Privacy policy pursuant to Legislative Decree 196/03 and EU Regulation no. 679/2016

Pursuant to art. 13 of Legislative Decree 196/03 and following the entry into force of EU Regulation no. 679/2016 in accordance with the provisions of art. 13 of the aforementioned European Regulation, we wish to inform you of the following:

Purpose of the treatment

Your personal data, freely communicated and acquired by us due to the activity carried out by:
Bruno Tedeschi
VAT number: IT067975208
Tax Code: TDSBRN87M21G273S

Types of data collected
Among the Personal Data collected by this Application, independently or through third parties, there are: Usage data; Cookies.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all the Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory are encouraged to contact the owner.
Any use of Cookies - or other tracking tools - by this Application or by the owners of third party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Method and place of processing the collected data Method of treatment The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The treatment is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, may have access to the Data). hosting provider, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Owner. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some legal systems, the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out"). to such treatment. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
processing is necessary for the execution of a public interest task or for the exercise of public powers with which the Data Controller is invested;
the processing is necessary for the pursuit of the legitimate interest of the owner or third parties.
However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Location
The Data are processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the owner.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of treatment, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User can check whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or requesting information from the Data Controller by contacting him at the details indicated at the beginning.

Retention period
The data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
Personal data collected for purposes related to the legitimate interest of the Data Controller will be retained until the satisfaction of this interest. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
When the treatment is based on the User's consent, the Data Controller can keep the Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the processing of the collected data
User data are collected to allow the owner to provide the service, fulfill legal obligations, respond to requests or executive actions, protect their rights and interests (or those of users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Interaction with external social networks and platforms, Optimization and distribution of traffic, Statistics and Platform and hosting services.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Detailed information on the processing of Personal Data" section.

Details on the processing of Personal Data
Personal data are collected for the following purposes and using the following services:

- Interaction with social networks and external platforms: This type of service allows interaction with social networks, or with other external platforms, directly from the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User's privacy settings relating to each social network.
This type of service could still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to disconnect from the respective services to make sure that the data processed on this Application is not connected to the User's profile.
Buffer button and social widgets (Buffer)
The Buffer button and social widgets are services of interaction with the Buffer service, provided by Buffer, Inc.
Personal Data processed: Usage data.
Category of personal data collected under the CCPA: information on the Internet.
This type of treatment constitutes a "sale of data" ("rooms") pursuant to the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

- Traffic optimization and distribution: This type of service allows this Application to distribute its content through servers located throughout the territory and to optimize its performance.
The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter the communications between this Application and the User's browser.
Given the distributed nature of this system, it is difficult to determine the places where the content is transferred, which could contain the User's Personal Data.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The Cloudflare integration methods provide that this filters all the traffic of this Application, that is, the communications between this Application and the User's browser, also allowing the collection of statistical data on it.
Personal Data processed: Cookies; various types of data as specified in the privacy policy of the service.
Category of personal data collected under the CCPA: information on the Internet.
This type of treatment constitutes a "sale of data" ("rooms") pursuant to the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

- Platform and hosting services: These services are intended to host and operate key components of this Application, making it possible to provide this Application from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for e-commerce, for processing payments etc. The use of these tools involves the collection and processing of Personal Data.
Some of these services work through servers located geographically in different places, making it difficult to determine the exact place where Personal Data is stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to develop, operate and host this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Category of personal data collected under the CCPA: information on the Internet.
This type of treatment constitutes a "sale of data" ("rooms") pursuant to the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

- Statistics: The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
WordPress Stat (Automattic Inc.)
Wordpress Stats is a statistics service provided by Automattic Inc.
Personal Data processed: Cookies; Usage data.
Category of personal data collected under the CCPA: information on the Internet.
This type of treatment constitutes a "sale of data" ("rooms") pursuant to the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

User rights
Users can exercise certain rights with reference to the Data processed by the Owner.
In particular, the User has the right to:
- withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
- object to the processing of their data. The user can object to the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
- access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the treatment and to receive a copy of the data processed.
- verify and request correction. The User can verify the correctness of his Data and request its updating or correction.
- obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose other than their conservation.
- obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
- receive your data or have it transferred to another holder. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the treatment is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
- propose a complaint. The User can lodge a complaint with the competent personal data protection control authority or take legal action.
Details on the right of opposition
When Personal Data are processed in the public interest, in the exercise of public powers with which the Data Controller is invested or to pursue a legitimate interest of the Data Controller, Users have the right to oppose the processing for reasons related to their particular situation.

Users are reminded that, if their data were processed for direct marketing purposes, they can oppose the processing without giving any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights
To exercise the rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

Further information on the treatment
Defense in court
The User's Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.

Specific information
At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance
For needs related to operation and maintenance, this Application and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time to the Data Controller using the contact details.

Reply to “Do Not Track” requests
This Application does not support "Do Not Track" requests.
To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying it to Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes of contact he has. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Information for Californian consumers
This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the company that manages this Application and, if applicable, by its parent company and by its subsidiaries and affiliates (for the purposes of this section collectively called "we" , "Ours" or "ours").

The provisions contained in this section apply to all Users who are considered consumers residing in the state of California, United States of America, pursuant to the "California Consumer Privacy Act of 2018" (these Users are referred to below simply as "you "," Your "," you "or" your "), and, for them, these provisions prevail over any other provision that may diverge or in contrast contained in this privacy policy.

In this part of the document, the term "personal information" is used as defined by the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold
This section summarizes the categories of personal information that we have collected, communicated or "sold" pursuant to the CCPA and the related purposes of the processing. You can find detailed information on these activities in the section called "Detailed information on the processing of Personal Data" in this document.

Information We Collect: The categories of personal information we collect
We have collected the following categories of personal information about you: information on the Internet.

We will not collect additional categories of personal information without first informing you of a new information.

How we collect information: what are the sources of personal information we collect?
We collect the aforementioned categories of personal information, directly or indirectly, from you when you use this Application.

For example, you directly provide us with your personal information when you send requests via any form on this Application. In addition, you indirectly provide us with personal information when you browse this Application, as the personal information concerning you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in relation to the provision of the Service or the functioning of this Application and its functionality.

How we use the information collected: sharing and communicating your personal information with third parties for operational purposes.
We may communicate your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with this third party which obliges the recipient of your personal information to keep this information confidential and not to use it for purposes other than those necessary for the execution of the contract.

We may also disclose your personal information to third parties when you ask us or authorize us to do so in order to provide you with our Service.

For more information on the purposes of the processing, please consult the relevant section of this document.

Selling your personal information
For the purposes of this document, the term "sale" means "sell, assign, release, make public, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic means, a consumer's personal information by a company to another company or to third parties, for consideration or drawing another type of profit ”.

This means that, for example, a sale can take place whenever an application publishes advertisements, performs statistical analysis on its traffic or views or, simply, uses tools such as social network plug-ins and similar tools.

Your right to opt out of selling your personal information
You have the right to opt out of the sale of your personal information. This means that every time you ask us not to sell your data, we will execute your request.
These requests can be made freely, at any time, and without submitting any request subject to verification, simply by following the instructions below.

Instructions for opting out of the sale of personal information
If you wish to have further information or exercise your right to opt-out in relation to all sales made by this Application, both online and offline, you can contact us using the contact details provided in this document.

What are the purposes for which we use your personal information?
We may use your personal information to allow the correct functioning of this Application and its functionalities ("operational purposes"). In such cases, your personal information will be processed in an adequate and proportionate way for the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the section "Detailed information on the processing of Personal Data" in this document), as well as to comply with the law and defend our rights before the competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for different, unrelated or incompatible purposes, without first communicating a new information to you.

Your California privacy rights and how to exercise them
Right to knowledge and portability
You have the right to know the following:
- the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information and with whom we share it;
- in case of sale or communication of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will communicate to you:
- for sale, the categories of personal information communicated to each category of recipients; and
- for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;
The above information will be limited to personal information collected or used in the past 12 months.

In the event that our response is provided electronically, the information it contains will be "portable", that is, delivered in a compatible format so as to allow you to transmit the information to other entities without impediments provided that this is technically feasible.

Right to request the deletion of your personal information
You have the right to request the cancellation of any of your personal information, subject to the exceptions provided by law (such as, by way of example and not exhaustively, in the event that the information is used to identify and repair errors on this Application, to detect accidents security, for purposes of protection from fraudulent or illegal activities, to exercise certain rights etc.).

If no exceptions provided for by law apply, following the exercise of your right, we will delete your personal information and ask our suppliers to do the same.

Come esercitare i tuoi diritti
Per esercitare i diritti sopra descritti, è necessario presentare una richiesta verificabile contattandoci tramite i recapiti forniti nel presente documento.

In order to respond to your request, it is necessary for us to be able to identify you. For this you can exercise the above rights only by submitting a verifiable request which must:

provide sufficient information to allow us to reasonably verify that you are the person to whom the personal information we have collected relate to or an authorized representative thereof;
describe your request with a degree of detail that is sufficient to make us understand, evaluate and respond correctly to what you ask us.
We will not respond to any request if we are unable to verify your identity and, therefore, to confirm that the information in our possession actually refers to you.

If you cannot personally submit a verifiable request, you can delegate a person registered with the "California Secretary of State" to do it on your behalf.

If you are an adult, you can make a verifiable request on behalf of those who fall under your parental authority.

A maximum of 2 requests can be submitted within 12 months.

How and how long we will handle your request
Within 10 days we will confirm that we have received your request and will provide you with information on how we will process it.

We will respond on the merit of the request within 45 days of receiving it. If we need more time, we will explain the reason and tell you how long we need. In this regard, please note that it may take up to 90 days to satisfy your request.

Our communications will cover the period of the previous 12 months.

If we were to deny your request, we will explain the reason for the refusal.

We will not charge any commission to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable commission, or deny the request. In both cases, we will notify you of our decisions and explain the reasons.

Definitions and legal references
Personal Data (or Data)
It constitutes personal data any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage data
These are the information collected automatically through this Application (also from third party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response from the server (successful, error, etc.). country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application, with particular reference the sequence of pages consulted, the parameters relating to the operating system and the IT environment of Uten you.

User
The individual who uses this Application which, unless otherwise specified, coincides with the interested party.

Interested
The natural person to whom the Personal Data refers.

Data Processor (or Manager)
The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application
The hardware or software tool through which Users' Personal Data is collected and processed.

Service
The service provided by this application as defined in the relative terms (if any) on this site / application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookies
Small portion of data stored within the User's device.

Legal references
This privacy statement has been prepared on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement only concerns this Application.