Information regarding the privacy policy of the site
1. This section contains information on how advisespa.it manages information related to the processing of data from users of advisespa.it.
2. This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Data Protection Code, and for the purposes of Article 13 of EU Regulation no. 2016/679, concerning the protection of natural persons with regard to the processing of personal data and the free circulation of such data, for persons who interact with advisespa.it and can be reached at the address corresponding to the home page: https://advisespa.it.
3. The information is rendered for advisespa.it only and also for other websites which may be consulted by the user through links contained therein.
4. The purpose of this document is to provide information about the methods, timing and nature of the information that the data controllers must provide to users when connecting to the web pages of advisespa.it, regardless of the purpose of the connection, according to the Italian and European legislation.
5. The information may undergo changes due to the introduction of new rules in this regard, therefore the user is invited to check this page periodically.
6. If the user is under the age of 16, pursuant to article 8, c.1 EU regulation 2016/679, he/she must legitimize his/her consent through the authorization of his/her parents or legal guardians.
Data processing
1 – Data Controller
1. The data controller is the natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data. He also deals with safety profiles.
2. Regarding to this website, the data controller is: Massimo Bagnoli, and for any clarification or exercise of all the rights of the user, he may be contacted at the following e-mail address: massimo.bagnoli@advisespa.it.
2 – Responsible for data processing
The controller is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.
1. Pursuant to Article 28 of EU Regulation no. 2016/679, upon the appointment of the data owner, the data controller of the advisespa.it site is: Massimo Bagnoli, Advise S.p.a.
3 – Data processing location
1. The processing of data generated by the use of advisespa.it takes place at Via Luca Gaurico 91/93 (Rome) and Via Fucecchiello 24E (Fucecchio – Florence).
Cookie
1 – Type of Cookie
1. advisespa.it website uses cookies to make the user’s browsing experience easier and more intuitive: Cookies are small strings of text used to store some information that may concern the user, his preferences or the device he uses for accessing the Internet (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user’s expectations, offering a more personalized browsing experience and memorizing the choices made previously.
2. A cookie consists of a reduced set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. This is not executable code and does not transmit viruses.
3. Cookies do not record any personal information and any identifiable information will not be stored. If you want, you can prevent the saving of some or all cookies. However, in this case the use of the site and the services offered could be compromised. To proceed without changing the options related to cookies, simply continue browsing. Below are the types of cookies that the site uses:
2 – Technical cookies
1. There are many technologies used to store information on the user’s computer, which are then collected by the sites. Among these, the best known and used is HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications on the electronic network or the supplier to provide the service requested by the customer.
2. The settings to manage or deactivate cookies may vary, depending on the internet browser used. In any situation, the user can manage or request the general deactivation or cancellation of cookies, modifying the settings of his internet browser. This deactivation can slow down or prevent access to some parts of the site. 3. The use of technical cookies allows the safe and efficient use of the site.
4. Cookies that are entered in the browser and retransmitted by Google Analytics are used solely for the purpose of optimizing the site directly from the owner of the site or the people in charge, to collect information in aggregate form about the number of users and how they visit the site. The IPs of the visitors are obscured and the data are kept for 50 months from the date of the last visit, so even these cookies can be considered technical and without personal data. 5. From the standpoint of duration, we can distinguish temporary session cookies which are deleted automatically at the end of the browsing session and serve to identify the user, thus avoid logging to every page visited, and the permanent ones that remain active in the PC until expiry or cancellation by the user.
6. Session cookies may be installed in order to allow access to and access to the reserved area of the portal as an authenticated user.
7. They are not stored permanently but only for the duration of the navigation, until the browser is closed, and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the safe and efficient exploration of the site.
3 – Third-party cookies
1. Regarding the provenance, we distinguish the cookies sent to the browser directly from the site you are visiting and those of third parties, sent to the computer from other sites and not from the one you are visiting.
2. Permanent cookies are often third-party cookies.
3. Most third-party cookies consist of tracking cookies used to identify online behavior, understand the interests and then customize the advertising proposals for users.
4. Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties, external to the site.
5. Third-party analytical cookies are used to detect information on user behavior on advisespa.it. The survey takes place anonymously, in order to monitor the performance and improve the usability of the site. The third-party profiling cookies are used to create profiles relating to users, in order to propose advertising messages in line with the choices expressed by the users themselves.
6. The use of these cookies is governed by the rules set by the third parties themselves, therefore, users are invited to read the privacy policies and indications to manage or disable the cookies published on their web pages.
4 – Profiling cookies
Profiling cookies are those used to create profiles related to the user and are used to send advertising messages in line with the preferences expressed by the same while surfing the net.
2. When these types of cookies are used, the user must give explicit consent, using the appropriate consent form displayed on first access to the site.
3. Article 22 of EU Regulation 2016/679 and Article 122 of the Code on data protection will apply.
Data processing
1 – Data processing mode
1. Like all websites, this site also makes use of log files in which information, collected in an automated manner, is kept during user visits. The information collected could be the following:
– internet protocol (IP) address;
– type of browser and device parameters used to connect to the site;
– name of the Internet service provider (ISP);
– date and time of visit;
– web page of origin of the visitor (referral) and exit;
– possibly the number of clicks.
2. The aforementioned information is processed in automated form and collected in aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the holder.
3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as IP address, which could be used, in accordance with applicable laws, in order to block damage attempts to the site itself or to damage other users, or any harmful activities which constitute a crime. Such data are never used for identification or profiling of the user, but only as a protection of the site and its users, and such information will be treated according to the legitimate interests of the owner.
4. If the site allows comments, or in case of specific services requested by the user, including the possibility to send the Curriculum Vitae for a possible working relationship, the site automatically detects and records some identification data of the user, including the email address. These data are voluntarily provided by the user in the moment of requesting service delivery. By inserting a comment or other information, the user explicitly accepts the privacy policy, and in particular agrees that the contents included are freely disseminated to third parties. The data received will be used exclusively for the provision of the requested service and only for the time needed to provide the service.
5. The information that users of the site believe to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violation of laws. It is up to the users to verify that they have permission to enter personal data of third parties or contents protected by national and international standards.
2 – Purposes of data processing
The data collected by the site during its operation are used for the purposes indicated above and for the following purposes:
– User registration
– Comments to articles and pages
– Profiling activities for commercial purposes (only with explicit consent of the interested party)
2. Data retention will be carried out for the period strictly necessary to achieve the aforemen-tioned purpose and in any case not exceeding 5 years.
3. The data used for security purposes (to block attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated end.
3 – Data provided by the user
1. As indicated above, the optional, explicit and voluntary sending of e-mails to the addresses in-dicated on this site entails the subsequent acquisition of the sender’s address, necessary to re-spond to requests, as well as any other personal data included in the message.
2. Specific summary information documents will be progressively reported or displayed on pages of the site prepared for particular services on demand.
4 – Support in the configuration of your browser
1. Users can also manage cookies through the settings of their browser. However, deleting cook-ies from your browser may remove the preferences you have set for the site.
2. For further information and support, you can also visit the specific help page of the web brows-er you are using:
-InternetExplorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-Cookie
-Firefox:https://support.mozilla.org/en-us/kb/enable-and-disable-Cookie-website-preferences
-Safari:http://www.apple.com/legal/privacy/it/
-Chrome:https://support.google.com/accounts/answer/61416?hl=it
-Opera:http://www.opera.com/help/tutorials/security/Cookie/
User rights
Article. 13, c. 2 of EU Regulation 2016/679 lists the user’s rights.
The advisespa.it website therefore intends to inform the user about the existence of:
– the right of the interested party to ask the holder for access to personal data (Article 15 of the EU Regulation), their update (Article 7, co 3, letter a) of Legislative Decree 196/2003), the amendment (Article 16 of the EU Regulation), integration (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003) or the limitation of processing that concerns them (Article 18 EU Regulation) or to oppose, for legitimate reasons, their treatment (Article 21 EU Regulation), in addition to the right to data portability (Article 20 EU Regulation);
– the right to request cancellation (Article 17 of the EU Regulation), the transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data are been collected or subsequently processed (Article 7, paragraph 3, letter b) of Legislative Decree 196/2003);
– the right to obtain the attestation that the operations of updating, rectification, inte-gration of data, cancellation, blocking of data, transformation 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 where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right (Article 7, paragraph 3, letter c) of Legislative Decree no. 196/2003);
The requests may be addressed to the data controller, without formalities or, alternatively, using the model provided by the “Garante per la protezione dei dati personali”, or by sending an email to: massimo.bagnoli@advisespa.it.
If the processing is based on the art. 6, paragraph 1, lett. a) – express consent to use – or on art. 9, paragraph 2, lett. a) – express consent to the use of genetic, biometric, healthrelated data revealing religious beliefs, philosophical or union membership, revealing racial or ethnic origin, political opinions – the user has the right to revoke the consent at any time without prejudicing the lawfulness of the processing based on the consent given prior to the revocation.
Likewise, in the event of violation of the law, the user has the right to lodge a complaint with the “Garante per la protezione dei dati personali”, as the authority responsible for monitoring the processing in the Italian State.
For a more in-depth examination of the rights that compete with it, see articles 15 and ss. of the 2016/67 EU Regulation and the art. 7 of Legislative Decree no. 196/2003.
Transfer of data to extra-ue countries
This site may share some of the data collected with services located outside the European Union area. In particular with Facebook, LinkedIn and through the social plugins and the service of Google Analytics. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
1. Data will not be transferred to third countries that do not comply with the conditions set out in Article 45 and SS of the EU Regulation.
Security of provided data
This site processes the data of users in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of said data. Processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.
1. In addition to the owner, in some cases, access to the data categories may be granted to employees involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (as suppliers of third party technical services, couriers postal services, hosting providers, IT companies, communication agencies).
Changes to this document
This document, published at: https://advisespa.it/privacy-policy/ constitutes the Privacy Policy of this site.
It may be subject to changes or updates. In the situation of significant changes and updates, these will be reported with appropriate notification to users.
Previous versions of the document will still be available on this page.
The document was updated on 11/06/2020 to comply with the relevant regulations, and in particular in accordance with EU Regulation 2016/679.