PRIVACY AND COOKIE POLICY
(version dated 06/28/2022)

HOLDER OF THE TREATMENT

Luigi Silvestri
via Torino 5
37069 Villafranca of Verona (VR)
CF SLVLGU82A13L949K
Email: infzjho@cdxwsluigi.com

DEFINITIONS

“csluigi.com” hereinafter will be referred to as: "THIS SITE"
" EU 2016/679 " hereinafter will be referred to as: "GDPR"
" Luigi Silvestri " hereinafter will be referred to as: "OWNER"

INTRODUCTION

In this document we describe our privacy policy, indicating how your personal information is handled when you use our services and to allow you to give consent to the processing of your personal data expressed and aware in the sections of THIS SITE where you are asked to provide the personal data.

Furthermore, it is declared that the DATA CONTROLLER applies the GDPR and provides for the protection of persons and other subjects regarding the processing of personal data. According to the indicated legislation, the treatments carried out by THIS SITE will be based on the principles of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.

PERSONAL DATA OBJECT OF THE TREATMENT

By "processing of personal data" we mean any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, registration, organization, structuring, the conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction (Article 4.2 of the GDPR).

We inform you that the personal data being processed will consist - also depending on your decisions on how to use the services of THIS SITE - by an identifier such as the name, email address, telephone number or other identification number, data relating to the location and other data suitable for making you identified or identifiable, depending on the type of services requested (hereinafter only "PERSONAL DATA"). The OWNER here does not in any case collect particular categories of data (religion, political affiliation, state of health, etc.).

The categories of PERSONAL DATA processed through THIS SITE are as follows:

Data provided voluntarily by the interested party

In the use of particular areas of THIS SITE, the processing of PERSONAL DATA voluntarily left by you may occur in order to be contacted and / or to obtain a service in exchange, such as: request for information, personalized offers, inclusion in newsletters, purchase of product or services.

Navigation data

The computer systems and software procedures used to operate THIS SITE acquire, during their normal operation, some PERSONAL DATA whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to THIS SITE, the 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 response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of THIS SITE and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site or third parties. Currently, THIS SITE is hosted on GoDaddy servers.

Cookies

While browsing THIS SITE, some cookies are used, for which specific please refer to the next section dedicated to the COOKIE POLICY.

COOKIE POLICY

WHAT COOKIES ARE

Cookies are simple files sent together with the pages of this site and saved by your browser on the hard drive of your computer or other devices. The information collected in them may be sent back to our servers or to third party servers during the next visit.

We can divide cookies into three broad categories:

Technical cookies

They are strictly necessary for the operation and use of the web service and for this reason I do not require your express consent to be used. They are used to collect information in aggregate form on visits to the site. Among these we have:

• navigation (or session) cookies
• authentication cookies (for example, entering user and password)
• personalization cookies (for example, relating to the saving of preferences)
• functionality cookies (for example, saving the shopping cart or language / currency preferences)
• analytics cookies (or statistical, considered technical if used by the manager to collect data in aggregate form, on the number of users and on how they visit the site)
• and other...

Statistical cookies

We use statistical cookies to optimize the website experience for our users. With these statistical cookies we obtain insights into the use of our website. The use of this type of cookie requires your consent.

Marketing cookies

Marketing / tracking cookies are cookies or any other form of local storage, used to create user profiles to display advertisements or to track the user on this website or on different websites for similar marketing purposes. The use of this type of cookie requires your consent.

SITE COOKIES

All cookies used on THIS SITE do not allow the acquisition of the user's personal data and cannot retrieve any other data from the user's hard drive or transmit computer viruses or take possession of the user's e-mail address.

By browsing THIS SITE, cookies defined as "technical" will be downloaded, necessary for the use of the site: in particular, the user gives consent to the installation of this type of cookie simply by continuing to browse the site, by selecting a link or a scroll action on the page itself (or by confirming the brief information proposed in the banner at the first access to the site).

By browsing THIS SITE, third-party cookies will also be downloaded, linked to other websites that may be consulted by the user via links: by browsing the site, in fact, you can be redirected to functions of other sites, which in turn use cookies and for which the relative policy will prevail.

By browsing THIS SITE you are consenting to the use of cookies in accordance with this Policy, remembering that the cookies stored on the hard drive of your device can be deleted at any time. If you do not consent to the use of cookies in this way, you can decide not to use THIS SITE or disable the use of cookies, following the instructions provided by each browser: Internet Explorer, Chrome, Opera, Safari, etc ... We remind you, however, that setting your browser by disabling cookies could affect your browsing experience on websites.

THIRD PARTY COOKIES

The third-party cookies on THIS SITE are:

Google: where there are services or content accessible through Google services, we inform you that Google may install cookies to detect user preferences on the use of its services. For more information, consult the Google policies, and in particular:

• Google privacy policy
• how Google uses cookies
• how Google uses information provided by apps or sites that use its services

YouTube: where there are videos published on Youtube, we inform you that Youtube may install cookies to detect preferences on the use of this service. In particular, when the user decides to click on 'Play' to play the video, he agrees to send his personal data to Youtube. For more information, consult the Google privacy policy listed above and the YouTube terms of service .

The same applies to any other links to third-party sites, to which the relative policies will refer.

By browsing THIS WEBSITE, Google Analytics cookies will also be downloaded, exclusively for statistical purposes. The cookies in question collect information in aggregate form in order to monitor and analyze access to the pages of the site: the information generated by the cookie on the use of the website is communicated to Google Inc In any case, on Google Analytics the retention period of user data is set to 14 months. For more information, consult the Google privacy policies listed above.

CURRENT SETTINGS OF YOUR COOKIES AND CHANGES

In the table below you can check your current cookie settings on THIS SITE and change them as you wish.

PURPOSE OF THE TREATMENT

The processing we intend to carry out, with your specific consent (where necessary), has the following purposes:

• Improve navigation on the site : allow navigation, consultation and view information material on THIS SITE, as well as improve your browsing experience on THIS SITE.
• Legal obligations : to fulfill legal, accounting and tax obligations to which the CONTROLLER is subject, representing this a legitimate processing of PERSONAL DATA (pursuant to Article 6.1 (c) of the GDPR).
• Respond to requests for information : respond to requests for information, which we will receive via e-mail, telephone or chat or via the appropriate form, on services and solutions proposed on THIS SITE.
• Sending newsletters: by expressly subscribing to the Newsletter service, you agree that the e-mail address and other personal data you have voluntarily provided us (when completing the registration form) are processed for the purpose of transmitting you periodically the Newsletter and any other personalized service to which you subscribe, as well as to improve the effectiveness of the advertising campaigns associated with our services. By subscribing to the newsletter, you will be periodically sent e-mails containing: updates on the news of THIS SITE (new services, etc.), useful information for your business, commercial news or news from the HOLDER's partner companies, commercial offers of products and services offered by the HOLDER. Once subscribed to the newsletter, you can cancel your subscription at any time, by making an express request through the mechanism proposed in the footer of the email received.
• Marketing purposes : carry out direct marketing via e-mail (soft spam) for services similar to those subscribed or purchased by you, for the pursuit of the legitimate interest of the OWNER to promote products or services in which you could reasonably be interested. This unless you have opposed this treatment initially or in subsequent communications. In fact, we remind you that the treatments carried out for e-mail marketing purposes on products or services similar to those purchased by you have a legal basis in the legitimate interest of the HOLDER (ref. Recitals (47) and (70) of the GDPR, Art. 6.1 ( f) of the GDPR) to promote its products or services in a context in which the interested party can reasonably expect this type of treatment, to which he can also oppose at any time. In fact, if you wish to object to the processing of your data for marketing purposes, you can do so at any time through the mechanism proposed in the commercial email footer or by sending a request to the OWNER's email.
• Statistical purposes and market research: to develop studies, research, market statistics; send you advertising material, information, commercial information or surveys to improve the service ("customer satisfaction") via e-mail or text message, and / or through the use of the telephone with operator and / or through the official pages of THIS SITE or on the OWNER's social networks or other official channels.
• Fraudulent conduct: for the exclusive purposes of security and prevention of fraudulent conduct, the CONTROLLER puts in place an automatic control system that involves the detection and analysis of user behavior on the site, associated with the processing of PERSONAL DATA including the address IP. The consequences of this treatment are that if a subject attempts to engage in fraudulent conduct on THIS SITE (for example to benefit from the same promotion several times without being entitled to it) the CONTROLLER reserves the right to exclude this subject from the promotion or to adopt any other appropriate measure for their protection. This treatment is also based on the HOLDER's legitimate interest in detecting frauds and scams committed to its detriment (ref. Recital (47) of the GDPR, Art. 6.1 (f) of the GDPR).
• Communication to third parties : only with reference to certain services, the data may be processed for communication purposes to third parties for their marketing purposes, that is to say to provide you with information and / or make offers on products, services or initiatives offered or promoted. by other companies of the HOLDER and / or by its affiliated and / or controlled companies, and / or by other commercial partners and outsourcers who act as independent data controllers.

The provision of your PERSONAL DATA for the purposes of processing carried out for purposes based on the release of your consent (pursuant to Article 6.1 (a) of the GDPR) is entirely optional and does not affect the use of the other services of THIS SITE.

RECIPIENTS OF PERSONAL DATA

Your PERSONAL DATA may be processed by electronic means with restricted access to persons appointed and authorized by the CONTROLLER, who has prepared all the IT security measures necessary to minimize the risk of violation of privacy by third parties, and is in every moment ready to adopt the safety measures that prove indispensable.

Your PERSONAL DATA may be shared, for the "Processing Purposes" listed above, with:

• Subjects who typically act as data processors, that is: people, companies or professional firms that provide assistance and advice to the HOLDER in management, accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of services, as well as people, companies or professional firms that carry out necessary professional assistance and consultancy activities and / or to support the provision of the services offered on THIS SITE. The complete list of data processors is kept at the OWNER's headquarters and you can request an updated copy at any time by sending a request to the OWNER's email address.
• Subjects who carry out activities necessary for the services offered by the HOLDER, or subjects with whom it is necessary to interact for the provision of services, or delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks), or companies of the group or connected to the HOLDER (Italian or foreign) that carry out administrative or statistical purposes (collectively "Recipients")
• Persons authorized by the HOLDER to process PERSONAL DATA necessary to carry out activities strictly related to the provision of services, who are committed to confidentiality or have an adequate legal obligation of confidentiality, such as the HOLDER's employees;
• Commercial partners for their own purposes, autonomous and distinct, for commercial information and market research, and only if you have given specific consent.
• Subjects, bodies or authorities to whom it is mandatory to communicate your PERSONAL DATA by virtue of legal provisions or orders of the authorities (for example, requests by the judicial authority in the course of criminal investigations);

TRANSFER OF DATA

Some of your PERSONAL DATA are shared with Recipients who may be found outside the European Economic Area. The CONTROLLER ensures that the processing of your PERSONAL DATA by these Recipients takes place in compliance with the GDPR. Indeed, the transfers can be based on an adequacy decision or on the “Standard Contractual Clauses” approved by the European Commission.

More information is available from the DATA CONTROLLER, in particular to find out which treatments involve the transfer of the data in question outside the European Economic Area. Given that this transfer is necessary for your use of the service, according to the privacy legislation in force, it is justified pursuant to Art. 44 and following of CHAPTER V of the GDPR.

DATA STORAGE

In general, all PERSONAL DATA collected for the purposes described above will be processed for the time strictly necessary to achieve the same purposes. In any case, the DATA CONTROLLER will process the PERSONAL DATA up to the time allowed by Italian law to protect their interests (Article 2946 of the civil code and following). The retention period of PERSONAL DATA varies according to the processing purpose for which they were collected:

• To improve navigation on the site: since these are data related to technical cookies, the details are described in the COOKIE POLICY.
• For legal obligations: they will be kept up to the time required by the specific legal obligation or applicable law, and subsequently they may be kept for a longer period necessary in order to protect the interests of the HOLDER from possible responsibilities relating to supplies.
• To respond to requests for information: they will be used for the time strictly necessary to achieve the same purpose, and will subsequently be stored exclusively for management purposes and to protect the interests of the HOLDER from possible responsibilities based on such treatments.
• For sending newsletters or for marketing purposes or for statistical purposes and market research: they will be kept by the HOLDER until the consent given by the interested party is revoked. Once the consent has been revoked, the use of the data for these purposes will cease, but the OWNER may keep them in order to protect themselves from possible responsibilities based on such treatments.
• To use the services of the site or to respond to requests for assistance or for communication to third parties: they will be used for the time strictly necessary to achieve the same purpose and, since such personal data are processed to provide the products / services, they will subsequently be stored for a longer period and for what may be necessary in order to protect the interests of the HOLDER from possible responsibilities relating to supplies.

In any case, the HOLDER has the possibility to keep his PERSONAL DATA up to the time allowed by Italian law to protect his interests (Art. 2947 (1) (3) of the Italian Civil Code) and in particular to protect himself from fraudulent conduct.

RIGHTS OF THE INTERESTED PARTY

You have the right to ask the HOLDER, at any time, to access his PERSONAL DATA (according to Art. 15 of the GDPR), to correct them (according to Art. 16 of the GDPR), to cancel them (according to Art. 17 of the GDPR). GDPR), the limitation of processing (according to Article 18 of the GDPR) or to oppose their processing in the cases provided for by Article 21 of the GDPR, as well as to obtain the data in a structured format, commonly used and readable by an automatic device, that concern you ("portability" according to Art. 20 of the GDPR). All requests can be addressed by writing an email to the OWNER, using the address indicated at the beginning of this document.

In any case, you always have the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the GDPR, if you believe that the processing of your PERSONAL DATA is contrary to the legislation in force.

CHANGES

This PRIVACY POLICY is effective from June 28, 2022. The OWNER reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. If the changes to this Policy concern substantial changes in the processing or may in any case have a significant impact on the interested parties, the OWNER will take care to notify them appropriately to the interested parties.

To read the previous version click here (only original version in Italian)

LANGUAGE

The native language in which this privacy policy was written is Italian, the translation into other languages was done through the Google Cloud translation API only to facilitate the user in understanding it. So the Italian version is the only one to be authentic.