DATA CONTROLLER INFORMATION
Business Name: Attivar Service & Production S.R.L., represented by its temporary legal representative (hereinafter referred to as "Attivar").
Headquarters: Borgata Vittori 1, Monta' 12046 (CN), Italy
VAT Number: 01787990041
Contacts: Tel +39 0173 975757 – email:
INTRODUCTION
This document provides the following notices regarding the processing of the User's personal data:
- Privacy Policy: Where we inform the User about which of their data we collect, how we process it, to whom we transmit it, for what purposes it is collected, and on what legal basis.
- Cookie Policy: Where we inform the User about the storage of cookies on their terminal by this website.
The above in implementation of applicable Italian and EU provisions, including but not limited to: Regulation (EU) 2016/679 (hereinafter referred to as "GDPR"), the Privacy Code (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018), and the provisions and guidelines of the Garante per la Protezione dei Dati Personali (hereinafter referred to as "GPDP").
This document intentionally quotes the contents of the Regulation, the Privacy Code, and the above-mentioned provisions, which the User can also find on the GPDP's website: https://garanteprivacy.it/home/.
WHO THIS INFORMATION IS FOR.
To the User, that is You, also referred to as the Data Subject, the person browsing the website, whether they are an individual or acting on behalf of legal entities providing personal data.
Thus, everyone interacting with Attivar's web services, accessible online at https://www.attivar.it/, and exclusively for personal data collected through this site.
Please note that this information is only provided and is valid on this website, not for other websites that may be consulted by the User via links present on the site.
Attivar has no control over these sites or the procedures they apply for data privacy, and we suggest consulting the privacy policies of any entities you come into contact with before providing personal information.
CHANGES
Attivar reserves the right to make changes to the Site, to these Privacy and Cookie Notices wherever they are published on the Site, at any time. Upon consultation, the User must always refer to the current version of the text published. Changes become effective when published on the Site.
The User's continued use of the Site following a change will be considered as acceptance of such changes. All users can check, at any time, by connecting to the Site, the latest version of the Cookie Notice as updated by Attivar.
Documents updated on 23.03.2024.
PRIVACY POLICY
1) WHAT DATA DO WE PROCESS AND WHY?
The User assumes responsibility for the personal data of third parties published or shared through this website and guarantees they have the right to communicate or disseminate them, freeing the Data Controller from any liability towards third parties.
A) BROWSING DATA
The IT systems and software procedures dedicated to the operation of the website https://www.attivar.it/ may collect, during the User's navigation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects but could, by its very nature, through processing and associations with data held by third parties, allow for identifying users. Collected data includes the internet protocol (IP) address; type of browser; device parameters used to connect to the site; name of the Internet Service Provider (ISP); date and time of visit; referring and exit web pages; and possibly the number of clicks, and other parameters regarding the User's operating system and IT environment.
Our site collects some of this data, and in some cases also through cookies (for more information, refer to the Cookie Policy) for different purposes:
- Security or legal compliance: In relation to access to systems, data may be communicated to competent authorities, upon their order, for security and public interest reasons. LEGAL BASIS: Legal obligation, Art. 6, para. 1, letter c) of the GDPR.
NATURE OF PROVISION: Necessary.
RETENTION PERIOD: Data is processed for the time necessary to fulfil the aforementioned purposes and as provided by law, and in any event, for a period not exceeding that dictated by civil law, therefore for 10 years.
- Technical: To make the website usable, enabling basic functionality since the website cannot function correctly without these cookies.
LEGAL BASIS: Performance of a service, contract or pre-contractual measures, Art. 6, para. 1, letter b)
NATURE OF PROVISION: Provision is necessary to make the site and the requested service available to users.
RETENTION PERIOD: Until the end of the browsing session, for more information refer to the cookie policy.
- Statistics: To collect information in aggregate form about the number of users and how they visit the site, for statistical purposes.
LEGAL BASIS: Consent pursuant to Art. 6, para. 1, letter a) of the GDPR.
NATURE OF PROVISION: Optional, consent is expressed by the User through the cookie information banner.
RETENTION PERIOD: 2 months.
- Advertising: To encourage the user to return to our site by showing them our advertisements while browsing other websites, to present personalized ads and measure their performance.
LEGAL BASIS: Consent pursuant to Art. 6, para. 1, letter a) of the GDPR.
NATURE OF PROVISION: Optional, consent is expressed by the User through the cookie information banner.
RETENTION PERIOD: Until consent is withdrawn for marketing campaigns, for 12 months for profile data.
B) DATA PROVIDED VOLUNTARILY BY THE USER
The site may collect other data, exclusively personal, never sensitive, besides browsing data, in case of voluntary use of services offered by the portal by the User, such as comments services, communication services (contact, consulting request forms), newsletter subscriptions, and product quotation services.
When the provision of data is necessary, it is marked with an asterisk; otherwise, all other provisions are optional but, if provided, will allow contacting the Data Subject/User by other means. These data will be used exclusively for providing the requested service or also for marketing purposes if appropriate consent is given.
These services include:
B1) CONTACT AREA
Allows the User to send requests to Attivar through the form, as well as receive commercial proposals upon appropriate consent.
Collected data: name, surname, address, email, phone.
Provided for the following purposes:
- Request management: To fulfil requests made by Users.
LEGAL BASIS: Performance of a service, contract or pre-contractual measures, Art. 6, para. 1, letter b)
NATURE OF PROVISION: Provision of data marked with an asterisk is necessary to fulfil the requests, other data is optional.
RETENTION PERIOD: For the time necessary to fulfil the request, otherwise when data is collected for purposes related to the execution of a contract or pre-contractual measures, also for quotations, between the Data Controller and the User, it will be retained until the completion of such contract, and consequently for 10 years from the last registration ex Art. 2220 c.c.
- Soft spam: When the User is already a Customer of the Data Controller, to allow the Data Controller to send promotional communications via email regarding Services/Products purchased (when there is a fair balance between the Data Controller's interests and the Customer's rights, and there is a relevant and appropriate relationship) without the need for the User's expressed and prior consent, as provided by Art. 130, paragraph 4 of the Privacy Code; This processing is based on Art. 130, paragraph 4 of the Privacy Code as amended by D.lgs n.101 of 2018.
LEGAL BASIS: Legitimate interest of the Data Controller, Art. 6, para. 1, letter f) of the GDPR.
NATURE OF PROVISION: Necessary
RETENTION PERIOD: Until objection.
- Direct marketing: For sending commercial and informational communications related to the sector in which the company operates or personalized announcements and measuring their performance. Through the sending of newsletters also with DEM campaigns, SMS, and WhatsApp.
LEGAL BASIS: Consent, Art. 6, para. 1, letter a) of the GDPR.
NATURE OF PROVISION: Optional, expressed by the User by selecting the appropriate box. Omission will only result in the failure to send commercial proposals but without hindering the fulfilment of requests.
RETENTION PERIOD: Until consent is withdrawn (opt-out). For the provision of the newsletter service, the Brevo platform is used. Data Communication: the data is transferred to the service provider, for the provision of the services themselves, in France; for more information refer to the provider's Policies at https://www.brevo.com/it/legal/privacypolicy/
B2) DIRECT CONTACT
Allows the User to send requests to Attivar through the contacts indicated in the footer.
Collected data: those provided by the User spontaneously at the time of contact.
Purpose: Data is provided for the management and fulfilment of requests.
LEGAL BASIS: Performance of a service, contract or pre-contractual measures, Art. 6, para. 1, letter b).
NATURE OF PROVISION: The provision of data is necessary to fulfil requests.
RETENTION PERIOD: For the time necessary to fulfil the request, otherwise when data is collected for purposes related to the execution of a contract or pre-contractual measures, also for quotations, between the Data Controller and the User, it will be retained until the completion of such contract, and consequently for 10 years from the last registration ex Art. 2220 c.c.
2) DATA PROCESSING METHODS
The processing of personal data communicated by Users is carried out through the operations indicated in Art. 4 No. 2) of the GDPR, specifically: “collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, communication, deletion and destruction of data".
The processing of the Data Subjects' (Users') data is carried out using tools and procedures suitable to ensure a high level of security and confidentiality, in accordance with Art. 32 of the GDPR, by specially authorized subjects, in compliance with Art. 29 of the GDPR. It can be executed through our website or other electronic tools, and sometimes by phone or with the help of paper supports. In particular, our Site has an SSL certificate and uses the HTTPS protocol to make personal data more secure.
By using this protocol, transactions and data transmitted on websites occur with the highest security and the content of the communication is not read or manipulated in any way by third parties.
3) RECIPIENTS AND CATEGORIES OF RECIPIENTS OF COLLECTED DATA AND DATA TRANSFER
Attivar processes Users' data in compliance with personal data protection obligations, provided by applicable legislation. The acquired information is not used to obtain any personal advantage for the company or third parties. The Data Controller ensures that the confidentiality duty is also respected by its interns, employees, and/or collaborators.
In particular, in relation to the above-mentioned purposes, the personal data may be "communicated," meaning with this term making them known to one or more specific subjects, as follows:
a) to authorized persons within our structure, in particular to the administrative office staff;
b) to subjects who may access the data under regulations or legal provisions, within the limits provided by these;
c) to persons who need to access the data for auxiliary purposes to the relationship in progress, including those who provide services for managing the information system used by the Data Controller and telecommunication networks (e.g., email, newsletters, website management); or freelancers, firms, or companies as part of assistance and consultancy relations (e.g., accountants);
d) to our consultants, within the limits necessary to carry out their assignment with the duty of confidentiality and security;
e) to other external subjects performing control, review, and certification of the activities put in place by the Data Controller who operate as external data processors in accordance with Art. 28 of the GDPR, or in total autonomy as distinct Data Controllers.
We specify that the site's hosting is located within the EEA (European Economic Area).
This site shares some of the collected data with services located outside the EEA, exclusively with suitable third parties that have adhered to the Data Privacy Framework protocol through the self-certification procedure; therefore, the transfer is authorized (for more information DPF) and does not require further consent.
In particular, the following services are indicated:
- For statistics.
Our site uses Google Analytics 4 for statistics, which allows greater privacy adjustments. This tool does not record or store individual IP addresses.
Analytics provides data on approximate geographical location by deriving the following metadata from IP addresses: city (plus derived city longitude and latitude), continent, country, geographic area, subcontinent (and equivalents based on ID).
User data within the EEA is collected in the EEA and Google Analytics 4 collects all these data (based on IP geolocation) through domains and servers located in the EU before forwarding the traffic to Analytics servers for processing.
This is asserted by the tool author itself https://support.google.com/analytics/answer/12017362?hl=en. The user provides their consent to processing through the cookie information banner.
Personal Data processed: Usage data collected via cookies.
Place of processing: Ireland and United States.
Privacy and Cookie Policy: https://policies.google.com/privacy and https://support.google.com/analytics/answer/12017362?hl=en
- For advertising.
Google ADS
The user provides their consent to processing through the cookie information banner.
***We use Google Ads, a remarketing (retargeting) service provided by Google. This system uses the DoubleClick cookie to allow the Data Controller to reach users who have already visited the site without completing a conversion, i.e., an action like purchasing a product, filling out a contact form, downloading a file, and so on.
Personal Data processed: Usage data collected via cookies.
Place of processing: United States.
Privacy and Cookie Policy: https://policies.google.com/technologies/cookies?hl=en#types-of-cookies
4) DATA RETENTION PERIOD
Respecting the principles of lawfulness, purpose limitation, data minimization, and storage as per Art. 5 of the GDPR, the personal data storage period of the Users is established for a period not exceeding the achievement of the purposes for which they are collected and processed, or for the entire duration necessary to meet the aforementioned purposes. For more information, refer to point 1) of this Policy (what data we process and why).
At the end of the retention period, the personal data of the Data Subjects will be deleted from all physical and electronic support (database/records) of the Data Controller.
5) USER RIGHTS
Right of Access as per Art. 15 of the GDPR
Right to Rectification as per Art. 16 of the GDPR
Right to Erasure as per Art. 17 of the GDPR
Right to Restriction of Processing as per Art. 18 of the GDPR
Right to Data Portability as per Art. 20 of the GDPR
Right to Object to processing as per Art. 21 of the GDPR
You also have the right to lodge a complaint with the Privacy Authority as the regulatory authority for data protection.
How to exercise User rights: The User can exercise the aforementioned rights by making a request to Attivar Service & Production S.R.L., as per Art. 38 of the GDPR, by sending it to the email address
The Data Controller will confirm receipt and provide information regarding the actions taken in response to exercising your rights under Articles 15-22 of the GDPR.
Should the Data Controller fail to comply with the User's request within one month from receipt, the User will be informed of the reasons for non-compliance, along with the User's right to lodge a complaint with the Supervisory Authority (Privacy Authority) as specified under Art. 13, para. 2, letter (d) and as governed by Articles 77 and following of the GDPR and 141 and following of Legislative Decree 196/2003, as amended by Legislative Decree 101/2018.
6) LEGAL DEFENSE
The User's personal data may be used for the Data Controller's defense in court or in the preparatory stages leading to possible legal action in case of abuse or violations committed by the User. The User also declares to be aware that the Data Controller may be required to reveal the Data upon request of public authorities.
COOKIE POLICY
1) WHAT ARE COOKIES AND OTHER TRACKING TOOLS?
Cookies can be defined as: “text strings that websites (so-called publishers or 'first parties') visited by the user or different websites/web servers (so-called 'third parties') place and store – directly, in the case of publishers, and indirectly, i.e., through the latter, in the case of 'third parties' – within a terminal device (such as a computer, a tablet, a smartphone, or any other device capable of storing information) at the user’s disposal.” Information encoded in cookies may collect personal data, such as an IP address, a username, a unique identifier, or an email address, but may also contain non-personal data, such as language settings or information about the type of device a person is using to browse the site.
Therefore, through cookies, it is possible to:
1) allow, among other things, web pages to load faster, route information across a network – in line with tasks strictly connected to the operation of websites,
2) convey behavioral advertising (so-called 'behavioral advertising') and then measure the effectiveness of the advertising message, or customize the type and mode of services provided according to the behaviors of the User who has been previously observed.
Other tracking tools can be defined as: passive identifiers that allow for similar processing as those mentioned above. These include fingerprinting, "which is a technique that allows the identification of the device used by the user by collecting all or some of the information related to the specific configuration of the device itself adopted by the individual.
This technique can be used to achieve the same profiling purposes aimed at viewing personalized behavioral advertising and analyzing and monitoring the behaviors of website visitors, or for customizing the type and mode of services provided according to the behaviors of the user who has been previously observed.”
This site exclusively uses cookies; therefore, this notice will be limited to the latter.
2) CLASSIFICATION OF COOKIES
Cookies may have different characteristics and, therefore, classifications:
Temporally, based on their duration, cookies are distinguished as Session Cookies (lasting until the browser is closed) or Persistent Cookies (they persist and continue to operate after the user's browser is closed, e.g., a language preference cookie, which allows future accesses by the user to be automatically redirected to the site with the chosen language preference).
By origin, subjectively, cookies are distinguished as First-Party Cookies (sent to the user's browser directly by the site being visited and belonging to it) or Third-Party Cookies (those belonging to domains different from the one shown in the address bar, i.e., other than the Site being visited).
By purpose (based on the use) of data processing, cookies are distinguished as Technical Cookies (used for navigation within the website, not requiring user consent), Statistical Cookies (used directly by the website owner for site optimization, collecting aggregate information on the number of users and how they visit the site), and Marketing and Profiling Cookies (advertising, aimed at providing advertising spaces, can be installed by the site owner or third parties only after obtaining the user's consent; they can be sent to the user's browser by third-party companies for their purposes, potentially including profiling).
3) MAIN COOKIES USED BY THE SITE ATTIVAR.IT
The classification which responds to the rationale of the legal discipline, under the GDPR and the GPDP Guidelines, and thus to the needs for personal protection, is linked to the purpose of processing (refer to Art 5 comma 1 b) of the GDPR), therefore, in this paragraph, the criteria for encoding the identifiers adopted by the site based on the purpose of processing will be indicated.
Cookies used by the website https://attivar.it/ can be categorized as follows:
A) Technical Cookies
Used solely for the purpose of "carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary to the provider of an information society service explicitly requested by the subscriber or user to provide that service" (cf. art 122, paragraph 1 of the Privacy Code).
These contribute to making the website usable by enabling basic functions and do not require user consent because the website cannot function properly without them. Purpose: Session or navigation cookies: ensure normal navigation and use of the website (allowing, for example, page navigation, access to protected areas of the site, payment via credit card or other systems, etc.).
Functional cookies: useful for enhancing the user's personalized navigation experience (e.g., tracking chosen language).
LEGAL BASIS: Performance of a service, contract, or pre-contractual measures, art. 6, para. 1, letter b)
NATURE OF PROVISION: Necessary to make the site and requested service usable by users.
RETENTION PERIOD: Until the duration of the navigation session.
B) Statistical Cookies
Purpose: used to optimize the website directly by the Owner, for website design or helping measure “traffic,” i.e., the number of visitors also potentially categorized by geographical area, connection time slot, or other characteristics.
LEGAL BASIS: consent under art. 6, para. 1, letter a) of the GDPR.
NATURE OF PROVISION: optional, consent is given by the User through the cookie information banner.
RETENTION PERIOD: 2 (two) months.
Third-party statistical cookies used by the site: *** Google Analytics 4 (Google Inc.) Google Analytics is a web analytics service provided by Google Inc. (“Google”). Name: The primary cookie used by Google Analytics is _ga.
This cookie allows a service to distinguish one user from another and lasts for 2 months.
Location of processing: Ireland.
Privacy Policy: https://analytics.google.com/analytics/academy/ and https://policies.google.com/privacy Opt-out: https://tools.google.com/dlpage/gaoptout?hl=en
C) Marketing and personalized advertising cookies:
“used to link specific actions or recurring behavioral patterns in the use of the offered functionalities (patterns) back to determined, identified, or identifiable subjects, for the purpose of grouping different profiles within homogeneous clusters of various sizes, so that the owner can, among other things, modulate the service provision in an increasingly personalized manner beyond what is strictly necessary for service delivery, and send targeted advertisements, i.e., in line with the preferences expressed by the user during web browsing” (cf. art. 4 GPDP Guidelines of 10.06.2021).
Purpose: These cookies are aimed at providing advertising spaces. They can be installed by the site owner or third parties only after obtaining user consent; they can be sent to the user's browser by third-party companies directly from their websites for their purposes, potentially including profiling. The owner has no control over third-party cookies, neither the activity and purposes of the third party nor the possibility that they will change them over time. In this sense, the owner acts as an intermediary and refers the user to the third party’s information in the table below.
LEGAL BASIS: consent under art. 6, para. 1, letter a) of the GDPR.
NATURE OF PROVISION: optional, consent can be given or revoked at any time via the dedicated area accessible in the footer.
RETENTION PERIOD: until consent is revoked.
Our site makes use of Google Analytics' personalized marketing functionalities, which allow showing ads based on the user's personal interests, identified through an analysis of the user's behavior on the web, whether on a mobile device or other devices.
As required by current privacy legislation, the prior consent of the user is required for installing such cookies.
List of third-party marketing cookies used by the site:
*** Google Location of processing: USA Privacy Policy: https://analytics.google.com/analytics/academy/ and https://policies.google.com/privacy
The main identifiers are: Name: IDE – RUL - DSID
Purpose: cookies set by double click for showing Google ads on non-Google sites.
Name: test_cookie
Purpose: This cookie is set by doubleclick.net when remarketing is active.
The purpose of the cookie is to determine whether the user’s browser supports cookies.
Name: NID – AID – _gat - _gcl - _gid
Purpose: Cookies set by Google Analytics used to publish and display ads, personalize ads, limit the number of views an ad has for a user, disable ads the user has decided not to see anymore, and evaluate the effectiveness of ads.
It is used for showing Google ads in Google services to users who have logged out after signing in.
Name: SID Purpose: related to security and installed when remarketing is active.
Cookies used for security enable user authentication, prevent fraudulent activity, and protect users during their interaction with a service.
D) Other third-party cookies
*** Google reCAPTCHA (Google Inc.)
Used solely to analyze traffic on the Attivar site to filter it from recognized
SPAM traffic, messages, and content.
Purpose: Functional cookies to ensure maximum security and protection of the site for the benefit of the user and our organization.
LEGAL BASIS: legitimate interest of the Owner, art. 6, para. 1, letter f) of the GDPR.
NATURE OF PROVISION: necessary for connecting to the site and providing the service.
RETENTION PERIOD: duration of the session. Location of processing: Ireland and United States Privacy Policy: https://policies.google.com/privacy
4) TRANSPARENCY IN THE USE OF COOKIES
We aim to make the use of cookies and other similar technologies as transparent as possible. The user can decide whether to accept cookies using their browser settings. or At the first access, through the banner, the User can:
continue browsing by maintaining the default settings that include the use of only the site’s technical cookies by selecting the X at the top right and closing the banner,
refuse cookies by clicking “reject,” in which case only technical cookies will be installed,
accept all cookies by clicking “accept”,
choose the categories of cookies to accept through the “manage preferences” button. On each subsequent access – through the “cookie preferences management” link in the footer of each page on the site, the User can access a dedicated area and:
if not already done, accept all cookies by clicking “accept all cookies”,
if previously accepted, revoke the consent given by selecting the “reject cookies” button,
choose which categories of cookies to authorize or, if already authorized, for which categories to revoke consent, and then confirm the choice by hitting “save preferences.” Once the cookie preference has been expressed, the banner will not be shown again for at least 6 months unless, before this period:
the User deletes cookies from their browser (refer to the “How to disable cookies” paragraph),
significantly one or more processing conditions change, a situation that occurs when new third parties are added, conversions. With the Facebook Pixel, one can understand the actions people take on the Site.
Disabling “marketing and profiling” cookies does not impair usability in any way.
5) HOW TO DISABLE COOKIES
A) By browser settings: Most browsers (Internet Explorer, Firefox, Chrome, etc.) are configured to accept cookies. The cookies stored on your device’s hard drive can still be deleted, and it is also possible to disable cookies by following the instructions provided by the main browsers. To do this, access your browser’s "Preferences." For information on how to change the settings of cookies, select the browser you are using:
Chrome https://support.google.com/chrome/answer/95647?hl=en
Firefox https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer https://support.microsoft.com/en-US/help/17442/windows-internet-explorer-delete-manage-cookies – Opera https://help.opera.com/en/latest/web-preferences/
Safari https://support.apple.com/en-us/HT201265
B) By mobile device settings: Users can manage preferences related to cookies (and similar technologies) directly through their device settings. For iOS devices, guidance can be found at the following address: https://support.apple.com/en-us/HT201265 For Android devices, guidance is at: https://support.google.com/chrome/answer/114662?hl=en
C) By Smart TV settings: It is possible to act on the Smart TV settings. As instructions differ based on the various brands and models, please read and follow the instructions illustrated in the Smart TV user manual.
6) DATA SUBJECTS' RIGHTS
Under EU Regulation 2016/679 ("GDPR”), data subjects have the right, at any time, to obtain confirmation of the existence or non-existence of the same data and to know their content and origin, verify their accuracy, or request their integration, updating, or rectification. Furthermore, data subjects have the right to request erasure, restriction of processing, data portability, to lodge a complaint with the supervisory authority, and to object in any case, on legitimate grounds, to their processing (Arts. 17 et seq. of the GDPR). Requests should be addressed to Attivar Service & Production S.R.L., under Article 38 of the GDPR, sent to the email address