(hereinafter referred to as the “site”).
- What personal data do we collect?
When you browse our site, we may collect the following categories of personal data about you:
- identification data (e.g., surname, first name, email address, username, password, Region, type of device).
- technical data (e.g., IP address, type of browser used, etc.); and
- any personal data contained in any correspondence you send to us.
Provision of your personal data is voluntary, but we will be unable to provide you with the information you request without it. For example, if you contact us through the site, you will need to provide us with your email address so that we can respond to you.
In any case, we will inform you when it is mandatory to provide your personal data.
Additionally, if you provide us with personal data belonging to third parties, you undertake to ensure that such persons have been duly informed of the processing of their personal data in accordance with this policy and, if required, have consented to the processing of their personal data.
2. What personal data do we collect?
The table below outlines the purposes that we process your personal data for and, for each purpose, the legal basis for the processing operation in question:
|Responding to requests and questions you may submit through the site, and more broadly, managing our relationship with visitors to the site.||The processing is carried out to provide you with the information you requested us.|
|Improving our services and our site.||The processing is carried out pursuant to our legitimate interest, which involves optimizing our tools and solutions to best accommodate our site visitors, clients, and prospects.|
|Complying with legal and regulatory obligations applicable to us.||The processing is necessary to comply with the legal obligations that we are subject to.|
|Managing any potential or actual disputes with you or third parties.||The processing is carried out pursuant to our legitimate interest, which involves defending our interests, including through legal action.|
In any case, please note that we will not process your personal data for any other purpose that is incompatible with the above-mentioned purposes.
3. Who do we share your personal data with?
In the context of our processing operations, we may communicate your personal data to the following recipients:
to administrative staff or to our service providers, suppliers, agents, and contractors, (e.g.,in order to manage the website).
Regardless of the recipient, we will only disclose your personal data to them on a strictly need-to-know basis and only to the extent required to fulfill the purposes identified in this policy.
4. Do we transfer data outside the european economic area?
Should your personal data be transferred outside the European Economic Area (“EEA”), we ensure that the level of protection your personal data is given is not adversely affected by such transfers.
This specifically means that each of the intended transfers is based on one of the following mechanisms at least:
- the existence of an adequacy decision issued by the European Commission for the country that your personal data is transferred to; or, alternatively;
- the conclusion of standard contractual clauses reproducing the models adopted by the European Commission; or, alternatively;
- the existence of an exemption related to one of the specific situations exhaustively provided for by the General Data Protection Regulation 2016/679 (“GDPR”) (e.g. where you have given your consent to such transfer having been informed of the absence of safeguards, where the transfer is necessary for the performance of a contract concluded between you and us, where the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and a third party, or where the transfer is necessary for the establishment, exercise or defense of our legal claims, etc.).
5. How long do we store your personal data for?
We store your personal data for no longer than is necessary for the purpose of the processing concerned.
In other words, this means that the storage periods we apply vary depending on the purpose for which we process the data in question. The table below therefore indicates, for each purpose, the storage period that will be applied to your personal data:
|Responding to requests and questions you may submit through the site, and more broadly, managing our relationship with visitors to the site.||We will store your personal data for a maximum of 1 year from our last contact with you.|
|Improving our services and our site.||We will store your data for a maximum of one year, although in most cases your data will be aggregated shortly after collection into non-identifiable statistics.|
|Complying with legal and regulatory obligations applicable to us.||We store your personal data for as long as we are subject to the relevant legal or regulatory obligations.|
|Managing any potential or actual disputes with you or third parties.||Your personal data will be stored until all potential remedies have been exhausted.|
In any case, once the applicable storage period has elapsed, we will irrevocably erase or anonymize your personal data so that you can no longer be identified.
7. What rights do you have?
In accordance with the applicable data protection legal framework, particularly the GDPR, you have the following rights as a data subject:
- You may request access to your personal data and request that it be rectified or erased.
- You also have the right to request that processing of your personal data be restricted or to object to the same.
- You have the right to portability of your personal data.
- Where processing of your personal data is based on your consent, please note that you may withdraw your consent at any time, without affecting the lawfulness of processing based on your consent carried out prior to your withdrawal of the same.
However, please note that some of the above rights are subject to specific conditions dictated by the applicable data protection legal framework. So, if your specific situation does not meet these conditions, we will unfortunately be unable to comply with your request.
To exercise your rights, please contact email@example.com
In any case, please note that you may lodge a complaint with the relevant data protection supervisory authority
8. How can you contact us?
This document has been prepared pursuant to EU Regulation 2016/679 (the “GDPR“) to enable users to understand what cookies are installed when they use the website (the “Website“).
- Data controller
Walter Lucherini, who can be contacted as indicated in the section “Contact me” is the data controller of the personal data (the “Data“) of the users of the Website collected using cookies.
- Data processed
- technical cookies, which allow to carry out activities related to the operation of the Site.
- profiling cookies, used to analyse user behaviour and, if necessary, to send advertising messages in line with the preferences expressed by the user during navigation.
This Website uses the following cookies:
|Cookies||Duration||Description||Host||Type (prima/terza parte)|
|Spotify||session||This cookie is set by the Spotify audio service on pages with embedded Spotify audio||spotify.com||3rd|
|YSC||session||This cookie is set by the YouTube video service on pages with embedded YouTube video||.youtube.com||3rd|
While technical cookies cannot be refused by the user of the Website, as they are strictly functional to the Website itself, the user can freely choose to accept or refuse the use of profiling cookies. The user can set and review their choices regarding cookies here.
- Purposes and legal basis of the processing
By using cookies, the following purposes are pursued:
3.1 to enable the navigation of the Website and its smooth functionality. The legal basis for the processing is the provision to users of services related to the Website and the legitimate interest of to have a functional website.
3.2 to fulfil any obligations under applicable laws, regulations, or EU legislation, or to comply with requests from the authorities. The legal basis for the processing is the obligation to comply with mandatory legislation.
3.3 analyse user behaviour and possibly send him advertising messages in line with the preferences expressed by the same during navigation. The legal basis for processing in this case is the consent of the interested party.
3.4 for the needs of defence of the rights of in the context of any litigation, even in court. The legal basis of the processing is the legitimate interest of the Owner to protect its rights.
The conferment of Data is optional, but (except in cases of processing based on consent) the failure to provide Data prevents the Controller from allowing the navigation of the Website.
- Recipients of the Data
The Data may be communicated:
(a) to third parties who need to perform specific activities in relation to the Data, in accordance with the purposes of the processing, or to service providers to the Data Controller.
(b) to authorities, entities and/or parties to whom the Data must be disclosed, pursuant to binding legal or contractual provisions.
- Transfer of Data outside the European Economic Area
As for the possible transfer of Data to countries not belonging to the European Economic Area, the processing will take place according to one of the legally permitted methods and therefore through the selection of recipients established in countries considered adequate by the European Commission or through the stipulation of standard contractual clauses.
- Data retention
The Data will be kept only for the time necessary for the purposes for which they were collected, respecting the principles of conservation limitation and minimization. More precisely, the terms of duration of the cookies are defined in the previous section 2. For the Data whose processing is based on the consent of the interested party, it is specified that the same will be kept until such consent is revoked.
- Data subjects’ rights
In the presence of the relevant legal prerequisites, the data subject may ask the Data Controller for access to their Data, to rectify or erase them or to object to their processing, to request the restriction of processing in the cases provided for by Article 18 GDPR, as well as to obtain in a structured, commonly used, and machine-readable format the data concerning him/her, in the cases provided for by Article 20 GDPR.
In addition, the user has the right to revoke any consent to processing at any time, without affecting the lawfulness of the processing carried out by the Controller before the revocation.
Requests should be made in writing to the Data Controller at the addresses firstname.lastname@example.org
In any case, the interested party may lodge a complaint with the Authority for the Protection of Personal Data if he believes that the processing of his Data is contrary to the regulations in force.