In compliance with the obligations deriving from national legislation (Legislative Decree 30 June 2003 n. 196, Code regarding the protection of personal data, as updated by Legislative Decree 101/2018) and community legislation (European Regulation 2016/679, GDPR) and subsequent amendments, this site respects and protects the privacy of visitors and users, making every possible and proportionate effort not to harm user rights.

This privacy policy applies exclusively to the online activities of this site and is valid for visitors/users of the site.

The purpose of the privacy policy is to provide maximum transparency regarding the information the site collects and how it uses it.

DATA COLLECTED

This site collects and processes Personal Data, as defined by the GDPR, independently or through third parties, or voluntarily provided by the user, including:

• Internet protocol (IP) address; Browser type and parameters of the device used to connect to the site; Name of the internet service provider (ISP); Date and time of the visit; Web page of origin of the visitor (referral) and exit; Possibly the number of clicks. Cookies and Usage Data, collected through automatic processes;

The aforementioned information is processed in an automated form and collected in an exclusively aggregate and pseudonymized form in order to verify the correct functioning of the site and for security reasons; such information will be processed based on the legitimate interests of the owner.

For security purposes (anti-spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with the laws in force on the matter, in order to block attempts to damage the site itself or to cause damage to other users, or in any case harmful activities or activities constituting a crime. Such data are never used for the identification or profiling of the user, but only for the purposes of protecting the site and its users; such information is processed based on the legitimate interests of the owner.

• Personal data, personal data (section “contacts”) – the latter voluntarily released by the user and not decisive on the functioning of the site.

Any use of Cookies – or other tracking tools – by this Site or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, to which reference should be made.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

TREATMENT METHODS

The Data Controller shall take appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other internal stakeholders may have access to the Data, or external parties (such as third-party technical service providers, hosting providers, IT companies, communication agencies) appointed as Data Processors by the Data Controller.

PLACE OF PROCESSING

The data collected by the site are processed by the Data Controller and are handled only by technical personnel authorized to process or appointed as external Data Processor pursuant to art. 28 Reg. EU 2016/679. The server hosting the site is located in Italy.

This site may share some of the data collected with services located outside the European Union area, always respecting the rights and guarantees provided for by current legislation, pursuant to articles 44 et seq. of the Reg. EU 2016/679.

STORAGE PERIOD

The Data is processed and stored for the time required by the purposes for which it was collected.
The Personal Data collected for purposes related to the execution of the service requested by the User will be retained until the execution of this service is completed. With regard to any Personal Data collected for purposes based on the User’s consent, the Owner may retain the Personal Data for longer until said consent is revoked.

Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period the Personal Data will be deleted. Therefore, upon expiry of this deadline, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

PURPOSE OF THE PROCESSING OF COLLECTED DATA

The User Data is collected for the purposes set out below:

• monitor infrastructure;

• contact the User in case of contact requests from them;

SECURITY MEASURES

This site processes user data in a lawful and correct manner, adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification or unauthorized destruction of data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the owner, in some cases, categories of persons involved in the organization of the site or external parties (such as third-party technical service providers, hosting providers, IT companies, communication agencies) may have access to the data.

USER RIGHTS

With regard to the personal data themselves, the data subject may exercise the rights provided for in Articles 15 et seq. GDPR, namely:

Right of access (art. 15) – consists in obtaining confirmation from the Data Controller as to whether or not personal data concerning him or her are being processed and in this case, obtaining access to the same data and certain information (explicit in the article cited) regarding the data in question. Right of rectification Blind. 16) – It consists of giving the interested party the opportunity to modify their data if they are inaccurate. Right of cancellation Blind. 17) – Possibility for the interested party to delete their data in the possession of the owner when, for example, consent to processing is revoked or the purpose pursued is achieved or when it is unlawful. Obviously, it will not always be possible to fulfill the cancellation request. This happens for example when the data is used to fulfill a legal obligation or is necessary for the defense of a right in court. Opposition Law Blind. 21) – The possibility to object to processing, must be guaranteed when the legal basis is the legitimate interest or the execution of a task of public interest. This right also has its limits as there may be cases in which the legitimate interest of the owner prevails over that of the interested party, it will be essential to carry out the right balance, or the processing is necessary for a task of public interest or the assessment, defense or exercise of a right before a judge. Right to portability(art. 20) – provides that, if processing is based on contract or consent, in the event of a request, the interested party is provided with his personal data in a structured format readable by an automatic device (json, xml, csv), this right applies only to data provided spontaneously and not to inferred or derived data.

Right of revocation Blind. 7) – In case of signing any form of consent to the processing requested by the Data Controller, please note that the interested party can revoke it at any time, without prejudice to the mandatory obligations established by the legislation in force at the time of the revocation request, by contacting the Data Controller of the processing at the contact details shown, at the address above, or by email, specifying the subject of your request, the right he intends to exercise and attaching a photocopy of an identity document certifying the legitimacy of the request.

The data subject shall have the right to lodge a complaint with the competent Supervisory Authority in the Member State in which he is habitually resident or working or in the State in which the alleged infringement occurred.

All the aforementioned rights may be exercised by sending a specific request to the Data Controller via the contact channels indicated in this information.

Data controller

The Data Controller is Polo SRL with registered office in Via Generale Dalla Chiesa, 74/76 – 20037 Paderno-Dugnano (MI) which you can contact by writing to the following email address: amministrazione@polosrl.it or by calling 02.991996522.