Dear user / visitor,

welcome to our website www.nicolaspadafora.it (hereinafter, also the "Site").

Browsing the Site and / or accessing certain sections of the Site and / or any requests for information or services by users of the Site may involve the processing of personal data referable to natural persons (hereinafter, jointly, also the "Interested").

This document is intended to provide, in a simple and intuitive manner, information on the type of information and personal data collected through the Site as well as all useful and necessary information so that the interested parties can provide their personal data in a conscious and informed manner, with the possibility of requesting and obtaining, at any time, clarifications and / or corrections.

This is an information (hereinafter, also the "Privacy Policy") drawn up on the basis of the principle of transparency and all the elements required by Article 13 of Regulation (EU) 2016/679 concerning the protection of individuals with regarding the processing of personal data, as well as the free circulation of such data (hereinafter, also the "Regulations").

This Privacy Policy is provided only for this Site and not for other websites that may be consulted by the user / visitor via links.

1.What is meant by personal data

Personal data means all information concerning an identified or identifiable natural person, which is already held by the data controller or which the latter could come into possession. By way of example and not exhaustive, the following are considered personal data: name and surname; Street address; email address; localization. The data generated through the use of the services offered through the Site are also personal data, such as: information on the browser and on the device; IP address; data on the use of the Site; information collected through cookies and other technologies (hereinafter, jointly, also the "Personal Data").

2. Who is the data controller

The subject who will process the personal data of the interested parties and who, therefore, will play the role of data controller, as defined in point 7) of article 4 of the Regulation, is:

Nicola Spadafora, with domicile in Milan at via Maurizio Gonzaga n. 5 (hereinafter, also the "Owner").

3.Type of data collected and processed

No registration is required to access the Site. There are, however, within the Site, services for the use of which it is necessary to provide your Personal Data, which will be processed only for the relative purposes and for the time strictly necessary.

The Personal Data collected through the Site - including, for example, name, surname, residence / domicile address, telephone number, e-mail address - will be processed by the Data Controller in full respect of confidentiality, in compliance with all current regulations ( and, therefore, also in compliance with the principles of correctness, lawfulness, transparency, proportionality and protection of confidentiality and rights) and with logic strictly related to the purposes indicated in this Privacy Policy.

In addition to the personal data provided directly by the interested parties (for example, by filling in and sending contact forms), during the connection to the Site, the computer systems and software procedures used to operate the Site acquire, during their normal exercise, additional Personal Data whose transmission is implicit in the use of Internet communication protocols. These are the so-called "navigation data" by which we mean information that is not collected to be associated with identified subjects, but which by their very nature could, through processing and association with data held by third parties, allow the identification of the same.

In this category of data include the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, 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 (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site only at the request of the supervisory bodies in charge.

For information on the cookies used by this Site, please consult the Cookie policy (link).

4. Purpose and legal basis of the processing

Depending on the needs expressed from time to time by accessing the various sections of the Site (and except for specific rules and information for individual operations that involve the provision of specific Personal Data, published from time to time on the Site), the main purposes are indicated below. of the processing of Personal Data, whether they are provided directly by the Data Subjects, or acquired automatically by browsing:

adherence to the services offered through the Site;
follow up, also by recontacting, any requests made by the interested parties themselves, for example by filling in and sending the forms on the Site or by spontaneously sending e-mail or traditional messages to the addresses indicated on the Site which involve the subsequent acquisition of the address, including e-mail address, of the sender or the relative telephone number necessary to respond to requests, as well as any other personal data included in the relative communications;
fulfill an obligation established by law, by a regulation or by community legislation;
ascertain, exercise or defend our right in court;
obtain anonymous statistical information on the use of the Site and to check its correct functioning;
management, administrative, accounting and tax obligations.

The processing of such data is allowed by the Regulation, as:

necessary to follow up on requests made by the interested parties themselves;
in some cases, necessary to fulfill a legal obligation, for example in case of communication to authorities, governmental or regulatory bodies;
necessary to initiate, prosecute or defend in legal actions.

Subject to specific and separate consent, and until its revocation, the Personal Data of the Data Subjects may be processed for the following additional purposes:

the proposition of offers, commercial communications and for the subsequent sending of advertising and / or promotional information material and / or opinion polls, market research and direct sales, sending newsletters (hereinafter, jointly, also the " Marketing ") regarding products or services offered by Nicola Spadafora. Processing for Marketing Activities will take place using "traditional" methods (by way of example, paper mail and / or calls from an operator), or by means of "automated" contact systems (by way of example SMS and / or MMS, telephone calls without intervention operator, e-mail, social networks, interactive applications, push notifications);
subject to different and specific consent, and until its revocation, to allow profiling and analysis activities with electronic tools, including through the use of cookies, including by way of example, the processing of data relating to choices, habits and preferences, of the geographical area of reference, as well as for the creation of profiles (individual and / or aggregated) in order to improve the Marketing Activities and to process communications and commercial offers studied on the basis of the interest shown.

Consent for the purposes indicated in letters a) and b) of this information is optional and, failing that, it will not be possible to process the data for the purposes indicated therein without prejudice to the main purposes of the processing.

The Data Controller has the right to process Personal Data for reasons other than those specified in this Privacy Policy, if such further processing is compatible with the purpose for which the data were initially collected or with the consent of the interested party and, in any case, subject to the release of appropriate information.

5. Compulsory or optional nature of the provision of Personal Data and consequences of any refusal

The provision of Personal Data, which are requested on the various collection occasions, may be necessary for the pursuit of the purposes identified in the specific information, or optional.

The mandatory or optional nature of the provision is specified by the symbol (*) next to the mandatory information.

Any refusal to communicate certain Personal Data marked as mandatory or to give consent where necessary, makes it impossible to pursue the purpose of the specific collection: such refusal could, for example, make it impossible to provide, in whole or in part, the services made available through the Site or to follow up on contact requests.

The provision of further Personal Data, other than those marked as essential, is optional and does not entail any consequence in order to pursue the purpose of the collection.

6.Communication of Personal Data

The Personal Data of the Data Subjects may be disclosed to specific subjects for instrumental purposes and / or strictly connected to the pursuit of the purposes referred to in this Privacy Policy.

These subjects may be considered data controllers pursuant to art. 28 of the Regulation or independent data controllers. Specifically, Personal Data may be disclosed to:

third parties who carry out part of the processing activities and / or activities connected and instrumental to them on behalf of the Data Controller such as the management of the computer system, the performance of Marketing and shipping activities, the sending of electronic communications. These subjects, adequately selected, with experience, skills and reliability, process Personal Data as data processors, pursuant to art. 28 of the Regulation;
individuals, employees and / or collaborators of the Data Controller or of the data processors who have been entrusted with specific and / or more processing activities on your Personal Data. These individuals have been given specific instructions on the subject of security and correct use of Personal Data;
public bodies or judicial authorities, where required by law or to prevent or suppress the commission of a crime;

A detailed and updated list of these subjects as well as those who operate as data processors can be easily found by sending an e-mail to: info@nicolaspadafora.it.

7. Processing methods and retention period

The processing of Personal Data will be carried out in a lawful and correct manner and, in any case, in compliance with current legislation, with or without the aid of electronic or, in any case, automated, IT or telematic tools, with logic strictly related to the purposes. expressed in this Privacy Policy.

Personal Data will be processed for a period of time equal to the minimum necessary to achieve the purposes for which they are collected, without prejudice to a further retention period that may be imposed by law. Personal data will in any case be deleted without undue delay.

In any case, the criteria used to determine the applicable retention period are: (i) time necessary to achieve the related purpose, (ii) time necessary to carry out the relationship with the interested party, (iii) time accepted by the interested party and / or (iv) the time required by applicable laws. Upon expiry of the retention period, the data will be deleted, or destroyed in a secure way where possible, or made anonymous.

8.Transfer of Personal Data to third countries or international organizations

Personal Data will be processed by the Data Controller within the territory of the European Union.

If for technical and / or operational reasons it becomes necessary to make use of subjects located outside the European Union, the transfer of your Personal Data to these subjects, limited to the performance of specific processing activities, will be regulated in accordance with the provisions provided for by Chapter V of the Regulations. Therefore, all the necessary precautions will be taken in order to guarantee the most complete protection of Personal Data, basing this transfer: (a) on adequacy decisions of the recipient third countries expressed by the European Commission; (b) on adequate guarantees expressed by the recipient third party pursuant to Article 46 of the Regulation; (c) on the adoption of corporate binding rules.

In any case, it is possible to request more details from the Data Controller if the Personal Data have been transferred outside the European Union by requesting evidence of the specific guarantees adopted.

9. Rights of interested parties and methods of exercise

As required by articles 15 et seq. of the Regulation, the interested parties will be able to access their Personal Data, request their correction and updating, if incomplete or incorrect, request their cancellation, limitation of processing and oppose the processing for legitimate and specific reasons.

Furthermore, the interested parties have the right to receive their data in a structured format, commonly used and readable by an automatic device.

They can object, in whole or in part, to the processing for marketing purposes including profiling if connected to marketing purposes. In this regard, they can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

If the interested party has given consent to the processing of personal data for one or more purposes for which it was requested, he may, at any time, revoke it totally and / or partially without prejudice to the lawfulness of the treatment based on the consent given before the revocation. .

You can exercise your rights at any time by sending an e-mail to the e-mail address: info@nicolaspadafora.it by sending a letter to be sent by ordinary mail to Nicola Spadafora, Via Maurizio Gonzaga n. 5, 20123 - Milan.

With reference to the newsletter service, the interested parties may oppose the further sending also by clicking on the appropriate revocation link present in each communication sent by e-mail.

Without prejudice to any other administrative or judicial appeal, the interested parties have the right to lodge a complaint with the Guarantor for the Protection of Personal Data if they believe that the processing of their data is carried out in violation of the Regulations. Further information is available on the website www.garanteprivacy.it

10. Updates

The Owner reserves the right to review, modify or simply update, in whole or in part, in any way and / or at any time, without notice, this Privacy Policy, also in consideration of changes in the law or regulations on the subject. of protection of personal data indicating at the bottom of the page the date of the last update. Changes and updates will be notified on the Home Page of the Site as soon as they are adopted and will be binding as soon as they are published on the Site. Users are invited to regularly access this section to check the publication of the most recent and updated Privacy Policy.

Last updated: September 27, 2021