PERSONAL DATA COLLECTED FOR THE FOLLOWING PURPOSES AND USING THE FOLLOWING SERVICES:

• Contact the User – Contact form
  Personal Data: surname, email, name, and telephone

• SPAM Protection
• Statistics
• Display of content from external platforms
• Platform and hosting services

CONTACT INFORMATION

Data Controller

Studio RCG Via Corsica 2/18, 16128 Genoa +39 010 8979200 | segreteria@studiorcg.it

TYPES OF DATA COLLECTED

Among the Personal Data collected by this Application, independently or through third parties, there are: name, surname, email, telephone, Cookies, and Usage Data. Complete 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 collection.

Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Application. Unless otherwise specified, all Data requested by this Application is 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 certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequences on the availability of the Service or its operation.

Users who may have doubts about which Data is mandatory are encouraged to contact the Data Controller. 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 the right to communicate or disseminate them, releasing the Data Controller from any responsibility towards third parties.

METHODS AND PLACE OF PROCESSING

PROCESSING METHODS

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

LEGAL BASIS OF 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 jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. This is not, however, applicable 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 performance of a task carried out in the public interest or for the exercise of public powers vested in the Data Controller
  
• processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, provided for by a contract, or necessary to conclude a contract.

Place of processing

Data is processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller. 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 processing, the User can refer to the section related 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 governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

Should one of the transfers just described take place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting them using the details provided at the beginning.

Retention period

Data is processed and stored for the time required by the purposes for which it was collected. Therefore:

Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of such contract is completed. Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until this interest is satisfied. 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 processing is based on the User’s consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, 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 expiration of this term, the right of access, deletion, rectification, and the right to data portability can no longer be exercised.

Purposes of Data Processing

The User’s Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Contacting the User and being able to provide services, Statistics, SPAM Protection, Platform and hosting services, and Display of content from external platforms.

To obtain further detailed information on the purposes of the processing and on the Personal Data actually relevant for each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User

Contact form (this Application). The User, by filling in the contact form with their Data, consents to their use to respond to requests for information, quotes, or any other nature indicated by the form’s header. Personal Data collected: surname, email, name, and telephone (optional).

SPAM Protection

This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages, and content recognized as SPAM.

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.

Platform and hosting services

These services aim to host and run key components of this Application, thus enabling the provision of this Application from a single platform. These platforms provide the Data Controller with a wide range of tools such as analytical tools, for user registration management, for comment and database management, for e-commerce, for payment processing, etc. The use of such tools involves the collection and processing of Personal Data. Some of these services operate through servers located geographically in different places, making it difficult to determine the exact place where Personal Data is stored.

Display of content from external platforms

This type of service allows for viewing content hosted on external platforms directly from the pages of this Application and interacting with them.

User Rights

Users can exercise certain rights with reference to the Data processed by the Data Controller. In particular, the User has the right to:

• Withdraw consent at any time. The User may withdraw consent to the processing of their – Personal Data previously given.
• 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 Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the accuracy of their Data and request its updating or correction.
• obtain processing limitation. 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 than its storage.
• obtain the deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Data Controller.
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party, or on contractual measures connected to it.
• lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or act in court.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons connected to their particular situation.

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

How to exercise rights

To exercise the User’s rights, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month. This Application makes use of Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy*.

Additional information on processing Legal defense

The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages to its possible establishment for 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 public authorities.

Specific information

Upon the User’s request, 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 logs and maintenance

For operational and maintenance needs, this Application and any third-party services used by it may collect system logs, i.e., files that record interactions and that may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “do not track” requests

This Application does not support “Do Not Track” requests. To find out whether 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 informing 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 contact details available to the Data Controller. Therefore, please regularly consult this page, referring to the date of last modification indicated at the bottom.

Should the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

DEFINITION AND LEGAL REFERENCES

Personal Data (or Data)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

Information automatically collected through this Application (including by third-party applications integrated in this Application), including: IP addresses or domain names of the computers used by the User connecting to this Application, addresses in URI (Uniform Resource Identifier) notation, 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 from the server (successful, error, etc.), the 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 about the path followed within the Application, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural person, legal person, 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 Controller)

The natural or legal person, public authority, service, or other body which, alone or jointly 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 the Personal Data of Users 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.

Cookie

Small piece of data stored inside the User’s device.

LEGAL REFERENCES

This privacy policy is drawn up based on multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy concerns exclusively this Application.

• Cookies are portions of code installed within the browser that assist the Data Controller in providing the Service according to the purposes described. Some of the purposes for installing Cookies may also require the User’s consent.

When the installation of Cookies takes place based on consent, such consent can be freely revoked at any time following the instructions contained in this document.

Technical cookies and aggregated statistics cookies

Activities strictly necessary for operation

Activities for saving preferences, optimization, and statistics

Other types of Cookies or third-party tools that might install them

Some of the services listed below collect statistics in an aggregated and anonymous form and may not require the User’s consent or may be managed directly by the Data Controller – depending on what is described – without the aid of third parties.

If among the tools indicated below there are services managed by third parties, these may – in addition to what is specified and also without the Data Controller’s knowledge – perform User tracking activities. For detailed information on this, it is advisable to consult the privacy policies of the services listed.

– SPAM Protection

– Statistics

How can I express consent to the installation of Cookies?

In addition to what is indicated in this document, the User can manage preferences for Cookies directly within their browser and prevent – for example – third parties from installing them. Through browser preferences, it is also possible to delete Cookies installed in the past, including the Cookie in which consent to the installation of Cookies by this site is possibly saved.

The User can find information on how to manage Cookies with some of the most popular browsers, for example, at the following addresses: Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Internet Explorer.

With reference to Cookies installed by third parties, the User can also manage their settings and revoke consent by visiting the related opt-out link (if available), using the tools described in the third party’s privacy policy, or contacting the third party directly.

Notwithstanding the above, the User can avail themselves of the information provided by EDAA (EU), Network Advertising Initiative (USA), and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan), or other similar services. With these services, it is possible to manage tracking preferences for most advertising tools. The Data Controller, therefore, recommends that Users use these resources in addition to the information provided in this document.

Data Controller

Studio RCG Via Corsica 2/18, 16128 Genoa +39 010 8979200 | segreteria@studiorcg.it

Email address of the Data Controller: segreteria@studiorcg.it

Since the installation of Cookies and other tracking systems operated by third parties through the services used within this Application cannot be technically controlled by the Data Controller, any specific reference to Cookies and tracking systems installed by third parties is to be considered indicative. To obtain complete information, the User is invited to consult the privacy policy of any third-party services listed in this document.

Given the objective complexity of identifying Cookie-based technologies, the User is invited to contact the Data Controller should they wish to receive any further information regarding the use of Cookies through this Application.