Privacy Policy

This is the privacy policy of the website accessible at the address: https://superpress.local (hereinafter: the site)

I – INFORMATION RELATING TO THE SITE’S PRIVACY POLICY

1. This section contains information on how the site is managed in relation to the processing of user data on the site.
2. This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of article 13 of EU Regulation no. 2016/679, relating to the protection of natural persons with regard to the processing of personal data and the free circulation of such data, for subjects who interact with the site and can be reached at the address corresponding to the home page indicated at the beginning of this privacy policy
3. The information is provided only for the site and not for other websites that may be consulted by the user through links contained therein.
4. The purpose of this document is to provide information on the methods, times and nature of the information that data controllers must provide to users when they connect to the website's web pages, regardless of the purposes of the connection itself, according to Italian and European legislation.
5. The information may be subject to changes 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 under 16 years of age, pursuant to art.8, c.1 EU regulation 2016/679, he/she must legitimise his/her consent through the authorisation of his/her parents or legal guardians.

II – DATA PROCESSING

The owner and person responsible for data processing is:

FFD by Francesco Fortino – Via dei Sestili, 3, 00174 – Rome – hello@sito.agency

III – COOKIES

The site uses the cookies indicated on the page Cookie Policy.

The user can refuse the use of marketing and third-party cookies by clicking on the appropriate button during his first visit. Later, it is possible to correct his preference by emptying the browser cache and visiting any page of the website again, or through the appropriate consent management page reachable from the cookie policy.

In no case does the owner sell or transfer to third parties personal information retained in cookies for purposes other than those described and for services other than those described.

More information about cookies is available on the Cookie Policy.

IV – DATA PROCESSED

1 – Data processing methods

1. Like all websites, this site also uses log files in which information collected automatically during user visits is stored. The information collected could be the following:

• internet protocol (IP) address;
• 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 from which the visitor came (referral) and exited;
• possibly the number of clicks.

1. The above information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. Such information will be processed based on the legitimate interests of the owner.
2. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with the laws in force on the matter, in order to block attempts to damage the site itself or to cause damage to other users, or in any case harmful or criminal activities. Such data are never used for the identification or profiling of the user, but only for the purposes of protecting the site and its users, such information will be processed based on the legitimate interests of the owner.
3. If the site allows the insertion of comments, or in the case of specific services requested by the user, including the possibility of sending the Curriculum Vitae for a possible working relationship, the site automatically detects and records some identifying data of the user, including the email address. Such data are intended to be voluntarily provided by the user at the time of requesting the provision of the service. By inserting a comment or other information the user expressly accepts the privacy policy, and in particular agrees that the contents inserted are freely disseminated also to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary for the provision of the service.
4. The information that users of the site will deem to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violations of the laws. It is up to the user to verify that they have permission to enter personal data of third parties or content protected by national and international laws.

2 – Purpose of data processing

The data collected by the website, depending on the user's behavior and preferences, are used for various primary and secondary purposes, in accordance with the provisions in force on the matter, the preferences expressed by the user, the terms and conditions of sale in the event of purchase if applicable, the cookie policy and within the technical limits of the technologies and channels used.

2.1 – Primary Purposes

2.1.1 – Request for data for direct contact purposes

To send a request for support, a quote or simple information, the user can use the dedicated contact forms on the website. These forms collect the data necessary to receive, manage and respond to requests sent by the user, with a level of detail appropriate to the type of request, in order to provide a response as precise and adequate as possible.

These forms use third-party services to ensure the safety of users who may collect some identifying data of the user and, by using them, the user accepts the conditions of use and their privacy policy linked to the following point 2.1.3.

The provision of the requested data and the full and conscious acceptance of what is defined here are mandatory to be contacted with a precise and adequate response guaranteeing maximum efficiency and shortest timing, at the same time guaranteeing the highest levels of security; in default the User will not be able to use the form to contact the owner.

These forms may also require consent for secondary, entirely optional purposes, for which reference is made to the homonymous point of this Privacy Policy.

Personal data will not be disclosed.

2.1.2 – Sending periodic newsletters

To stay updated on offers, promotions, events and/or other initiatives promoted by the owner, the user can use the forms dedicated to newsletter subscription on the website. This form collects the data necessary to be able to send promotional and informative material via email to the user who wishes, without involving other functions of the site. The owner may therefore process the contact data to send periodic newsletters to the User upon explicit request of the latter through the relative subscription to the service. The prerequisite for the processing and legal basis is the fulfillment of contractual obligations to allow the User to receive the newsletter.

These forms use third-party services to ensure the safety of users who may collect some identifying data of the user and, by using them, the user accepts the conditions of use and their privacy policy linked to the following point 2.1.3.

The provision of the requested data and the full and conscious acceptance of what is defined here are mandatory to manage the contractual relationship at the same time guaranteeing the highest levels of security; in the absence of this, the User will not be able to register and receive the newsletter.

2.1.3 – Services for user safety

In order to guarantee maximum security to the users of the website, we use Altcha on all the contact forms on the site. The service offered by Altcha is configured in self-hosted mode and allows to reduce, up to the point of eliminating, fraudulent sending attempts by bots in a manner that is fully compliant with the GDPR by design without having to install cookies and/or contact third-party services.

2.2 – Secondary Purposes

2.2.1 – Secondary purposes of the processing of personal data of a promotional, advertising and marketing nature in the broad sense

The data collected from the online forms necessary to carry out the primary purposes indicated above may, where necessary where foreseen and at the exclusive and optional preference of the user, also be processed for different purposes as indicated below.

The owners may therefore process the contact data to send the User promotional material upon explicit request of the latter for the following purposes:

• commercial promotion, communication, solicitation of purchasing behavior, analysis of the commercial performance of established relationships; carrying out other sample marketing research in the broad sense; organization and carrying out of promotional campaigns, discounts, prize events, games and competitions involving products and/or services attributable to the owner;
• initiative management fidelity & loyalty such as, for example, loyalty programs to access goods and/or services offered by the owner at preferential conditions reserved for program members;
• invitations to events organized by the owner;
• sending of advertising and information material of a promotional nature (e.g. newsletter) or in any case of a commercial solicitation nature.

All the purposes and treatments indicated above are hereinafter collectively defined as "Processing for Marketing Purposes”.

2.2.1.1 – Categories of personal data processed for Marketing Purposes

The categories of personal data subject to processing are represented by common personal data.

To proceed to the Processing for Marketing Purposes it is mandatory to acquire prior, free and specific consent for each purpose.

The owner draws particular attention to the fact that the provision of personal data and the provision of consent to the Processing for Marketing Purposes for the purposes and in the manner described above:

1. it is absolutely optional and facultative (and in any case the consent can be revoked without formalities even after the service has been provided);
2. Failure to provide such data will not result in any consequences other than the impossibility of carrying out the marketing treatments mentioned.

Exclusively with reference to the use of the interested party's email, we inform you that pursuant to article 130, paragraph 4, of Legislative Decree 30 June 2033, n. 196 containing the Privacy Code, it is always possible for the owner to send (without the need to acquire specific consent) informational and advertising material only via email and only if it relates exclusively to products similar to those that the interested party originally purchased within the scope of contractual relationships. In this particular case, the right to object (opt-out) at any time to the processing upon receipt by contacting the owner according to the methods provided for in this privacy policy remains unchanged.

In other different cases of use of the interested party's email to send informative and advertising material different and not analogous to the products object of previous relationships, the obligation to acquire a specific and separate consent remains in force.

a) Basis of legitimacy of the processing and obligation of consent for the pursuit of marketing purposes

Pursuant to Article 6, paragraph 1, letter (a) of the GDPR, the legal basis of the processing is represented by the free, specific and optional consent of the interested party.

In the event of failure to provide consent, the consequence will be the impossibility for the owner to carry out the relevant processing, without any prejudice or impact on commercial or other legal relationships that may be in progress between the owner and the interested party.

In the event of communication of personal data to third parties for marketing purposes, it is necessary to request a separate and specific consent from the interested party in order to make personal data available to third parties. If the communication is based on the specific consent of the interested party, the recipient may carry out processing for marketing purposes without having to request further consent.

b) Scope of communication and dissemination of data processed for marketing purposes

The personal data will not be subject to further communication to different third parties nor will they be subject to dissemination.

In the event that a fixed or mobile telephone number is processed that the interested party has optionally indicated in the contact forms on the Site, also providing optional and specific consent to the processing of such personal data for the purposes of commercial promotion and marketing in a broad sense, we inform you that the owner may legally process the telephone number for marketing purposes even if it is registered in the Public Register of Oppositions, as it is processed from a source other than public telephone directories and covered by specific consent. For maximum transparency and respect for privacy, the interested party is therefore reminded with particular attention to evaluate the indication (in any case not mandatory) of his telephone numbers in the forms.

2.3 – Profiling and other purposes

2.3.1 – Processing of personal data for profiling purposes

The owner also processes the data of the interested parties for profiling purposes, as better explained in this paragraph.

For such treatments, and for the purposes of complete information, reference is made to the definition in art. 4, paragraph 1, n. (4) of the GDPR: «profiling": any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”.

As regards the obligations of the owner to provide – pursuant to art. 13, paragraph 2, letter f) of the Regulation – information on the logic of the profiling processing as well as the importance and consequences of such processing, the following is further clarified.

The founding elements of profiling treatment are:

1. the predetermination of the parameters for the structuring of the data considered individually;
2. the comparison, cross-referencing, correlation of such data between them and the comparative analysis carried out on the basis of predefined parameters, also through automated processes (i.e. the cataloguing of individual data in clusters);
3. obtaining a profile through the preceding activities and which allows for obtaining additional analytical indications with respect to single data and allows for generating the mapping/segmentation into homogeneous groups of behavior (dynamic creation of behavioral profiles).

In the spirit of absolute transparency, the owner therefore informs that the data collected on the basis of a specific consent may be subject to a Profiling Treatment for the following purposes:

• planning of commercial and advertising strategies and campaigns based on purchasing behavior;
• statistical processing (in identifying form);
• creation of profiles for behavioral advertising purposes;
• management of fidelity & loyalty initiatives based on specific customer profiles, such as, for example, loyalty programs to access goods and/or services offered at preferential conditions reserved for certain customer profiles;
• management of cookies and other tracking technologies and online identifiers for profiling purposes on the owner's social networks for marketing purposes;
• sending of advertising and informative material (e.g. Newsletters), of a promotional nature or in any case of a commercial solicitation nature with particular technical options such as tracking and profiling of open links, pages visited, etc.

The owner, in the spirit of transparency, lists by way of example some examples of profiling carried out through the processing of the interested party's data:

• use of identifying profiling data and profiles resulting from the analysis of purchased goods and services;
• processing of personal data carried out in the context of the analysis of profiling cookies for the creation of personalized marketing campaigns or targeted behavioral advertising.

The owner then proceeds – in general – to profiling treatments by cross-referencing parameters and indexes such as those reported below:

• number and type of purchases of goods and services made by the interested party within a predetermined time frame;
• number and type of expenses incurred in a predetermined time frame;
• purchase method;
• number and type of support requests sent within a predetermined time frame;
• number and type of disputes received and/or sent within a predetermined time frame.

The treatments and the logic of the treatment illustrated above will be hereinafter collectively defined as "Profiling Treatment“

Categories of personal data processed for Profiling Purposes

The categories of personal data subject to processing are represented by common personal data. The data of the interested party involved by the Processing for Profiling Purposes I am:

• personal data (title, name, surname, nationality, date of birth)
• contact details (address, city, postal code, email address, mobile phone number, contact preferences)
• data relating to purchases made;
• data relating to purchases made and purchasing behaviour (e.g. products/services purchased and characteristics, price, frequency, purchasing method, spending segment, etc.)
• data relating to habits, behaviors and lifestyles.

2.3.2 – Mandatory or optional consent to the processing of personal data for the pursuit of profiling purposes

To proceed to a Profiling Treatment it is mandatory to acquire specific, separate (also from marketing consent), express, documented, preventive and entirely optional consent.

Consequently, where the interested parties decide to give specific consent, they must be informed in advance and aware that the purposes of the processing pursued are of a specific commercial, advertising, promotional and marketing nature in the broad sense based on a Profiling Treatment.

The owner draws particular attention to the fact that the provision of personal data and the provision of consent to the Profiling Treatment for the purposes and in the manner described above:

1. they are absolutely optional and facultative (and in any case the consent can be revoked without formalities even after the service has been provided);
2. failure to provide such data will not result in any consequences other than the impossibility for the owner to proceed with the aforementioned profiling treatments.

In case of refusal of consent to the Profiling Treatment there will be no interference and/or consequences on business, contractual or other relationships and whose personal data processing pursues different purposes (e.g. contractual) and is based on suitable bases of legitimacy of the processing.

2.3.3 – Scope of communication and dissemination of data processed for profiling purposes.

The personal data subject to Profiling Treatment they will not be the subject of further communication to other third parties nor will they be disseminated.

The mere provision of data to third-party suppliers for the sole purpose of receiving the following services does not constitute communication of personal data to third parties for profiling purposes:

• technical managers of the owner's apps, electronic platforms and websites;
• companies that provide services to the owner for the organization of marketing or profiling activities, campaigns and strategies;
• communication agencies;
• companies that support the owner in organizing events;
• market research and analysis company.

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 site pages set up for particular services on request.

4 – Support in configuring your browser

1. The user can also manage cookies through the settings of his browser. However, deleting cookies from the browser could remove the preferences that he has set for the site.
2. For further information and support you can also visit the specific help page of 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/
• Chrome: https://support.google.com/accounts/answer/61416?hl=it
• Opera: http://www.opera.com/help/tutorials/security/cookies/

V. USER RIGHTS

1. Art. 13, c. 2 of EU Regulation 2016/679 lists the user's rights.
2. The site therefore intends to inform the user of the existence: – of the right of the interested party to ask the owner for access to personal data (art. 15 EU Regulation), their updating (art. 7, co. 3, lett. a) Legislative Decree 196/2003), rectification (art. 16 EU Regulation), integration (art. 7, co. 3, lett. a) Legislative Decree 196/2003) or the limitation of the processing that concerns him (art. 18 EU Regulation) or to oppose, for legitimate reasons, to their processing (art. 21 EU Regulation), in addition to the right to data portability (art. 20 EU Regulation);

• the right to request the cancellation (art. 17 EU Regulation), the transformation into anonymous form or the blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed (art. 7, co. 3, lett. b) Legislative Decree 196/2003);
• the right to obtain certification that the operations of updating, rectification, integration of data, cancellation, blocking of data, transformation 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 in which such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right (art. 7, co. 3, lett. c) Legislative Decree 196/2003);

1. Requests can be addressed to the data controller, without formalities or, alternatively, using the form provided by the Guarantor for the Protection of Personal Data, or by sending an email to the address indicated above.
2. If the processing is based on art. 6, paragraph 1, letter a) – express consent to use – or on art. 9, paragraph 2, letter a) – express consent to use genetic, biometric, health-related data, data revealing religious or philosophical beliefs or trade union membership, data revealing racial or ethnic origin, political opinions – the user has the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.
3. Likewise, in the event of a 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 responsible for monitoring the processing in the Italian State.
4. For a more in-depth examination of your rights, see articles 15 et seq. of EU Regulation 2016/679 and art. 7 of Legislative Decree 196/2003.

VI – DATA TRANSFER TO NON-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, so no further consent is required.
2. If you agree to receive direct marketing emails, we rely on the services made available by Mailchimp And Short with which we share your email address, name, surname and some tags, which may vary depending on the type of form and the page from which you filled out the form. Only the site staff has direct access to this data.
3. The companies mentioned above guarantee their adherence to the Privacy Shield.
4. 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 OF DATA PROVIDED

1. This site processes user data in a lawful and correct manner, adopting appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.
2. In addition to the owner, in some cases, categories of persons involved in the organization of the site (administrative, commercial, marketing, legal, 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.

VIII. CHANGES TO THIS DOCUMENT

1. This document constitutes the privacy policy of this site.
2. It may be subject to changes or updates. If there are significant changes or updates, these will be reported with specific notifications to users.
3. Previous versions of the document will still be available on this page.
4. The document was updated on 05/24/2018 to comply with the relevant regulatory provisions, and in particular in compliance with EU Regulation 2016/679.