1. This section contains information relating to the management methods of Kleecks with reference to the processing of Kleecks user data.
2. This information is also valid for the purposes of Article 13 of EU Regulation no. 2016/679, concerning the protection of individuals with regard to the processing of personal data and the free circulation of such data, for those who interact with Kleecks and can be reached at the address corresponding to the initial page:
3. The information is provided only for Kleecks and not for other websites that may be consulted by the user via links contained therein.
4. The purpose of this document is to provide information about the methods, timing and nature of the information that data controllers must provide users when connecting to the Kleecks web pages, regardless of the purposes of the connection itself, according to Italian law and European.
5. The information may be changed due to the introduction of new regulations in this regard, therefore the user is invited to periodically check this page.
6. If the user is less than 14 years old, pursuant to article 8, regulation 1 of the EU regulation 2016/679, and of the Art. 2 – Quinquies of Legislative Decree 196/2003, as amended by Legislative Decree 181/18, must legitimize its consent through the authorization of parents or guardians.
II – DATA PROCESSING
1 – Data Controller
1. The data controller is the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. It also deals with security profiles.
2. With regard to this website, the data controller is: Alessandro Giorgi (AD), and for any clarification or exercise of your rights, you can contact him at the following email address: [email protected]
2 – Data processing manager
1. The controller is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.
2. In accordance with article 28 of the EU regulation no. 2016/679, upon appointment of the data holder, the data processor of the Kleecks site is: Alessandro Giorgi.
3 – Data processing location
1. The data processing generated by the use of the website takes place mainly at Via Privata Cascia, 6 – 20128 MILAN (MI), registered office of Vivian Srl in Italy, as well as at other operative sites of the company.
2. In case of need, the data connected to the newsletter service may be processed by the data controller or persons appointed by it for this purpose at the relative site.
III – COOKIES
1 – Type of Cookies
2. A cookie consists of a reduced set of data transferred to the user’s browser by a web server and can only be read by the transferring server. This is not executable code and does not transmit viruses.
3. Cookies do not record any personal information and any identifiable data will not be stored. If desired, you can prevent some or all cookies from being saved. However, in this case the use of the site and the services offered may be compromised. To proceed without changing the cookie options, simply continue browsing.
The following are the types of cookies used by the site:
2 – Technical cookies
1. There are numerous technologies used to store information on the user’s computer, which are then collected by the sites. Among these the most known and used is that of HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications over the electronic network or for the supplier to provide the service requested by the customer.
2. The settings to manage or disable cookies may vary depending on the internet browser used. However, the user can manage or request the general deactivation or cancellation of cookies by modifying the settings of his or her internet browser. Such deactivation can slow down or prevent access to some parts of the site.
3. The use of technical cookies allows the secure and efficient use of the site.
4. The cookies that are inserted in the browser and retransmitted by Google Analytics or through the statistics service of bloggers or similar are technical only if used for the purpose of optimizing the site directly by the owner of the site itself, which can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, for analytics cookies the same rules apply, in terms of information and consent, provided for technical cookies.
5. From the point of view of duration, temporary session cookies can be distinguished that are automatically deleted at the end of the browsing session and are used to identify the user and therefore avoid the login to every page visited and the permanent ones that remain active in the PC up to upon expiration or cancellation by the user.
6. Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
7. They are not stored permanently but exclusively for the duration of the navigation until the browser is closed and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow a safe and efficient exploration of the site.
3 – Third-party cookies
1. In relation to the origin, we distinguish the cookies sent to the browser directly from the site you are visiting and those of third parties sent to the computer from other sites and not from the one you are visiting.
2. Permanent cookies are often third-party cookies.
3. Most third-party cookies consist of tracking cookies used to identify online behavior, understand interests and therefore customize advertising proposals for users.
4. Third-party analytical cookies may be installed. They are sent from domains of the aforementioned third parties external to the site.
5. Third party analytical cookies are used to collect information on user behavior on Kleecks. The survey takes place anonymously, in order to monitor performance and improve the usability of the site. Third-party profiling cookies are used to create user profiles, in order to offer advertising messages in line with the choices made by the users themselves.
6. The use of these cookies is governed by the rules established by the third parties themselves, therefore, users are advised to read the privacy information and instructions to manage or disable the cookies published on the relative web pages.
4 – Profiling cookies
1. Profiling cookies are those used to create user profiles and are used in order to send advertising messages in line with the preferences shown by the user while surfing the net.
2. When these types of cookies are used, the user must give explicit consent.
3. Article 22 of EU Regulation 2016/679 and Article 122 of the Data Protection Code will apply.
IV – DATA PROCESSED
1 – Data processing mode
1. Like all websites, this site also uses log files in which information collected in an automated manner during user visits is stored. The information collected could be the following:
– internet protocol address (IP);
– type of browser and parameters of the device used to connect to the site;
– name of the internet service provider (ISP);
– date and time of visit;
– web page of the visitor’s origin (referral) and exit;
– possibly the number of clicks.
2. The aforementioned information is processed in an automated manner and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed based on the legitimate interests of the owner.
3. For security purposes (anti-spam filters, firewalls, virus detection), automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with the relevant laws in force, in order to block attempts to damage to the site itself or damage to other users, or in any case harmful activities or offenses. These data are never used for the identification or profiling of the user, but only for the purpose of protecting the site and its users, such information will be treated according to the legitimate interests of the owner.
5. The information that the users of the site will deem to make public through the services and the tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any responsibility for any violations of the laws. It is up to the user to verify that they have the permissions to enter personal data of third parties or contents protected by national and international standards.
2 – Purpose of data processing
1. The data collected by the site during its operation are used for the purposes indicated above and for the following purposes:
Sending informative material, newsletters, contact for the purpose of following up the requests received
2. The data will be stored for the period strictly necessary to achieve the aforementioned purpose and in any case not exceeding 3 years.
3. The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the purpose previously indicated.
3 – Data provided by the user
1. As indicated above, the optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
2. Specific summary information will be progressively reported or displayed on the pages of the site set up for particular services on request.
4 – Support in the configuration of your browser
1. The user can also manage cookies through his browser settings. However, deleting the cookies from the browser may remove the preferences set for the site.
2. For further information and support you can also visit the help page specific to the web browser you are using:
– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
– Safari: http://www.apple.com/legal/privacy/it/
– Chrome: https://support.google.com/accounts/answer/61416?hl=it
– Opera: http://www.opera.com/help/tutorials/security/cookies/
5 – Social Network Plugin
2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of social networks, to which please refer:
Google+: http: //www.google.com/policies/technologies/cookies
V. USER RIGHTS
1. The art. 13, c. 2 of EU Regulation 2016/679 lists the user’s rights.
2. The Kleecks website therefore intends to inform the user of the existence:
– the right of the interested party to request the owner access to personal data (Article 15 EU Regulation), their update (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003), the correction (art. 16 EU Regulation), integration (art. 7, co. 3, lett. a) D.Lgs. 196/2003) or the limitation of the treatment concerning it (art. 18 EU Regulation) or oppose, for legitimate reasons, to their treatment (art. 21 EU Regulation), in addition to the right to data portability (art. 20 EU Regulation);
– the right to request cancellation (art. 17 EU Regulation), transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes for which the data are been collected or subsequently processed (Article 7, paragraph 3, letter b) of Legislative Decree 196/2003);
– the right to obtain the attestation that the updating, rectification, data integration, deletion, data blocking and transformation operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment proves impossible or involves the use of means manifestly disproportionate with respect to the protected right (art. 7, co. 3, lett. c) D.lgs. 196/2003);
3. Requests can be addressed to the data controller, without formalities or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to the address: [email protected]
4. If the treatment is based on the art. 6, paragraph 1, lett. a) – express consent to use – or on art. 9, paragraph 2 letter. a) – express consent to the use of genetic, biometric, health-related data revealing religious or philosophical beliefs or union membership, which reveal racial or ethnic origin, political opinions – the user has the right to revoke consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
5. Likewise, in case of violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority in charge of controlling the processing in the Italian State.
6. For a more in-depth examination of the rights that belong to you, see the articles 15 and ss. of the EU Regulation 2016/679 and the art. 7 of Legislative Decree 196/2003.
VI – TRANSFER OF DATA TO EXTRA EU COUNTRIES
1. This site may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
2. Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 et seq. Of the EU Regulation.
VII. SECURITY DATA PROVIDED
1. This site treats users’ data in a lawful and correct manner, taking appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the data. Processing is carried out using IT and / or telematic tools, with organizational methods and logic strictly related to the purposes indicated.
2. In addition to the owner, in some cases, the categories of employees involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, couriers postal services, hosting providers, IT companies, communication agencies).
VIII. CHANGES TO THIS DOCUMENT
1. This document, published at:
2. It may be subject to changes or updates. Users are encouraged to periodically consult this page to keep up to date with the latest legislative changes.
3. The previous versions of the document will still be available on this page.
4. The document was updated on 14/09/2020 to comply with the relevant regulatory provisions, and in particular in compliance with EU Regulation 2016/679