About the processing of users’ personal data

(Personal data protection code pursuant to art. 13 of Leg. Dec. 196/2003 – EU Regulation 2016/679)

Data Controller

Proedit Srl – registered office in Via Lago Dei Tartari 63, 00012 – Guidonia Montecelio RM

Controller’s email address: info@proedit.it

Introduction

This Notice seeks to inform the user about the way in which his or her personal data are processed. Pursuant to Leg. Dec. 196/2003 (hereinafter the “Privacy Code”) and Regulation (EU) 2016/679 (hereinafter “GDPR”), we intend to ensure the privacy and security of each visitor’s personal data in keeping with the requirements herein. This information refers to art. 13 of the Privacy Code and articles 13 and 14 of the GDPR.

Type of data processed

The website offers informative and sometimes interactive content. While browsing the site, we may acquire information regarding the visitor, in the following ways:

Usage data: Computer systems and software procedures used to operate this website acquire, during normal operations, some personal data whose transmission is implicit in Internet communication protocols. This category of data includes: IP addresses, type of browser used, operating system, domain name and addresses of websites from which access was effected, information on pages visited by users within the site, time of access, time spent on each page, internal path analysis and other parameters relating to the operating system and the user’s computer /IT environment.
Additional data categories All other personal data provided by the visitor through the site, for example, by registering and/or accessing a restricted area and/or a service and/or participating in one of the initiatives alone or in partnership with third parties, requesting information, or making a phone call to contact customer service directly.

Purpose of processing

PURPOSE To provide the goods and/or services requested by the user, manage user contracts, carry out the relative administrative, accounting, fiscal and legal obligations and process requests from users. To evaluate your experience of using our platforms, products and services and ensure web pages and their contents are working properly. To send you commercial communications relating to promotions and/or offers to which you may be entitled, in the interests of the Data Controller or other affiliated companies. To carry out profiling activities, i.e. analysis and processing of information relating to the user, his/her preferences, habits, consumption choices and/or browsing experiences. This activity is also carried out through the use of technologies such as cookies (for further information please refer to paragraph 14, “Cookie Policy”).
LEGAL BASIS The processing of data for the above purposes is needed to fulfill contractual obligations, and does not require specific consent from the data subject. These data are processed further to a legitimate interest of the Data Controller. These data are processed with the specific consent of the user, except for commercial communications relating to goods and/or services similar to those already purchased and/or subscribed to by the user for which processing is based on a legitimate interest of the Data Controller. These data are processed with the specific consent of the user, with the exception of the analysis of basic information relating to the user’s consumption preferences.

Scope of data circulation

For administrative purposes, we inform you that your data may be communicated by the Data Controller to other affiliated companies. With your consent, your data may also be communicated to third party companies with whom we may enter into partnership agreements, in the areas of: social networking and interactive platforms, consumer goods, distribution, finance, insurance, automotive, services, humanitarian and charitable organisations, telecommunications, for commercial and/or promotional purposes.

Transfer of data outside EU

Pursuant to art. 43 of the Privacy Code and art. 44 of the GDPR, our company may transfer your personal data to Third Parties located in countries outside the European Union or the European Economic Area. In such cases, we ensure the adoption of appropriate safeguards (such as the signing of standard contractual clauses approved by the EU Commission) with the foreign company receiving the data; these clauses guarantee a level of data protection on a par with that established by European legislation.

Privacy roles and responsibilities

Your personal data are processed by our company, in its capacity as Data Controller. More detailed information on the names of Data Processors may be requested by email.

Data processing methods

Personal data are processed mainly using electronic procedures and media (DB, CRM platforms, etc.) for the time strictly needed to achieve the purposes for which the data are collected and, in any case, in accordance with the principles of lawfulness, fairness, non-excess and relevance as provided by current privacy legislation.

Redirect to external sites

The website may use external components, such as social plug-ins. Social plug-ins are special tools that make it possible to incorporate social network functions directly in the website (e.g. the Facebook “like” function). All social plug-ins on the website are marked with the respective logo of the social network platform (e.g. Facebook, Google, Twitter, Linkedin). When you visit a page on our website and interact with the plug-in (e.g. by clicking the “Like” button) or decide to leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform and stored there. For information on the purposes, type and methods of collection, processing, use and storage of personal data by the social network platform, as well as on how to exercise your rights, please consult the privacy policy adopted by the individual social network.

Links to/from third-party sites

There are links from this website to other websites, or from third party websites to our website. The Data Controller accepts no liability for requests for and/or the issue of personal data to third party sites and the management of login details provided by third parties.

Data retention

We inform you that the data relating to navigation logs, if recorded, will be kept by the Data Controller for a period of 3 months. We also inform you that the data you provide will be processed for the entire duration of the contractual relationship, and stored only for the period required to fulfill legal obligations, providing it is not necessary to store them for a further period of time to defend or enforce a right or to fulfill any further legal obligations or orders of the authorities.

Rights of data subjects

The subjects to whom the above-mentioned personal data refer (so-called “data subjects”), may exercise their rights in the manner and within the limits provided by current privacy legislation. With regard to the processing of your personal data, you are entitled to ask our company:

access: you may request confirmation as to whether or not data regarding you are being processed, as well as further clarification about the information referred to herein, and to receive such data, within reason;
rectification: you may ask us to correct or supplement the data you have provided us with or we have in our possession, if inaccurate;
deletion: you may ask for your data to be deleted if it is no longer necessary for our purposes or if there are no longer ongoing disputes, if you withdraw your consent or object to processing, in the event of unlawful processing, or if there is a legal obligation to delete data;
limitation: you can ask for the processing of your personal data to be limited, when one of the conditions of art. 18 of the GDPR is met; in this case, your data will not be processed, barring storage, without your consent, except as explained in the same article, under paragraph 2.
opposition: you may object at any time to the processing of your data based on our legitimate interest, unless there are legitimate reasons for processing that override your own, e.g. for exercising or defending our legal rights; your objection will always override our legitimate interest when processing your data for marketing ends;
portability: you may request receipt of your data, or ask to have them transmitted to another data controller indicated by you, in a structured, commonly used and machine-readable format.

Furthermore, pursuant to art. 7, para. 3 of the GDPR, we inform you that you may exercise the right to withdraw your consent at any time, without this affecting the lawfulness of processing based on your prior consent. Finally, we inform you that you are entitled to lodge a complaint before the respective supervisory authority, which in Italy is the Garante per la Protezione dei Dati Personali. To exercise these rights, report problems or request explanations on the processing of one’s personal data, you can send an email to the contacts on this page. We would also like to inform you that it is possible to forward your requests by post, specifying the subject of the request.

Right to be forgotten

We would like to inform you that this privacy policy relates solely to the processing of personal data that you have provided or will provide on our website – possibly by purchasing our products and/or services or taking part in our promotions and/or offers – and to data that we may acquire during the course of this relationship and/or other relations between you and us. Should you wish to assert your right to be forgotten with reference to your personal data, we remind you that the Data Controller may be contacted for the purpose of exercising this right as per art. 17 of the GDPR, by writing an email to the address on this page.

Changes to Privacy policy

The possible entry into force of new industry regulations, as well as constant reviews and updating of user services, may make it necessary to change the terms and conditions described herein. This document may thus undergo changes over time. We invite you, therefore, to consult this page periodically. We will post any changes to this Policy on this page and, if changes are substantial, we will provide you with a more prominent notification. Previous versions of this Policy will, in any case, be archived for consultation.

Cookie Policy

What are Cookies?

Cookies are packets of information sent by a web server (e.g. the site) to the user’s Internet browser, automatically stored on his/her computer and automatically sent back to the server each time the site is accessed. By default, almost all web browsers are set to automatically accept cookies. Typically, cookies can be installed:

directly by the owner and/or manager of the website (so-called first party cookies);
by managers unrelated to the website visited by the user (so-called third-party cookies). Unless otherwise specified, it is noted that these cookies come under the direct and exclusive responsibility of the same manager. Further information on privacy and the use of cookies can be found directly on the websites of the respective managers.

This website may use the following types of cookies, possibly in combination, classified according to the guidelines of the supervisory authority and the Opinions of the Article 29 Working Party:

Session cookies, they are not permanently stored on the user’s computer, and are deleted when the browser is closed, are strictly limited to the transmission of session identifiers needed to browse the site safely and efficiently, avoiding the use of other techniques that may be detrimental to the privacy of users.
Persistent, they remain stored on the computer’s hard drive until they expire or are deleted by users/visitors. Persistent cookies are used to automatically recognise visitors accessing the site (or any other users using the same computer) on each visit. Visitors can set their computer’s browser to accept/reject all cookies or to display a notification whenever a cookie is proposed, so that they can decide whether or not to accept it. The user may in any case modify the default configuration and disable cookies (i.e. block them permanently), setting the highest level of protection.
Technical, these cookies are used to log in, use multimedia content such as flash players or allow the choice of language. For these cookies, therefore, it is not usually necessary to acquire the user’s prior and informed consent. This also includes cookies used to statistically analyse access/visits to the site only if they are used solely for statistical purposes and through the collection of data in aggregate form.
Non-technical, these are all cookies used for profiling and marketing purposes. Their use on users’ terminal equipment is prohibited if the user has not been adequately informed beforehand and has not given valid opt-in consent. These types of cookies are, in turn, grouped according to the functions they perform:
- Analytics. These cookies are used to collect and analyse statistical information about access/visits to the website. In some cases, associated with other information such as login details to access restricted areas (your email address and password), they can be used to profile the user (personal habits, sites visited, contents downloaded, types of interactions, etc.).
- Widgets. This category includes all the graphical components of a programme user interface, seeking to facilitate the user in interacting with the programme itself. Facebook, google+, twitter cookies for instance are widgets.
- Advertsing, this category includes cookies used to advertise within a site. Google, Tradedoubler fall into this category.
- Web beacons, this category includes code snippets that allow a website to transfer or collect information through the request for a graphic image. Websites may use them for a variety of ends, such as analysing website usage, monitoring and reporting advertisements, and customising advertisements and content.

Cookies on the site

Technical cookies that do not require consent

Through our site, we may install on your device and, in particular, in your browser, or allow third parties to install, certain cookies that are necessary for us or our partners to acquire statistical information in anonymous and aggregate form relating to your browsing of site pages. These cookies relate in particular to the following statistical analysis services:

Google Analytics: https://support.google.com/analytics/answer/2763052?hl=it
WebTrekk: https://www.webtrekk.com/en/index/opt-out-webtrekk/
Nielsen NetRatings: http://uk.nielsennetpanel.com/pls/mguk/mgp_main.privacy_Policy
Chartbeat: https://chartbeat.com/privacy/
Addthis: http://www.addthis.com/privacy
Comscore Analytics: http://www.comscore.com/ita/Chi-siamo/Privacy-Policy

Cookies for which consent is required

If, moreover, you give your consent through one of the simplified procedures described in the notification presented when you first access the site or by following the instructions below, our site may install and/or allow third party companies to install additional cookies, so-called profiling cookies, for which you can choose to give or deny consent, in part or in full, through the following links:

Third-party cookies

For the processing of personal data that, with your consent, third party companies known to our site may implement through cookies, click on the links below to give or deny your consent, following the relevant instructions, after reading the various guidelines:

Facebook: through the site, if you give your consent, Facebook may process your personal data to enable a browsing experience enriched with social network features and services https://www.facebook.com/policies/cookies/.
Twitter: through the site if you give your consent, Twitter may process your personal data to enable a browsing experience enriched with social network features and services https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter.
Google+: through the site, if you give your consent, Google may process your personal data to enable a browsing experience enriched with social network features and services https://policies.google.com/privacy?hl=it.
Linkedin: through the site, if you give your consent, Linkedin may process your personal data to allow you a browsing experience enriched with social network features and services https://www.linkedin.com/legal/cookie-policy?trk=%7Berror-page%7D-cookie-policy.
Pinterest: Through the site, if you give your consent, Pinterest may process your personal data to allow you a browsing experience enriched with social network features and services https://help.pinterest.com/en/articles/personalization-and-data.
Banca Sella: We may disclose your personal information to Banca Sella S.p.A and relative Group in order to: prevent, detect, mitigate and ascertain potentially unlawful acts, fraud and/or security breaches and assess and manage risks, e.g. by reporting any fraudulent activity detected on your accounts; provide services to customers, including account assistance or dispute settlement (e.g. regarding billing or transactions); facilitate payment card processing for our applicable Services in which Banca Sella S.p.A is used as payment processor; facilitate shipping and related services for purchases effected through Banca Sella S.p.A; https://www.sella.it/banca-online/privacy/privacy.jsp
PayPal: We may disclose your personal information to PayPal Inc. and the relative Group in order to: prevent, detect, mitigate and ascertain potentially unlawful acts, fraud and/or security breaches and assess and manage risk, e.g. by reporting any fraudulent activity detected on your accounts; provide services to customers, including account or dispute settlement assistance (e.g. regarding billing or transactions); facilitate payment card processing for our applicable Services where PayPal is used as payments processor; facilitate shipping and related services for purchases effected through PayPal; https://www.paypal.com/it/webapps/mpp/ua/privacy-full
Google Analytics: Our site has enabled Google Analytics advertising functions; the functions implemented are: Google Analytics demographic and interest data reports. Enabling these advertising features enables Google Analytics to collect traffic data via Google advertising cookies and anonymous identifiers, in addition to data collected via standard Google Analytics implementation. Our site may collect and use data from Google’s interest-based advertising or third-party audience data (e.g. age, gender, and interests) from Google Analytics and Google Analytics functions based on display advertising (e.g. remarketing, demographic and interest data reports from Google Analytics) for statistical and audience analysis purposes only. Data are collected and aggregated anonymously using proprietary or third-party software (e.g. Google Analytics). Our site, and third-party vendors, including Google, use both proprietary cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) to inform, optimise and serve ads based on users’ previous visits to our site. Google Analytics for display advertising can be disabled and Google Display Network ads can be customised as follows:
- Using Ad Settings: https://www.google.it/settings/ads
- Through currently available components for disabling Google Analytics for the Web: https://tools.google.com/dlpage/gaoptout/

I give my consent for your website to install profiling cookies and to carry out – for itself and/or for other affiliated companies – processing instrumental to the marketing activities described in this privacy policy / I do not give my consent for your website to install profiling cookies or to carry out – for itself and/or for other affiliated companies – processing instrumental to the marketing activities described in this privacy policy For the processing of personal data that, with your consent, third party companies not known to our site may implement through cookies, you may customise your choices by connecting to this link and using the relevant service: http: //www.youronlinechoices.com/it/le-tue-scelte

How to disable cookies via browser configuration

If you wish, you may manage cookies directly through your browser settings. Deleting cookies from your browser may however remove the preferences you set for our site, so you should periodically visit this page to check your preferences. For further information and help you can also visit the specific help page of the web browser you are using: