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COMPLETE COOKIE AND PRIVACY POLICY
 


Data Controller
The Data Controllers in accordance with applicable laws are the website administrators, Roberto Saba and Giorgia Giani, who can be contacted via the CONTACTS section.
 

Legal Basis for Processing
We process data mainly based on user consent. Consent is given via the banner located at the bottom of the page, or through specially provided communication or service request forms, through which consent is collected for the specific purpose of the service. Providing data and therefore consenting to the collection and processing of data is optional; the User may withhold consent, and may revoke previously given consent at any time (via the banner at the bottom of the page, browser settings for cookies, or the Contacts link). However, withholding consent may result in the inability to provide certain services and the website browsing experience may be reduced. Data for site security and the prevention of abuse and SPAM, as well as data for site traffic analysis (statistics) in aggregate form, are processed based on the Data Controller's legitimate interest in protecting the site and the users themselves. In such cases, the user always has the right to object to data processing (see section User Rights). Data provided for consultations or professional assignments are processed based on the performance of a contract and compliance with a legal obligation. In such cases, a specific privacy notice is provided.
 

Purposes of Processing
The processing of data collected by the site, in addition to purposes connected, instrumental, and necessary to provide the service, is aimed at the following purposes:

  • Statistics (analysis)
    Collection of data and information in strictly aggregate and anonymous form to verify the correct functioning of the site. None of this information is linked to the physical person-User of the site, and does not allow their identification in any way. Consent is not required.

  • Security
    Collection of data and information to protect the security of the site (antispam filters, firewalls, virus detection) and Users, and to prevent or uncover fraud or abuse against the website. Data are automatically recorded and may possibly include personal data (IP address) that could be used, in accordance with applicable laws, to block attempts to damage the site itself or cause harm to other users, or otherwise harmful or criminal activities. Such data are never used for User identification or profiling and are periodically deleted. Consent is not required.

  • Ancillary Activities
    Communicating data to third parties who perform functions necessary or instrumental to the operation of the service, and allowing third parties to perform technical, logistical, and other activities on our behalf. Suppliers only have access to personal data necessary to perform their tasks, agree not to use the data for other purposes, and are required to process personal data in compliance with current regulations.

  • Consultations and Professional Assignments
    In case of spontaneous submission of data to request professional advice or a professional assignment, the data will be used solely for the purpose of evaluating the assignment and for its potential execution. In such cases, a specific privacy notice will be provided.

 

Data Collected
We collect user data in two ways.

  • Data Collected Automatically
    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 referral and exit web pages;

    • possibly the number of clicks. These data are used for statistics and analysis purposes, exclusively in aggregate form. The IP address is used exclusively for security purposes and is not cross-referenced with any other data.

  • Voluntarily Provided Data
    The site may collect other data in case of voluntary use of services by users, such as comment services, communication services (contact forms, consultation requests), and will be used exclusively to provide the requested service:

    • name;

    • email address;

    • any additional data spontaneously sent by the user.


Place of Processing
Data are processed at the Data Controller's headquarters, and at the web Hosting datacenter. The web host (VHosting Solution), acts as data processor processing data on behalf of the controller, is located in the European Economic Area, and acts in compliance with European standards (VHosting privacy policy).
 

Data Retention
Period Data collected during site operation are retained for the time strictly necessary to carry out the specified activities. Upon expiration, data will be deleted or anonymized, unless further retention purposes exist. Data (IP address) used for site security purposes (blocking attempts to damage the site) are retained for 30 days. Data for analytics (statistics) purposes are retained only in aggregate form. Data collected for consultation requests or professional assignments are retained for the time necessary to execute the assignment and for ancillary purposes (legal protection, etc.).

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Data Transfer to Third Parties
Data recorded by the site are generally not provided to third parties, except in specific cases:

  • legitimate request by the judicial authority and solely in cases provided by law;

  • when necessary for the provision of a specific service requested by the User;

  • for conducting security checks or site optimization.
     

Data Transfer to Non-EU Countries
We may need to share some of the collected data with services located outside the European Union area. In particular with Google, Facebook, and Microsoft (LinkedIn) through social plugins and the Google Analytics service. Transfer is authorized based on specific decisions of the European Commission, or based on Standard Contractual Clauses of individual services (see sections regarding third-party services).
 

Security Measures
We process visitor/user data lawfully and fairly, adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification, or unauthorized destruction of data. We are committed to protecting the security of your personal data during transmission, using Secure Sockets Layer (SSL) software, which encrypts information in transit. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Controller, in some cases, categories of authorized persons involved in the organization of the site or external entities (such as third-party technical service providers, hosting providers) may have access to the data.

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Cookies
We use cookies, text files recorded on the user's terminal or allowing access to information on the user's terminal. Cookies allow storing information on visitor preferences, are used to verify the correct functioning of the site, and to improve its functionality by customizing page content based on browser type, or to simplify navigation by automating procedures (e.g., Login, site language), and finally for analyzing site usage by visitors. We use the following categories of cookies:

  • technical cookies, used solely to carry out the transmission of an electronic communication, to ensure correct display of the site and navigation within it. Additionally, they distinguish between connected users to provide a requested service to the right user (Login), and for site security reasons. Some of these cookies are deleted when closing the browser (session cookies), others have a longer duration (such as the cookie required to store user consent regarding cookie usage, which lasts 1 year). Consent is not required for these cookies;

  • analytics cookies, used directly by the site operator to collect aggregate information on the number of users and how they visit the site. They are assimilated to technical cookies as the service is based on aggregate data.

  • profiling and marketing cookies, used exclusively by third parties other than the controller of this site to collect information on user browsing behavior, interests, and consumption habits, including to provide personalized advertising. As far as possible, these cookies are blocked and activated only following a user choice.
     

By clicking "I Agree" on the banner present upon first accessing the site, the visitor expressly consents to the use of cookies and similar technologies, and in particular to the recording of such cookies on their terminal for the purposes indicated in this document, or to access information on their terminal via cookies.
 

Disabling Cookies via Browser
The user can refuse the use of cookies and can revoke previously given consent at any time. Since cookies are linked to the browser used, they can be disabled directly from the browser, thus refusing/revoking consent to cookie use, or via the banner located at the bottom of the page (Cookie Settings).
Disabling cookies may prevent proper use of some site functions; in particular, services provided by third parties may not be accessible and therefore not viewable. For example:

  • YouTube videos or other video sharing services;

  • social media buttons for social networks.

Instructions for disabling cookies can be found on the following web pages: Mozilla Firefox - Microsoft Internet Explorer - Microsoft Edge - Google Chrome - Opera - Apple Safari
 

Third-Party Cookies/Services
The site also acts as an intermediary for third-party cookies (such as social network buttons), used to provide additional services and features to visitors and simplify site usage. These services are also used by third parties to collect data on user interests to provide personalized advertising on partner sites. Not on this site, which features no advertising of any kind. This site has no control over their cookies, which are fully managed by third parties, and has no access to information collected through these cookies. Information on the use of these cookies and their purposes, as well as methods for potential disabling, is provided directly by third parties on the pages indicated below. Please note that user tracking generally does not involve user identification, unless the User is already registered for the service and logged in, in which case the User is understood to have already given consent directly to the third party upon registering for that service (e.g., Facebook). The site uses cookies/services from the following third parties.

  • Google Ireland ltd
    For information on data use and processing by Google Ireland ltd, please review Google's privacy policy, Google's How Google uses data when you use our partners' sites or apps, and Google Ads Data Processing Terms.

  • Youtube:
    a video-sharing platform owned by Google. Cookies are set upon accessing the page containing the embed, and upon launching the video, and do not allow User identification unless already logged into a Google profile. For videos on the site, the "enhanced privacy (no cookies)" option has been activated, ensuring YouTube does not store visitor information unless they voluntarily play the video. Data collected: number and behavior of service users, IP address, information linking site visits to the Google account for logged-in users, video display preferences. Place of processing: USA. Users may grant consent for the use of Youtube cookies for each individual video.

  • Matomo Analytics:
    ​service to analyze website usage by users. It features the following:

    • Data are stored in the EU;

    • Data are anonymized (including IPs);

    • Uses first-party cookies only;

    • Data are aggregated and not shared even with the service provider.

Consent is not required to use the service. EU Representative: ePrivacy Holding GmbH Große Bleichen 21 20354 Hamburg Germany Privacy Policy: https://matomo.org/privacy-policy/
 

Social Network Plugins
The site also incorporates plugins and/or buttons to enable easy sharing of content on your favorite social networks. When you visit a page on our website containing a plugin, your browser connects directly to the servers of the social network where the plugin is loaded. That server can track your visit to our website and, if applicable, associate it with your social account, particularly if you are logged in at the time of the visit or have recently browsed a website containing social plugins. If you do not want the social network to record data regarding your visit to our website, you must log out of your social account and likely delete the cookies that the social network has installed in your browser. Plugins with enhanced User privacy protection features are installed on this site; they do not send cookies or access cookies on the User's browser when opening the page, but only after the User clicks the plugin. Collection and use of information by such third parties are governed by their respective privacy policies, which you are advised to consult:

  • Facebook (link to cookie policy)

  • Twitter (link to cookie policy)

  • LinkedIn (link to cookie policy)
     

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

  • object in whole or in part, for legitimate reasons, to the processing of personal data concerning them for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication;

  • request confirmation of the existence of personal data concerning them (right of access);

  • know its origin;

  • receive intelligible communication thereof;

  • have information about the logic, methods, and purposes of processing;

  • request updating, rectification, integration, erasure, transformation into anonymous form, or blocking of data processed in violation of the law, including data no longer necessary for the purposes for which they were collected;

  • in cases of consent-based processing, receive, solely at the cost of any support, their data provided to the controller, in a structured and machine-readable format commonly used by an electronic device;

  • the right to lodge a complaint with the Supervisory Authority (Garante Privacy – link to the Garante page);

  • as well as, more generally, exercise all rights recognized by current legal provisions. Requests should be addressed to the Data Controller.
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Updates to the Privacy Policy

This privacy policy was updated on July 4, 2022.

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