at the bottom. In case of non-acceptance of the changes made to this privacy policy, the User must cease using this Website and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected up to that point.

Last modification: May 24, 2018.