Policy Privacy

Information pursuant to art. 13 of the EU General Regulation 679/2016 on the protection of personal data.

The company Tradizioni Associate S.r.l.a. (hereinafter, the “Company”) informs that it is the Data Controller pursuant to Articles 4, no. 7) and 24 of EU Regulation 2016/679 of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data (hereinafter, the “Regulation”) of personal data collected on this website (“Site”). Hereinafter, with the terms “Interested” or “User”, both in the singular and in the plural, we mean overall the natural persons of age; individuals aged sixteen on their own; minors under the age of sixteen authorized by those exercising parental authority.

The processing of personal data means 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, even if not registered in a data bank, such as collection, registration, organization, structuring, storage, processing, selection, blocking, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, cancellation or destruction.

Identification details and contact details of the Data Controller.
As required by the WP 260/2017 Transparency Guidelines, the identification details of the Data Controller and all the information to contact him are provided in the first instance.

COMPANY DATA: Tradizioni Associate S.r.l.a.
Tel: +39 055 8469903
EMAIL: info@tradizioniassociate.com

The personal data acquired by the Data Controller may be disclosed to third parties, such as Data Processors. It should be noted that the relationship between the Data Controller and the Data Processor is governed by a specific agreement, in accordance with the provisions of art. 28 of the EU Regulation 679/2016.

Definition of “cookies”.

Cookies are short fragments of text (letters and / or numbers) that allow the web server to store information on the client (the browser, eg Internet Explorer, Chrome, Firefox, Opera …) to be reused during the same visit to the site (session cookies) or later, even after days (persistent cookies). Cookies are stored, according to user preferences, by the single browser on the specific device used (computer, tablet, smartphone).

Similar technologies, such as, for example, web beacons, clear GIFs and all forms of local storage introduced with HTML5, can be used to collect information on user behavior and use of services.

A cookie cannot retrieve any other data from the user’s hard drive or transmit computer viruses or acquire email addresses. Each cookie is unique to the user’s web browser. Some of the functions of cookies can be delegated to other technologies. The term ‘cookies’ refers to cookies and all similar technologies.

Based on the characteristics and use of cookies, various types of cookies can be distinguished:

  • Strictly necessary technical cookies. These are cookies that are essential for the proper functioning of a website which are used to manage various services related to websites (such as a login or access to reserved functions on the sites). The duration of cookies is strictly limited to the work session or they can use a longer stay time in order to remember the visitor’s choices. Disabling strictly necessary cookies can compromise the experience of use and navigation of the website.
  • Analysis (analytics) and performance cookies. These are cookies used to collect and analyze the traffic and use of a website anonymously. These cookies, even without identifying the user, allow, for example, to detect if the same user returns to connect at different times. They also allow you to monitor the system and improve its performance and usability. The deactivation of these cookies can be performed without any loss of functionality and will be dealt with in detail later.
  • Profiling cookies. These are permanent cookies used to identify (anonymously or not) user preferences and improve their browsing experience, allowing the sending of personalized advertising messages.Finalità del trattamento e scopi dei cookies tecnici di sessione.

Purpose of processing and purposes of technical session cookies.

The cookies used on the Site are both technical and analytics: cookies are not used for profiling purposes.

“Technical” cookies (and analytics, equated to technical cookies) can be used even without the consent of the interested party.

Among other things, the same European body that brings together all the Privacy Authorities of the various Member States (the so-called “Article 29” Group) clarified in Opinion 4/2012 (WP194) entitled “Exemption from consent for the use of cookies “which are cookies for which it is not necessary to acquire the user’s prior and informed consent: cookies with data compiled by the user (session identifier), lasting a session or persistent cookies limited to a few hours in some cases ; authentication cookies, used for the purposes of authenticated services, for the duration of a session; user-centric security cookies, used to identify authentication abuses, for a limited persistent duration; session cookies for multimedia players, such as cookies for “flash” readers, for the duration of a session; session cookies for load balancing, for the duration of a session; persistent cookies for customizing the user interface, for the duration of a session (or a little more); cookies for sharing content through third party social plug-ins, for members of a social network who have logged in.

The Data Controller therefore informs that technical cookies (such as those listed above) are operational on the Site, which are necessary to navigate the Site as they allow essential functions such as authentication, validation, management of a browsing session and fraud prevention and allow for example : to identify whether the user has had regular access to the areas of the site that require prior authentication or user validation and the management of sessions relating to the various services and applications or the storage of data for access in a secure mode or the functions of control and prevention of fraud. Furthermore, analytical and profiling cookies are operational.

For maximum transparency, a series of technical cookies and cases of specific operation on the Site are listed below.

  • cookies implanted in the user’s / contractor’s terminal directly (which will not be used for other purposes) such as session cookies used to “fill the cart” in online reservations on the Site, authentication cookies, cookies for multimedia content such as flash players that do not exceed the duration of the session, personalization cookies (for example, for the choice of the navigation language, recall of the complete ID and password by typing the first characters, etc);
  • the cookies used to statistically analyze accesses / visits to the site (so-called “analytics” cookies) that exclusively pursue statistical purposes (and not even profiling or marketing) and collect information in aggregate form without the possibility of tracing the identification of the individual user. In these cases, since the current legislation requires that for analytics cookies the interested party is provided with a clear and adequate indication of the simple ways to oppose (opt-out) to their system (including any anonymization mechanisms of the cookies themselves) , we specify that it is possible to deactivate analytics cookies as follows: open your browser, select the settings menu, click on the internet options, open the privacy tab and choose the desired cookie blocking level. If you want to delete the cookies already saved in the memory, simply open the security tab and delete the history by checking the “delete cookies” box.

Third party cookies:

By visiting a website, you may receive cookies from sites managed by other organizations (“third parties”) that may reside in Italy or abroad.

An example present on most websites is represented by the presence of YouTube videos, Google API, use of Google Maps, and the use of “social plugins” for Facebook, Twitter, Google+ and LinkedIn. These are parts of the visited page generated directly by the aforementioned sites and integrated into the page of the host site. The most common use of social plugins is aimed at sharing content on social networks in order to increase the visitor’s user experience.

The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by “third parties” is governed by the relevant information to which reference should be made. To ensure greater transparency and convenience, the web addresses of the various information and methods for managing cookies are shown below, specifying that the Data Controller has no responsibility for the operation of third-party cookies on this Site.

Google information: on the use of data at the link http://www.google.com/policies/technologies/cookies/ and complete information at the link http://support.google.com/analytics/answer/6004245

Google (configuration): the general out-out guide for Google services (Maps, YouTube …) is available at the web address http://support.google.com/accounts/answer/61416?hl=it

Facebook information: https://www.facebook.com/help/cookies/ and https://it-it.facebook.com/about/privacy/cookies

Facebook (configuration): log into your account. Privacy section. Or follow the various guides on the web for example https://support.mozilla.org/en-US/kb/disable-third-party-cookies

Analysis cookies (Analytics)

The Site uses the Google Analytics service but intervention is required to make the IP anonymous with the tools offered by Google. See the Google cookie policy for Google Analytics at the following link http://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage and learn more about the method by which Google – third party – uses the data of its users at the link https://support.google.com/analytics/answer/6004245.

As clarified by the General Provision of the Privacy Guarantor on cookies of 8 May 2014, analytics cookies are assimilated to technical cookies when used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site. : these are exactly the functions and purposes of the processing on this Site.

You can still opt-out by visiting the website http://tools.google.com/dlpage/gaoptout?hl=en by performing the opt-out, it is also possible to deny consent and block third-party cookies through plugins for browsers, searching on Google “block and delete third-party cookies” there are many guides that differ depending on the operating system and browser used.

Responsibility for the operation of Third Party Cookies.

In this regard, reference is made to the provisions of the General Provision of the Privacy Guarantor on cookies of 8 May 2014: “There are multiple reasons why it is not possible for the publisher to provide the information and obtain consent to the ‘installation of cookies within its site also for those installed by “third parties”. First of all, the publisher should always have the tools and the economic-legal capacity to take on the obligations of third parties and should therefore also be able to verify from time to time the correspondence between what is declared by the third parties and the purposes they actually have. prosecuted with the use of cookies. This is made very difficult by the fact that the publisher often does not directly know all the third parties that install cookies through their site and, therefore, not even the logic underlying the related processing. In addition, it is not uncommon for the publisher and third parties to interfere with subjects who play the role of concessionaires, making it very complex for the publisher to control the activities of all those involved. Third-party cookies could then be modified over time by third-party suppliers and it would be impractical to ask publishers to keep track of these subsequent changes as well.”
As indicated by the Privacy Guarantor, this Site does not have the ability to control third-party cookies if it uses third-party services (YouTube, Google Maps, “social buttons”) for which only third parties are responsible. Furthermore, the possibility is recalled for the user to cancel and block the operation of cookies at any time by also using plugins for the browser and changing their settings as indicated in the various manuals contained in the browsers.

Mandatory or optional consent for the operation of cookies that do not pursue marketing purposes.

It is not mandatory to obtain consent to the operation of only technical or third-party or analytical cookies similar to technical cookies. Their deactivation and / or denial of their operation will result in the impossibility of proper navigation on the Site and / or the inability to use the services, pages, features or content available there.

Exercise of rights by the interested party.
Pursuant to articles 13, paragraph 2, letters (b) and (d), from 15 to 22 of the Regulation, the interested party is informed that:

  • has the right to ask the Company for access to personal data, the correction or cancellation of the same or the limitation of their processing or to oppose their processing, in the cases provided;
  • has the right to lodge – in Italy – a complaint with the Guarantor for the protection of personal data, if competent authority, following the procedures and indications published on the official website of the Authority on garanteprivacy.it;
  • alternatively, has the right to lodge a complaint with another competent European privacy authority located in the place of habitual residence or domicile in Europe of whoever disputes a violation of their rights, following the appropriate procedures and indications;
  • any corrections or cancellations or limitations of processing carried out at the request of the interested party – unless this proves impossible or involves a disproportionate effort – will be communicated by the Firm to each of the recipients to whom the personal data have been transmitted. The Firm may communicate these recipients to the interested party if the interested party requests it.

The exercise of rights is not subject to any formal constraints and is free. Only in the event of a request for additional copies of the data requested by the interested party, the Firm may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format. The specific address of the Company to transmit requests for the exercise of rights as recognized by the Regulations is as follows: info@tradizioniassociate.com No other formalities are required. The reply will be given within the terms provided for in article 12, paragraph 3 of the Regulation (“The data controller provides the data subject with information relating to the action taken regarding a request pursuant to articles 15 to 22 without undue delay and, in any case, at the latest within one month of receipt of the request. This deadline can be extended by two months, if necessary, taking into account the complexity and number of requests. The data controller informs the interested party of this extension, and of the reasons for the delay, within one month of receipt of the request. If the interested party submits the request by electronic means, the information is provided, where possible, by electronic means, unless otherwise indicated by the interested party“).
Based on the provisions of the WP 260/2017 Transparency Guidelines issued by the Group of EU Guarantors, the data controller must specify a summary / summary of each right in question in the indication of the rights of the data subject and must provide separate indications. on the right to portability.

Specific information on the right to the portability of personal data.

The Company informs the interested party about the specific right to portability. Article 20 of the General Data Protection Regulation introduces the new right to data portability. This right allows the interested party to receive the personal data provided to the Firm in a structured format, commonly used and readable by an automatic device, and – under certain conditions – to transmit them to another data controller without hindrance.

Only personal data that (a) concern the interested party, and (b) have been provided by the interested party to the Firm on the basis of consent are portable; (c) are processed electronically as part of the stipulation of a contract.

Since the processing is not based on consent or on a contract, the right to portability does not apply.

Summary information on the other rights of the interested party.

The Regulation grants the interested party a series of rights which, pursuant to the WP 260 Transparency Guidelines, it is mandatory to summarize in their main content within the information. These rights are summarized and summarized below:

Right of access (to personal data only): the right to obtain from the data controller confirmation that personal data concerning the data subject is being processed and, in this case, to obtain access to personal data and to be informed about the purposes of the processing; on the categories of personal data in question; on the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients of third countries or international organizations; when possible, on the retention period of personal data provided or, if not possible, on the criteria used to determine this period; if the data have not been collected from the data subject, the right to receive all available information on their origin; the right to receive information on the existence of an automated decision-making process, including profiling and significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.

Right of rectification and integration: The interested party has the right to obtain from the data controller the correction of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the interested party has the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration. The data controller communicates any corrections to each of the recipients to whom the personal data have been transmitted, unless this proves impossible or involves a disproportionate effort. The data controller informs the data subject of these recipients if the data subject requests it.

Right to cancellation: the interested party has the right to obtain from the data controller the cancellation of personal data concerning him without undue delay (and where the specific reasons of art.17 paragraph 3 of the Regulation do not exist, which on the contrary raise the holder from the cancellation obligation) if the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; or if the interested party revokes the consent and there is no other legal basis for the processing; or if the interested party opposes the processing for marketing or profiling purposes, even by revoking the consent; if the personal data have been unlawfully processed or relate to information collected from minors, in violation of art. 8 of the Regulation. The data controller communicates any cancellations to each of the recipients to whom the personal data have been transmitted unless this proves impossible or involves a disproportionate effort. The data controller informs the data subject of these recipients if the data subject requests it.

Right to limitation of treatment: the interested party has the right to obtain from the data controller the limitation of treatment (ie, pursuant to the definition of “limitation of treatment” provided by Article 4 of the Regulation: “the personal data marking stored with the aim of limiting their processing in the future “) when one of the following hypotheses occurs: the data subject disputes the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; the processing is unlawful and the interested party opposes the deletion of personal data and instead requests that its use be limited; although the data controller no longer needs it for processing purposes, the personal data are necessary for the data subject to ascertain, exercise or defend a right in court; the interested party opposed the marketing treatment, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party. If the processing is limited, these personal data are processed, except for storage, only with the consent of the interested party or for the assessment, exercise or defense of a right in court or to protect the rights of a other natural or legal person or for reasons of significant public interest The interested party who has obtained the limitation of the processing is informed by the data controller before said limitation is revoked. The data controller communicates any limitations to each of the recipients to whom the personal data have been transmitted, unless this proves impossible or involves a disproportionate effort. The data controller informs the data subject of these recipients if the data subject requests it.

Right to object: the interested party has the right to object at any time, for reasons connected to his particular situation, to the processing of personal data concerning him carried out by the owner or for the execution of a task of public interest or connected to the exercise of public authority vested in the data controller or carried out for the pursuit of the legitimate interest of the data controller or third parties (including profiling). Furthermore, the interested party, if personal data are processed for direct marketing or commercial profiling purposes, has the right to object at any time to the processing of personal data concerning him / her carried out for these purposes.

Right not to be subjected to automated decisions, including profiling: the interested party has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects him on his person, except in cases where the automated decision is necessary for the conclusion or execution of a contract between the data subject and a data controller; is required by law, in compliance with measures and precautions; is based on the explicit consent of the interested party.