Privacy Policy

1. PURPOSES AND PRINCIPLES FOR THE PROCESSING OF THE DATA.

In compliance with the relative legal requirements, this page describes the way in which the website is managed as regards the processing of the personal data of the users who navigate the site and interact with the web services accessible via from the following address: www.adacta.it.

Please be informed that  ADACTA STUDIO ASSOCIATO and ADACTA ADVISORY SPA (Joint Contollers) will utilize your personal data in order to manage access to the portal and to the services offered, to manage the technical procedures, to carry out all the activities that are useful or necessary to the constant improvement of the service provided, and also to ascertain any responsibility in the event of damage to the Site and/or unlawful acts perpetrated via the Site. Further specific purposes relative to the individual processing activities may be identified in detail by means of supplementary information provided in the portal.

Consultation of the Site may involve the processing of data relative to identified or identifiable persons. The personal data provided by the users who consult the Site are processed by recipient of the communication in order to fulfil the requests entered.

2. TYPES OF DATA

The data we process can be of three general categories: navigation data, data actively provided by the data subject and data collected from third parties.

Online browsing data
When (also via mobile via smartphone or tablet) you access our website or use our services, the IT systems and software procedures used to manage the operation of the site acquire certain information about you as part of their normal operations, referred to as “personal data”, whose transmission is implicit in the use of internet communication protocols.

These data include the hardware model, operation system and its version, information concerning the mobile phone network and the country from which access takes place, the time of the request, the method used to send the request to the server, the period of access, the dimensions of the file provided in response, the numerical code indicating the status of the data response from the server (successful, error, etc.), details relative to the itinerary followed within the web page, with special reference to the pages visited and other parameters relative to the user’s operating system and IT environment (browser used, version, geographic location, last page visited before accessing the services of ADACTA’s site) and the unique device identifiers (e.g. IP address or domain ADACTAs of the computers used by the users, the URI (Uniform Resource Identifier) address and MAC (Media Access Control) address.

This information is not collected with the purpose of being directly associated with the data subjects, but by its very nature may, in theory, by means of processing and association with data held by third parties (in particular, providers of internet connectivity), make it possible to identify the users.

These data, however, are used by us exclusively for the purpose of collecting statistical information in aggregate and anonymous form relative to the use of the site, in order better to understand the way in which the user navigates the site and thus to improve the user experience, to enable the technical functionalities of the site, to control and optimize its operation, to improve the quality of the services that the site offers, and also to guarantee the maintenance of the relative database and the underlying IT structure.

These navigation data, after processing in anonymous form as described above, will be deleted within 12 months after the date of their collection.

Online browsing data may also be used to ascertain responsibility in the event of unlawful acts committed against the Site or those carried out via the Site (malware attempts, spamming, abusive access to IT systems, etc.) and, in such case, the data will be conserved for the period necessary to safeguard the rights of ADACTA and/or third parties.

Data provided by the user
These data include:

• information sent by the user voluntarily and electively by filling in and sending online registration and / or data collection forms or on company blogs, published on the website (e.g. e-mail address, subject of the e-mail, name or company name, name and surname, etc.);
• the personal data provided by the users in order to utilize the services offered by the Site or to take part in initiatives promoted on the Site;
• the personal data provided by users who enter requests to receive newsletters and/or informative material;
• the personal data provided by users who send employment proposals (“curriculum vitae”, etc.).

Through the web forms available on the sites we never ask you for “particular” personal data (ie personal data suitable for revealing racial and ethnic origin, religious, philosophical or other beliefs, political opinions, adherence to parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data suitable for revealing the state of health and sexual orientation) or “relating to crimes, criminal convictions and security measures” (data in matters of criminal records, or relating to the status of accused or suspected, etc.).

In the use of some services of the Site, the processing of Personal Data of third parties sent by you to ADACTA may occur. With respect to these hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damage from treatment, etc. that it should reach ADACTA from third parties whose Personal Data have been processed through its use of the Site functions in violation of the applicable Personal Data protection rules.

In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it guarantees from now – assuming all related responsibility – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to art 6 of the GDPR which legitimizes the processing of the data in question.

Data collected from third parties

ADACTA collects some personal data of the interested party through registration forms contained in websites managed by third party co-owners or independent data controllers (together with which ADACTA organizes the Events), data used for registration to Events is collected, to give reply to pre-contractual requests from interested parties (such as requests for contact and information), eg. name and surname, nationality, tax code, date of birth, belonging to companies, bodies or organizations, landline or mobile phone, postcode, city, address, email address, data relating to the methods of providing the service purchased by the customer, price, methods payment) or for the additional purposes described in this Notice.

3. PURPOSES OF PROCESSING

The processing of personal data has the purpose of:

a) to meet the requests of the user for the sending of information material or explanations (bulletins, newsletters, replies to queries, notices, specifications, price lists, other documentation etc.),

b) to allow users to register on the site and access the services and/or the purchase of products/services,

c) to provide the service or supply the product requested by the user and to organize all the management and production activities required (including relations with suppliers) for the delivery, and also

d) to comply with the relative legal obligations, regulations and/or EU norms

e) carry out all legal obligations related to or deriving from the terminated contractual relationship with the interested party and / or with the organization to which the same belongs

(which together comprise the “primary purposes“).

f) The data collected will also be utilized for:

f1) Direct marketing (sending through any automated means of communication – email, telephone with operator, sms, chat messages, social networks, etc. – or non-automated – ordinary mail – of periodic communications and newsletters relating to jurisprudential and / or regulatory news and in general to ” activity carried out by ADACTA, as well as email invitations to conventions, conferences and seminars organized by us relating to legal, economic, financial and business organization and strategy issues and other promotional communications and offers for the sale of our services);

f2) Profiling (i.e. limited to the use of only data relating to: name and surname of the interested party, organization to which he belongs, role, contact data such as email and telephone numbers, state, region, province or municipality of residence or headquarters and language of contact, areas of professional or economic interest, participation of the interested party in events organized by ADACTA and / or its partners), essentially focused on understanding your degree of appreciation of the aforementioned promotional communications, the professional topics of your possible interest, type of business activity carried out by you, the role played in the organization you belong to, in order to propose only the marketing initiatives closest to your probable interest, thus reducing useless and dispersive involvement proposals both for you and for ADACTA

((which together comprise the “secondary purposes”)

The logic and forms of organization of the processing will be closely linked to each of the individual purposes referred to above. Processing will take place electronically, telematically and/or in printed form. During the course of processing, the data will be subjected to the security measures implemented by ADACTA in order to protect the data against the risk of unauthorized access or unlawful processing. For example, personal data processed using electronic information systems may be examined only by accessing the various processing or data entry programmes using obligatory personal passwords, and only by personnel authorized by ADACTA, who must in all cases comply with pre-determined limits of utilization.

4.  LEGAL BASIS OF THE PROCESSING

ADACTA may lawfully process the data for the following reasons:

– In the case of the primary purposes, the processing is necessary, depending on the case, for the execution of pre-contractual measures adopted at the request of the interested party (e.g. requests for clarifications, sending information or commercial offers), for the execution of a contract to which the interested party is a party, or to fulfill a legal obligation to which ADACTA is subject (e.g. to allow the verification of the correct fulfillment of the legal and contractual obligations towards the interested party or towards third parties by the administrative authorities and tax, of the board of statutory auditors or auditors, etc.) and / or based on legitimate interest;

a) of ADACTA (prevailing over the interests or fundamental rights and freedoms of the data subject) to process the data in order to be able to effectively and efficiently manage the relationship with its users, customers and / or suppliers and to organize the related processes productive, organizational and management (including relationships with its sub-suppliers) aimed at allowing this objective;

b) of third parties, to receive from the Data Controller and process personal data i) for the purpose of verifying the correct fulfillment of the legal and contractual obligations existing towards the interested party or towards third parties (for example verification by the public authority about the ” fulfillment of tax obligations, or by the board of statutory auditors or auditors regarding the fulfillment of legal obligations, etc.) or ii) to be able to manage the activities related to the request of the Data Controller to receive support to manage the activities towards the interested subjects.

– In the case of secondary purposes, the processing is based on:

a) in relation to direct marketing as described above in point 3, f) 1, to customers operated by sending e-mails / newsletters to promote our goods or services similar to those already purchased by you: on the legitimate interest of ADACTA in make known the activities and skills of ADACTA professionals (so-called soft spam);

b) in relation to direct marketing to customers operated exclusively by sending e-mails / newsletters, to promote our goods or services other than those already purchased by you: on your prior specific consent to the processing for this purpose, not subsequently revoked;

c) in relation to direct marketing to customers operated through automated tools other than sending e-mails / newsletters (eg sending sms, social messages, instant messaging messages such as WhatsApp etc.): on your prior specific consent to the processing for this purpose, not subsequently revoked;

d) in relation to the so-called profiling basic, on our legitimate interest in having a minimum information set to plan direct marketing actions both towards potential customers and towards subjects who are already our customers.

5.  COMPULSORY OR OPTIONAL COMMUNICATION OF DATA AND CONSEQUENCES OF FAILURE TO PROVIDE

For the aforementioned primary purposes, the provision of data to ADACTA is optional, however if the personal data are necessary for the fulfillment of legal obligations, failure to provide it in this case will make it impossible to enter into the contract with you and / or with the organization you belong to. In other cases you are free not to provide us with the data, but this will make it impossible to proceed with pre-contractual relationships, the online registration of the interested subject on the Website and / or the provision of services for which ADACTA requests registration and / or the provision of data.

The user not registered in the Academy SECTION of the site will be able to browse the Site and view only the content and materials available without registration.

In relation to the secondary purposes of processing (direct marketing and profiling as described in paragraph above) and to the communication of the data by ADACTA to third parties for the same purposes:

• consent is always voluntary (free and subject to withdrawal); your consent must be given or withheld separately for (i) processing exclusively by ADACTA or (ii) communication of data by ADACTA to third parties for the same purposes;
• failure to provide or consent to the processing of your personal data will in this case make it impossible for ADACTA to process and/or communicate your data to third parties for secondary purposes, while this will not affect the pre-contractual or contractual relationship between ADACTA and the subject or the subject’s organization.

Are there any cases of simplified consent or exceptions to the obligation of consent for the purposes of direct marketing?

As provided for in current legislation, and in order to ensure the compliance of ADACTA with the principles of simplification (pursuant to the General Provision issued by the Italian Data Protection Authority – 15/05/2013 – “Consent to the processing of personal data for the purposes of direct marketing using traditional and automated contact methods”), the consent required by ADACTA regarding the secondary purposes of profiling and direct marketing is unitary and comprehensive for all possible means utilized for processing for the purposes of marketing (electronic/telematic or printed), as well as for all possible direct marketing purposes (thus without using different consent forms for each individual marketing purpose).

N.B.   ADACTA may process personal data, by means of operator telephone calls and surface mail, for the above-mentioned secondary purposes, without obtaining the prior specific consent of the subject (in this case, without prejudice to the right of the subject to object to processing using simplified procedures and also telematically by the registration of the telephone number held in the ADACTA of the subject and of other personal data relative to subscribers contained in the printed and electronic directories in the public domain, in the “Registro Pubblico delle Opposizioni” (Public Register of Objections) (http://www.registrodelleopposizioni.it/) provided for in [Italian] Presidential Decree no. 178/2010).

If ADACTA should – for the purposes of direct marketing – request your telephone number and you have given your optional and specific consent to its use, then ADACTA may use it even if you have registered the number with the Public Register of Objections, because in this case the number has been provided by you and not taken from public telephone directories.

You should note that the Privacy Code allows the use of so-called “soft spam”. This means that, without having to obtain your express consent, we can utilize the e-mail address supplied by you for a previous purchase in order to send you e-mails containing commercial information and special offers, on condition that these refer to products and services that are similar to those already purchased by you.

Each time you receive a communication and/or promotional e-mail from ADACTA for the purposes set out above, you will be informed of the possibility of objecting at any time to such processing, in a simple way and free of charge (by entering your opt-out choice on our online platform).

Does the consent of the data subject to processing for the purpose of profiling and direct marketing apply also to the communication of the data to third parties?

ADACTA communicates certain data to other companies within the ADACTA Group or to third party subjects who by contract or as “Data Processors” are tasked with processing the data (e.g. sending commercial messages) on behalf of ADACTA, data based on the same specific marketing consent (including consent to communicate the data to third parties for such purposes) already provided by you to ADACTA.

ADACTA may also, though subject to your prior further, separate, supplementary, documented, express, elective consent, communicate or transfer data to third parties who process the data as co-controllers or independent controllers of the processing (generally third party partners in the promotion of events), who may use the data for direct marketing or profiling purposes).

Withdrawal of consent

As the data subject, and even after having given your consent to the processing of your personal data for the purposes of profiling and direct marketing, you may at any moment notify ADACTA of your intention of withdrawing your consent. This may be achieved in any of the following ways:

• by clicking the “unsubscribe” button, which may be found at the bottom of the promotional e-mails sent you, an e-mail will be sent automatically to ADACTA and as a consequence the ADACTA of the registered subject will be added to a special black-list, thus preventing any further direct marketing actions on the part of ADACTA to that subject.
• by sending to ADACTA, either by surface mail or e-mail, your declaration of withdrawal of consent (which in this case will be registered manually in the Company’s CRM system). This method of communication is always necessary if the data subject wishes to express a more articulated preference, either as regards the use of certain procedures rather than others (e.g. only printed material, only electronic, refusing any communications sent using automated systems, etc.) for the receipt – subject to consent – of ADACTA’s marketing communications, or as regards individual marketing information (e.g. choosing to receive only newsletters and not invitations to our events);
• by telephone, clearly communicating the withdrawal of consent to ADACTA. On receipt of this opt-out request, ADACTA will proceed to the removal and cancellation of the data from the databases used for direct marketing activities and, where possible, so inform any third parties who have received the data for the same purposes of such cancellation.

    The receipt of the request for cancellation shall be considered automatically as being confirmation that the data have been cancelled.

• If you wish to withdraw your consent to the sending of advertising material from social media platforms (e.g. Twitter, etc.), you must communicate your withdrawal directly to the individual social platforms according to the procedures specified by each and/or by your browser (since ADACTA is not technically in a position to modify third party social platforms).

In this case your opposition will not affect the fulfilment of any current contractual agreement.

6.  Communication of the data to third parties

The data collected will be processed by delegated personnel within ADACTA for whom it is necessary to have your data at their disposal in order to fulfil their working activities (e.g. sales office, marketing office, administrative office, technicians tasked with maintaining the Company’s IT system, etc.).

ADACTA communicates your personal data to third party recipients only when necessary to complete the data processing procedure relative to the service or product requested by you, and in any case will communicate your data only after so informing you and, where necessary, obtaining your consent to do so. Communication of your data to third parties will in all cases be limited to the data that are strictly necessary for the relative purpose.

Third party recipients of the data – who are listed in a later section – will process the data either (a) as “Data Processors” (i.e. those working on our behalf and in accordance with our written instructions, which guarantee compliance with the privacy norms during processing, and under our supervision), or (b) as Joint Controllers (i.e. on the basis of a written agreement governing their activities and responsibilities regarding the personal data), or as independent Controllers (in this case, they will provide all the legally-required information concerning their processing activities).

As regards the primary purposes, and in particular when the interested party enters into a contract with ADACTA, the data may be communicated by ADACTA to all subjects whose participation in their processing is reasonably necessary on the basis of the requests of the data subject and/or legal requirements, who may be (by way of example):

• hird-party partner companies whose activities are functional or complementary to the supply of the services requested by the data subject (e.g. handling of requests for information, estimates, orders, contracts, after-sales service),
• third parties engaged in activities connected with or instrumental to the processing (such as sales agents, banks for the handling of collections and payments, companies providing commercial information, debt-collecting services, credit transfer services, credit insurance companies, providers of electronic payment services, couriers, haulage and shipping companies, factoring companies, insurance companies, attorneys and legal offices, accountants, accounting consultants, auditors and auditing companies, statutory auditors, third parties assigned to the provision of web hosting services and/or maintenance of this website and/or the IT systems utilized by the same and/or the electronic files connected to the Site; carriers and shippers assigned to deliver goods);
• public security authorities and computer forensics companies in the event of suspected offenses or other illicit activitis carried out against ADACTA and/or third parties.

Only in the case of processing for secondary purposes (profiling and direct marketing), pursuant to the General Provision issued by the Italian Data Protection Authority on 4 July, 2013, containing the “Guidelines for combatting spam”: please be informed that we will also communicate your data – subject to your specific prior consent – to the following product or economic categories of third party recipients: advertising and public relations agencies, market analysis, communications and/or public relations companies, companies engaged in the design, printing and maintenance of advertising or promotional material and/or the online management of the same, website production companies, web marketing companies, direct e-mailing service companies (e.g. Mail-up and similar), call-centre service companies with legal offices and operational centres in Italy, consultants and/or other organizations assigned by us to carry out activities in relation to these purposes; IT system maintenance companies where our databases are stored or processed; providers of electronic communications and ICT services; third party commercial partners, including those operating in production sectors not included in the e-shop, and with which ADACTA conducts co-marketing actions.

The data will not be distributed.

7. TRANSFER OF DATA ABROAD

ADACTA for the execution of the contractual service to the customer (e.g. for the management of e-mails or the drafting of documents) and / or for the fulfillment of the related legal obligations, communicates personal data to Microsoft Corporation, with registered office 1 Microsoft Way, Redmond, WA 98052, USA, as a provider of the following services: individual productivity cloud application (called “Office 365”), “TEAMS” videoconferencing, “POWERBI” e-mail and business intelligence application.

As indicated in Attachment 1 to the Conditions for the Use of Online Services, with reference to the 365 Service, Microsoft undertakes to archive the inactive Company data processed by Della Toffola as follows: “if the Company provides its tenant (… ) in the European Union, Microsoft will store the following Inactive Company Data only within that Geographic Area: (1) the contents of the Exchange Online mailbox (body of the e-mail message, calendar entries, and content of e-mail attachments), (2) the contents of the SharePoint Online site and files stored on that site, and (3) files uploaded to OneDrive for Business “For such data, therefore, no transfer takes place in the USA or the same is purely occasional”.

See Microsoft’s policy at: https://docs.microsoft.com/it-it/microsoft-365/enterprise/o365-data-locations?view=o365-worldwide. You can view the Microsoft privacy policy at the following address: https://privacy.microsoft.com/it-it/privacystatement.

However, it is possible that other inactive data, in particular different from those indicated above, are transferred from the EU to the USA for the service in question and that their transfer is not occasional.

With reference to this hypothesis, the Data Controller applies adequate guarantees consisting in the stipulation – automatic when the service is activated – of the Standard Contractual Clauses (CCS), as a result of which the supplier, with regard to the treatments under its competence, undertakes to comply with obligations privacy substantially equivalent to those provided for by the GDPR for the Organization. These CCS have been previously submitted by Microsoft to the Article 29 Working Group of the European Union and have obtained the relative approval.

In the abstract, the risk cannot be excluded with certainty that in exceptional situations the American public authority for national security purposes provided for by US legislation (Article 702 of FISA and Executive Order EO 12333) will access personal data as transferred above from the Owner from the EU to the USA. However, the possibility of a concrete interest in such access to data (of which the supplier by law may not give notice to the Data Controller) appears limited, considering: i) the core business of the Company ii) the type of personal data processed by the Company and iii) the limited categories of interested parties to whom the data refer (candidates). Therefore, the Company believes that the aforementioned CCS guarantee a protection of the rights of the interested parties substantially similar to that provided for by the GDPR. The adoption of any additional measures will be communicated to the Interested Subject.

ADACTA may also share some data (name, surname, e-mail) with social media platforms (eg YOUTUBE, GOOGLE) which use them to identify other people similar to the user who may be interested in ADACTA’s services and / or products, in order to advertise them through social media platforms.

8. Duration of processing

In the case of treatment for primary purposes, it will last for the time necessary for the fulfillment of the assigned tasks and for the fulfillment of the legal obligations to which we are subject, and for 10 years after the conclusion of the respective professional assignment; in the event of non-payment of ADACTA’s fees, the processing will last, within the strictly necessary limits, until the relative professional or settlement fee has been fully paid and the relative dispute is waived by ADACTA or by the ADACTA shareholder, after which the data and documents they can be destroyed, deleted or anonymized.

The particular data are kept, for the period of time required by European Union legislation, by laws, or by regulations and, in any case, for a period not exceeding that strictly necessary to fulfill the assigned tasks. To this end, also through periodic checks, the strict relevance, non-excess and indispensability of the data with respect to the assignments in progress, to be established or terminated, must be verified, also with reference to the data that the interested party provides on his own initiative. The data that, even following the verifications, are excessive or irrelevant or not essential cannot be used, except for the eventual conservation, by law, of the deed or document that contains them. Specific attention is paid to the indispensability of the data referring to subjects other than those to whom the services and obligations directly refer.

The particular data acquired during previous assignments are kept if pertinent, not excessive and indispensable with respect to subsequent assignments.

Logs. If the data are processed for the purpose of IT security (e.g. registration of logs), the data will be conserved for a period of time which is sufficient to complete all the necessary security checks, assess the results and prepare the relative corrective measures, which is normally not more than 1 year from the date of collection.

The duration of processing for secondary purposes will last until you revoke the consent previously given, or until you communicate the opposition to further processing for the aforementioned purposes (using the “unsubscribe” button located at the bottom of each promotional e-mail message that you will receive , or by communicating your will in a clear way by communicating to the e-mail address referred to below).

9. The Data controller

Joint Controllers are ADACTA STUDIO ASSOCIATO and ADACTA ADVISORY SPA, with registered offices in 36100 Vicenza, Strada Marosticana 6/8, e-mail privacy@adacta.it.

The complete and updated list of Data Controllers may be consulted at the Company’s head offices by written request of the data subject.

10. Rights of the data subject

Regarding the processing of personal data, You may exercise the following rights listed below, by contacting us without any formalities at the above email address:

1) ask us to confirm that it is or is not undergoing the processing of personal data concerning it and, in this case, obtaining access to personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data in question;

c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third countries or international organizations;

d) where possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period;

e) the existence of the right of the Interested Subject to ask our Company the rectification or cancellation of personal data or the limitation of the processing of personal data concerning him or to object to their treatment;

f) the right to lodge a complaint with a supervisory authority; if the data are not collected from the Interested Subject, right to obtain all information available on their origin;

g) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the Interested Subject.

2) if the personal data are transferred to a third country or to an international organization, the Interested Subject has the right to be informed of the existence of adequate guarantees related to the transfer;

3) request, and obtain, without undue delay, the correction of inaccurate data; taking into account the purposes of the processing, the integration of incomplete personal data, also by providing an additional declaration;

4) request deletion of data if:

a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

b) the Interested Subject revokes the consent on which the treatment is based and there is no other legal basis for the treatment;

c) the Interested Subject opposes the processing, if there is no legitimate overriding reason to proceed with the processing, or opposes the processing performed for direct marketing purposes (including the functional profiling of such direct marketing);

d) personal data have been processed unlawfully;

e) personal data must be deleted in order to fulfill a legal obligation provided for by the law of the Union or of the Member State to which our Company is subject;

f) personal data have been collected regarding the offer of information society services from our Company database;

5) request the limitation of the treatment that concerns You, when one of the following hypotheses occurs:

a) the Interested Subject disputes the accuracy of personal data; in this case the limitation of the treatment (i.e. the suspension of the same) may take place for the period necessary to our Company to verify the accuracy of such personal data;

b) the processing is unlawful (for example because the prior information of the law has not been provided to the Interested Subject) and the Interested Subject opposes the deletion of personal data (that is, he/she prefers to be stored in our paper and / or computer files ) and instead asks that its use be limited as above;

c) although our Company no longer needs it for the purposes of processing, personal data are necessary for the person concerned to ascertain, exercise or defend a right in court;

d) the Interested Subject has opposed the processing carried out for direct marketing purposes, pending verification of the possible prevalence of the legitimate reasons of our company compared to those invoked by the Interested Subject;

6) get from our Company, upon request, the communication of the third recipients to whom the personal data have been transmitted;

7) revoke at any time the consent to the treatment where previously communicated for one or more specific purposes of their personal data, being understood that this will not affect the lawfulness of the treatment based on the consent given prior to the revocation.

8) receive in a structured format, in common use and readable by automatic device, personal data concerning the Interested Subject supplied by him to our company and, if technically feasible, to transmit such data directly to another Data Controller without impediment on our part, if the following (cumulative) condition occurs:

a) the processing is based on the consent of the Interested Subject for one or more specific purposes, or on a contract of which the Interested Subject is a Subject and whose processing is necessary; and

b) the processing is carried out by automated means (software) (total right to the “portability“).

The exercise of the portability right implies the right to cancellation specified above;

9) not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects affecting him or which significantly affects his person. For clarification we specify that we do not operate any automated treatment of the aforementioned type;

10) propose a complaint to the competent Supervisory Authority based on the GDPR (Privacy Guarantor) or the ordinary Court.

Modification of the policy

This Privacy Policy, as from the date of its publication, shall supersede all and any previous versions of the same. Unless otherwise specified, the previous Privacy Policy shall continue to be applicable to any personal data collected up to that date. ADACTA reserves the right to modify this Privacy Policy at any time, so advising the users on this page. We recommend that you visit this page regularly and check the date of last version shown at the bottom of the page.

In the event that the data subject should not accept future modifications, they should cease using the website or the feature to which the privacy modification refers; in the event that the data subject does not cease their use of the site or feature, the modifications shall be considered as having been accepted (with the exception of those which modify the conditions for obtaining consent, where obligatory, for processing).

This policy complies with the provisions of the provision of 8.05.2014 with which the Privacy Guarantor implemented, with effect in Italy from 2 June 2015, the European directive 2009/136 / EC, which requires web page administrators to publish an information relating to the cookie policy of the site that visitors are browsing, as well as the requirements of the European Data Protection Board (“EDPB”) Guidelines of 2020 on retargeting.

On this page you can therefore find the necessary information on the use of cookies on the ADACTA website and how to identify and disable or delete them.

The Site may contain links to other Web sites that have their own privacy policy which may be different from that adopted by the SEO positioning of the Site and therefore not responsible for these sites.

WHAT COOKIES ARE AND HOW THEY ARE USED

Cookies are usually text strings that the websites (so-called publisher or “first party”) visited by the user or different sites or web servers (so-called “third parties”) place and store within a terminal device in the user’s availability (e.g. a personal computer, a tablet, a smartphone, or any other device capable of storing information).

The software for browsing the internet and the operation of these devices, such as browsers, can store cookies and then transmit them again to the sites that generated them on the occasion of a subsequent visit by the same user, thus maintaining memory of his previous interaction. with one or more websites.

The information encoded in the cookies may include personal data, such as an IP address, username, unique identifier or email address, but may also contain non-personal data, such as language settings or information about the type of device that a person is using to browse the site.

Cookies can therefore perform important functions among the most disparate, including the execution of computer authentication, monitoring of sessions, storing information on specific configurations regarding users who access the server, facilitating the use of online content, etc. For example, they can be used to keep track of items in an online shopping cart or information used to fill in a computer form. Cookies cd. “Authentication” are of particular importance whenever a verification is required in relation to the subject accessing certain services, such as payment.

The same result can also be achieved through the use of other tools (so-called “active identifiers” and “passive”), which allow for processing similar to those indicated above.

Among the “passive” tools, fingerprinting is increasingly used, ie the technique that allows you to identify the device used by the user by collecting information relating to the specific configuration of the device itself adopted by the person concerned. This technique can be used to achieve the same profiling purposes also aimed at displaying personalized behavioral advertising and analyzing and monitoring the behavior of website visitors. For these reasons, fingerprinting and additional tracking tools must therefore be included in the scope of application of these Guidelines.

Cookies can be first-party or third-party, depending on whether they are created and used directly by the first-party site (without, therefore, the intervention of third parties), or by third parties respectively (other than the owner of the site before part).

In order to always guarantee the best possible navigation, our site offers the best performance with cookies enabled. By default, almost all web browsers are set to automatically accept cookies.

WHICH COOKIES WE USE AND FOR WHAT PURPOSE

The Site uses or may use, also in combination with each other, the following categories of cookies:

• Permanent or “persistent” cookies: these cookies remain stored on the device even after leaving the website or in any case closing the browser: in particular, they remain until their expiry date or until they are manually deleted by the user. Persistent cookies fulfill many functions in the interest of surfers (such as, for example, password storage), however in some cases they can also be used for promotional purposes.
• Session cookies (or temporary): They have a limited duration for the visit and are deleted when the browser is closed, which ends the “session” to access the website. As a rule, they allow the user to access personalized services and to take full advantage of the site’s features, avoiding the use of other IT techniques that are potentially detrimental to the confidentiality of users’ browsing.
• Technical-functional cookies, for example for the transmission of session identifiers necessary to allow safe and efficient exploration of the site. These cookies avoid the use of other IT techniques that are potentially prejudicial to the privacy of users’ browsing.

For the use of technical cookies, the law requires the mere release of the information to the interested party at the time of the first “landing” on the site, as it happens via banner on the site or with this communication and that is even without the creation and publication of specific banners on the Site.

By default, at the time of the user’s first access to the ADACTA website, no cookies other than technical ones are placed on his device.

• Analysis cookies (so-called “analytics“): these cookies can be both temporary and permanent, and allow for the collection and analysis of statistical information relating to accesses in an aggregate and / or disaggregated manner (eg geographical area of origin of the user, access tool used, age, etc.) and in general to the behavior of users on the site and therefore to improve the experience and content provided.

These analytical cookies can be assimilated to technical-functional cookies and therefore do not require prior consent only if:

1. they are used only to produce aggregate statistics (i.e. without direct and univocal identification of the data subject, so-called single out) and in relation to a single site or a single mobile application, so as not to allow tracking of the navigation of the person who uses different applications or browse different websites;
2. the possibility is foreseen that the cookie is referable not only to one, but to several devices, in order to create a reasonable uncertainty about the computer identity of the subject who receives it (e.g., for those of third parties, at least the fourth is masked component of the IP address within the cookie);
3. third parties refrain from combining these analytics cookies, even as minimized above, with other processing (customer files or statistics of visits to other sites, for example) or from transmitting them to third parties.

An example of a first-party cookie is when the site uses log files (i.e. records the history of operations performed) and log files (which include IP addresses, browser type, operating system used by the user’s device. , Internet Service Provider (ISP), date, time, entry and exit page and the number of clicks, but also the pages visited on the site, the third party sites from which the user comes). All this to analyze user behavior trends and to administer and optimize the site. The information collected in this way is not personal in nature as the data is collected and analyzed anonymously.

In the event that analytical cookies are created and / or used by third parties (other than the owner of the first part site), they cannot be assimilated to technical cookies and have a different legal treatment.

• “Profiling” (or advertising) cookies (always permanent). they are used to bring back to specific, identified or identifiable subjects, specific actions or behavioral patterns recurring in the use of the functions offered (pattern) in order to group the different profiles (aggregated, i.e. anonymous, or not) within homogeneous clusters of different amplitude, so that it is possible to send targeted advertising messages, that is, in line with the preferences expressed by the user in the context of surfing the net (instead of the generalist ones offered indiscriminately to all) (so-called “behavioral advertising”).
• Social cookies: these cookies are from third parties, ie provided directly by the domains of the most common social media networks that are connected to our. Site through links to official pages, content sharing buttons and links. The use of these buttons and functions implies the exchange of information (e.g. texts, photographs, videos, etc.) with these sites.

The use of social cookies is purely anonymous, no personal information is collected unless the user intends to provide it explicitly by sending contact and / or information request forms to ADACTA. More information on this is contained in our. Privacy Policy.

LEGAL BASIS OF THE PROCESSING

For the use of technical cookies, the law requires that the information be made available to the interested party, as is the case with this communication and that is also without the creation of specific banners on the Site. The installation of technical-functional cookies is possible from part of ADACTA even without the need for the user’s prior consent, being based on ADACTA’s legitimate interest in making the Website work regularly, making it possible to access and use the various services published therein, also in the interest of user himself.

The installation of all non-technical cookies, on the other hand, is subject to the manifestation of the prior and informed consent of the contractor or user (in the simplified forms provided for by the Provision 8.5.2014 of the Guarantor as integrated by the Guidelines on cookies of the Guarantor of 10 December 2020 on the use of cookies and other tracking tools, also in light of the Guidelines no. 5/2020 of the European Data Protection Board – “EDPB”, and that is) by publishing a synthetic banner – cd brief information “- viewable by the user at the time of the first” landing “on our Site.

This banner allows you to generate a further univocal use of the Site with which the user can implicitly communicate his consent, or, alternatively, which allows access to an analytical (i.e. complete) cookie information, as part of the which one can express one’s necessary consent or dissent, of course not in reference to the individual cookies installed but in relation to broader categories of cookies as well as to specific producers and / or intermediaries with whom the Site has established commercial relationships (so-called “granular consent”).

ADACTA refrains from applying any “take it or leave it” mechanism, in which the user is obliged to express his consent to the receipt of profiling cookies, under penalty of inability to access the site.

In particular, when dealing with cookies other than technical ones, ADACTA uses an immediately pop-up banner of adequate size that contains:

a) the minimum indication relating to the fact that the site uses technical cookies and, only with the user’s consent, profiling cookies or other tracking tools indicating the related purposes (so-called “brief information”);

b) the link to the privacy policy containing the complete information on a second layer, including any other recipients of personal data, the data retention times and the exercise of the rights referred to in the GDPR;

c) the indication that the continuation of navigation by selecting an explicit command or an element contained in the page below the banner entails the provision of consent to profiling;

d) a command to accept the placement of all cookies or the use of other tracking techniques;

e) the link to another dedicated area in which you can analytically choose the functions, third parties and cookies, possibly even grouped by homogeneous categories, that you want to install and, through two further commands, you can give consent to use of all cookies if not previously given or revoke it, even in a single solution, if already expressed; even this user’s choice is adequately documented by the owner.

f) a command (e.g. an X at the top right) to close the banner without giving consent to the use of cookies or other profiling techniques while maintaining the default settings.

It is also specified that it is not necessary to reiterate the user’s consent to the installation of cookies if this has been previously given, validly acquired (and the owner is able to prove it) and there has been no change in the cookies with respect to the list. of those for which consent has previously been given or when it is impossible, for the site manager (for example because cookies have been deleted by the user or are blocked by the operating system or browser), to know if a cookie is previously stored in the device to be transmitted again, on the occasion of a subsequent visit by the same user, to the site that generated it; for example in the event that the user chooses to delete the cookies legitimately installed on his device and the owner has not adopted another system to keep track of the consent expressed.

In any case, the user is guaranteed the right to withdraw his consent on cookies at any time by accessing the appropriate dashboard that is made available to him by clicking on the appropriate banner for cookies published on the home page of the ADACTA website. From this reserved area, the user can make more detailed choices both with regard to the types of cookies and the list of third parties who may be recipients of the cookies themselves.

LIST OF COOKIES ACTUALLY PRESENT ON THE WEBSITE

The aforementioned premise does not automatically imply that this website currently uses all the categories of cookies indicated below.

The complete list of cookies actually used by ADACTA is only the one indicated within the second layer of the cookie banner published on our website and that the user can previously view upon landing on the site itself. By way of example, some of the active cookies are indicated below.

Storage of preferences and settings. Settings that allow products to function properly or that maintain preferences over time may be stored in the user’s device. For example, if a user specifies an application access setting, ADACTA can store this data in a cookie to allow the user to view relevant local information when he returns to the site. In addition, ADACTA saves preferences such as language settings.

Access and authentication. When you log in to a site with a personal account, a unique ID number and the time of access may be identified in an encrypted cookie on the user’s device. This cookie allows the user to move between the pages of the site without having to log in to each page again. In addition, the user can save the login information so that it is not necessary to log in every time you return to the site.

Social media. Some of our websites include social media cookies, including those that allow users connected to the social media service to share content through that service.

Performance. Some web applications use load balancing cookies to ensure that websites are always operational.

Google Analytics. The Site also uses Google Analytics cookies (cookies from Google Inc., an American company based in the USA). We specify that through the functions of Google Analytics no strictly personal information is collected, but, only in aggregate statistical form, data on the age, gender, and preferences of interest of our visitors (in order to better evaluate the use of the our website and the activities carried out by the visitor and to better target the services provided). These cookies are stored on servers that can be located in the United States or in other countries. Google reserves the right to transfer the information collected with its cookie to third parties where this is required by law or where the third party processes information on its behalf.

The “Analytics” functionality, in particular, is natively configured in such a way as to mask so significant, within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area, portions of the user’s / visitor’s IP address, and therefore the data relating to the IP address thus collected is already anonymized at the origin and therefore the analytical cookie does not allow to trace even indirectly – and in particular through further processing – to the identity of the user / visitor. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States. For more information on this, please refer to the following URL: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

For any further information relating to Google Analytics, please refer to the Privacy Policy at the following link: http://www.google.com/intl/it_ALL/analytics/learn/privacy.html.

Linkedin Business is also active as an analytics tool (all anonymous aggregate statistics) (see the Linkedin Business privacy policy at link xxx.

NAME PROFILING AND REMARKETING COOKIES

The site www.adacta.it does not use name profiling cookies, i.e. based on personal identification data.

Our site does not use remarketing lists and ads from the Google Display network, i.e. online advertisements based on categories of general interests expressed by categories of users through previous web browsing.

Without prejudice to the generality of the foregoing, our site does not use the special advertising functions of Google Analytics, which allow you to activate additional features not available through the standard implementations of Google Analytics and the related cookies.

These advertising features, when present, also allow the collection of traffic data (through Google advertising cookies and anonymous identifiers) in addition to the data normally already collected by us through a standard implementation of Google Analytics. The advertising functions of Google Analytics are as follows:

• Remarketing with Google ADS
• Reports on the impressions of the Google Display Network (when used through AdWords). The Display Network is a group of over two million websites, videos and apps on which our. Company can run their own AdWords ads. Display Network sites cover over 90% of Internet users around the world.
• Integrations with the DoubleClick platform
• Reports on demographic, territorial data and on the interests of Google Analytics

For info on the advertising functions of Google Analitycs: https://support.google.com/adwords/answer/117120?hl=it.

Other advertising cookies are processed by ADACTA through the following services:

• Google Ads conversion tracking

Google Ads conversion tracking is a statistics service provided by Google Inc. based in the USA that connects data from the Google Ads ad network with actions performed on this Website. With this technology, cookies are set when you interact with one of our ads, eg. click on it. Cookies are used to analyze what happens after interacting with an advertisement, eg. whether you have purchased our product, viewed the ad on a mobile phone, downloaded our app or signed up for a newsletter.

Place of processing: U.S.A. – Google Privacy Policy: https://policies.google.com/privacy?hl=it.

For how to disable the personalization of Google advertisements, see the URL: https://adssettings.google.com/authenticated?hl=it.

• Linkedin Website Retargeting

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.

Personal Data collected: Cookies and Usage Data. Place of processing: U.S.A. – Privacy Policy

• Linkedin conversion monitoring

LinkedIn Conversion Tracking is a statistics service provided by LinkedIn Corporation that connects data from the LinkedIn ad network with actions performed within this Application.

Personal Data collected: Cookies and Usage Data. Place of processing: U.S.A. – Privacy Policy.

For more information on online behavioral advertising and some suggestions on possible measures to disable the display of online interest-based advertisements: visit the sites www.youronlinechoiches.eu/it or http://optout.networkadvertising.org/?c=1#!/

COOKIES STORAGE DURATION

Cookies are stored by ADACTA for the durations respectively indicated in the List of Cookies present in the second layer of the cookie banner published in our Website.

MORE INFORMATION ON ADACTA’S SOCIAL CHANNELS

LinkedIn

ADACTA manages the LinkedIn page accessible at https://www.linkedin.com/company / adacta-studio-associate

On this page https://www.linkedin.com/legal/privacy-policy and also on this page https://privacy.linkedin.com/it-it/gdpr you can consult the LinkedIn privacy policy.

On this page https://www.linkedin.com/legal/cookie-policy you can consult the LinkedIn cookie policy.

YouTube

ADACTA manages the YouTube channel accessible at https://www.youtube.com/UCifF34Yjt6AVNJ2u2xR5bcg.

On this page https://policies.google.com/privacy you can consult the privacy policy of Google, of which YouTube is a part.

On this page https://policies.google.com/technologies/cookies?hl=it you can consult the cookie information from Google, of which YouTube is a part.

ACCEPTING OR REFUSING COOKIES IS YOUR RIGHT. HOW COOKIES ARE DISABLED

Browser settings

By default, browsers generally accept the use of cookies both from our site and from third-party sites.

To allow the site to function properly, exploit its features and use it in its entirety, we recommend that you accept the use of cookies other than advertising cookies.

However, the user is enabled to change the default (default) configuration at any time. To manage how cookies work, as well as the options for limiting or blocking cookies, it is in fact sufficient for the user to change the settings of their Internet browser through the relative toolbar. It is possible to choose between

• the unconditional acceptance of all cookies (in particular: browsing in any form on our site after the initial appearance on the video of the synthetic banner that warns you of the presence of cookies on our website, you implicitly consent to the use of cookies) ,
• indistinct rejection of all cookies permanently, or
• the display of a popup window (notice) every time a cookie is proposed, in order to be able to evaluate whether to accept it or not through an explicit action by the user.

Below are the links for configuring the most popular browsers that describe how to manage cookies:

• Chrome: https://support.google.com/accounts/answer/61416?hl=it
• Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
• Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
• Opera: http://help.opera.com/Windows/10.00/it/cookies.html
• Safari: https://support.apple.com/it-it/HT201265
• Microsoft Edge: https://support.microsoft.com/it-it/microsoft-edge/eliminare-i-cookie-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

To change the cookie settings in browsers other than those listed, refer to the help documentation prepared by the manufacturer of the specific browser.

Remember that you must set the cookie preferences for each device and each browser used when browsing the internet.

To delete cookies from the Internet browser of your smartphone / tablet, you need to refer to the device’s user manual.

Social network sites settings

The management of information and how to delete social cookies is regulated by the social media sites themselves: the user is invited to consult the respective privacy policies of each of them, at the following links:

• Linkedin: https://www.linkedin.com/legal/privacy-policy?trk=uno-reg-guest-home-privacy-policy
• YouTube: https://www.google.com/policies/technologies/types/

The use of these cookies is purely anonymous, no personal information is collected unless the user intends to provide it explicitly by sending contact forms and / or information requests.

Further information on privacy and the use of social cookies can be found directly on the websites of the respective third party managers.

For more information on cookies and privacy, please consult the specific document prepared by the Guarantor for the protection of personal data at the following link:

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/2142939

Use the area reserved for the user

Some registered users can update their settings and user profiles, organization settings and event registrations by logging into their accounts and directly modifying the settings or profiles.

Disable Google Analytics

The user can also selectively disable the action of Google Analytics by downloading and installing the additional opt-out component specifically provided by Google for your browser on your browser, at the following link: http://tools.google.com/dlpage/gaoptout

Disable the DoubleClick cookie

Users can disable DoubleClick’s use of cookies by visiting DoubleClick’s opt-out page https://adssettings.google.it/authenticated?hl=it#display_optout or the Network Advertising Initiative’s opt-out page http://optout.networkadvertising.org/.

MORE INFORMATION ABOUT COOKIES

For more information on the Italian rules on cookies, you can consult the Guidelines of the Privacy Guarantor at the link: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/9501061.

RIGHTS

Regarding the processing of personal data, You may exercise the following rights listed below, by contacting us without any formalities at the above email address:

1) ask us to confirm that it is or is not undergoing the processing of personal data concerning it and, in this case, obtaining access to personal data and the following information:

1. a) the purposes of the processing;
2. b) the categories of personal data in question;
3. c) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if recipients of third countries or international organizations;

(d) where possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period;

1. e) the existence of the right of the Interested Subject to ask our Company the rectification or cancellation of personal data or the limitation of the processing of personal data concerning him or to object to their treatment;
2. f) the right to lodge a complaint with a supervisory authority; if the data are not collected from the Interested Subject, right to obtain all information available on their origin;
3. g) the existence of an automated decision-making process, including profiling and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the Interested Subject.

2) if the personal data are transferred to a third country or to an international organization, the Interested Subject has the right to be informed of the existence of adequate guarantees related to the transfer;

3) request, and obtain, without undue delay, the correction of inaccurate data; taking into account the purposes of the processing, the integration of incomplete personal data, also by providing an additional declaration;

4) request deletion of data if:

1. a) personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;
2. b) the Interested Subject revokes the consent on which the treatment is based and there is no other legal basis for the treatment;
3. c) the Interested Subject opposes the processing, if there is no legitimate overriding reason to proceed with the processing, or opposes the processing performed for direct marketing purposes (including the functional profiling of such direct marketing);
4. d) personal data have been processed unlawfully;
5. e) personal data must be deleted in order to fulfill a legal obligation provided for by the law of the Union or of the Member State to which our Company is subject;
6. f) personal data have been collected regarding the offer of information society services from our Company database;

5) request the limitation of the treatment that concerns You, when one of the following hypotheses occurs:

1. a) the Interested Subject disputes the accuracy of personal data; in this case the limitation of the treatment (i.e. the suspension of the same) may take place for the period necessary to our Company to verify the accuracy of such personal data;
2. b) the processing is unlawful (for example because the prior information of the law has not been provided to the Interested Subject) and the Interested Subject opposes the deletion of personal data (that is, he/she prefers to be stored in our paper and / or computer files ) and instead asks that its use be limited as above;
3. c) although our Company no longer needs it for the purposes of processing, personal data are necessary for the person concerned to ascertain, exercise or defend a right in court;
4. d) the Interested Subject has opposed the processing carried out for direct marketing purposes, pending verification of the possible prevalence of the legitimate reasons of our company compared to those invoked by the Interested Subject;

6) get from our Company, upon request, the communication of the third recipients to whom the personal data have been transmitted;

7) revoke at any time the consent to the treatment where previously communicated for one or more specific purposes of their personal data, being understood that this will not affect the lawfulness of the treatment based on the consent given prior to the revocation.

8) receive in a structured format, in common use and readable by automatic device, personal data concerning the Interested Subject supplied by him to our company and, if technically feasible, to transmit such data directly to another Data Controller without impediment on our part, if the following (cumulative) condition occurs:

1. a) the processing is based on the consent of the Interested Subject for one or more specific purposes, or on a contract of which the Interested Subject is a Subject and whose processing is necessary; and
2. b) the processing is carried out by automated means (software) (total right to the “portability” ).

The exercise of the portability right implies the right to cancellation specified above;

9) not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects affecting him or which significantly affects his person. For clarification we specify that we do not operate any automated treatment of the aforementioned type;

10) propose a complaint to the competent Supervisory Authority based on the GDPR (Privacy Guarantor) or the ordinary Court.

DATA CONTROLLERS. CONTACTS

Joint controllers of personal data are ADACTA STUDIO ASSOCIATO and ADACTA ADVISORY SPA, with registered office in 36100 Vicenza, Strada Marosticana 6/8, e-mail: privacy@adacta.it.

CHANGES TO THE COOKIE POLICY

This Policy can be updated at any time to change the current legislation or for any change in the configuration and type of cookies used, therefore we suggest that you periodically view this cookie policy in order to know all subsequent updates of the same. The latest version of the Cookie Policy is indicated at the bottom of this document, which applies to the processing of Personal Data from the date indicated therein.

Changes and updates to the Site Cookie Policy will be effective as soon as they are published on the Site, in this section. In any case, you are required to regularly access this section to check the publication of the most recent and updated Cookie Policy of the Site.

As in fact clarified in the General Provision of the Guarantor of 4 July 2013 containing the “Guidelines for combating spam“:

• the communication or transfer of personal data to third parties for marketing purposes in general cannot be based on the acquisition of a single and generic consent from the interested parties for such purposes;
• the owner must acquire a specific consent for the communication (and / or transfer) of personal data to third parties for promotional purposes, as well as distinct from that required by the same owner to carry out a promotional activity himself; if the interested party gives such consent, third parties may carry out promotional activities for him also with the automated methods referred to in art. 130, paragraphs 1 and 2 of the Privacy Code without having to acquire a new consent for the promotional purpose.
• the data controller who intends to collect the personal data of the interested parties also to communicate them (or transfer them) to third parties for their marketing purposes must first issue them with suitable information which also identifies each of the third parties or, alternatively, indicates the categories (economic or commodity) to which they belong.