PRIVACY POLICY

Article 13 of EU Regulation 2016/679 (GDPR)

WHY THIS INFORMATION?
Pursuant to the Legislative Decree 196/03 and the EU Regulation 2016/679 (GDPR), this page describes how the users’ personal data is processed by the data controller, owner of the following website:
www.sbalchieropartners.com
This information does not concern other websites, pages or online services that can be reached through links published on the site.

DATA CONTROLLER
By browsing this website, personal data relating to identified or identifiable natural persons may be transferred to and processed by the data controller.
The data controller is Sbalchiero & Partners Srl, in Viale Quintino Sella 5 – 36100 Vicenza (VI) (Italy) – e-mail: info@sbalchieropartners.com PEC: sbalchieropartners@pec.it – Phone + 39 0444 567736.

LEGAL BASIS OF THE PROCESSING OF DATA
The personal data received by this page is processed by Sbalchiero & Partners Srl for the purposes of managing the business relationship and to offer any requested services.

TYPES OF PROCESSED DATA AND THE PURPOSES OF PROCESSING
Browsing data
The computer systems and software procedures used by this website normally acquire some personal data to function properly.
This information is not collected with the purpose of association to identified persons but contains sufficient information that could allow users to be identified by analysis and combination with data held by third parties.
This category of data includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters relating to the user’s operating system and computer environment.
This data is necessary for the use of web services, and is also processed for the purpose of:
obtaining statistical data on the use of the services (most visited pages, number of visitors per time slot or day, geographical areas of origin, etc.);
to obtain anonymous statistical data on the use of the site and to check its proper functioning (data that is deleted immediately after processing). The data could be used to ascertain responsibility in the event of computer crimes against the site.

Data voluntarily communicated by the user
The optional, explicit and voluntary sending of personal data to access certain services:
User registration for access to reserved areas;
To request the newsletter and other commercial or technical information regarding services and products offered by Sbalchiero & Partners;
Requesting information by contacting the addresses indicated on the website
involves the acquisition of personal data included in the sender’s request (processed because it is necessary for responding to the requests). Any e-mail sent to the addresses found on the website involves the acquisition of your e-mail address. We will process this as well as any other personal information included in your message solely for the purposes of responding to your requests.

In order to use automated marketing tools as referred to in point B, explicit consent is necessary (art. 6, (1), GDPR) by ticking the appropriate box in the form. This consent can be withdrawn at any time (13, (2), GDPR).

This category of data includes the name, surname, e-mail address, street address, telephone contact, company name, etc.

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COOKIES
In accordance with the provision of the Italian Data Protection Authority no. 229 of 8 May 2014: “Identification of simplified procedures for the information and acquisition of consent for the use of cookies”, Sbalchiero & Partners Srl informs users about the use of navigation cookies on this website www.sbalchieropartners.com. It should be noted that this information refers only to this website and not to websites of third parties, which may be reached through links.

What are cookies?
A cookie is a small file that is sent to your browser and saved on your device when you visit a website such as www.sbalchieropartners.com. Cookies allow the website to function efficiently and improve its performance by providing information to the website owner for statistical or advertising purposes, mainly to personalize the browsing experience and to remember preferences. www.sbalchieropartners.com uses different types of first party cookies (prepared and managed by Sbalchiero & Partners Srl) and third-party cookies (prepared and managed by third parties according to their privacy policies and not under the control of Sbalchiero & Partners Srl) as follows:

TYPES OF COOKIES	FUNCTIONS	USE
Technical cookies (session or navigation cookies)	They guarantee the normal browsing and use of the website and check the functioning and optimization of the site.	Sbalchiero & Partners Srl uses this type of cookie by default.
Functionality cookies	They are necessary to provide services explicitly requested by the user.	Sbalchiero & Partners Srl uses this type of cookie by default.
Analytical cookies (first part)	They are used exclusively by the data controller to collect data, in aggregate and anonymous form, on the number of users and on how users visit the site.	Sbalchiero & Partners Srl uses this type of cookie by default.
Third party analytic cookies (e.g., Google Analytics)	Sbalchiero & Partners Srl has adopted appropriate tools to ensure that the processing with these cookies is carried out for statistical purposes only.	Sbalchiero & Partners Srl does not use this type of cookie.

PURPOSE OF PROCESSING DATA BY COOKIES
The purposes for which this website uses cookies are as follows:
Facilitate user navigation
Perform computer authentication
Monitor browsing sessions

THE NATURE OF THE PROVISION OF DATA AND THE CONSEQUENCES OF REFUSAL TO PROVIDE IT
The installation of cookies detailed in points 1, 2 and 3 above is not subject to the prior consent of the users, as they are strictly necessary for transmission of information over the internet.
The processing will be carried out with automated systems in order to store and manage the data in accordance with the indicated purposes and to ensure the security and confidentiality of data.

Enabling and disabling cookies from the browser
Most browsers are configured to accept, control or disable cookies through their settings. Disabling navigation cookies or functional cookies may cause the website www.sbalchieropartners.com to malfunction and/or offer a limited service.
How to manage cookies from the following browsers:
Chrome:
https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
Firefox:
https://support.mozilla.org/it/kb/Eliminare%20i%20cookie
Internet Explorer:
https://support.microsoft.com/it-it/help/278835/how-to-delete-cookie-files-in-internet-explorer
Opera:
https://www.opera.com/help/tutorials/security/privacy/
Safari:
https://support.apple.com/it-it/HT201265

Enabling and disabling third party cookies
Below are the links to the information provided by third parties who manage cookies within the website www.sbalchieropartners.com and the instructions to manage and disable them:
Facebook:
https://it-it.facebook.com/policies/cookies/
Google Analytics:
https://support.google.com/analytics/answer/181881?hl=en
Instagram:
https://help.instagram.com/1896641480634370
LinkedIn:
https://www.linkedin.com/legal/cookie-policy?_l=it_IT

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PURPOSE OF AND OPTIONAL COOKIE PROCESSING
The personal data collected through the website www.sbalchieropartners.com are used for the following purposes:
for your requests to be contacted by our company, Sbalchiero & Partners Srl
for your requests of commercial information on the services of the company
for sending us your CV.
Specific summarized information will also be sent directly to the user or can be displayed in specific sections of the website, offering particular services and can be subject to the consent of the data subject.
Apart from the above, the user is free to provide personal data, in particular the data contained in the request forms on the website www.sbalchieropartners.com. Failure to provide them may make it impossible to offer the requested service.

METHODS OF DATA PROCESSING
Personal data is processed automatically for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are adopted to prevent data loss, illicit or incorrect use and unauthorised access.

PERIOD OF DATA RETENTION
Personal data collected through the use of the website www.sbalchieropartners.com is processed for the length of time strictly necessary to achieve the purposes for which they were collected and, for the time established by law.
For further details, see specific privacy policies that apply to customers, suppliers, employees, etc.

DATA COMMUNICATION AND CATEGORIES OF RECIPIENTS
All data collected and processed through the website may be disclosed to persons within the company duly authorized to process the data by reason of their duties, as well as to external persons to whom it may be necessary to communicate the data, exclusively for the aforementioned purposes. These external recipients, should they process data on behalf of Sbalchiero & Partners Srl, will be designated as External Data Processors by contract or another legal act under Article 28 GDPR.
For further details, see privacy policies for particular services.

DATA TRANSFER TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANISATION
The personal data of users will not be transferred to non-European third countries.
For strictly organizational reasons, some personal data may be transferred to countries outside the EU, as the data controller uses Cloud services provided by suppliers who provide adequate guarantees, as provided for in Article 46 GDPR.

THE RIGHTS OF THE DATA SUBJECTS
The data controller hereby informs the users (“data subjects”) of the website www.sbalchieropartners.com of the following rights, which they may exercise at any time:
Right to be informed (transparency in data processing)
The data subject has the right to be informed of how the data controller processes their personal data, for what purposes and on other information provided for in art. 13 GDPR. To this end, the data controller has set up organisational processes that allow, at the time of acquisition or request of personal data, the release of a model of information created “ad hoc” according to the category of data subject to whom the data subject belongs (employee, customer, supplier, etc.). This document allows to adequately inform all the data subjects about how the processing is carried out in their case. The information form can be requested directly from the data controller.
Right to withdraw consent (Art. 13(2)(a) GDPR)
The data subject has the right to withdraw consent at any time for any data processing that requires a manifestation of consent. Withdrawal of consent shall not affect the lawfulness of the processing carried out up to that time.
Right of access to data (art. 15 GDPR)
The data subject may request information on: (a) the purposes of data processing; (b) the categories of personal data; (c) the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular if they are recipients from third countries or international organisations; (d) where possible, the intended retention period for the personal data or, where that is unknown, the criteria used to determine that period; (e) the right of the data subject to request the controller to correct or erase the personal data, to request the restriction of or to object to their processing; f) the right to contact the Data Protection Authority; g) when the data is not received directly from the data subject, the origin of the data; (h) the existence or otherwise of an automated decision-making process, including profiling as referred to in Article 22(1) and (4), and in case of profiling, meaningful information on the logic, importance, and the expected consequences of such processing for the data subject. The data subject also has the right to request a copy of the personal data being processed.
Right to rectification (Art. 16 GDPR)
The data subject has the right to request the rectification of inaccurate personal data and to obtain the addition to incomplete personal data.
Right to be forgotten (Art. 17 GDPR)
The data subject has the right to the erasure of their personal data if the personal data is no longer necessary for the purposes for which they were collected or otherwise processed, if the data subject withdraws their consent, if there is no legitimate reason to proceed with profiling, if the data have been processed unlawfully, if there is a legal obligation to erase them; if the data relates to web services provided to minors without the relevant consent. Erasure may take place unless the right to freedom of expression and information prevails, unless the data is retained for the fulfilment of a legal obligation or for the performance of a task carried out in the public interest or in the exercise of official authority, for the benefit of public health, for the purpose of public archives, for scientific or historical research or for statistical purposes or for the establishment, exercise or defence of a right in court.
Right to restriction of processing (Art. 18 GDPR)
The data subject has the right to restrict the data processing when he has protested the accuracy of the personal data (valid for the time it takes to verify the accuracy of such personal data). If the processing is unlawful the data subject may oppose the erasure of personal data and request limited processing if the data is necessary for the assessment, exercise or defence of a right in court, and the data is no longer necessary for the data controller.
Right to data portability (Art. 20 GDPR)
The data subject has the right to receive in a commonly used, structured, and machine-readable format all their personal data and to transmit them to a third party if the processing is based on consent, a contract and if the processing is carried out by automated means; unless the processing is necessary for the performance of a task of public interest or related to the exercise of official authority and that such transmission does not infringe the rights of third parties.
Right to contact the Italian Data Protection Authority (art. 77 GDPR).
Without prejudice to any other administrative or judicial remedy, whereby the data subject may bring the matter before the competent judicial authorities pursuant to Article 79 of the GDPR, if the data subject considers that the processing of personal data concerning him or her is in breach of the regulation on the protection of personal data, he or she has the right to lodge a complaint with a supervisory authority, in particular in the Member State in which he or she habitually resides, works or the place where the alleged infringement took place.
Requests for data protection should be addressed to the data controller for the exercise of rights under Articles 13-20 GDPR:

– by e-mail to: info@sbalchieropartners.com
– by certified e-mail to: sbalchieropartners@pec.it
– by post to the data controller: Sbalchiero & Partners Srl, Viale Quintino Sella n.5 – 36100 Vicenza (VI) (Italy)

Requests for data protection in accordance with Article 77 GDPR should be addressed to the Italian Data Protection Authority.
– by post, to the Italian Data Protection Authority, Piazza Venezia, 11, IT-00187, Rome
– by e-mail to: rpd@gpdp.it

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Last updated: May 2018.
This Policy is subject to change. We therefore recommend that you check this web page regularly and consider the most recent version of this policy.