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Privacy Policy

POLICY STATEMENT ON THE PROCESSING OF PERSONAL DATA
GDPR European Regulation 2016/679

The EU Regulation No. 2016/679, laying down provisions for the protection of persons and other subjects regarding the processing of personal data establishes, in particular, that the data subject (the user who visits the site) must be informed in advance about the use of data concerning him/her and that the processing of personal data is allowed only with the express consent of the data subject except in the cases provided by law.

The data controller under the laws in force is the administrator and owner of the site promanagers.it , Valerio Li Puma, who can be contacted at the following e-mail: lipumavalerio@gmail.com.

1. Users’ consent

The use of the banner has an informative function towards all those who visit the site, with the aim of informing visitors and users about this privacy policy and the use of the data collected during navigation (anonymously) in relation to the methods and purposes described below, including the possible dissemination to third parties if necessary for the provision of a service.

The giving of consent is done through the banner placed at the bottom of the page viewable at the first access on the site, or through the use or consultation of the site, as concluding behavior. By acceptance via banner, use or consultation of the site, visitors and users agree to this privacy policy.

This site does not currently include communication or service request forms. In the event of future introduction, this additional data will be collected upon request for additional consents related to the specific purpose of the service.

The user may deny consent, and may revoke a consent already provided via the browser settings for cookies at any time.

However, denying consent may result in the inability to deliver certain services and the site experience would be impaired.

Data for site security and prevention from abuse and SPAM, as well as data for site traffic analysis (statistics) in aggregate form, are processed based on the legitimate interest of the Data Controller in protecting the site and the users themselves. In such cases, the user always has the right to object to the processing of data .

Any data provided for consulting or professional assignments are processed according to the specific fulfillment. In such cases, specific information is provided.

Reference is made to what is stated in the “Chiarimenti in merito all´attuazione della normativa in materia di cookie“, where the following is specified:

-“It is confirmed that for the use of exclusively technical cookies, it is only required to issue the information in the manner deemed most appropriate (e.g., by including the reference in the privacy policy of the site) without the need to make the banner required by the provision.”
-“In view of the simplification that the Authority is pursuing, it has already been clarified in the measure how analytical cookies – which serve to monitor the use of the site by users for purposes of optimization of the same – can be assimilated to technical cookies where they are made and used directly by the first party site (without, therefore, the intervention of third parties). In many cases, however, sites use, for mere statistical purposes, analytical cookies made and made available by third parties. In these cases, it is considered that the aforementioned sites are not subject to the obligations and fulfillments required by the legislation (notification to the Guarantor in the first place) if they are adopted appropriate tools to reduce the identifying power of the analytical cookies they use (for example, by masking significant portions of the IP address).”

As specified several times below, this site makes use of  Google Search Console and Google Analytics in order to collect information about the use of the site made by users in an anonymous form such as: pages visited, time spent, source traffic origins, geographical origin, gender and interests for statistical purposes. These cookies are sent from third-party domains external to this site as immediately below.

2. Purpose of processing and Data collected

The processing of data collected by the site, in addition to the purposes related, instrumental and necessary to the provision of the service, is aimed at the following purposes:

-Analysis
Collection of data and information in aggregate and anonymous form only in order to verify the proper functioning of the site and to understand the way users interact with our Platform and allow us to improve it. None of this information is related to the physical person-User of the site, and does not allow in any way its identification.

-Security
Activation of mechanisms necessary for the purpose of protecting the security of the site and Users and to prevent or expose fraud or abuse.

-Accessory Activities.
Communicating data to third parties that perform functions necessary or instrumental to the operation of the service (e.g., insights), and to enable third parties to perform technical and other activities. Providers have access only to data that are necessary to perform their tasks and are required to process personal data in accordance with applicable regulations.

-Consulting and professional assignments
In the case of spontaneous submission of data for the purpose of requesting professional advice or for a professional assignment, the data will be used only for the purpose of evaluating the assignment and for its eventual fulfillment. In such cases, appropriate information will be provided.

Data collected

This site may collect user data in two ways.

-Navigation Data
The computer systems and software procedures designed for the proper functioning of the Site acquire, in the course of their normal operation, certain Data whose transmission is implicit in the navigation of the websites.

This information is not collected to be associated with identified data subjects.

They include IP addresses or the names of the computers used by Users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the resources requested, 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 and other parameters relating to the operating system and the computer platform used by the User. This data is used for statistical and analytical purposes, in an aggregated and anonymous form only (User-ID function disabled).

The above data is used in order to obtain 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.

-Data provided voluntarily
Data provided, in case of voluntary use of services, by users. Potential services include comment and communication services (contact forms, comment box).

Data will be used exclusively for the provision of the requested service:

  • name;
  • email address;
  • any additional data sent voluntarily by the user.

Transfer of data collected by third parties

For the purpose of monitoring the performance of the site and the use of related services, we make use of applications developed by third parties and dedicated to web data analysis, such as Google Analytics and Google Search Console.

For GDPR compliance of these applications, please consult the owners’ documentation in terms of privacy and data tracking. This site does not use Google Analytics to collect sensitive data or IP addresses.

Data collected by the site is not provided to third parties, except in specific cases:

-legitimate request by the judicial authority and only in cases provided by law;
-if it is necessary for the provision of a specific service requested by the User (e.g.Google Analytics);
for the execution of security checks or optimization of the site.

Transfer of data to countries outside the EU

This site may share some of the data collected with services located outside the European Union area.

In particular with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service.

The transfer is authorized under specific decisions of the European Union and the Garante per la tutela dei dati personali in particular Decision 1250/2016 (Privacy Shield – here the information page of the Italian Data Protection Authority Garante italiano), so no further consent is needed. The companies mentioned above guarantee their adherence to the Privacy Shield.

This site uses cookies

This is the information on the use of cookies in implementation of the provision of the Guarantor for the protection of personal data of May 8, 2014 “Identification of simplified procedures for information and acquisition of consent for the use of cookies” and in compliance with Article 13 of the Privacy Code (Legislative Decree No. 196/2003).

Definition of cookies

In order to make its services as efficient and easy to use as possible this Site makes use of cookies. Therefore, when you visit the Site, a minimal amount of information is placed on your device as small text files called “cookies,” which are saved in the directory of your Web browser.

There are different types of cookies, but basically the main purpose of a cookie is to make the Site work more efficiently and to enable certain features of the Site.

Cookies are used to improve the User’s overall navigation. More information on the Garante della Privacy‘s website.

We remind you that by proceeding with navigation on this site or by clicking on the ok and X buttons on the short information banner, you declare that you have read and accepted the privacy policy and cookies policy, thereby consenting to the use of cookies on this site.

This site also acts as an intermediary for third-party cookies (such as buttons for social networks), which are used in order to provide additional services and features to visitors and to simplify the use of the site itself, or to provide personalized advertising. This site has no control over their cookies wholly operated by third parties and has no access to the information collected through said cookies.

Information about the use of said cookies and their purposes, as well as how to disable them, is provided directly by the third parties on the pages indicated below.

It should be noted that generally the tracking of users does not involve identification of the same, unless the User is already subscribed to the service and is also already logged in, in which case it is understood that the User has already expressed his or her consent directly to the third party when subscribing to the relevant service (e.g. Facebook).

There are various types of cookies (source garanteprivacy.it/cookie). Below are the types of cookies that may be used on the Site.

-Technical cookies

Technical cookies are those whose use does not require the user’s consent. These cookies are essential to enable you to navigate the Website and use all of its features. Without these cookies, which are absolutely necessary, a website could not provide certain services or functions and navigation would not be as smooth and easy as it should be. A cookie of this type is also used to store a user’s decision to use cookies on the website.

-WordPress cookies

This website was developed on the wordpress platform, so it uses cookies implemented by that platform.

The stored cookies concern those who have registered an account on the wordpress blog and those who comment on articles.

-Cookies to integrate third-party software products and functions

This type of cookie integrates functionality developed by third parties within the pages of the site such as icons and preferences expressed in social networks in order to share content on the site or for the use of third-party software services. This site also incorporates plugins and/or buttons in order to allow easy sharing of content on your favorite social networks. When you visit a page on our website that contains a plugin, your browser connects directly to the servers of the social network from where the plugin is loaded, which server can track your visit to our website and, if appropriate, associate it with your social account, particularly if you are logged in at the time of your visit or if you have recently browsed one of the websites containing social plugins. If you do not want the social network to record data about your visit to our website, you should log out of your social account and, probably, delete the cookies that the social network has installed in your browser.

For more information regarding cookies from major social networks you can visit: Facebook Privacy, Instagram Privacy, Youtube Privacy, Twitter Privacy, LinkedIn Privacy, Pinterest Privacy, Whatsapp Privacy, and Telegram Privacy.

-Analysis Cookies

They are used to collect information about the use of the site, information regarding anonymous statistical analysis in order to improve the use of the site and to make content more interesting and relevant to user preferences. This type of cookie is used on this site to collect data anonymously about user activity and how they arrived at the site (search engine searches, social posts, etc.). Analytical cookies may be sent by the site itself or by third parties.

This site uses cookies from the following third parties in an anonymous form

These cookies are used in order to collect information about the use of the site made by users in an anonymous form such as: pages visited, time spent, source traffic origins, geographical origin, gender and interests for statistical purposes. These cookies are sent from third-party domains external to this site as immediately below.

This site is analyzed using Google Search Console and Google Analytics (a service offered by Google, Inc.).

-The first one allows us to monitor and manage the site’s presence in Google Search results, as well as troubleshoot any problems (click here to learn more).

Google Analytics allows us to anonymously collect and examine visitor behavior while using the site and to improve its usability and user experience.

They are defined as anonymous in that they cannot be used to identify specific individuals.

Through the use of the Google Analytics panel, it is possible for us to understand whether visits were made by new or returning visitors by checking how pages are navigated (entry links, exit links, movement between pages, dwell times, geographic origin, etc.).

Google Analytics is also used to analyze users’ use of the site, compile reports on site activity, see how often users visit the site, how the site is tracked, and which pages are visited most frequently.

The data collected do not allow personal identification of users, and are not cross-referenced with other information about the same person. They are processed in aggregate form and anonymized (truncated to the last octet). Under a special agreement (DPA), Google Inc. (data controller) is prohibited from cross-referencing this data with data obtained from other services.

More information about Google Analytics cookies can be found on the Google Analytics Cookie Usage on Websites page or here.

Users can selectively disable (opt out) the collection of data by Google Analytics by installing the appropriate component provided by Google on their browser (opt out).

Linked Internet sites

This site may sometimes contain links to other sites or from other Internet sites belonging to our business partners, Manufacturers sites or affiliates.

Such sites have their own privacy policies for the collection, processing and use of which we are in no way or in any capacity responsible.

Users visiting such sites are encouraged to read their privacy policy before possibly registering their personal data.

3. Procedure for disabling cookies from browser settings

a) Internet Explorer
Start Internet Explorer → Internet Options → select Privacy Tab → Settings → change according to preferences.
For more information visit the dedicated Microsoft page.

b) Firefox
Start Motzilla Firefox → Tools menu → Options item → choose Privacy tab → click on Show advanced settings → in the Privacy section click on Content settings → change according to preferences.
For more information visit Mozilla’s dedicated page.

(c) Google Chrome
Start Chrome → click on the Options → Settings item → Show advanced settings → in the Privacy section click on Content settings → change according to preferences.
For more information visit Google’s dedicated page.

(d) Opera
Start Opera → select Preferences → Advanced → select Cookies → change according to preferences.
For more information visit the dedicated Opera page.

(e) Safari
Start Safari → click Preferences → Privacy → go to Block Cookies → edit according to preferences.
For more information visit the dedicated Apple page.

(f) Safari iOS (mobile devices)
Start Safari iOS → choose Settings → Safari → go to the Cookie Blocking section → change according to preferences.
For more information visit the dedicated Apple page.

4. User Rights

Pursuant to European Regulation 679/2016 (GDPR), the User may, in the manner and within the limits provided by the current legislation, exercise the following rights:

  • object in whole or in part, for legitimate reasons, to the processing of personal data concerning him/her for the purpose of sending marketing or direct sales material or for carrying out market research or commercial communication;
  • revoke any consent given in relation to the processing of your Personal Data, without prejudice to the lawfulness of the processing carried out up to that point;
  • to request confirmation of the existence of Personal Data concerning him/her (right of access) and to know its origin;
  • have information about the logic, methods and purposes of the processing;
  • request the updating, rectification, integration, cancellation, transformation into anonymous form, blocking of data processed in violation of the law, including those no longer necessary for the purposes for which they were collected;
  • receive in a structured, commonly used and machine-readable format the Personal Data processed and, except where it is not technically feasible, transmit your data directly to another Data Controller;
  • the right to lodge a complaint with the Supervisory Authority (Privacy Guarantor –link);
  • as well as, more generally, to exercise all the rights granted to him/her under current legal provisions.

Requests should be addressed to the Data Controller.

The exercise of these rights must not prejudice and/or impair the rights and freedoms of others.

If the User’s requests are manifestly unfounded or excessive, in particular due to their repetitive nature, the Data Controller may alternatively charge a reasonable fee taking into account the administrative costs incurred in providing the information or communication or taking the requested action; or refuse to comply with the request

5. Changes to the Privacy Policy

This privacy policy is effective as of 10/04/2021.

promanagers.it reserves the right to modify or simply update its content, in part or in full, also due to changes in applicable legislation.

We therefore recommend that you check this section regularly to become aware of the most recent and up-to-date version of the privacy policy so that you are always up-to-date on the data collected and its use on the site.

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