1. Introduction.
By using this website: www.italleghe.eu (the “Website”), owned by Italleghe S.r.l., with legal office at 21, Via G. Galilei, Guanzate (Co) (“Italleghe”), you will transfer to Italleghe a certain quantity of your personal data (the “Personal Data“).
Some Personal Data will come to be known by Italleghe through automatic procedures. Some others will be provided voluntarily by you, during the procedures necessary to obtain the services supplied by Italleghe, for instance, by filling in the form active in the page “Contacts”.
By way of this policy (the “Policy”), drafted pursuant to the regulations of Legislative Decree 196/2003 (the “Privacy Code“), as amended and supplemented by the European Regulation 2016/679 concerning the protection of personal data as currently in force (“GDPR“), Italleghe, in its quality of controller of your Personal Data, desires to inform you about the purposes and modalities according to which such Personal Data will be processed, as well as about the rights you are entitled to by the applicable laws.
According to the regulations provided for by the GDPR, the processes carried out by Italleghe will be marked by principles of legality, correctness, transparency, limitation of the objectives, as well as by principles of conservation, accuracy, integrity and confidentiality.
This Policy is provided to you only with regard to the use of the Website and not also to the possible use of other websites that could be reached through the links therein.
2. Which data we do process.
A)Browsing data.
The IT systems and the software procedures utilized for the functioning of the Website collect, during their normal activity, some Personal Data, which transmission is implied in the use of the Internet communication protocols. Such information are not collected in order to be associated to identified and specific subjects but, for their own nature, through elaborations and associations with data held by third parties, could allow the identification of the Website’s users.
In such category of data fall, for instance, the IP addresses of the devices used by the users to visit the Website, the URI notation addresses (Uniform Resource Identifier) of the requested resources, the time in which the request is made, the method used to submit such request to the server, as well as other parameters related to the operating system and to the IT environment of the user. These data are used to collect anonymous statistical information about the use of the Website and to check its correct functioning, or to identify abuses and/or anomalies and they are deleted right after their processing. Such data could be used by the competent authorities to check responsibilities in case of IT crimes against the Website.
B)Data voluntarily submitted by the user.
Beside the browsing data of necessary acquisition, you will be free to provide your Personal Data by filling in the request forms available in the Website (for instance, as anticipated, the one active in the “Contact” page). In this respect, you will be asked to provide only the Personal Data strictly necessary in order to allow Italleghe to duly provide you with the service from time to time in object. To supply certain services it could be necessary the Personal Data you transferred to Italleghe to be shared with third parties, which are trusted partners of Italleghe.
The Personal Data voluntarily provided by you, fall within the category of common data such as, for example, the registry data (name, surname, tax code, address, e-mail, telephone number and other addresses). In relation thereto, we do inform you that, should you provide Italleghe with third parties’ data (e.g. family or friends), according to the laws currently in force you will be responsible for such transfer and you will have to keep harmless and indemnified Italleghe from any damage it may incur in due to claims carried out towards Italleghe by such third parties, whose Personal Data have been transferred by you.
The Personal Data can be transmitted by Italleghe to third parties only when such trasfer is necessary in order to provide the user with an adequate feedback. The optional, explicit and voluntary transmission of e-mail communications to the addresses available on the Website, automatically implies the collection of the sender’s e-mail address, as well as of the other personal data eventually included in the communication. Such data will be used exclusively in order to provide an answer to the requests contained in the received communication. In such a case, the lawfulness of the data processing is impled in the explicit user’s permit, provided upon the free informed provision of his data, representing a clear positive action.
3.Purposes of the processing.
The Personal Data provided by you shall be processed in order to:
- duly and timely provide you with the requested service, carrying out the relevant administrative, accounting, tax and legal fulfillments;
- carry out the other activities directly connected with and/or instrumental to the performance of Italleghe’s services;
- generally comply with the legal requirements;
- eventually serve you with information and/or commercial communications. The processes having these purposes, if implemented by Italleghe, will be carried out only upon your explicit consent and, for instance, by means of transmission of price lists, brochures or questionnaires of satisfaction about Italleghe’s services.
- elaborate possible internal statistics and draft technical reports about the services requested by you.
As anticipated, the transmission of your Personal Data could be, from time to time, optional or necessary in order to allow Italleghe to provide you with the requested services. Should you not agree with the processing of the data with necessary transfer, Italleghe will not be able to provide you with any service through the Website.
The Personal Data transmitted to us will not be sold or transferred, in any way whatsoever, to third parties without your prior and express consent, except from what otherwise provided for in this Policy.
4.Share and transfer of the Personal Data.
The Personal Data communicated by you to Italleghe will be shared with third parties only for the purposes listed above.
Italleghe will not transfer your Personal Data to third parties different from those listed in the present Policy. In the performance of our activity -and exclusively for the purposes listed in the present Policy– your Personal Data could be transferred to the following categories of recipients:
- our collaborators and employees, within the limits of their tasks connected to the supply of the services requested by you;
- the partners supplying the products and services of Italleghe, including herein our legal, accountant and tax consultants;
- the administrator of the domain “Italleghe.eu”;
- other individual and/or legal entities, public and/or private, as far as the communication is necessary or functional for the performance of our activity;
- all the subjects whose faculty to access the Personal Data is granted by the laws;
- any other subjects, also foreigner, that Italleghe uses for the sole purpose of carrying out the activities described above.
Your consent, that is considered as given through the conscious use of the Website, is extended, beside the processing, the communications and the transfers made by us, also to the specific processes, communications and transfers made by such subjects, that will operate as independent data controllers.
We inform you that the same modalities and procedures of processing of Personal Data described in the present Policy will be adopted also in the case the Personal Data will be transmitted – in Italy or abroad – to the subjects listed above, who, on their side, are committed to process them according to the applicable law regulations.
5.Modalities of processing and protection.
In relation to the purposes described above, your Personal Data will be processed digitally and/or on paper, in compliance with the regulations provided by the Privacy Code and the GDPR. The processing operations will be carried out in order to guarantee the physical security and the confidentiality of your Personal Data, complying with the provisions set forth under article 32 of the GDPR. Italleghe has arranged technical and organizational measures adequate in order to guarantee a sufficient level of security and confidentiality of the Personal Data, also in order to protect them from possible destructions, alterations, disclosures or unauthorized accesses, both of accidental and illegal nature.
6.Storage times of the Personal Data.
Without prejudice for your right to challenge the processing of your Personal Data and/or to request their deletion, Italleghe will store your Personal Data only for the period of time strictly necessary in order to achieve the results for which they have been collected and received and to comply with the legal and regulatory requirements.
In case of termination, for whatever reason, of the processing activity of the Personal Data transferred by you, they will be or destroyed or kept stored, but no more used for any systematic communication or dissemination, or they will be kept stored or transmitted to a different controller only for historical, statistical or scientific purposes, in compliance with the law, the regulations and the national and European legislation.
7.Your legal rights
The rights connected to the Personal Data processed by Italleghe, listed in the articles 15 and subsequent of the GDPR, are the following:
Right to correction: You have a right to obtain from Italleghe the correction of the Personal Data. Italleghe undertakes to act diligently, so that the Personal Data in its possession are correct, complete, updated and appropriate, according to the most recent information in its possession.
Right to limitation: You are entitled to obtain limitations of the processing of the Personal Data if:
- you challenge the correctness of your Personal Data in Italleghe’s possession;
- the processing is unlawful and you decide not to request the cancellation of your Personal Data, but to limit their use;
- it is no more necessary for Italleghe to store your Personal Data;
- You need the Personal Data in order to ascertain, exercise or defend a right in front of the judicial authorities;
Right to access: You are of course entitled to ask Italleghe for information in relation to your Personal Data stored by it, including the information on which categories of Personal Data Italleghe holds or controls, for which purposes they are used, how they have been collected and to whom they have been possibly communicated. In this case, Italleghe shall notify you with the summary of your Personal Data held by Italleghe, in a structured format of common use and readable by automatic device.
Right to transfer: Following to your explicit request, if technically practicable, Italleghe will transfer your Personal Data to a different controller.
Deletion’s right: You are entitled to obtain from Italleghe the deletion of your Personal Data if:
- such Personal Data are no more necessary in relation to the purposes for which they have been collected or otherwise processed;
- the Personal data have been processed unlawfully;
- you have revoked your consent to their treatment and no juridical circumstance grounds a mandatory treatment;
- you successfully challenged the Personal Data treatment;
- the Personal data must be deleted in order to comply with a legal obligation.
The right to the deletion does not apply if the processing is necessary in order to comply with a legal obligation or in order to perform a task in the public interest or to assess, exercise or defend a right in front of a Court of Justice.
Right to file a claim. In case of supposed violation of the privacy legislation in force, you are entitled to file a complaint with the appropriate Control Authority (Guarantor for the Protection of Personal Data) at the address https://www.garanteprivacy.it/home/modulistica-e-servizi-online, pursuant to art. 77 of the GDPR.
8.Modalities to request information and revoke the treatment’s consent
You can exercise the rights under the previous paragraphs, alternatively, by sending a registered letter to the following address: Italleghe S.r.l., 21, Via Galileo Galilei, 22070, Guanzate (Co), or an e-mail to the following address: anna.arrighi@italleghe.eu, together with a copy of an identity document of yours. Following this, in case of revocation of the consent to the processing, your Personal Data will be removed from our digital files. However, in case of requests clearly groundless or excessive, also for their possible reiteration, Italleghe could charge you with a reasonable fee, according to the administrative expenses incurred to manage your request.
9.Modification of this privacy policy.
Italleghe reserves the right to amend or to simply update this Policy, either according to further events involving Italleghe (e.g. transfer of the legal office, modification of Italleghe’s activity, implementation of new services or inclusion of Italleghe among the subjects bound to appoint a Data Protection Officer), or in connection with amendments or integrations of the applicable laws.
Any amendments or integrations of this Policy will be notified to you through the communication channels normally used by Italleghe.
10.Data controller and references for the protection of the Personal Data.
In order to exercise the rights under article 7 of the Privacy Code and under articles 15 and subsequent of the GDPR, you can contact the data controller: Italleghe S.r.l., with legal office at 21 Via G. Galilei, 22070 Guanzate (Co), Tel.: +39 031977487, Email: info@italleghe.eu.
The contact person for the protection of the Personal Data is Mrs. Anna Arrighi, e-mail anna.arrighi@italleghe.eu.
Italleghe is not included within the category of the subjects bound to appoint a Data Protection Officer.
INFORMATIVA COOKIES
1. Introduction
In accordance with the provision of the Guarantor for the Protection of Personal Data (hereinafter, the "Guarantor") of 8 May 2014, containing "the identification of simplified procedures for the information and the acquisition of consent for the use of cookies ", As well as in accordance with the provisions introduced by the GDPR, Italleghe wishes to inform you that this Site uses cookies, in order to make its services as efficient and easy to use as possible.
Cookies are text files that are sent to you from our site while you are visiting it and that are saved in the directory of the browser you are using at that time.
2. First party or third party cookies
Cookies differ, first of all, between "first party" cookies (so-called first party cookies) and "third party" cookies (so-called third party cookies), based on the website or domain from which they come.
First-party cookies are essentially the cookies set and / or managed by the owner of the site you are visiting at a given time.
With regard to these cookies, the obligations of drafting this information, acquiring the user's consent and providing for the possibility for the user to block its transmission, are the responsibility of the owner of the site that the user is visiting.
Third-party cookies, on the other hand, are cookies set by a domain other than the one the user is visiting.
With regard to these cookies, the obligations of drafting the information, acquiring the user's consent and providing for the possibility for the user to block its transmission, are the responsibility of the third party, while the owner of the site has only the obligation to insert the link to the third party site, where such elements are available.
3. Purpose of cookies
There are different types of cookies but, essentially, the main purpose of a cookie is to make websites work more effectively and to enable certain features which, generally, aim to improve user navigation.
Among the main functions of cookies, there are those of (i) allowing a more efficient navigation from one page to another of a website, (ii) memorizing the user name and the preferences entered by him, so as to simplify subsequent navigations. of that user on a particular website, (iii) to avoid entering the same information (such as username and password) several times during the visit of a site, (iv) to measure the use of services by users ; this is to optimize the navigability of the site and improve the services themselves, both for statistical purposes and (v) to present advertising information, calibrated on the interests and behavior expressed by the user while browsing.
Pursuant to current legislation, some of the purposes for installing cookies require the user's consent.
4. Categories of cookies
There are various types of cookies. The types of cookies that may be used on the Site are listed below.
a) Technical cookies. these cookies are necessary for the proper functioning of the Site. Without them we would not be able to fully provide the services for which you have accessed the Site. Therefore, technical cookies are always used, regardless of user preferences. Cookies in this category are therefore always sent from our domain. Technical cookies are divided into (i) functionality cookies, which allow the user to browse the Site according to a series of selected criteria in order to improve the service provided through the Site, (ii) navigation cookies or session, which guarantee normal navigation and use of the Site and (iii) "analytics" cookies, used exclusively by the Site manager, to collect information, in aggregate and anonymous form, on the number of users and on how users visit the site.
The Site uses the following technical cookies:
• cookieEuAcc
• ppl_language (wordpress multilingual)
[Note MR: The list is an example. Indicate the technical cookies actually used]
b) Own or third-party analytical cookies. Cookies in this category are used to collect information on the use of the Site. Italleghe, as well as other owners of websites, uses this information to perform statistical analyzes, to improve the Site and simplify its use, as well as to monitor its proper operation. Cookies in this category include both session cookies and interaction measurement cookies. This type of cookie collects anonymous information on user activity on the site, on how the user arrived at the site and on the pages he visited. Cookies in this category are sent from the Site itself or from third-party domains.
Italleghe uses third-party analytical cookies and specifically:
• Google Analytics, a web analytics service provided by Google. The information generated by these cookies on the use of the Site is transmitted to Google, which uses this information to carry out statistical evaluations relating to the use of the Site. Google may transfer this information to third parties only if required by law or in the case of third parties who process the aforementioned information on behalf of Google. Italleghe has decided to make use of the user IP anonymization function provided by Google described at the following link: https://support.google.com/analytics/answer/2763052?hl=it
Therefore, Google does not associate your IP address with any other data that Google possesses and we have not given Google permission to use the information collected through the Google Analytics service for other Google services. Since these are cookies linked to a service provided by third parties, Italleghe advises you to read the Google privacy policies relating to the Google Analytics service to learn more about the processing of your data, including personal data, processed through these cookies. The data generated by Google Analytics are stored by Google as indicated in the information that you can find by connecting to the following internet address https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
In light of the measures adopted, the Site does not require the express authorization of users to use Google Analytics and the related cookies. At the following link https://support.google.com/analytics/answer/181881?hl=it there is however the browser add-on for the deactivation of Google Analytics.
c) Own or third-party tracking and profiling cookies
These cookies allow the Site to monitor the user's browsing also, but not only, for the purpose of sending advertising and / or offering services in line with the preferences expressed by the user while surfing the net. The use of these cookies must be expressly authorized by the user. The Site uses third-party profiling cookies
The Site uses the following third-party profiling cookies:
AddThis, [Note MR: Verify that this is the case. If there are no third-party profiling cookies, delete the entire period] a plugin that website operators install to facilitate the sharing of content between users through social networks. Since these are cookies linked to a service provided by third parties, Italleghe advises you to read the AddThis information relating to its services, to learn more about the processing of your data, including personal data, processed through these cookies, available here: http : //www.addthis.com/privacy/privacy-policy
AddThis cookies can be disabled as indicated here: http://www.addthis.com/privacy/opt-out
The Site uses the following third-party cookies:
• __atuvc (addthis)
• __atuvs (addthis)
• _ga (google analitycs)
• _gat (google analitycs) [Note: the list is an example. Check if they are used. If so, insert the correct list. Otherwise, delete the period]
d) Cookies for the integration of third-party functionality
Cookies of this type are used to integrate third-party functionality on the Site (for example, forms for comments or icons of social networks that allow visitors to share the content of the site). Cookies in this category can be sent from the domains of partner sites or that in any case offer the features present on the site.
(e.g. cookies from Facebook, Youtube, Instagram etc ... ..)
6. Provision of data
With the exception of technical cookies, which are strictly necessary for normal browsing purposes, the provision of data is left to the will of the user who decides to browse the Site after having read the brief information contained in the appropriate banner.
Each user can therefore avoid the installation of cookies by keeping the banner (thus refraining from closing it by clicking on the "ok" button), as well as through the special functions available on their browser.
Many browsers are set up in such a way as to accept cookies in the absence of different instructions from the user. Italleghe therefore invites you to check your browser settings with reference to cookies and to adjust them according to your preferences. However, please note that disabling cookies on the browser may prevent the proper functioning of some areas of the Site that require their use.
Each browser has different procedures for managing settings. The user can obtain specific instructions through the following links.
• Microsoft windows explorer:
http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
• Google chrome:
https://support.google.com/accounts/answer/61416?hl=it
• Mozilla firefox:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Apple safari:
http://www.apple.com/legal/privacy/
• Edge
https://privacy.microsoft.com/it-IT/windows-10-microsoft-edge-and-privacy
•Safari
https://support.apple.com/kb/PH17191?locale=it_IT&viewlocale=it_IT
•Opera
http://www.opera.com/help/tutorials/security/cookies/