Privacy Policy – Diennea S.r.l.

 

Dear User,
DIENNEA S.r.l., as Data Controller (hereafter “Controller”) pursuant to Legislative Decree 196/2003 – Personal Data Protection Code (henceforth the “Code”) – and subsequent amendments, considers privacy and the protection of personal data as two of the main objectives of its business. Before providing any personal information to the Controller we therefore invite you to carefully read this Privacy Policy as it contains important information regarding privacy, the protection of personal data and the security measures in place to ensure confidentiality in full compliance with the applicable regulations.

This Privacy Policy:

  • is intended specifically for this website (hereinafter “the Site”) which is operated by the Controller;
  • forms an integral part of the Site and the services we offer;
  • is also be intended as Information pursuant to art. 13 of the Personal Data Protection Code for those who interact with the web services of this Site;
  • conforms to Recommendation no. 2/2001 on the minimum requirements for the online collection of data in the European Union, adopted on 17 May 2001 by the Article 29 Working Party.

***The Controller informs you that the processing of your personal data shall follow principles of correctness, lawfulness, transparency and the protection of your privacy and your rights. Your personal data will therefore be processed in accordance with the legislation governing Privacy and confidentiality obligations.

INDEX
Below we provide the index of this Privacy Policy so that you can easily find the information relating to the processing of personal data which interest you
1.    DATA CONTROLLER AND DATA PROCESSOR
2.    PERSONAL DATA SUBJECT TO PROCESSING
2.1   NAVIGATION DATA
2.2   DATA PROVIDED VOLUNTARILY BY THE USER
2.3   COOKIES
3.    PURPOSE OF PROCESSING AND OBLIGATORY OR OPTIONAL NATURE OF DATA DISCLOSURE
4.    PROCESSING METHODS, SECURITY AND LOCATION OF DATA PROCESSING
5.    COMMUNICATION AND DISSEMINATION
6.    YOUR RIGHTS
7.    MODIFICATIONS
8.    CONTACT

1.    DATA CONTROLLER AND DATA PROCESSOR
Following consultation and use of the services of the site, data related to identified or identifiable natural persons may be processed. The identity of the data controller and operator of the Site are as follows:
DIENNEA S.r.l., with its registered office at Viale G. Marconi 30/14, 48018, Faenza (RA), Italy, P. IVA 02243600398, email: privacy@diennea.com.
Your personal data may be disclosed to employees or collaborators of the Controller, belonging to the categories of administrative, commercial, legal, or accounting staff or administrators of computer systems, depending on the type of processing, which, operating under the direct authority of the latter, are nominated as data processors or persons in charge of the processing according to Articles 29 and 30 of the Personal Data Protection Code and receive appropriate operational instructions.
In compliance with art. 13.1.f, the company Aruba S.p.A has been appointed as one of the external data processors. The updated list of any further data processors is available and may be requested from the Data Controller by e-mail to the following email address: privacy@diennea.com.

2.    PERSONAL DATA SUBJECT TO PROCESSING

2.1   Navigation Data
During their normal operation, the computer systems and software procedures used to operate the Site acquire some personal data whose transmission is implicit in the communication protocols of the Internet. This information is not collected to be associated with identified subjects, but by their very nature could identify users through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by users that connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and computer of the user’s IT environment. These data are used in order to obtain anonymous statistical information about the site and to allow its proper operation, to permit – given the architecture of the systems used – the proper delivery of services, for motives of security and to establish liability in case of computer crimes against the Site or third parties; navigation data are normally deleted after thirty days.

2.2   Data provided voluntarily by the user
The Site offers users the opportunity to voluntarily provide personal information through, for example, registering a contact form, requesting services, information or quotes, the optional sending of, explicit and voluntarily, an e-mail to the addresses listed on the site, etc.

2.3   Cookies
– Definition, characteristics and application of regulations

Cookies are small text files that websites visited by the user send and record on the computer or mobile device of the same, and then are transmitted back to the relative sites during the next visit. Thanks to cookies the site remembers the actions and preferences of the user (such as, for example, login data, the default language, font sizes, additional display settings, etc.) so that the user doesn’t need to specify them again when they re-visit the site and browses its pages. Cookies are therefore used to perform authentication information, session monitoring and the storing of information about the activities of users access of a website and may also contain a unique identifier that allows for the monitoring of user experiences on the site for statistical or advertising purposes. During the navigation of a site, the user may also receive cookies on their computer or mobile device from sites or web servers other than the one they are visiting (so-called “third party” cookies). Some operations cannot be performed without the use of cookies, which in some cases are technically necessary for the operation of the site.

There are various types of cookies, depending on their features and functions, and these may remain on the computer or mobile device of the user for different periods of time: so-called session cookies, which are automatically deleted when you close your browser; so-called persistent cookies, which remain on the user’s device until a pre-established date.
Under the legislation in force in Italy, prior explicit consent for the use of cookies is not always required. In particular, such consent is not required for “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary to provide a service explicitly requested by the user. In other words, cookies which are indispensable for the operation of the site or to perform tasks requested by the user.

Among the technical cookies, which do not require prior explicit consent for their use, the Italian Data Protection Authority (see General Measure “Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – May 8, 2014”) also includes:

  • “analytic cookies” used directly by the site operator to collect information , concerning the number of users and how they visit the site, provided they only process information in aggregate form,
  • navigation or session cookies (for authentication),
  • functional cookies which allow user navigation on the basis of a set of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided to the same.

The prior consent of the user is instead required for “profiling cookies”, i.e. those aimed at creating profiles related to the user in order to send him/her advertising messages in line with the preferences expressed by the same while surfing the web.

– Types of cookies used by the Site and the possibility of (de-)selection

The Site uses the following cookies offering the possibility to (de-)select the same (and therefore to disable them), except for third-party cookies, for which the user must directly refer to the relevant procedures for selecting and de-selecting the cookies mentioned below indicated by way of links:

  • Technical cookies – session or navigation – are strictly necessary for the operation of the Site or to allow the users to make use of the content and services they have requested.
  • Technical-analytics cookies, which allow for an understanding of how the site is used by users. These cookies do not collect information about the identity of the user or any personal data. The data is processed in an aggregate and anonymous form.
  • Technical-functional cookies, i.e. used to activate specific functionalities of the site and a number of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
    WARNING: disabling the technical and/or functional cookies of the Site may lead to certain services or features of the Site being unavailable or the Site many not function properly, and the user may be forced to change or manually enter some information or preferences each time they visit the site.
  • Third-party cookies, i.e. cookies from web sites or servers other than that of the Controller, used for the purposes of third parties, including profiling cookies. Please note that these third parties, listed below with the corresponding links to the privacy policy, are independent data controllers of the personal data collected through the cookies they sent. Therefore, the user should refer to their privacy policies, information and consent forms (selection and de-selection of the respective cookies) listed below (as specified in the general measure “Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies – 8 May 2014”):

Specifically, the cookies present on the Site are indicated at the following link: http://www.emailsuccess.com/cookie

– How to view and modify the cookies through your navigation program (so-called browser)

The user can select which cookies to allow through the appropriate procedure described here: http://www.emailsuccess.com/cookie, and can authorize, block or delete (in whole or in part) cookies through the specific functions of their navigation program (so-called browser). However, in the hypotheses in which all or some of the cookies are disabled it is possible that the site may not be consulted or that certain services or certain features of the Site will not be available or will not work properly and/or the user may be forced to change or manually enter some information or preferences each time he/she visits the site.

For more information on how to set preferences on the use of cookies through your browser, it is possible to consult these instructions:

3.    PURPOSE OF PROCESSING AND OBLIGATORY OR OPTIONAL NATURE OF DATA DISCLOSURE

The data you provide through the Site will be processed by the Controller for the following purposes:
a) purposes related to the provision of the requested services (e.g. a contact request, a “Demo” or a quote, subscription to the newsletter, request for information or enrollment in training courses, request for documentation or permission to download from the Site, reporting abuse).

Providing your data for the purposes listed above (a) is optional, but the failure to do so may make it impossible to provide the services requested.

Pursuant to Article 24 paragraph 1, letter b of the Personal Data Protection Code, consent is not required for the processing of personal data for such purposes as such data are necessary to fulfill obligations arising from a contract to which the data subject is part and/or to fulfill, before the conclusion of the contract, specific requests of the data subject.

b) purposes of research/statistical analysis of aggregate or anonymous data, without, however, the possibility to identify the user, aimed at measuring the effectiveness of web marketing campaigns, to measure traffic and to evaluate usability and interests

The Personal Data Protection Code does not apply to the processing of aggregate or anonymous data.

c) purposes related to the fulfillment of obligations provided for by law, regulations or Community legislation

Providing your data for the purposes listed above (c) is mandatory, the failure to do so would not allow the Controller to fulfill the obligations required by law, regulations or Community legislation.
It should be noted that pursuant to art. 24 paragraph 1, letter a, of the Personal Data Protection Code, consent for the processing of personal data for such purposes is not required.

d) purpose of promotional communications. In accordance with the “Guidelines on Marketing and Against Spam – 4 July 2013 [Web doc 2542348]” issued by the Italian Data Protection Authority, if you decide to give your consent to receive information related to promotional activities of the Controller including market research, we inform you that said activity can be performed, as provided for in the applicable regulations, by way of postal mail, a telephone contacts operator (“traditional methods”), e-mail, SMS and through the use social networks (“automated methods”). We also advise you that at any time you can decide to withdraw consent previously granted by traditional or automated methods by giving notice to the Controller without any formality by writing to privacy@diennea.com.

Providing your data for the purposes listed above (d) is optional and requires your prior consent.

e)purpose of data profiling (e.g. creation through electronic means of users profiles based on their preferences, habits and consumption choices

Providing your data for the purposes listed above (e) is optional, but necessary. Failure to do so would prevent the Data Controller from performing data profiling.

4.    PROCESSING METHODS, SECURITY AND LOCATION OF DATA PROCESSING

Your personal data are processed by the Data Controller – or third parties carefully selected for their reliability and competence, and rightly appointed data processors – limited to the achievement by the same of the purpose specified above, mainly with automated tools, but also in paper form, for the time necessary to achieve the purposes for which they were collected.

Specific security measures are taken to prevent data loss, illicit or incorrect use and unauthorized access in full compliance with the requirements of Art. 31 and the following articles of the Personal Data Protection Code and the Technical Specifications – Annex B to the Personal Data Protection Code – regarding minimum security measures.
The processing related to the services of this Site will primarily be located at the offices of the Controller. The data centers of the Controller are located on Italian territory. The Controller also makes use of the technology services/data centers of Telecom Italia S.p.A. and Aruba S.p.A. to carry out some of the processing referred to the purposes described above, with the result that the data will also reside at the premises of these companies.

5.    COMMUNICATION AND DISSEMINATION

Your personal data may be disclosed to parties other than of the Controller, whose activities are necessary for the provision of services.

Your personal data may be communicated to third parties such as: 1. people, companies or professional offices that provide assistance and advice to the Controller, rightly appointed as data processors; 2. individuals, entities or authorities to whom the communication of your personal data is mandatory in accordance with provisions of law or orders from the competent authorities; 3. subjects delegated and/or engaged by the Controller to carry out activities strictly related to the purposes mentioned above (including maintenance of technical systems), rightly appointed as data processors; 4. commercial partners only in the case you have granted specific permission to do so. With reference to the scope of dissemination of personal data, the personal data required to activate the Services will not be disseminated.

Your personal data will not normally be disseminated by the Controller. The Controller reserves the opportunity to perform, from time to time, processing that comports dissemination, after having obtained your specific consent.

6.    YOUR RIGHTS

The subjects to whose personal data are referred to have the right at any time to obtain confirmation of the existence of such data and to know its content and origin, to verify its accuracy or request its integration, updating, or correction (art. 7 Personal Data Protection Code).

For the purposes of the same Article, the user shall have the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose, in any case, for legitimate reasons, their processing.

Requests should be sent by e-mail to: privacy@diennea.com

7.    MODIFICATIONS

The data controller may modify or update the Privacy Policy of the site in part or completely, partly as a result of changes in laws and regulations governing this matter and to protect your rights. These changes and updates to the Privacy Policy will be notified to users on our home page as soon as they are introduced and will be binding once posted on the site. We therefore invite you to regularly visit this section in order to be aware of the most recent and updated version of this Privacy Policy so that you are always up to date on the information we collect and the use we make of it.

8.    CONTACT

If you would like to receive any information concerning the processing of personal data carried out by the Controller, please send an e-mail to privacy@diennea.com

Privacy Policy ultima modifica: 2016-03-18T12:11:28+00:00 da Gabriele Tassara