DATA PROTECTION POLICY
EC Directive 2002/58/EC – on the processing of personal data and protection of private life in the field of electronic communications
EU Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with reference to the processing of their personal data, as well as the free circulation of such data, abrogating the EC directive 95/46/EC (General Data Protection Regulation)
THE DATA CONTROLLER
Following the surfing of this web site, data concerning identified or identifiable persons can be processed. The Data Controller is District Advisory S.r.l., seated in via A. Saffi 25, 20123 Milano (MI) – Italy
DATA PROCESSING PLACE AND STORING TIMES
The processing operations connected with the web services of this site are carried out at the seat of the above-specified Data Controller only by the expressly authorized staff, or by possible third suppliers in charge of occasional maintenance operations, appointed as Data Processors pursuant to article 28 of the GDPR. The collected data will be stored – for each type of data processed – only for the time needed to carry out the specific purposes explained in the special summarizing information notices displayed in the pages of the web site and drawn up for particular services.
TYPES OF DATA PROCESSED
The information systems and the software procedures needed for the operation of this web site acquire, during their normal exercise, some personal data whose transmission is implicit in the use of the Internet communication protocols. Such data are not collected to be associated with identified Data Subjects, but due to their nature, they could allow to identify the users, through processing and association with data held by third subjects. To this category of data belong the IP addresses or the domain names of the PC used by the users who connect to the web site, the URI notation addresses of the required resources, the time of the request, the method used while sending the request to the server, the dimension of the file obtained as an answer, the numeric code specifying the status of the answer given by the server (successful, error, etc.) and other parameters concerning the operation system and the user’s information environment. Such data are used only in order to obtain anonymous statistical information on the use of the web site and to control the correct operation and are cancelled immediately after their processing. The data could be used to ascertain the liability in case of possible cybercrimes damaging the web site.
Data voluntarily supplied by the user
The optional, explicit and voluntary supply of personal data by the user in the registration forms present in this web site entails the following acquisition of the data supplied by the sender, needed to provide the service required. Specific summarizing Information Notices will be progressively shown or displayed in the pages of the web site created for particular services upon request.
Anonymous or aggregated data
Anonymisation is a processing aimed at preventing the Data Subject’s identification. The data made anonymous don’t belong to the application field of the data protection regulation. We collect, process and share aggregated data as statistical or demographical data for different purposes. The aggregated data can derive from personal data supplied by the user but are not considered personal data since, as specified, they don’t allow to directly or indirectly identify the Data Subject. Such data will be used even in order to improve the quality of our existing products/services, to develop new functions, as well as for further general research purposes (for example, in order to check the frequency with which a specific product or service is used; to calculate the percentage of users accessing a specific function of the web site, etc.). Since such data don’t allow to identify a natural person and aren’t considered personal, they will be shared with further third parties, subsidiaries, parent companies or partners.
Cookies are little text files containing a certain quantity of information exchanged between a web site and the user’s terminal (usually, the browser). They are mainly used with the purpose of operating the web sites in a more efficient way and of providing information to the web site’s owners. Cookies can be session or persistent ones. Session cookies are stored in the terminal for a short time and eliminated as soon as the user closes the browser. Their use is strictly limited to the transmission of the session identifiers (constituted by numbers generated random by the server) needed to allow the safe and effective surfing of the web site. Persistent cookies, on the contrary, are stored in the user’s terminal up to a pre-set period of time. Since they are not cancelled directly at the closure of the browser, they allow to remember the user’s choices made on its web site, as well as to collect information on the pages of the web site that have been surfed by the user, the frequency with which the site is surfed and to identify the user’s surfing path, in order to improve the experience on the web site. Session or persistent cookies can be internal or third party’s cookies, depending on the subject that installs them on the user’s terminal. If it’s the manager of the web site the user is surfing we speak of internal cookies, if it’s a different subject, we speak of third parties’ cookies.
Cookies used by this web site
http://www.google.com/intl/it/policies/technologies/cookies/ and https://developers.google.com/analytics/devguides/collection/analyticsjs/cookies-usage
the information notice for Google Analytics’ data protection policy, at the following link: http://www.google.com/intl/en/analytics/privacyoverview.html
In the following table the cookies currently present in the web site are detailed
More than the cookies in the above table, this web site can avail itself even of further session cookies, that is the ones that are not stored in a persistent way on the user’s PC and disappear while closing the browser. Their use is strictly limited.
Usually, browsers allow to control most of the cookies through the settings of the browser. However, the total or partial disabling of the so-called technical cookies can compromise the use of the web site functions. Anyway, in case users don’t want to receive the cookies on their processor, neither from this site, nor from others, they can increase the data protection level, by modifying the security settings of the browser:
Mozilla Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Google Chrome: https://support.google.com/chrome/answer/95647?hl=it
Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
Safari 6/7 Mavericks: https://support.apple.com/kb/PH17191?viewlocale=it_IT&locale=it_IT
Safari 8 Yosemite: https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=it_IT
Safari on iPhone, iPad, or iPod touch: https://support.apple.com/it-it/HT201265
LINK TO OTHER WEB SITES
This web site could contain links or references for the access to other sites, such as for example the following social networks: Facebook, Instagram, Google+, Twitter and Pinterest. By clicking on the special links, for example, our contents can be shared. We inform you that the Data Controller doesn’t control the cookies or other monitoring technologies of such web sites to which this policy doesn’t apply.
OPTIONAL SUPPLY OF DATA
Apart from what has been specified for the surfing data, users are free to supply their personal data or not. However, the non-supply of them can entail the impossibility to obtain what has been asked.
The personal data are processed even with the aid or automated devices. Specific security measures are taken in order to prevent the loss of data, the unlawful or wrong use of them and the non-authorized accesses. The Data Controller adopted all minimum security measures provided by the law and inspired to the main international standards. Besides, it adopted further security measures to minimize the risks on confidentiality, availability and integrity of the personal data collected and processed.
SHARING, COMMUNICATION AND DIFFUSION OF DATA
The collected data can be transferred or communicated to other companies for activities strictly connected and instrumental to the operativeness of the service, such as the management of the information system. The personal data provided by the users that submit requests of literature (brochures, etc.) are used only in order to execute the service or performance required and communicated to third parties only in case it is necessary for such purpose (companies providing enveloping, labelling, shipment services). Apart from these cases, personal data won’t be communicated unless there’s a contractual or legal provision, or upon specific consent by the Data Subject.
Personal data could be transmitted to third parties, but only in case:
- There’s an explicit consent to share the data with third parties;
- There’s the need to share information with third parties in order to provide the service required;
- It’s needed in order to meet a request by the judicial or public security authorities.
No data deriving from the web service are disseminated.
DATA SUBJECTS’ RIGHTS
The regulation protecting the personal data expressly provides some rights for the subjects to whom the data are referred (the so-called Data Subjects). In particular, pursuant to articles 15 and following ones of the EU Regulation 2016/679, each Data Subject has the right to obtain the confirmation of the existence of his/her data, to obtain the specification about the origin, purposes and methods of processing, the updating, rectification, integration of data, as well as their cancellation in case they are processed infringing the law or in case one of the reasons specified in article 17 of the EU Regulation 2016/679 should exist.
MODIFICATIONS TO THIS DATA PROTECTION POLICY
The Data Controller periodically controls its data protection and security policy and – if needed – reviews it in connection with modifications deriving from regulations or organization or dictated by the technological evolution. In case the policy should be modified, the new version will be published on this web page.
QUESTIONS, CLAIMS, SUGGESTIONS AND EXERCISE OF RIGHTS
Those who are interested in more information, who want to contribute with their suggestions or make a claim on the data protection policy or on the way our Company processes the personal data, or want to assert the rights provided by the data protection regulation, can contact the Data Controller, writing to Palmer Corporate Finance S.r.l., seated in via A. Saffi, 25, 20123 Milano (Italy), or sending an email to firstname.lastname@example.org.