PRIVACY NOTICE

Processing of Personal Data

This Privacy Policy describes how the website WWW.INETPROJECT.IT (the “Site”) is managed with regard to the processing of personal data of users/visitors who access it. This notice is also provided pursuant to Article 13 of Italian Legislative Decree 196/2003 (“Data Protection Code”), Measure No. 229 of 8 May 2014 of the Italian Data Protection Authority, and Articles 13 and 14 of the GDPR – EU Regulation 2016/679.

The Site is owned by STEFANO BISTACCHIA, VAT number 02522270541, stefano@inetproject.it (the “Data Controller”).

This notice is provided by the Data Controller only for this Site and not for any other websites or sections/pages/spaces belonging to third parties that the user may access via links. The purpose of this notice is to allow users to understand, even before accessing the various sections of the Site, how the Data Controller processes users’ personal data; users must review this notice before providing their personal data when registering on the Site.

Data Controller and Data Processors

The Data Controller is STEFANO BISTACCHIA. Personal data processing may be carried out by third parties for activities connected to or instrumental in the processing operations. In such cases, these parties will be appointed as Data Processors or authorized personnel.

Purpose of Processing

The purposes for which personal data is processed — meaning data provided directly by users via email or by filling out online forms (see the section “Nature and Method of Collecting Users’ Personal Data” below), or data collected automatically (see the section “Categories of Personal Data Processed” below) (collectively, “Personal Data”) — are: responding to requests or questions received by email.

Method of Processing

Processing will be carried out using automated tools (e.g., electronic procedures and media) and/or manually (e.g., on paper) for the time strictly necessary to achieve the purposes for which the data was collected, and in any case in accordance with applicable regulations.

Nature and Method of Collecting Users’ Personal Data

Providing personal data is optional. If you write to us, the Data Controller will see your email address and everything you include in your message.

Categories of Personal Data Processed

In addition to the Personal Data provided directly by users (such as first name, last name, email address, etc.), when connecting to the Site, the computer systems and software procedures used to operate the Site automatically and indirectly acquire certain information whose transmission is implicit in the use of Internet communication protocols. This includes, for example but not limited to, so-called “cookies” (described in more detail below), IP addresses, domain names of the computers used by users connecting to the Site, the URL addresses of the resources requested, and the time of the request to the server.

Minors

Minors under the age of 16 must not provide information or Personal Data without the consent of their parent or legal guardian. The Data Controller invites all parents and legal guardians to inform minors under their responsibility about the safe and responsible use of the Internet and the Web.

Use of Cookies

Cookies are small text markers sent by a server (in this case, this Site’s server) to a user’s device (generally to their web browser) when they access a given page of a website. Cookies are automatically stored by the user’s browser and sent back to the server that generated them each time the user accesses the same web page. In this way, cookies enable and/or facilitate access to certain web pages to improve the user’s browsing experience, and allow the storage of visited pages and other specific information, such as the pages visited most frequently, connection errors, etc. For optimal and full use of this Site, users should configure their browser to accept such cookies. Browsers are often set by default to accept cookies automatically. However, users can change the default configuration to disable or delete cookies (on a case-by-case basis or entirely), although this may prevent optimal use of certain areas of the Site. Users can also check which types of cookies are stored on their browser by adjusting their browser’s cookie settings.

Types and Management of Cookies

Technical Cookies

Strictly necessary cookies: required for browsing the Site and using its features, such as ensuring correct display or access to restricted areas. Disabling these cookies will prevent such functions from working.

Performance cookies: collect anonymous information on how efficiently the Site responds to user requests, solely to improve the Site’s functionality — for example, which pages are visited most often, and whether there were errors or delays in delivering web pages.

Functionality cookies: allow the Site to remember choices made by the user and apply them on subsequent visits, in order to provide better, personalized services — for example, they may be used to suggest content similar to what the user has previously requested.

Profiling Cookies for Targeted Advertising (“targeting cookies”)

These are used to offer users advertising that is potentially relevant to their interests, as determined through their browsing activity. They may, for example, be used to limit how often a given ad is shown, or to assess the effectiveness of a campaign based on how frequently the related ad is displayed. Such cookies may also be provided by third parties, including on behalf of advertisers. Users may accept or decline such cookies by giving their consent (“opt-in”) before the cookies are used. This Site does not use this type of cookie.

Social Media Sharing Cookies

Where present, these third-party cookies are used to integrate certain popular social media features into the Site — in particular, enabling “like” functions for Facebook and Instagram. Below are links to the respective cookie policy pages for managing consent:

• Facebook – https://www.facebook.com/about/privacy/
• Instagram – https://help.instagram.com/196883487377501
• YouTube – https://www.youtube.com/static?template=privacy_guidelines
• LinkedIn – http://www.linkedin.com/legal/privacy-policy

Disabling Cookies (“Opt-Out”)

Data protection regulations allow users to disable cookies that have already been set (“opt-out”). Opt-out applies to so-called “technical cookies” (Article 122 of the Data Protection Code), as well as to cookies not falling within “technical cookies” that were previously accepted (“opt-in”) by the user. Based on this distinction, users may disable and/or delete cookies (“opt-out”) through their browser settings, and disable and/or delete individual non-“technical” cookies provided by third parties. EU-based users can do so via the website managed by the European Interactive Digital Advertising Alliance (EDAA) at www.youronlinechoices.eu, and users based in the United States can do so at http://www.aboutads.info/choices/. These websites are not managed by the Data Controller, who therefore assumes no responsibility for their content.

How to Enable or Disable Cookies in Your Browser

Users can block their browser from accepting cookies. However, this may prevent some website functions from working correctly. Below are links explaining how to block cookies in the main browsers:

• Internet Explorer: http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Chrome: https://support.google.com/chrome/answer/95647

Categories of Parties Who May Access Users’ Personal Data

Personal Data may be disclosed to the Data Controller’s collaborators or to third parties who, acting under the Data Controller’s direct authority, are appointed as Data Processors or authorized personnel pursuant to Articles 29 and 30 of the Data Protection Code, and who will receive appropriate operating instructions. The same applies — under the responsibility of Processors appointed by the Data Controller — to employees or collaborators of those Processors. Specifically, the following categories of authorized personnel may have access to the data: staff involved in organizing the Site (administrative, sales, marketing, legal personnel, system administrators) or external parties (third-party technical service providers, hosting providers, IT companies, communication agencies).

International Data Transfers

The Site may share some of the data collected with service providers located outside the European Union — in particular the Hosting Provider, as well as Google, Facebook, and Microsoft (LinkedIn) through social plugins. Such transfers are authorized and strictly regulated by Article 45(1) of EU Regulation 2016/679, so no further consent is required. The companies mentioned above certify their adherence to the Privacy Shield framework. Data will never be transferred to third countries that do not meet the conditions set out in Article 45 et seq. of the EU Regulation.

Data Security

The Site processes user data lawfully and fairly, adopting appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the stated purposes.

Users’ Rights under Article 7 of the Data Protection Code

“Article 7 – Right of access to personal data and other rights”

1. Data subjects have the right to obtain confirmation of whether or not personal data concerning them exists, even if not yet recorded, and to have it communicated in an intelligible form.
2. Data subjects have the right to obtain information regarding: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the case of processing carried out with the aid of electronic tools; d) the identity of the Data Controller, the Data Processors, and any appointed representative under Article 5(2); e) the parties or categories of parties to whom the personal data may be disclosed, or who may become aware of it as an appointed representative within the State’s territory, as Data Processors, or as authorized personnel.
3. Data subjects have the right to obtain: a) the updating, correction, or, where they have an interest, supplementation of their data; b) the deletion, anonymization, or blocking of data processed in violation of the law, including data that does not need to be retained for the purposes for which it was collected or subsequently processed; c) confirmation that the operations described in points (a) and (b) have been notified, including as regards their content, to those to whom the data was disclosed or disseminated, except where this proves impossible or involves a disproportionate use of resources relative to the right being protected.
4. Data subjects have the right to object, in whole or in part: a) on legitimate grounds, to the processing of their personal data, even where relevant to the purpose of collection; b) to the processing of their personal data for the purposes of sending advertising material, direct selling, market research, or commercial communications.

How to Exercise Rights under Article 7 and Obtain the List of Data Processors

Users may, at any time, exercise the rights set out in Article 7 of the Data Protection Code by sending an email to the relevant Data Controller. Where the user has given consent, they may also object to processing carried out for such purposes via the email address they provided, by clicking the relevant “link” included in every email communication.