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Privacy Policy

Information on the processing of personal data pursuant to Articles 13 and 14 of EU Regulation No. 2016/679 concerning the website http:// www. comedincanto.eu/

In accordance with current legislation on the protection of personal data, Monica Riboni – P.IVA 09345661210, Tel. +39 351 034 9196, wishes to provide users of the website http:// www. comedincanto.eu/ the information regarding the processing of personal data, in the capacity of Data Controller o (from now on, also “Owner”) and the site.

This information is provided only for the website http:// www. comedincanto.eu/ (from now on, “site”), and not for other web spaces accessible through links on the site, which have their own policies for the protection of personal data that the user can consult by accessing their respective websites.

The site also allows you to interact with the platforms Facebook, Twitter, Google +, LinkedIn, Flickr, Vimeo, and Google Map, each of which, in case of use through the site, may collect and process user data according to their respective privacy policies also from places outside the European Union. Therefore, before interacting with these web platforms, the user is encouraged to consult the data processing information on each of them and only then decide whether or not to use them through the site.

The services offered through the site are generally aimed at companies and are exclusively reserved for persons over the age of eighteen. The Data Controller will provide for the immediate cancellation of all personal data involuntarily collected in relation to subjects who have not reached the age of eighteen years.

In order to take advantage of the services offered through the site, the user is invited to fill out the appropriate information request form that can be found on the “contacts” page. If desired, the user can also contact the Owner by sending e-mails or even by telephone.

The site also uses third party cookies to offer the user a better navigation experience. All the information regarding the use of Cookies and how to select or deselect them and possibly deny consent to the installation of any Cookie, can be found in the specific information on the use of Cookies available here.

1) Categories of data subject to processing

1.1. Navigation data

The computer systems that ensure the functioning of the site collect certain so-called “surfing” data, such as: IP addresses, domain names of computers used by users who connect to the site, URI addresses of requested resources, parameters relating to the user’s computer system. The provision of this data is automatic and is mandatory for the purposes of navigation on the site. These data are not collected to be referred to identified users, but they could allow the identification of the user if they are associated with other data held by third parties. The Owner has no possibility to identify the user independently through navigation data only, and guarantees that this data will be used for the sole purpose of obtaining statistical information on the use of the site and will be deleted as soon as the activities for which they were collected have been carried out. The data may be used to ascertain responsibility in the event that computer crimes are committed against the site.

1.2. Data provided voluntarily by the user

The personal data provided by users when filling out the information request form belong to the category of common data, and do not include sensitive, health, genetic, biometric, judicial data, or data referred to in Articles 9 and 10 of EU Regulation no. 2016/679, since the processing of these latter categories of data is not necessary for the pursuit of the purposes pursued by the Owner. The data that the user will enter to fill in the electronic information request form, and that will be acquired by the Owner, are: name, surname, e-mail address, telephone number. The Data Controller may process the data voluntarily entered by the user in the “message” section of the information request form, as well as the data that will be communicated spontaneously by sending e-mails, including the sender’s e-mail address. In any case, only personal data strictly necessary for the pursuit of specific and legitimate purposes will be processed, with respect to which the processing will always be relevant and never excessive.

2) Source from which personal data originate

The so-called “navigation” data referred to in art. 1.1 above are automatically acquired by the software procedures used to operate the site. The personal data referred to in art. 1.2 above are provided by the users of the site through the compilation of special electronic information request forms on the pages of the aforementioned site, or through the sending of spontaneous communications.

3) Purposes of the treatment

Except as specified in art. 1.1 above with regard to the so-called “browsing” data, the personal data provided by users of the site may be processed: a) to meet the requests made by the user and perform specific pre-contractual activities that may be desired by the user (for example, the preparation of an estimate); b) for the fulfillment of obligations under the law and regulations; c) for commercial, advertising, promotional and marketing purposes in the broad sense, which involve processing: – c. 1) for the sending of communications of information regarding new offers of products and services, of a commercial nature and/or commercial solicitation (Newsletter) by the Data Controller; – c. 2) to carry out sales activities of services of the Data Controller; – c. 3) to send unsolicited commercial communications, immediately identifiable as such and containing the indication that the recipient of the same may object to the receipt of further communications of this kind; d) for so-called “profiling” activities. This activity consists in the processing of the personal data of the individual user in order to analyze his or her commercial preferences and obtain a profile as a consumer, so as to send him or her commercial offers of customized products or services. This processing therefore involves sending commercial communications regarding products or services deemed to conform to the commercial profile of the individual user (for example, because similar to products or services already requested or purchased by the latter), for a time not exceeding that of the processing. This purpose is in fact connected to those of a commercial, advertising, promotional and marketing nature in the broad sense of the previous letter c) and is pursued only with the express consent of the interested party.

4) Manifestation of consent

The consent to the processing of personal data, where required, is given by the person concerned through the selection of the appropriate fields on the data collection form.

5) Consequences of non-communication of personal data

The communication of personal data requested in the information collection forms on the site, while being left to the free will of the user, is necessary to achieve the specific purposes pursued by the Owner and related to the processing of this information. Consequently, failure to communicate, through the aforementioned information collection form or through another means of contact, the mandatory data will prevent the achievement of the main purpose for which they are required. Therefore, the lack of communication of this data will prevent the Owner from processing the user’s requests, from carrying out any pre-contractual activities desired by the latter.
Although not communicating obligatory data, the user will still be able to continue to navigate the site. The communication of data other than those requested in the information collection form is left to the discretion of the user; consequently, failure to communicate this data, which are defined as optional data, will not produce any consequences. Likewise, consent to the processing of personal data for marketing purposes referred to in art. 3 letter c) of the informative note, or for profiling purposes referred to in art. 3 letter d), is purely optional. Therefore, the lack of consent to its processing will not entail any consequences for the user, except that the user will not receive the promotional and commercial communications indicated in art. 3 letter c) and will not be subject to profiling. By consenting to the processing of personal data for commercial, advertising, promotional and marketing purposes in the broadest sense of the term, the user authorizes the processing of his/her data: – both through “traditional” methods, such as: telephone calls with operator and contact by other non-electronic means or not supported by automatic or telematic procedures, and through automated and assimilated telephone calls such as: sms and similar, systems supported by automatic, electronic or telematic procedures, without operator; – with reference to all the purposes indicated in Art. 3 letter c). 3 letter c), i.e. both those indicated in letter c.1 ) both those indicated in letter c.2) and those indicated in letter c.3). The user has the right at any time to request the Owner to limit the processing of personal data for the purposes referred to in art. 3 letter c) to only some of the above mentioned methods (for example, only through “traditional” means) or to some of the types of processing indicated in letters c.1), c.2) and c.3). (for example, only when sending Newsletters).

6) Legal basis of the treatment

The legal basis for the processing of data for the purposes referred to in Article 3 letter a) consists in the need to implement specific pre-contractual measures requested by the user. With reference to these purposes, although not mandatory, the Owner also requires the user’s consent. In the event the user decides to contact the Owner by sending e-mail messages or other means of communication other than filling out the appropriate form, the legal basis of the processing will consist solely in the need to implement the specific pre-contractual measures requested by the user. The legal basis for the processing of personal data for the purposes referred to in art. 3 letter b) consists in the fulfilment of legal obligations. The legal basis for the processing of personal data for the purposes referred to in Article 3 letters c) and d) consists exclusively in the prior, free, specific, optional and informed consent to the processing for the aforementioned purposes. The legal basis for the processing of navigation data consists exclusively in the necessity of the functioning of the site.

7) Modalities of the treatment

The personal data provided by the users of the site will be processed at the offices of the Owner, or in other places where the parties involved in the processing operate, through electronic and/or mechanical and analogical means for the time strictly necessary to achieve the purposes for which they were collected and in any case not exceeding the limits indicated in art. 13 of this information notice, in full respect of the purposes pursued by the Owner and in accordance with current regulations on privacy. Specific security measures are observed to prevent the loss of data, illicit or incorrect use of the same as well as unauthorized access.

8) Communication of personal data for the satisfaction of the request for information made by the user or for the fulfilment of legal obligations

In compliance with current privacy legislation, the user’s personal data may be disclosed to third parties to whom the communication is necessary for the purposes of pursuing the purposes referred to in art. 3 letter a) and b), without the need to obtain separate consent. Pursuant to art. 13 letter e) of EU Regulation no. 216/679, it is specified that the Customer’s personal data may be communicated to the following categories: – employees and collaborators of the Data Controller, appointed in charge of processing and specifically instructed pursuant to art. 29 of EU Regulation no. 2016/679;
– the Data Processor or the Data Protection Manager of the Data Controller and the Owner, where appointed; – third parties offering services related to digital communication and belonging to the following categories: technical studios, subjects and/or companies offering digital communication services, including hosting services, services related to the publication of websites, software design and development, or operating as providers of computer and logistics services functional to the operation of the site; – Public Authorities or any other third party if required by law.

9) Communication of personal data for the pursuit of promotional and marketing purposes in the broadest sense of the term

The Owner will not communicate the user’s data to third parties for promotional or marketing purposes in the broad sense of art. 3 letter c).

10) Further hypothesis of communication of personal data

For the sole purpose of satisfying the legitimate interest of the Data Controller in the protection of its rights, the user’s personal data may be communicated, without the consent of the latter, to subjects and companies that provide legal, fiscal, administrative, tax advice, or defense and technical assistance, both judicial and extrajudicial, who will act in their capacity as autonomous Data Controllers.

11) Dissemination and transfer of personal data to countries outside the EU or to international organizations

Your data may be transferred to one or more countries within or outside the European Union, only in those countries deemed by the European Commission to offer an adequate level of protection, a list of which can be found here: https://ec.europa.eu/info/law/law-topic/data-protection_en. The Owner will not disseminate the user’s personal data to international organizations.

12) Period of retention of personal data

The personal data voluntarily provided by the interested party to request information or other pre-contractual activities will be kept for the time strictly necessary to process the request made by the user and in any case not exceeding 12 months from their collection, unless previously cancelled at the request of the interested party. If the user’s request is followed by the stipulation of a contract for the supply of the services offered by the Owner, the personal data will be processed for the period indicated in the specific information that will be attached to the contract. The personal data processed for promotional, commercial and marketing purposes in the broadest sense and profiling as per art. 3, letters c) d), will be kept for a period not exceeding 12 months from collection. The navigation data will remain for a period not exceeding one month. In any case, the terms of five or ten years of conservation of the documents and related data will be respected only for the purposes of fulfilling the civil, accounting and fiscal obligations prescribed by current legislation.

13) Rights of the interested party

Pursuant to Article 7 of the Privacy Code and Articles 13, paragraph 2, letters b) and d), 15, 18, 19, 21 of EU Regulation no. 2016/679, the user may at any time exercise the rights referred to in the aforementioned Article 7 of the Privacy Code as well as the rights referred to in Articles 15 to 23 of the aforementioned EU Regulation. In particular, the interested party may exercise them: – the right to have access to their personal data and to obtain confirmation of the existence or not of personal data concerning them, even if not yet recorded, and the communication of such data in an intelligible form, as well as the right to data portability (i.e. the right to receive the personal data provided, in a structured format, in common use and readable by automatic device); – the indication of their origin, the purposes and methods of processing, as well as, if the processing is carried out by electronic means, the logic on which the processing is based; the indication of the identity of the owner and any managers; – the indication of the subjects and categories of persons to whom the personal data may be communicated or who can learn about them as managers or agents; – the updating, rectification or, if interested, integration of data; – the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; – to oppose, in whole or in part, for legitimate reasons, the processing of personal data concerning him, even if pertinent to the purpose of collection; to oppose the processing of personal data concerning him/her for purposes of commercial information or sending advertising materials or direct selling or for carrying out market research or commercial communication; – to obtain the rectification and/or cancellation of the same and/or the limitation of the processing concerning him/her; – to revoke the consent to the processing, if the processing is based on their consent, without prejudice to the processing already carried out; – to submit a complaint to the supervisory authority. This authority is represented, in Italy, by the Privacy Guarantor, based in Rome, piazza Monte Citorio n. 121, c.a.p. 00186.

14) Use of profiling processes by the Owner

The Data Controller may submit the user’s personal data to profiling processes as indicated in art. 3 letter d), only with the express consent of the latter.

15) Data Controller

In order to exercise his rights, the user can contact, at any time, the Data Controller, whose identification details are indicated: Monica Riboni – P.IVA 09345661210, Tel. +39 351 034 9196, info@comedincanto.eu. The Data Controller makes available to users of the site the following e-mail address for the exercise of rights, also with reference to requests addressed to third parties to whom the data have been communicated with the specific consent of the person concerned: info@comedincanto.eu. An updated list of the persons in charge of processing appointed can be found at the registered office of the Data Controller.

This text has been translated via the machine translation system DeepL (https://www.deepl.com). For any kind of misunderstanding related to the translation methods, reference should be made to the text written in the Italian language.

 

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