Data Controller

ASW-ATI, Via Volontari della Libertà, 54/56, 50053 Empoli FI

Owner’s email address: a.allocca@asw-ati.com

Types of Data collected

Among the Personal Data collected by this Application, either autonomously or through third parties, there are:
Tracking Tool; Usage Data.

Complete details on each type of Data collected are provided in the dedicated sections of this privacy policy or by specific information texts displayed prior to the Data collection itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without any consequence on the availability of the Service or its operation.
Users who are uncertain about which Data are mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate them, holding the Owner harmless from any liability towards third parties.

Methods and place of processing the collected Data

Methods of processing

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

Legal basis of processing

The Owner processes Personal Data relating to the User if one of the following conditions applies:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be allowed to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. This, however, does not apply where the processing of Personal Data is regulated by European data protection legislation;
• processing is necessary for the performance of a contract with the User and/or for any pre-contractual measures;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

It is always possible to ask the Owner to clarify the specific legal basis applicable to each processing and, in particular, to specify whether the processing is based on the law, required by a contract, or necessary in order to enter into a contract.

Place

The Data are processed at the operational offices of the Owner and in any other places where the parties involved in the processing are located. For further information, contact the Owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information regarding the place of processing, the User may refer to the section containing details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Owner to protect the Data.

The User can verify whether any of the transfers just described takes place by examining the relevant sections of this document regarding details on the processing of Personal Data or by asking the Owner for information via the contact details indicated at the beginning.

Retention period

Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User will be retained until such contract has been fully performed.
• Personal Data collected for purposes linked to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When processing is based on the User’s consent, the Owner may retain the Personal Data for a longer period until such consent is withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, erasure, rectification, and the right to Data portability can no longer be exercised.

Purposes of the processing of collected Data

The User’s Data are collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of the Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes:
Access to accounts on third-party services, Statistics, Interaction with social networks and external platforms, Tag management, Displaying content from external platforms, and Content performance and functionality testing (A/B testing).

For detailed information on the purposes of processing and on the Personal Data processed for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions requested by this Application

This Application may request certain Facebook permissions that allow it to perform actions with the User’s Facebook account and to collect information, including Personal Data, from it. This service allows this Application to connect with the User’s account on the social network Facebook, provided by Facebook Inc.

For more information about the permissions below, please refer to the Facebook permissions documentation and the Facebook privacy policy.

The permissions requested are as follows:

Basic information

Basic information of the User registered on Facebook which normally includes the following Data: id, name, picture, gender, and locale; and, in some cases, Facebook “Friends”. If the User has made additional Data publicly available, such Data will be available.

Read content posted by the Page

Allows reading content (posts, photos, videos, events) published by the Page, reading follower data (including name, PSID) and profile picture, and reading metadata and other statistical data about the Page.

Detailed information on the processing of Personal Data

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

• Access to accounts on third-party services

  This type of service allows this Application to retrieve Data from your accounts on third-party services and perform actions with them.
  These services are not activated automatically, but require the User’s explicit authorization.

  Access to the Facebook account (Facebook, Inc.)

  This service allows this Application to connect with the User’s account on the social network Facebook, provided by Facebook, Inc.

  Permissions required: Read content posted by the Page.

  Place of processing:
  United States

• Tag management

  This type of service is functional to the centralized management of tags or scripts used on this Application.
  The use of such services entails the flow of the User’s Data through them and, where applicable, their retention.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Usage Data.

  Place of processing:
  Ireland

• Interaction with social networks and external platforms

  This type of service allows interactions with social networks, or other external platforms, directly from the pages of this Application.
  The interactions and information acquired by this Application are, in any case, subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services to ensure that the data processed on this Application are not connected back to the User’s profile.

  YouTube social button and widgets (Google Ireland Limited)

  The YouTube social button and widgets are services allowing interaction with the YouTube social network, provided by Google Ireland Limited.

  Personal Data processed: Usage Data.

  Place of processing:
  Ireland

• Statistics

  The services contained in this section enable the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, to prepare reports, and to share them with other services developed by Google.
  Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing:
  Ireland

  WordPress Stat (Aut O’Mattic A8C Ireland Ltd.)

  WordPress Stats is a statistics service provided by Aut O’Mattic A8C Ireland Ltd.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing:
  Ireland

• Content performance testing and functionality testing (A/B testing)

  The services contained in this section allow the Data Controller to track and analyze User response, in terms of traffic or behavior, in relation to changes to the structure, text, or any other component of this Application.

  Google Optimize (Google Ireland Limited)

  Google Optimize is an A/B testing service provided by Google Ireland Limited (“Google”).

  Google may use Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing:
  Ireland

  Google Optimize 360 (Google Ireland Limited)

  Google Optimize 360 is an A/B testing service provided by Google Ireland Limited (“Google”).

  This service allows the Owner to target groups of Users based on their past use of this Application. Users who disable tracking by Google Analytics will not be included in experiments created within Google Optimize 360.

  Google may use Personal Data to contextualize and personalize the ads of its advertising network.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing:
  Ireland

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
  This type of service may still collect web traffic data relating to the pages where the service is installed, even when users do not use it.

  YouTube Video Widget (Google Ireland Limited)

  YouTube is a video content display service managed by Google Ireland Limited that allows this Application to integrate such content within its pages.

  Personal Data processed: Usage Data; Tracking Tool.

  Place of processing:
  Ireland

  Google Fonts (Google Ireland Limited)

  Google Fonts is a font style display service managed by Google Ireland Limited that allows this Application to integrate such content within its pages.

  Personal Data processed: Usage Data; various types of Data as specified by the service’s privacy policy.

  Place of processing:
  Ireland

User rights

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, the User has the right to:

• withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.
• object to the processing of their Data. The User can object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are indicated in the section below.
• access their Data. The User has the right to obtain information about the Data processed by the Owner, on certain aspects of the processing, and to receive a copy of the Data processed.
• verify and seek rectification. The User can verify the accuracy of their Data and request that it be updated or corrected.
• obtain restriction of processing. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Owner will not process the Data for any purpose other than storage.
• obtain the erasure or removal of their Personal Data. When certain conditions are met, the User may request the erasure of their Data by the Owner.
• receive their Data and have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transmitted without hindrance to another controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, on a contract to which the User is a party, or on related pre-contractual obligations.
• lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details about the right to object

When Personal Data are processed in the public interest, in the exercise of official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users have the right to object to the processing on grounds relating to their particular situation.

Users are reminded that, where their Data are processed for direct marketing purposes, they may object to the processing at any time without providing any justification. To find out whether the Owner processes Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

To exercise the User’s rights, Users may send a request to the Owner’s contact details indicated in this document. Requests are made free of charge and processed by the Owner as soon as possible and, in any case, within one month.

Cookie Policy

This Application uses Tracking Tools. To learn more, the User can consult the Cookie Policy available in the footer of the site www.asw-ati.com.

Additional information about Data processing

Legal defense

The User’s Personal Data may be used by the Owner in court or in the stages leading to possible legal action for the defense against abuse in the use of this Application or the related Services by the User.
The User declares to be aware that the Owner may be required to reveal Data upon order of public authorities.

Specific information

Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

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

Information not contained in this policy

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

“Do Not Track” requests

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services used honor “Do Not Track” requests, the User is invited to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, within this Application as well as, where technically and legally feasible, by sending a notice to Users via any contact details available to the Owner. Please therefore consult this page frequently, referring to the date of the last modification indicated below.

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