Clienti Business

Privacy Policy

This document of privacy policy, updated with EU Regulation (GDPR) 2016/679 relating to the processing of personal data, as well as with the Legislative Decree 181/18 which modifies the Legislative Decree 196/2003, regulates the modes of data processing collected by a website during the navigation by the user.

It has the precise purpose of inform the user regarding the processing of your personal data in accordance with the law and the recent EU Regulation 679/2016, which has profoundly changed the regulation.

A website must have a Data controller (Data Controller) . The data controller is the one who has decision-making and organizational power over the processing, as well as deciding the methods of data processing and is responsible towards the privacy guarantor. Two or more joint owners can also be appointed. In this case, it is mandatory for the user to know what the skills of each joint owner are, through a link indicating the agreement between them.

The data controller is supported by Data Processor (Data Processor) . This figure is the person who processes the data on behalf of the data controller. This means that it will be a person close to the owner, from whom he receives directives on how to manage the data. The Data Controller must be a competent figure capable of fully satisfying the security implemented by the Data Controller.

These two figures are joined by the Data Protection Officer (DPO), who, despite being appointed directly by the owner, is still a subject independent of the latter. The DPO, previously only optional, is now a sometimes mandatory figure pursuant to art. 37 of Regulation (EU) 679/2016. This article indicates the obliged subjects and those who are exempt. In any case, the DPO, called RPD in Italian, is an independent subject and processes the data autonomously. Furthermore, he is directly responsible for and communicates with the privacy guarantor. Ultimately, the DPO designation reflects the new approach of the GDPR, towards a responsibility for data processing, being aimed at facilitating the implementation of the regulation by the owner and manager. The role of DPO is to protect personal data, not the interests of the data controller.

Therefore, while the Data Controller is a figure close to the Data Controller, the DPO is a much more independent figure, who cannot and must not receive orders from the Data Controller on effective data protection.

Returning to the information, the place where the data will be processed, which coincides with the headquarters of the data controller.

It is essential to also include the purpose of data processing. In fact, according to the new legislation, the data must be kept for a period suitable for achieving the purposes set by the site, and then be deleted. It is therefore mandatory that the purposes are indicated clearly and concisely within the information.

The document must also indicate the types of Cookies that are used on the web page. Cookies are small pieces of information that can be saved on the user's computer when the browser calls up a particular website. With them the server sends information which will be re-read and updated every time the user returns to the site.

There are various types of cookies:

  • Technical cookies : in accordance with the law, they are those used for the sole purpose of "carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or by the user to provide this service". They are not used for other purposes and are normally installed directly by the owner or manager of the website.
  • Third party cookies: occur when a third party inserts cookies into an internet page. In this case, the user must be informed that there will be cookies from other parties in addition to those of the web page. Typical third-party cookies are those of social networks
  • Profiling cookies: are aimed at creating profiles relating to the user and are used to send advertising messages in line with the preferences expressed by the user when browsing the net. According to the privacy guarantor these can be:
    • Of advertising profiling , i.e. they collect and process user data for advertising purposes (e.g. to pass them on to advertising agents);
    • Of retargeting activities , consisting of forms of online advertising chosen based on the user's previous actions or searches on the web (e.g. Google AdWords);
    • set by social networks ;
    • Of statistical activities, managed by third parties (e.g. Google Analytics).

The document must also indicate whether the site allows it social network plug-ins and any transfer of data to companies located in extracontinental countries.

It is also important to mention what the new rights of the interested party are under the new European legislation, such as the right to deletion of data, the update of the same or of oppose to a possible data transfer.

How to use the document?

Through this document you will be able to:

  • Indicate the website for which the following document is used;
  • Indicate the data owner and the place in which these will be treated;
  • Indicate the possible presence of more owners of the treatment;
  • Indicate the responsible of data (DPO);
  • Indicate what they are purpose of data processing, and the time that the site will need to be able to use them;
  • Determine which ones Cookies they will be used by the site, if only technical cookies, third-party cookies and/or profiling cookies;
  • Indicate whether the site uses social network plug-ins;
  • Indicate whether the user will receive notifications for any site updates.

Once you have the document, it must be inserted into the site's web page and made available to the user.

Reference legislation

REGULATION (EU) 2016/679 of the European Parliament and Council, of 27 April 2016, on the protection of natural persons with regard to the processing of personal data, as well as on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) .

Legislative Decree 181/18, containing "Provisions for the adaptation of national legislation to the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, as well as on free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)" amending the Legislative Decree 196/2003 , "Code regarding the protection of personal data."

Provision of the Privacy Guarantor n. 229/2014 , relating to the "Identification of simplified methods for providing information and obtaining consent for the use of cookies."