PRIVACY POLICY

INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 OF REGULATION (EU) 679/2016

QUATTROCAPPA SOC. COOP , as Data Controller (hereinafter, “QUATTROCAPPA“, “4K“), under the EU Regulation 679/2016 (from now on:” Regulation“) – takes the privacy and data protection as the main focus of its business.

We invite you, before communicating any personal data to 4K, to read carefully this privacy policy because it contains important information on the protection of your personal data.

This Privacy Policy entails the following:

Intended for the site https://quattrocappa.com/ (from now on: “Site“);

An integral part of the website and the services we offer;

Is given under article 13 of the Regulation, to those who interact with the web services of the Site, or by simply consulting the Site.



INDEX


1) Data controller

2) Personal data processed

a. Navigation data
b. Special categories of personal data
c. Data provided voluntarily by the data subject

3) Purpose of the processing

4) Legal basis and mandatory or optional nature of the processing

5) Recipients of personal data

6) Transfers of personal data

7) Storage of personal data

8) Rights of the data subject

9) Changes

10) Cookies



1) Data controller
The controller of the processing carried out through the website is QUATTROCAPPA SOC. COOP (“4K”).


2) Personal data processed
The personal data processed through the Website are the following:
Contact details such as name, surname, email and telephone.
Particular data could be processed if freely given by you sending e-mail requests.


a. Navigation data
The computer systems and software procedures used to operate the 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 data subjects, 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 IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, at 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 (success, error, etc.) and other parameters related to the operating system and the user’s computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the website and to check its correct functioning  to identify anomalies and/or abuse and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the site or third parties: except for this possibility, the data on web contacts do not persist for more than seven days.



b. Special categories of personal data
In the use of the “Contacts” section of the Site, it may be possible to provide personal data”. We invite you to communicate such data only when strictly necessary. It is paramount to remember that in in case of the transmission of your special categories of data, in the absence of specific manifestation of consent to process such data (eventuality that however obviously allows you to send a curriculum vitae), QUATTROCAPPA can not be held responsible in any way, nor can receive disputes of any kind, since in this case the processing will be allowed as having data object made manifestly public by the data subject, in accordance with the art. 9 (1)(e) of the Regulation. However, we specify the importance, as mentioned above – to express the explicit consent for the processing of the special categories of personal data where you decide to share such information.



c. Data Provided Voluntarily by the Data Subject
In using some Site Services, personal data may be processed by third parties sent by you to QUATTROCAPPA. With respect to these hypotheses, you act as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, you will be charged of any objection, claim or request for compensation expressed to 4K by third parties whose personal data were processed through your use the Site in violation of the rules on data protection. In any case, if you provide or otherwise process personal data of third parties when using the Site,  guarantees from now – and taking any related liability – that this particular hypothesis of processing is based on a suitable legal basis under Art. 6 of the Regulation that legitimizes the processing of the information in question.



3) Purpose of the Processing
The processing that we intend to carry, behind your specific consent where necessary, has the following purposes:

a) registration to the site;

b) newsletter subscription via email;

c) sharing of content on the site;

d) generic request for information;

e) request of quotation and or services provided by QUATTROCAPPA sponsorships, marketing initiatives;

f) analysis of curriculum vitae for purposes of collaboration.

g) fulfilling any legal, accounting and tax obligations.



4) Legal basis and mandatory or optional nature of the processing

The legal basis for personal data processing for the purposes set out in section 3a-b is art. 6 (1)(b) of the Regulation as the processing is necessary for the supply of the services or for the response of requests by the data subject. The provision of personal data for these purposes is optional, but if you do not provide it would make impossible to activate the services provided by the Site. The purpose of section 3c represents a legitimate processing of personal data pursuant to art. 6 (1)(c) of the Regulation. Once the personal data has been provided, the processing is actually necessary to fulfill a legal obligation to which QUATTROCAPPA is subject. For the processing carried out for the purpose of sending direct advertising material or direct sales or for carrying out market research or commercial communications in relation to products or services of QUATTROCAPPA similar to those you requested, QUATTROCAPPA may use, without your consent, e-mail and paper mail addresses pursuant to and within the limits allowed by the provision of the Data Protection Authority of 19 June 2008; the legal basis of the processing of your data for this purpose is art. 6(1)(f) of the Regulation.


5) Recipients of Personal Data

Your personal data may be shared, for the purposes referred to in Section 3 above, with:

1) subjects that typically act as data controllers pursuant to art. 28 of the Regulation, namely:

    I. persons, companies or professional firms that provide assistance and advice to QUATTROCAPPA in accounting, administrative, legal, tax, financial and debt collection matters relating to the supply of services;
    II. subjects with whom it is necessary to interact for the supply of services (for example hosting providers);
    III.  or subjects delegated to perform technical maintenance activities (including maintenance of network equipment and electronic communications networks); (collectively “recipients”); the list of data processors who process data can be requested from the data controller.

2) subjects, bodies or authorities, autonomous data controllers, to whom it is mandatory to communicate your personal data under the provisions of law or orders of the authorities;

3) persons authorized by QUATTROCAPPA to the processing of Personal Data pursuant to art. 29 of the Regulation necessary to carry out activities strictly related to the supply of services, which are committed to confidentiality or have an appropriate legal obligation of confidentiality (e.g. employees of QUATTROCAPPA).



6) Data Retention

Personal Data processed for the purposes referred to in section 3a-b will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and storage limitation, ex art. 5(1)(e) of the Regulation. In any case, the data controller will process personal data for the time necessary to fulfill contractual and legal obligations.

Further information about the data retention period and the criteria used to determine this period can be requested by writing to the data controller.



7) Rights of the data subject

Pursuant to articles 15 and following of the Regulation, you have the right to ask at any time for access to your personal data; the correction or cancellation of the same, the restriction of the processing in the cases  provided  by art. 18; obtaining, in a structured format, in common use and readable by automatic device, the data concerning you, in the cases provided for by art. 20. At any time, you can withdraw (ex art. 7) the consent given; lodge a complaint to the competent authority pursuant to article 77, if you consider that the processing of your data is contrary to the law in force. You can make a request to object to the processing of your data pursuant to Article 21 in which you have to give evidence of the reasons that justify the objection: the data controller reserves the right to evaluate the application, which would not be accepted in case of legitimate reasons to proceed with the processing that prevail over your interests, rights and freedom.Requests must be made in writing to the data controller.



8) Changes

This privacy policy is effective from 01 Genuary 2019. QUATTROCAPPA reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation.QUATTROCAPPA will inform you of these changes as soon as they are introduced and they will be binding as soon as published on the Site. QUATTROCAPPA invites you to visit this section regularly to get to know the most recent and updated version of the privacy policy in order to be always up to date on the collected data and on the use made by QUATTROCAPPA .



9) Cookies

This cookie policy refers exclusively to the Site and must be understood as an integral part of the Privacy Policy of the same.

a) Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on his/her computer or mobile device, then are re-transmitted to the same sites at the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as login data, the chosen language, font size, other display settings, etc.) so that they do not have to be re-indicated when the user returns to visit the site or browser from one page to another. Cookies, therefore, are used to perform computer authentication, monitoring sessions and storing information regarding the activities of users accessing a site and may also contain a unique identification code that allows to track the user’s navigation inside of the site itself for statistical or advertising purposes. During navigation on a site, the user can also receive on his/her computer or mobile device cookies of websites or web servers other than the one he/she is visiting (so-called “third-party” cookies). Some operations could not be performed without the use of cookies, which in some cases are technically necessary for the same functioning of the site.

There are various types of cookies, depending on their characteristics and functions, and these can remain in the user’s computer or mobile device for different periods of time: e.g. session cookies are automatically deleted when the browser is closed; e.g. persistent cookies remain on the user’s equipment until a predetermined deadline.

According to the legislation in force in Italy, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Guidelines for Identification of the simplified procedures for the disclosure and acquisition of the   consent for the use of cookies   of 8 May 2014, hereinafter only “Ruling”) also includes:

For “profiling cookies”, vice versa, i.e. those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent of the user is required.

b) Types of cookies used by the site

The website uses the following types of cookies, and offers the possibility to de-select the same, except for third-party cookies for which the user must refer directly to the relative methods of selection and de-selection of the respective cookies, indicated by links:

    Technical cookies – navigation or session – strictly necessary for the operation of the site or to allow the user to take advantage of the contents and services requested by them.

    Cookie analytics , which allow the site manager to understand how this is used by users. With these cookies are not collected information about the user’s identity or any personal data. The information is processed in aggregate and anonymous form.

    Functionality cookies, used to activate specific functions of the site and a series of selected criteria (for example, language, products selected for purchase) in order to improve the service rendered.

    Profiling cookies, aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.

WARNING: by disabling technical and/or functional cookies, the site may not be available for consultation or certain services or certain functions of the site. They may be unavailable or not working properly, and you may be forced to change or manually insert some information or preferences each time you visit the site.

4K uses third-party cookies, i.e. cookies of sites or web servers other than that of the owner, used for the purposes of these third parties, including analytical cookies and profiling . It should be noted that these third parties, listed below with the relative hypertext links to the privacy policies, act as   independent data controllers collected through the cookies sent by them therefore, the user must refer to their data processing policies   personal, informative and possible forms of consent collection (selection and de-selection of the respective cookies).

    The links to the respective information on the use of cookies are listed below:

    Google: https://www.google.it/intl/it/policies/technologies/types/

    Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=en-GB

    In detail, cookies sent directly through the website are shown below:

    Please refer to the specific page COOKIE POLICY on this website.

c) How to view and modify cookies through your browser

the user can select which cookies to authorize through the appropriate procedure in the section Settings related to cookies, as well as authorize, block or delete (in whole or in part) cookies through the specific functions of your browser (browser): however, in the event that all or some of the cookies are disabled, it is possible that the site can not be consulted or that certain services or certain functions of the Website are not available or do not work properly and / or the user may be forced to modify or manually enter some information or preferences each time you visit the site.

For more information on how to set preferences on the use of cookies through your browser, you can consult the instructions:

d) Settings related to cookies

Below it is possible for the user to make a choice and to indicate specifically which cookies to authorize.

The user is informed that not allowing technical cookies may make it impossible to use the website, view its contents and take advantage of the related services. Inhibiting cookies of functionality could mean that some services or certain functions of the website are not available or do not work properly and the user may be forced to change or manually insert some information or preferences each time he visits the website.

The lack of authorization with respect to other cookies indicated by third parties will not affect the operation of the site; however, being such types of cookies sent exclusively by third parties, and not being able to control the site manager to send these cookies to the user’s terminal, the relative opposition can be exercised only by accessing the consent forms prepared by the aforementioned third parties, if any, or through the settings of your browser. The links to the privacy policies and any consent collection forms for the receipt of cookies prepared by the third parties that send cookies through the website are provided in the section Types of Cookies Used by the Site.

As for cookies directly sent by the site operator, as well as through the procedure made available on this page, the user can block or delete (in whole or in part) cookies through the specific functions of your browser (in this regard, see the above).

The choices made by the user in relation to cookies on the site will in return be recorded in a special technical cookie, having the characteristics shown in the table of cookies. This cookie may, however, in some circumstances not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use through the functionality of your browser.

Your preferences in relation to cookies will be reset if you use different devices or browsers to access the site.