According with D.lgs 196/2003 italian law, with Personal Data Protection Authority’s General Provision nb. 229 8th of May 2014 and with EU Directive 2002/58/CE, Atti2de Srl, based in Corso Italia 45, 20122 Milan (Italy), identified as Data Controller, informs the users acquired through its websites within the scope about the data management, processing, communication and data provision.
The person who uses this website who usually is the Person concerned or anyway authorized by him.
3. Person concerned
Individual or legal person owner of Personal Data processing.
4. Data Controller
Individual, legal person, public administration and every further public authority, association, entity that makes decisions about purpose, use, processing, tools and data security related to the website management. The Data Controller is, unless otherwise specified, the website’s owner.
Cookies are small text files that the websites send to the user’s device (usually to the web browser), where are stored in order to be resend to those same websites during the user’s following web session. During the web session, the user could stored in his device also cookies of different websites or webserver (so-called third parties’ cookies).
This happens because on the visited website there could be contents like images, maps, sounds, links to web pages of other web domains managed in a different web servers.
There are two different categories of cookies:
technical and aggregate statistics cookies that do not required the user’s authorization when send to the user’s device;
cookies used neither for technical nor statistics purposes that instead required user’s authorization before their use.
Atti2de’s websites use technical cookies. These cookies are necessary to carry out preferences saving, optimization and statistics activities: in this specific case the cookies are used to save the web surfing preferences and to optimize the user’s experience. Within these cookies there are, for example, those to set up the language or to manage statistics.
By referring to on line data collection, Atti2de’s websites can adopt the following services, used to monitor and analyze the aggregate on line traffic data:
Google Analytics: Google Analytics is an web analysis service provided by Google Inc. (“Google”). Google manages personal data collected (usage data) with anonymous IP to track and analyze the website usage, to fulfil reports and shared them with other services developed by Google.
Google could use personal data to adapt and personalize advertisements of its network.
Within the European Community’s States or in other Countries joining the European Economic Area agreement the anonymous IP address is obtained reducing the user’s IP address length. Just exceptionally the IP address will be send to Google’s servers and shorted in USA.
external platform Cookie
These services allow to view directly from this website pages contents hosted in external platform and to interact with them. In case there is this type of service, even if users do not use the service, it is possible that the service collects traffic data related to the web pages where it is installed.
The user who continues surfing our websites (closing the banner or accessing whichever page’s content) accepts the cookies that could be stored in its device by these websites.
Anytime user can deny its consent and disable cookies usage:
changing his browser set up options.
Please note that disabling totally technical cookies the user could reduce some of our websites functionalities even in some cases stop completely the website usage.
In case of non technical cookies disabled, it is possible access and use our websites.
Anytime the user can remove the cookies already stored in his web browser.
6. Website data management
The website standard software procedures acquire some data included in IP (Internet Protocol) communication.
These information are not collected to be associated to specific users, but elaborated with other data managed by Data Controller could allow the users identification.
This data category include IP addresses or computer domain names used by customers who access to website, the URI addresses (Uniform Resource Identifier) of resources requested, the time of request, the methodology used to submit the request to the server, the replied file size sent, the numeric code containing the reply status (successful conclusion, error, etc.), the areas website viewed, the used device, the Country of origin and other parameters related to the user’s operational system.
The data derivable from website visits could be used, after authorization, also to understand users preferences and behaviours to evaluate profitability of each online activity and to offer more fitting contents and services. Anytime the user can remove the authorization cost-free.
The data can be used to check the user responsibility in case of cyber crimes.
The Atti2de purpose is to make user able to register his/her data, perform the Atti2de test, see the results, elaborated in form of the attitudinal profile (“Profile”) and use all functionalities and services offered by the Data Collector and declared in User Agreement.
Personal data will be collected, stored, interrogated and used by Data Collector for disclosed purpose and for billing when necessary, according with trasparency, fairness principles and law.
8. Methods applied to the Data processing
The Data processing is carried out by using electronic and telecommunication instruments of Data Collector and trusted persons in charge of the processing specifically identified and contrctualized, guaranteeing always compliance with laws and regulations.
The Data are stored in electronic archives and according with the law are applied at least those measurs to guarantee a proper level of Data protection.
9. Data transfer and communication
User’s personal data will not communicated, sold or transfer to third parties, excluded the Data Collector and the persons in charge of the processing, without user’s authorization except necessary communications to process user’s requests.
Specifically, the data may be communicated to informatics companies and consultants for technical and/or financial and/or fiscal and/or legal assistance, indirectly and incidentally to hosting companies used by Data Collector to achieve its purpose.
In any case the data management by third parties will be compliant with fairness principles and with law. The data managed by Data Controller may be transferred abroad to achieve its purpose according the art. no. 42 of D.Lgs no. 196/2003 of italian law.
10. User Rights
User can change and add information to his/her data into the personal area and may cancel anytime his/her Atti2de account and all linked personal data writing to firstname.lastname@example.org.
Anonymous elaborated data in the form of Profile (gender, age, nationality, job and attitudinal evalutaions) never attributable to user, will be stored, managed and elaborated to statistical and research purposes.
In case of user will cancel his/her account, it will never be possible restore the link within Profile and personal data, not even the user will ask for it.
User has the power to exercise his/her right according with art. no. 7, 8, 9 and 10 of D.Lgs June, 30 2003 no. 196 of italian law, addressing to Data Collector through the email@example.com email.
In particular, according with art. 7, the user may obtain confirmation of the existence of his/her personal data and its communication in an intelligible format.
User may obtain information about: a) indication of the origin of personal data,; b) relevant purposes and processing methods as well as the logic applied if the processing is carried out by means of electronic instruments; c) according to art. no 5, identification details of the data controllers and data processors as well as of those subjects or categories of subjects to whom personal data may be communicated or who may gain knowledge thereof i.e. Country representatives.
User may obtain statement of information about persons who received data related to operations mentioned at a), b) and c) letters above, except when the fulfilment of this obligation becomes impossible or entails the use of means that are manifestly disproportionate in comparison with the protected right.
User has the right to oppose if the purpose of the processing is the sending of advertising or sale materials, market researches or business communications.
11. Nature and consent of submission of the Data
User has the power to decide discretionary about the data submission. However, the user
refusal to give his/her consent to the processing of personal data may prevent the proper performance of the contract and the continuation of the provision of services like the registration phase and the Atti2de test.
According with art. 23 of D.Lgs 196/2003 of italian law, the consent to processing personal data is necessary because they are collected out of previous activities and/or agreements.
The consent is freely declared selecting the “sign up” button during the registration data phase.