Information on the processing of your personal data
Pursuant to the general personal data protection regulation 2016/679 of 27 April 2016 (“GDPR”), we hereby provide you ex art. 13 with the following information on the processing of your data that our Company is required to collect, record, update, store and use for the purposes described herein.
- Processed data and processing purposes We do not process any of your data that may be qualified as sensitive/special or legal. We process data needed to establish and carry out current and/or future contractual relationships with your company, such as personal, tax, economic and commercial data. The processing serves to fulfil contractual obligations and the consequent legal and tax obligations deriving from the establishment of the contractual relationship, including the fulfilment of obligations towards the financial administration and relations with credit institutions for the payment of fees due to you.
- Processing methods The processing is carried out only by the data controller and/or persons authorised by him. The data are processed in a lawful manner, according to correctness and with utmost confidentiality, using mainly electronic and computer tools, and stored both on computer media and hard copy and on any other suitable media, in compliance with the provisions of the Law and always with respect for the purposes described above. The processing is carried out by means of the operations or set of operations stated in Privacy Code Art. 4 para. 1, letter a) as well as GDPR Art. 4 no 2, and more precisely: collecting, recording, organising, storing, consulting, processing, changing, selecting, extracting, comparing, using, interconnecting, blocking, sharing, disclosing, deleting and destroying data, including when not recorded in a database.
- Nature of providing data – Refusal to provide data Personal data is provided on an optional basis and is strictly necessary for carrying out the activities referred to in point 1. However, please note that any interested party refusal to provide personal data implies the impossibility of fulfilling the activities referred to in point 1.
- Scope of data sharing and dissemination. Your data are not subject to dissemination. However, your data subject to processing may be shared with: external collaborators, (tax) consultants, accountants and, in general, all parties needed for the correct fulfilment of the purposes indicated in point 2 (e.g. group companies, Financial Administration, insurance companies, professionals, banks). The Data Controller, Manager and Processors will process the data only if necessary to carry out the tasks assigned to them.
- Duration of processing The data will be processed for the duration of the contractual relationship and in any case within a 10-year deadline. After the deadline, an internal procedure will provide for the destruction of paper documents and deletion of information from the IT systems. If consent is revoked, the data will be deleted within 15 days from the request, without prejudice to specific legal obligations on keeping accounting and administrative documentation.
- Your rights As provided in GDPR Arts. 15, 16, 17, 18, 19, 20 and 21, your personal information rights, which may be applied according to circumstances, are the following:
- Right of access: the right to obtain access to the data (if the organization is processing them) and some other information (similar to that provided herein).
- Right of rectification: the right to have information changed if it is inaccurate or incomplete.
- Right of cancellation: in simple terms, it means requesting the deletion or removal of information concerning you when there is no valid reason for an organization to continue using it. This right is also known as “the right to be forgotten” and is not a general cancellation obligation; there are exceptions such as, for example, if we must comply with a legal obligation or keep the data for legal defence purposes.
- Right to limitation: the right to “block” or suppress further use of information that concerns you in certain circumstances. For example, you may wish to limit the purposes for which we may process your data. With limited processing, the affected organization can still store information, but cannot use it further for any of the initial purposes, only limited ones.
- Right to data portability: the right to obtain and reuse personal data in a structured format, commonly used with and readable by a computer in certain circumstances.
- Right to object: the right to object to certain types of processing, under certain circumstances.
To exercise your rights, you may send a message to the contact details, together with a copy of a valid identity document. If you are not satisfied with the response or believe that your information is not being processed in compliance with the data protection law, you can file a complaint with the competent supervisory authority. You can find a list of supervisory authorities at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
- Automated decision-making processes The Data Controller does not carry out any automated decision-making processing.
- Transferring data abroad Personal data can be transferred to EU countries for the purposes mentioned in point 1. Furthermore, in compliance with the provisions of GDPR Art. 44 and following, if cloud platforms are used to store and/or transfer data, these could be transferred to non-EU countries, especially for server support. Only services that comply with current legislation requirements (such as the Privacy Shield certification of the bilateral EU-USA agreement) will be used in this case.
- Data controller The data controller is Libera ADV firstname.lastname@example.org
INFORMATION ON COOKIES
What are cookies
Cookies are information saved on the hard disk of the user’s terminal and that are sent from the user’s browser to a web server and refer to the use of the network. As a consequence, they allow to know the services, the sites frequented and the options that, while surfing the net, have been manifested. In other words, cookies are small files, containing letters and numbers, that are downloaded to your computer or mobile device when you visit a website. Cookies are then sent back to the original site at each subsequent visit, or to a other website that recognizes these cookies. Cookies are useful because they allow a website to recognize the user’s device.
This information is not, therefore, provided spontaneously and directly, but leaves a trace of the user browsing the net.
Cookies perform different functions and allow you to browse the pages efficiently, remembering user preferences and, more generally, improving your experience. They can also help to ensure that the advertisements shown during browsing are of interest to them and that the marketing activities carried out comply with their preferences, avoiding promotional initiatives that are unwelcome or not in line with the user’s needs.
While browsing on a site, the user can also receive cookies on their terminal that are sent from different websites or web servers (so-called “third parties”), on which some elements may exist (eg: images, maps, sounds, specific links to pages of other domains) on the site that the same is visiting. Therefore, there can be in this respect:
- Direct cookies, sent directly from a site to the user’s device. This site does not use direct profiling cookies, but only technical cookies (see below).
- Third-party cookies, coming from a third party but sent on our behalf. This site uses third-party cookies to facilitate the analysis of our website and its use (as described below).
1. Technical cookies: they are used to allow the transmission of a communication on an electronic communication network or to provide a service expressly requested by the user. They are not used for other purposes. In the category of technical cookies, the use of which does not require the user’s consent, are distinguished:
- Browsing or session cookies: guarantee the normal navigation and use of the website (for example: to authenticate and access reserved areas). The use of these cookies (which are not stored permanently on the user’s device and are automatically deleted when the browser is closed) 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.
- Analytics cookies: if they are used only to collect information in aggregate form, the number of users who visit the site and how they visit it
- Functionality cookies: allow the user to navigate on the basis of a series of selected criteria (eg: language or services to which he has adhered) to improve the service rendered to the user.
2. Profiling cookies: they are aimed at creating profiles related to the user and used to send targeted promotional messages according to the preferences shown when surfing the net. These cookies are usable for such purposes only with the consent of the user.
How cookies are used by this site
- know the total number of visitors on a continuous basis in addition to browser types (eg Firefox, Safari or Internet Explorer) and operating systems (eg Windows or Macintosh) used;
- monitor site performance, including how visitors use it, and improve its functionality.
What categories of cookies we use and how they can be managed by the user
The types of cookies used can be classified into one of the categories, shown below in the table below:
|Type of cookies||Purpose of the cookie||Origin and how to block it|
|Essential website cookies (session and navigation)||These cookies are essential for correct navigation and to use the functions of the site. These cookies do not collect personal information usable for marketing purposes, nor do they store visited sites. The use of these cookies (which are not stored permanently on the user’s device and are automatically deleted when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary for allow safe and efficient exploration of the site. This category of cookies can not be deactivated.||(direct cookies)|
|Direct functionality cookies||These cookies allow us to remember the choices made (such as user name, language or geographical location) and provide improved and personalized features. The information collected by these cookies can be made anonymous and do not keep track of the browsing activity on other websites. This category of cookies can not be deactivated.||(direct cookies)
|Analytics cookies and third-party advertising||These cookies, also cache cookies, are set by Google Analytics and are used to gather information on how visitors use the site, including the number of visitors, the sites of origin and the pages visited on our website. . We use this information to compile reports and to improve our website; this allows us, for example, to know any errors detected by users and to ensure them an immediate navigation, to easily find what they are looking for. In general, these cookies remain on the visitor’s computer until they are deleted.
How to check or delete cookies
You can block cookies by following the instructions provided by the browser (usually found in the “Help”, “Tools or” Edit “menus). The deactivation of a cookie or a category of cookies does not remove them from the browser. Therefore, this operation must be done directly in the browser.
If you want to delete, disable or restore cookies on your computer, you can use the configuration pages cookies made available by any third-party content providers, or through the options of the user’s browser.
Below is a list of instructions to manage cookies in relation to the most popular browsers:
- Chrome – https://support.google.com/chrome/answer/95647?hl=en&topic=14666&ctx=topic
- Firefox – https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Internet Explorer – http://windows.microsoft.com/en-US/internet-explorer/delete-manage-cookies#ie=ie-11
- Safari – https://support.apple.com/kb/PH17191?viewlocale=en_US&locale=en_GB
If you use a mobile device, refer to its instruction manual to find out how to handle cookies.
For more information on cookies, also on how to view those that have been set on the device, on how to manage and delete them, visit www.allaboutcookies.org.
Cookies set previously
If the user has disabled one or more cookies, we will still be able to use the information collected before this disabling by means of preferences. However, from that moment on, we will cease to use disabled cookies to collect further information.