Privacy and cookie policy

This site is managed by “Conform – Consulenza Formazione e Management S.c.a.r.l.” and this Policy explains the purpose of personal data processing in this website, the use of cookies and the manner of exercising rights granted to users.

Navigation data

The computer systems and software procedures used to operate this website acquire, during normal operation, some personal data whose transmission is implicit in  Internet communication protocols. This information is not collated to be associated to interested parties, but for its very nature could, through processing and association of data held by third parties, identify users. This category of data includes IP addresses or users’ computer domain names when connecting to the site, URI (Uniform Resource Identifiers) of requested resources, times of request, methods used to submit  requests to the server, the file size obtained in response, the numerical code indicating the status of response from the server (successful, error, etc.) and other parameters regarding the operating system and computer environment. This data is only used to obtain anonymous statistical information about the site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to damage this site:  except for this case, the data on web contacts are not kept for more than seven days.

Data provided voluntarily by users

The optional, explicit and voluntary sending of e-mail addresses indicated on this site involves the acquisition of the sender’s address to respond to requests, and any other data included in the message. Specific summary information will be progressively reported or displayed on web pages dedicated to particular services requested.

The purposes and methods of personal data processing in this website or otherwise will conform with provisions of Regulation UE 679/2016.

Sensitive data

Conform – Consulenza Formazione e Management S.c.a.r.l. neither requires nor collects sensitive personal information through this website (such as information that could reveal racial or ethnic origin, political belief, philosophical or religious convictions, sexual habits or medical data). Should this not be the case, prior written consent or equivalent will be requested.

Cookies

Conform – Consulenza Formazione e Management S.c.a.r.l. may collect, process and analyse information regarding usage of this web site, including domain names, number of hits, pages visited, previous or subsequent sites visited and length of user login sessions. This information can be collected through the use of cookies. A cookie is a text file that resides on your hard drive, where it was sent through our server web page. Cookies allow efficient operation of the site and improve its performance.

There are several types of cookies. Here follow the types of cookies that may be used in the site with a description of aims linked to use.

• Technical Cookies: these cookies are necessary for the proper functioning of some site areas. Cookies in this category include both persistent cookies and session cookies. Without these cookies, the site or parts of it may not work properly.
• Analytical Cookies: these cookies are used to collect information on the use of the website by visitors, keywords used to reach the site, websites visited and origins of visitor traffic for marketing campaigns. The cookies collect information in an anonymous way. Cookies of this type are sent from the site itself or from third-party domains.
• Cookies for the integration of third-party functionality: these cookies are used to integrate third-party functionality in the site (for example, forms for comments or social networks icons that allow visitors to share the site content ). This type of cookie can be sent from the domains of partner sites or actually offer the site features.
• Profiling Cookies: these aim to create user profiles and are used in order to send advertising messages in line with user preferences when surfing the net. This site does NOT use these types of cookies.

Third-party Cookies

When visiting a website you may receive cookies from the site visited (“owners”) and from websites maintained by other organizations (“third parties”). An example on our site is the presence of “social plugins” for Facebook, Twitter, Google+, Youtube and LinkedIn. These are parts of the page visited generated directly by these sites and integrated into the site host page. The most common use of social plugins aims at sharing content on social networks.

The presence of these plugins involves the transmission of cookies to and from all sites operated by third parties. The management of the information collected by “third parties” shall be governed by the relevant information that you are asked to refer to. To ensure greater transparency and convenience, here follow web addresses concerning information and ways to manage cookies.

• Facebook policy (access one’s account -> privacy section)
• Instagram policy
• Twitter policyTwitter settings
• Linkedin policy Linkedin settings
• YouTube policy YouTube settings

Matomo Analytics

This site makes use of the tracking service offered by “Matomo On-Premise” (Piwik) and the data collected via its cookies are stored directly in an internal statistics system installed on a server in France owned by OVHcloud for the sole purpose of analysing the visitor’s interest in the web content offered. Visitors’ IP addresses are anonymised, and the data collected via Matomo (Piwik) are managed directly by Conform S.c.a.r.l. in order to optimise and improve the dissemination service and assess the implementation of the most visited areas of the site, and will not be passed on to third parties.

For each session, Matomo will keep track of the following information:

• the visitor’s IP address (made completely anonymous 0.0.0)
• the user ID (Matomo replaces the user ID with pseudonyms – unique random identifiers – for complete respect of user privacy) to find out more see: https://matomo.org/faq/reports/user-id-privacy-considerations/
• Date and time of request
• Number of visits by the user (based on the unique pseudonym)
• Title of the page viewed (Title of the page)
• URL of the page viewed (URL of the page)
• URL of the page viewed before the current page (Referrer URL)
• Screen resolution in use
• Time in local user’s time zone
• Clicked and downloaded files ( Downloads )
• Links to an external domain clicked on ( Outlinks )
• Page generation time (the time it takes for web pages to be generated by the web server and then downloaded by the user: page speed )
• Location of the user: country, region, city, approximate latitude and longitude (Geolocation)
• Main language of the browser used (Accept-Languageheader)
• User Agent of the browser used (User-Agentheader)
• From the User-Agent, we use our Universal Device Detection library to detect the browser, operating system, device used (desktop, tablet, mobile, TV, car, console, etc.), make and model.

For Matomo’s (Piwik) general privacy policy, see: https://matomo.org/faq/general/faq_146/

Cookie duration

Some cookies (session cookies) remain active only until you close the browser. Other cookies “survive” the closure of the browser and are also available in future user visits. These cookies are known as persistent and their duration is set by the server at the time of their creation. In some cases there is a fixed deadline, in other cases duration is unlimited. This site does not use persistent cookies. However, navigating the pages of this website, you can interact with sites operated by third parties that can create or modify persistent cookies and profiling.

Cookie management

Users can decide whether to accept cookies using the settings on their browsers. Warning: total or partial disabling of the technical or third-party cookies may affect the use of some website features. The best browsers allow you to define different settings for cookie “owners” and those of “third parties”. The following web resources illustrate how to proceed for each of the major browsers: Chrome https://support.google.com/chrome/answer/95647?hl=it Mozilla Firefox https://support.mozilla.org/it/kb/Gestione%20dei%20cookie Internet Explorer http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9 Opera http://help.opera.com/Windows/10.00/it/cookies.html Safari  http://support.apple.com/kb/HT1677?viewlocale=it_IT Third Party Web Sites

Users are informed that this Policy does not include the privacy policies adopted by third-party websites to which this site may be linked.

Exercising user rights

If the user is a consumer, the processing of personal data for commercial or marketing purposes will be based on the acquisition of prior and specific consent. If the user is a professional and no longer wishes to receive any advertising messages fromConform – Consulenza Formazione e Management S.c.a.r.l. or for any questions or requests about the treatment of personal data, including the integration, updating or rectification, please contact us at the following address [email protected]

EXERCISE OF USER RIGHTS

General aspects

In accordance with the provisions of the GDPR, the Data Controller facilitates the exercise of the rights of the individual concerned, bearing in mind that the related interactions and communications must always respect the following criteria:

• concise form,
• transparent,
• intelligible and easily accessible, with simple and clear language, in particular in the case of information intended specifically for minors.

Information is provided in writing or by other means, including, where appropriate, by electronic means. Although it is foreseen that upon express request by the interested party, information can be provided orally, the Data Controller, except in specific cases, tends to prefer the written form.

Terms and timing

The Data Controller provides the interested party with information relating to the action taken regarding a request without undue delay and, in any case, at the latest within one month of receiving the request. In accordance with the provisions of the GDPR, this term can be extended by two months, if necessary, taking into account the complexity and the number of requests: in this case, the Data Controller will inform the interested party of this extension, and the reasons for the delay, within one month of receiving the request. If the interested party submits the request by electronic means, the information is provided, where possible, by electronic means, unless otherwise indicated.

Exercisable rights

The interested party has the right to obtain confirmation that personal data concerning him or her is being processed.

Furthermore, the interested party has the right to obtain access to personal data as well as to the following information:

1. the purposes of the treatment;
2. the categories of personal data in question;
3. the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular if recipients from third countries or international organizations;
4. when possible, the retention period of the personal data foreseen or, if not possible, the criteria used to determine this period;
5. the existence of the right of the interested party to ask the data controller to rectify or delete personal data or limit the processing of personal data concerning him/her or to oppose its treatment;
6. the right to lodge a complaint with a supervisory authority;
7. if the data is not collected by the interested party, all information available on its origin;
8. the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such treatment for the interested party.

If personal data is transferred to a third country or to an international organization, the interested party has the right to be informed of the existence of adequate guarantees pursuant to article 46 relating to the transfer. The Data Controller provides a copy of the personal data being processed, and if the interested party requests further copies, he/she can charge a reasonable fee for costs based on administrative costs.

The interested party also has the right to obtain the correction of inaccurate personal data concerning him/her without undue delay, and 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 an additional declaration.

The interested party has the right to obtain from the data controller the cancellation of personal data concerning him/her without undue delay and the data controller has the obligation to delete personal data without undue delay, if one of the following reasons exists:

1. personal data is no longer necessary with respect to the purposes for which it was collected or otherwise processed;
2. the interested party revokes the consent and if there is no other legal basis for processing (for example, a legal obligation);
3. the interested party opposes the processing and there is no prevailing legitimate reason to proceed with the processing (for example, a legal obligation);
4. personal data has been unlawfully processed;
5. personal data must be deleted in order to fulfil a legal obligation under Union or Member State law to which the data controller is subject;
6. personal data has been collected in relation to the offer of information society services.

If the Data Controller has made personal data public and is obliged to delete it, taking into account the available technology and implementation costs, he/she adopts reasonable measures, including technical measures, to inform the data controllers who are processing the personal data of the request of the interested party to delete any link, copy or reproduction of personal data.

The interested party has the right to obtain the limitation of processing by the data controller when one of the following hypotheses occurs:

a) the interested party disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data;

b) the treatment is unlawful and the interested party opposes the cancellation of personal data and instead requests that its use be limited;

c) although the data controller no longer needs it for processing purposes, personal data is necessary for the interested party to ascertain, exercise or defend a right in court;

d) the interested party has opposed the processing pursuant to Article 21, paragraph 1, pending verification of the possible prevalence of the legitimate reasons of the data controller with respect to those of the interested party.

If the treatment is limited, this personal data is processed, except for storage, only with the consent of the interested party or for the assessment, exercise or defence of a right in court or to protect the rights of another natural or legal person or for reasons of significant public interest of the Union or a Member State.

The interested party who obtained the limitation of treatment is informed by the data controller before said limitation is lifted.

The data controller will inform each of the recipients who have provided their personal data of any corrections or cancellations or limitations of the processing carried out, unless this proves impossible or involves a disproportionate effort. The data controller will communicate these recipients to the interested party if the interested party should request it.

The interested party has the right to receive personal data concerning him/her provided to a data controller in a structured format, commonly used and readable by an automatic device, and has the right to transmit this data to another data controller without impediments by the data controller to whom it was provided if:

1. the processing is based on consent pursuant to Article 6, paragraph 1, letter a), or Article 9, paragraph 2, letter a), or on a contract pursuant to Article 6, paragraph 1, letter b); and the processing is carried out by automated means.
2. In exercising their rights relating to data portability pursuant to paragraph 1, the interested party has the right to obtain the direct transmission of personal data from one data controller to the other, if technically feasible.
3. The exercise of the right referred to in paragraph 1 of this article is without prejudice to Article 17. This right does not apply to the processing necessary for the performance of a task in the public interest or connected to the exercise of public authority of the data controller.

The request to exercise rights can be exercised by sending an email to the address above.

Changes

Considering that the state of improvement of control mechanisms does not make them exempt from errors and malfunctions, please note that Conform – Consulenza Formazione e Management S.c.a.r.l. reserves the right to modify in whole or in part at any time this Policy and asks you to consult from time to time the current version to check for any changes.