Subjects of treatment

The data controller under applicable laws is the site administrator, Avvinamente di Gaetano Minoia, who can be contacted through the section
CONTACTS

Legal basis for processing
This site processes data primarily on the basis of users’ consent. Consent is given through the banner at the bottom of the page, or through use or consultation of the site, as a concluding behavior. By using or consulting the site, visitors and users approve this privacy policy and consent to the processing of their personal data in the manner and for the purposes described below, including possible disclosure to third parties if necessary for the provision of a service. Through communication or service request forms, additional consents related to the specific purpose of the service are collected.

The provision of data and thus consent to the collection and processing of data is optional, the User may withhold consent, and may revoke a consent already provided at any time (via the banner at the bottom of the page or the browser settings for cookies, or the Contact link). However, denying consent may result in the inability to deliver some services and the site browsing experience would be compromised.

Data for site security and prevention from abuse and SPAM, as well as data for site traffic analysis (statistics) in aggregate form, are processed based on the legitimate interest of the Data Controller in protecting the site and the users themselves. In such cases, the user always has the right to object to data processing (see par. User Rights).
Purpose of processing
The processing of data collected from the site, in addition to the purposes related, instrumental and necessary to the provision of the service, is aimed at the following purposes:

Statistics (analysis)
Collection of data and information in aggregate and anonymous form only in order to verify the proper functioning of the site. None of this information is related to the physical person-User of the site, and it does not in any way allow their identification. No consent is needed.

Security
Collection of data and information in order to protect the security of the website (spam filters, firewalls, virus detection) and Users and to prevent or expose fraud or abuse against the website. The data are recorded automatically and may possibly include personal data (Ip address) that could be used, in accordance with the relevant laws, in order to block attempts to damage the site itself or to harm other users, or otherwise harmful or criminal activities. This data is never used for identification or profiling of the User and is deleted periodically. No consent is needed.

Ancillary activities
Communicate data to third parties who perform functions necessary or instrumental to the operation of the service (e.g., comment box), and to enable third parties to perform technical, logistical, and other activities on our behalf. Providers have access only to personal data that are necessary to perform their tasks, and agree not to use the data for other purposes, and are required to process personal data in accordance with applicable regulations.

Data collected
This site collects user data in two ways.

Data collected in an automated manner
During Users’ browsing, the following information may be collected and stored in the log files of the site’s server (hosting):
– internet protocol (IP) address;
– browser type;
– Parameters of the device used to connect to the site;
– Internet service provider (ISP) name;
– Date and time of visit;
– Visitor’s source (referral) and exit web pages;
– possibly the number of clicks.

This data is used for statistical and analytical purposes, in aggregate form only. The IP address is used for security purposes only and is not cross-referenced with any other data.

Data given voluntarily

The site may collect other data in case of voluntary use of services by users, such as comment services, communication services (contact forms, comment box), and will be used only for the provision of the requested service:
– name;
– email address.

Place of processing
Data are processed at the Data Controller’s office, and at the Aruba Web Hosting datacenter. Aruba web hosting, is responsible for the processing, processing the data on behalf of the owner. Aruba is located in the European Economic Area and acts in accordance with European standards.

Period of data retention
The data collected by the site during its operation are kept for the time strictly necessary to carry out the specified activities. Upon expiration, the data will be deleted or anonymized unless there is no further purpose for retaining the data.

Data (IP address) used for site security purposes (blocking attempts to damage the site) are kept for 30 days.
Data for analytics (statistical) purposes are kept in aggregate for 24 months.

Transfer of collected data to third parties
The data collected by the site are generally not provided to third parties, except in specific cases: legitimate request by the judicial authority and only in cases provided by law; if it is necessary for the provision of a specific service requested by the User; for the performance of security checks or optimization of the site.

Transfer of data to countries outside the EU
This site may share some of the data collected with services located outside the European Union area. Specifically with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized under specific decisions of the European Union and the Italian Data Protection Authority, in particular Decision 1250/2016(Privacy Shield – here is the Italian Data Protection Authority’s information page), so no further consent is needed. The companies mentioned above guarantee their adherence to the Privacy Shield.

Security measures
We process visitor/user data lawfully and fairly, taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of data. We are committed to protecting the security of your personal information as it is sent, using Secure Sockets Layer (SSL) software, which encrypts information in transit. The processing is carried out by means of computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, categories of appointees involved in the organization of the site or external parties (such as third-party technical service providers, hosting providers) may have access to the data.

Cookie
This site makes use of cookies, text files that are recorded on the user’s terminal or allow access to information on the user’s terminal. Cookies allow storing information about visitors’ preferences, are used in order to verify the proper functioning of the site and to improve its functionality by customizing the content of the pages according to the type of browser used, or to simplify navigation by automating procedures (e.g. Login, site language), and finally for the analysis of the use of the site by visitors.

This site makes use of the following categories of cookies:

Technical cookies, used for the sole purpose of carrying out the transmission of an electronic communication, to ensure the proper display of the site and navigation within it. In addition, they allow distinction between different logged in users in order to provide a required service to the right user (Login), and for site security reasons. Some of these cookies are deleted when the browser is closed (session cookies), others have a longer lifetime (such as the cookie required to store user consent regarding the use of cookies, which lasts 1 year). No consent is needed for these cookies;

analytics cookies, used directly by the site operator to collect information, in aggregate form, about the number of users and how they visit the site. They are assimilated to technical cookies if the service is anonymized.

Profiling and marketing cookies, used exclusively by third parties other than the owner of this site to collect information about users’ browsing behavior, and interests and consumption habits, including for the purpose of providing personalized advertising.

By clicking OK on the banner present when first accessing the site or navigating the site, the visitor expressly consents to the use of cookies and similar technologies, and in particular to the recording of such cookies on his or her terminal equipment for the purposes indicated above, or to access through cookies to information on his or her terminal equipment.


Disabling cookies
The user can refuse the use of cookies and at any time can revoke a consent already provided. Since cookies are linked to the browser used, THEY CAN BE DISABLED DIRECTLY FROM THE BROWSER, thus refusing/revoking consent to the use of cookies, or via the this dedicated area (click here).

DISABLING COOKIES MAY PREVENT THE CORRECT USE OF CERTAIN FUNCTIONS OF THE SITE ITSELF, in particular services provided by third parties may not be accessible, and therefore may not be viewable:
– YouTube videos or other video sharing services;
– social media buttons;
– Google maps.

Instructions for disabling cookies can be found at the following web pages:

Mozilla Firefox – Microsoft Internet ExplorerMicrosoft EdgeGoogle ChromeOperaApple Safari

Third-party cookies
This site also acts as an intermediary for third-party cookies (such as social media buttons), which are used in order to provide additional services and features to visitors and to simplify the use of the site itself, or to provide personalized advertising. This site has no control over their cookies wholly managed by third parties and has no access to the information collected through said cookies. Information about the use of said cookies and their purposes, as well as how to disable them, is provided directly by the third parties on the pages indicated below.

It should be noted that user tracking generally does not involve user identification, unless the User is already subscribed to the service and is also already logged in, in which case it is understood that the User has already given consent directly to the third party when subscribing to the relevant service (e.g., Facebook).

This site uses cookies from the following third parties.

Google Inc.
For information about Google’s use of data and its processing, it is recommended that you review Google’sPrivacy Policy and Google’s Terms of Use of Data when using partner sites or apps.

Google Analytics: used to analyze user use of the site, compile reports on site activity and user behavior, check how often users visit the site, how the site is tracked, and which pages are visited most frequently. The information is combined with information collected from other sites in order to create a comparative picture of site usage against other sites in the same category.
Data collected: browser identifier, date and time of interaction with the site, page of origin, IP address.
Place of data processing: European Union being active service anonymization.

The data collected do not allow personal identification of users, and are not cross-referenced with other information about the same person. They are processed in aggregate and anonymized (truncated to the last octet). Under a special agreement (DPA) Google Inc. is prohibited from. (data controller) the cross-referencing of such data with data obtained from other services.

More information about Google Analytics cookies can be found on the Google Analytics Cookie Usage on Websites page.

You can selectively disable (opt-out) the collection of data by Google Analytics by installing theappropriate component provided by Google(opt out) on your browser.

Youtube: a platform, owned by Google, for sharing videos. Cookies are set when the page containing the embed is accessed, and when the video is started, and do not allow the User to be identified unless they are already logged into their Google profile.
For videos on the site, an “enhanced privacy (no cookies)” option has been enabled, which makes YouTube not store information about visitors unless they voluntarily play the video.
Data collected: number and behavior of service users, IP address, information linking site visits to Google account for already logged in users, video viewing preferences.
Place of data processing: USA.

Social Network Plugin
This site also incorporates plugins and/or buttons in order to allow easy sharing of content on your favorite social networks. When you visit a page on our website that contains a plugin, your browser connects directly to the servers of the social network from where the plugin is loaded, which server can track your visit to our website and, if appropriate, associate it with your social account, particularly if you are logged in at the time of your visit or if you have recently browsed one of the websites containing social plugins. If you do not want the social network to record data about your visit to our website, you must log out of your social network account and, probably, delete the cookies that the social network has installed in your browser.

Plugins with advanced privacy protection features for Users are installed on this site, which do not send cookies or access cookies on the User’s browser when the page is opened but only after the plugin is clicked.

The collection and use of information by such third parties is governed by their respective privacy policies to which please refer.

Facebook(cookie policy link)
Twitter(cookie policy link)
LinkedIn(cookie policy link)
Google+(cookie policy link).

User Rights
Pursuant to the European Regulation 679/2016 (GDPR), the User may, in the manner and within the limits provided by the current legislation, exercise the following rights:

– oppose in whole or in part, for legitimate reasons, the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
– Request confirmation of the existence of personal data concerning him/her (right of access);
– Know its origin;
– Receive intelligible communication;
– Have information about the logic, methods and purposes of processing;
– request the updating, rectification, integration, cancellation, transformation into anonymous form, and blocking of data processed in violation of the law, including data no longer necessary to achieve the purposes for which they were collected;
– in cases of consent-based processing, receive at the sole cost of any support, your data provided to the data controller, in structured, machine-readable form and in a format commonly used by an electronic device;
– The right to file a complaint with the Supervisory Authority (Privacy Guarantor – link to the Guarantor’s page);
– as well as, more generally, to exercise all the rights granted to him by the current legal provisions.

Requests should be addressed to the Data Controller.

Updates
This privacy policy is current as of November 29, 2018.