THE PROTECTION OF YOUR PRIVACY IS ONE OF OUR MAIN OBJECTIVES.
TAGLIORETTI S.r.l. with registered office in Via dei tigli, 5 – Gornate Olona, CAP 21040, undertakes to constantly protect the privacy of its users on-line. This document outlines our policy on privacy, explaining how your personal data are managed when using our services, and to enable you to give express consent to the processing of your personal data while being aware of the website sections requiring the entry of such data. Note that the various sections of the web sites of www.taglioretti-srl.eu (hereinafter “Site”) requiring entry of your personal data may contain specific disclosure options in accordance with art. 13 of the Regulation (EU) 2016/679 (hereinafter “GDPR”), which must be viewed by you before providing the requested data. The information and data supplied by you or otherwise acquired when registering for the various services of TAGLIORETTI, (for example to register domain names, to supply an email account, to supply a certified email account (PEC), supply web space, supply hosting services, supply other accessory services, hereinafter referred to in general as “Services”), will be processed in observance of the provisions of the GDPR and the obligations for confidentiality that form the basis of the work of TAGLIORETTI. In accordance with the provisions of the GDPR and the Legislative Decree 196/2003 and its subsequent amendments (hereinafter “Italian Data Protection Code”), the processing operations carried out by TAGLIORETTI will comply with the principles of lawfulness, fairness, transparency, purpose and retention limitation, data minimisation, accuracy, integrity and confidentiality.
1. Data Controller and Data Protection Officer
2. Personal data undergoing processing
- a. Browsing data
- b. Data processed during engagement with social media
- c. Cookies
4. Recipients of personal data
5. Transfer of personal data
6. Retention of personal data
7. Data subjects’ rights
1. Data Controller and Data Protection Officer
The controller of the processing operations carried out through the Site is TAGLIORETTI (hereinafter “Controller” or “Data Controller” or “Company”). The Data Controller’s organisation comprises a Data Protection Officer (hereinafter “DPO”). The DPO is available for any information regarding the processing of the personal data carried out by TAGLIORETTI. It is possible to contact the DPO by writing to firstname.lastname@example.org.
With specific regard to the activities carried out by TAGLIORETTI through the services of Facebook Inc., as described in Section 3 (h) of this policy, TAGLIORETTI acts as a joint controller of the processing together with Facebook Inc.: please refer to Section 3 (h) of this policy for more information.
2. Personal data undergoing processing
Processing of personal data means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We inform you that the personal data undergoing processing – depending also on how you intend to use the Services – may consist of an identifier such as the name, e-mail address, ID number, location data, online identifier, purchases made and other data enabling you to be identified or identifiable, depending on the type of Services requested (hereinafter “Personal Data”).
In particular, the Personal Data processed through the Site are the following:
a. Browsing data
The computer systems and software procedures used for operation of the TAGLIORETTI web site acquire, during routine operation, some personal data, the transmission of which is considered implicit in the use of the Internet communication protocols. This information is not collected to be associated with identified persons, but which in their nature may, through processing and associations with data retained by third parties, enable the identification of users. This category of data includes IP addresses or domain names of the computer used by the users to connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the dimensions of the file obtained in the response, the numerical code indicating the status of the response sent by the server (successful, error, etc.) and other parameters regarding the operating system and IT environment of the user. These data are used exclusively to retrieve anonymous statistical information on use of the present site and the sites of our clients, and to ensure correct operation of the latter, identify faults and/or abuse, and are deleted immediately after processing. The same data may be used to ascertain responsibility in the hypothetical case of computer crime harmful to the site or third parties: with the exception of this case, the data on web contacts are not stored for more than fourteen days, unless specific requests are made by the user (e.g. access to the user’s personal pages within TAGLIORETTI summarising services used, information published etc.).
b. Data processed during engagement with social media
Besides filling out the appropriate registration form, you can register to the Services if you have a Facebook profile by just clicking on the “Login with Facebook” button. In this case, Facebook will automatically send TAGLIORETTI some of your Personal Data, indicated in the pop-up window, which appears upon applying, and you will not need to fill out any other forms. If, instead, you are already a registered user of TAGLIORETTI and also have a Facebook profile, you can choose to associate your TAGLIORETTI account to your Facebook account by clicking on “Login with Facebook” and then on “Associate Account”: this way, your Register identification code will be associated to your Facebook user code, and you can then directly authenticate yourself by just clicking on “Login with Facebook” to your Register control panel without entering any credentials.
In the same way, TAGLIORETTI gives you the possibility of associating your TAGLIORETTI account to any Google, Twitter and LinkedIn accounts. In such cases too, these social media sites will automatically send a TAGLIORETTI some of your Personal Data, indicated in the pop-up window, which appears upon applying.
Definitions, characteristics, and application of standards
There are various types of cookie, depending on their characteristics and functions, and these may remain stored on the user’s computer or mobile device for different periods of time: the so-called session cookies, which are automatically deleted on closure of the browser; the so-called persistent cookies, which remain on the user’s device through to a pre-set expiry.
• analytics cookies, where used directly by the site manager to collect information, in aggregate form, on the number of users and how the latter visit the site itself;
• browsing or session cookies (for login);
• function cookies, which enable the user to browse a site according to a selected set of criteria (for example language, products selected for purchase) for the purposes of improving the service provided to the user.
On the contrary, “profiling cookies”, i.e. those used to create user profiles and used to send advertising messages in line with the preferences outlined by the user while browsing on the network, required specific consent from the user.
Types of cookie used by the site and option of (de)-selection (cookies – or links to the information policies of the third parties that send cookies – marked with an asterisk refer to the website www.taglioretti-srl.eu)
The Site uses the following cookies that can be deselected as required, with the exception of third-party cookies, in which case the user should refer directly to the selection and deselection modes of the respective cookies, indicated via the links:
• Technical browsing or session cookies strictly necessary for operation of the Site or to enable the user to use the contents and services requested by the latter.
• Analytics cookies, which enable the system to understand how the site is used by the users and from which external websites or advertising campaigns users have landed on the Site. These cookies are NOT used to send advertising messages based on the preferences expressed by the user while browsing the network and simply allow to use statistical information – in an aggregate form – in a useful manner to improve the Site and the services.
• Function cookies, i.e. cookies used to activate specific site functions and a selected set of criteria (for example language, products selected for purchase) for the purposes of improving the service provided to the user.
• Profiling cookies used to send advertising messages in line with the preferences shown by the user within the online browsing environment. In particular, where you have given your consent to receive such cookies through the continuation of navigation or through the “enable” button at the bottom of this page, these cookies keep track of the pages you have visited within the site www.taglioretti-srl.eu so that TAGLIORETTI can send or allow you to view content relevant to the searches you have made within the site and to the products which you have shown interest in. You may refuse this processing, at any time, by setting the button at the bottom of this page to “disable” in correspondence with the words “profiling cookies”.
CAUTION: disabling the technical and/or function cookies of the Site could make it impossible to browse or render unavailable certain services or functions of the Site, causing some malfunctions, in which case the user would be obliged to modify or manually enter some information or preferences each time he/she visits the Site.
• Third-party cookies, i.e. cookies of sites or web serves other than that of TAGLIORETTI, used for specific purposes of the said third parties, including profiling cookies. Note that these subjects, listed below with the relative links to their privacy policies, are autonomous Controllers of the data collection and handling processes via cookies; you must therefore refer to their personal data handling policies, information policies and consent forms (selection and disabling of respective cookies) as specified in the aforementioned Provision. To complete this it must be noted that TAGLIORETTI makes the utmost effort to track cookies on its own Site. These are updated regularly on the table below, where we ensure transparency of the cookies sent directly by TAGLIORETTI and the purposes of these procedures. Regarding these cookies, we provide the links to the information policies of the third parties that send them via our Site: we assign these third parties, as noted above, with the responsibility of supplying the information policy and collecting consent from the users, as envisaged in the Provision. This responsibility refers not only to the cookies sent directly by the third parties but also to any additional cookies sent via our Site based on the use of the services used by the third parties themselves. In fact, with regard to these cookies, sent by the suppliers of services of the aforementioned third parties, TAGLIORETTI cannot exercise any right of control and cannot be aware of either the characteristics or purposes of these.
In some cases, however, third-party cookies are sent on the basis of a contract between these third parties and TAGLIORETTI; this is the case, for example, with some Google cookies. Without prejudice to the autonomous controllership of the processing activity carried out by Google, over which TAGLIORETTI has no control, these cookies are used by TAGLIORETTI to receive services, such as services for analysis of the use of the site by its users, or services that allow advertising messages from TAGLIORETTI to be routed through the Internet in the form of advertising banners, which the user who has visited this Site may notice appearing on third-party websites.
The following section lists the links to the information on third party cookies:
In detail, the cookies sent from TAGLIORETTI via their own Site are specified below:
Cookies present on the Site
No Cookies present on the site (Analysis carried out with: webcookies.org)
Below you can make a choice with reference to the receipt of profiling cookies. Failure to authorize the use of the indicated cookies (profiling) will not affect the operation of the Site. You may block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. We inform you however that not authorizing technical cookies could make it impossible to use the Site, view its contents and use the relative services. Inhibit functionality cookies may mean that some services or certain functions of the Site are not available or do not work properly and you may be forced to change or manually enter some information or preferences whenever you visit the Site.
The choices made regarding the site’s cookies will in turn be recorded in a special cookie. This cookie may, however, in some circumstances not function properly: in such cases, we advise you to delete unwanted cookies and to inhibit their use also through the functionality of its browsers.
Your preferences regarding cookies should be reset if you use different devices or browsers to access the site.
They are sent in order to send advertising messages in line with the preferences expressed by the user in the context of web browsing.
How to view and modify cookies via your browser
You can select which first-party cookies to authorise via the relative procedure set up in this page, and can also authorise, block or delete (totally or in part) the cookies via the specific functions in your browser.
For more information on how to set the preferences for cookies via your browser, refer to the following instructions:
3. Purposes of processing, legal basis and mandatory or discretionary nature of processing
The purposes of the processing we intend to carry out, following your express consent where necessary, are the following:
a. to allow us to provide the Services you requested and the subsequent, independent management of your control panel, which you will access by registering and creating your user profile on providing the Services, including the collection, retention and processing of data for the establishment and subsequent operational, technical and administrative management of the relationship arising from the provision of the Services, and the exchange of messages during the course of the relationship;
b. to allow you to browse and explore TAGLIORETTI websites;
c. to answer requests for assistance or information, which we will receive via e-mail, telephone or chat through the “Contact us” section of our Site, or through the appropriate “Privacy Notices” form at https://www.taglioretti-srl.eu/privacy-policy-en/?lang=en. For answers to telephone requests for assistance received by TAGLIORETTI, we inform you that the calls are going to be recorded so that TAGLIORETTI can prove it has properly handled requests received. With regards to requests received by TAGLIORETTI by e-mail, they too will be retained, together with the appropriate replies, for the time necessary to assure the correct processing of the requests, as well as, subsequently, to allow TAGLIORETTI to defend itself in court, where necessary. The legal basis for the processing of Personal Data for the purposes referred to in letters (a), (b) and (c) above is art. 6(1)(b) of the GDPR as the processing is necessary for the provision of contractual services. The provision of Personal Data for these purposes is optional, but failure to provide it entails the impossibility to activate the requested Services. On the other hand, with specific regard to the recording of telephone calls, the processing is based on art. 6 (1)(f) of the GDPR, as TAGLIORETTI has a legitimate interest in making such recordings, which according to the balancing assessment made by the Data Controller, does not prevail over the fundamental rights and freedoms of the individuals concerned. If you do not wish for this processing to take place, we invite you to submit only written requests to our customer service and to avoid the use of the telephone;
d. to fulfil legal, accounting and tax obligations: this processing is legitimate under art. 6(1)(c) of the GDPR. Once the Personal Data has been provided, the processing may indeed be necessary to comply with legal obligations to which TAGLIORETTI is subject; and in those cases, it is not possible for the users to object to this processing, since it is a processing operation deriving from legal obligations;
e. to carry out direct marketing activities via e-mail for services similar to those you have subscribed to, unless you objected to such processing initially or in subsequent communications, in order to pursue TAGLIORETTI legitimate interests to promote products and services which you may be reasonably interested in; this processing is based on the assumption of lawfulness under art. 130, paragraph 4 of the Italian Data Protection Code: “if the owner of the processing uses, for the purpose of direct sale of its products or services, the e-mail address provided by the data subject in the context of the sale of a product or service, the consent of the data subject may not be required, provided that these services are similar to those being sold and the data subject, who is adequately informed, does neither at first nor in the occasion of subsequent communications refuse such uses. The Data Subject, at the time of collection and at the time of sending any communication made for the purposes referred to in this paragraph, is informed of the possibility to object at any time to the processing, in an easy manner and free of charge”; objections to this processing have no impact on the use of services;
f. to conduct studies, research, market statistics; to send you advertising and information material, commercial information, or surveys to improve the service (“customer satisfaction”) via e-mail or SMS, and/or over the telephone through operator and/or through the official pages of TAGLIORETTI on social media as well as through your control panel, if you are a TAGLIORETTI customer; furthermore, if you are a Facebook user, you may see TAGLIORETTI advertising banners on your Facebook profile (hereinafter reference will be made to the activities listed herein as “Marketing”): the processing of your data for Marketing purposes is based on your consent pursuant to art. 6(1)(a) of the GDPR. You may object to the processing of your data for Marketing purposes through your control panel, or by sending a request from the Site or through the mechanism specified in the footer of commercial e-mails, or by writing to email@example.com. Objections to this processing have no impact on the use of services;
g. only with regard to certain services, the data may be processed for disclosing to third parties for their marketing purposes, namely to provide you with information and/or to propose offers on products, services or initiatives offered or promoted by other companies of the TAGLIORETTI Group and/or its affiliates and/or subsidiaries and/or other business partners and outsourcers who act as independent data controllers: this processing is also based on your consent, pursuant to art. 6(1)(a) of the GDPR, which may be given specifically; any refusal to grant consent has no effect on the use of the services;
i. solely for purposes of security and prevention of fraudulent conduct, on the basis of a legitimate interest of TAGLIORETTI in preventing fraud and deception to its own detriment or to the detriment of its customers, pursuant to art. 6(1)(f) of the GDPR and on the basis of Recital 47 of the GDPR, which expressly provides that the processing of personal data strictly necessary for the purposes of preventing fraud also constitutes a legitimate interest of the data subject, as well as on the basis of various balances of interests carried out by the Controller which do not show that the processing operations in question are detrimental to the Data Subject’s fundamental rights and freedoms. In particular, such activities shall include:
i. an automated control system in place to track and analyse certain behaviour of the users on the Site, associated with their IP addresses and other Personal Data associated with the browsing on the Site. The consequence of such processing is that, if a person attempts to engage in fraudulent conduct on TAGLIORETTI Site, for example in order to benefit several times from the same promotion without having the right to do so, TAGLIORETTI reserves the right to exclude such person from the promotion or to take any other appropriate measure for its own protection.
ii. anti-spam: TAGLIORETTI reserves the right to block email accounts or hosting of its customers from which spamming or phishing activities originate. This activity involves the processing of personal data such as e-mail addresses and other traffic data and finds its legal basis in article 6 (1) (f) and Recital 49 of the GDPR, which refers to the legitimate interest of the Controller;
iii. checks on the usage of hosting: if there is an exceptional increase in the disk space used by the customer, the Company – limiting itself to external checks that neither have an impact on the Personal Data of the customer, nor include the identification of the content that has been uploaded – attempts to determine whether there are unlawful uses of the service (both in terms of contractual or regulatory provisions), in order to notify the customer, to protect its rights and to ensure the security of its systems.
4. Recipients of personal data
For the purposes referred to in Section 3 above, your Personal Data may be shared with:
a. subjects typically acting as data processors, namely: i) persons, companies or professional firms providing TAGLIORETTI with advice and consulting in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services; ii) subjects to engage with in order to provide the Services (for instance, the national and international Registration Authorities to send the technical and administrative documentation and Maintainer forms to, the authorities that manage the WHOIS database containing the personal data of the domain name assignees, credit card payment service providers (Mercury Payments and Banca Sella), etc.) iii) persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks); iv) Italian or foreign Dada Group companies, for administrative and statistical purposes (collectively “Recipients”);
b. subjects, bodies or authorities to disclose your Personal Data to in accordance with the provisions of law or under the orders of the authorities (for example, during the course of criminal investigations, TAGLIORETTI may receive requests from the judicial authority to provide traffic logs);
c. persons authorized by TAGLIORETTI to process the Personal Data required for carrying out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an appropriate legal obligation of confidentiality, for example TAGLIORETTI employees;
d. business partners for their own autonomous and separate purposes, only if you have given your specific consent.
The full list of data processors is available by sending a written request to firstname.lastname@example.org.
5. Transfer of personal data
Some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. TAGLIORETTI ensures that your Personal Data are processed by these Recipients in accordance with the GDPR. Indeed, transfers can be based on an adequacy decision or on the Standard Contractual Clauses approved by the European Commission. For further information please send a written request to email@example.com. In the domain name registration services, data are communicated to the subjects listed in section 2 (d) of this policy: in some cases, such processing involves the transfer of data at stake outside the European Economic Area. In these cases the data are transferred on the basis of article 46 and article 49 of the GDPR.
6. Data retention
The Personal Data processed for the purposes referred to in Section 3 (a-b-c) will be retained for the period deemed strictly necessary to fulfil the stated purposes. In any case, since the Personal Data are processed for the provision of the Services, TAGLIORETTI will retain the Personal Data for the period allowed by Italian law to protect its interests (art. 2946 and ensuing articles of the Italian Civil Code).
The Personal Data processed for the purposes referred to in Section 3 (d) will be retained for the period required by the specific obligation or by applicable law. By way of example, as already specified traffic data will be retained for judicial purposes for six years from their generation; otherwise, they will be retained for six months.
For the purposes referred to in Section 3 (e) (f), your Personal Data may, instead, be processed until you withdraw your consent or until three years after you have ceased to be a TAGLIORETTI customer, or have only registered to the Site and have not made any purchase of products or services. TAGLIORETTI has, in any case, the possibility of retaining your Personal Data for the period allowed by Italian law to protect its interests (art. 2947 (1) (3) of the Italian Civil Code). For the purposes referred to in section 3 (h), the retention criteria of your Personal Data are those governing the processing of data for Marketing purposes. For the purposes referred to in section 3(i)(i), the data will be retained for three months from collection; for the purposes referred to in section 3(i)(ii), the retention criteria follows the scheme of traffic data retention (six months); for the purposes referred to in section 3(i)(iii), the data will be retained for the duration of time that the customer uses the service.
Further information on the data retention periods and the criteria adopted in determining these periods may be requested in writing from the Data Controller or to the DPO.
7. Data subjects’ rights
You are entitled to request TAGLIORETTI at any time to access your Personal Data, correct, erase or object to their processing in the cases provided for by art. 20 of the GDPR; you are entitled to request the processing limitation in the cases under art. 18 of the GDPR, and to obtain, in a structured and commonly used and machine-readable format, the data regarding you (portability), in the cases under art. 20 of the GDPR.
Send written requests to firstname.lastname@example.org.
It should be noted that, in the case of requests from data subjects regarding the reporting of abuse in the use of the Services or of spamming – activities already prohibited by contract as set out in par. 8 of the General Conditions of Service – carried out by a TAGLIORETTI Customer (it should be noted that such customer typically acts as a data controller pursuant to the GDPR), and in the case of any further requests for the exercise of the rights under art. 15 and ensuing articles of the GDPR, TAGLIORETTI, without going into the details of the request, will, on the one hand, promptly inform the customer/data controller and, on the other, provide the data subjects with the details of the customer/data controller.
In any case, you will always be entitled to file a complaint with the competent supervisory authority (the Italian Data Protection Authority), pursuant to art. 77 of the GDPR, if you believe that the processing of your data violates applicable law, as well as to seek judicial redress through the courts (art. 79 of the GDPR).
If the changes to this policy concern substantial changes in processing activities or may have a significant impact on the data subjects, TAGLIORETTI will notify them appropriately and in due time to the data subjects.