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Privacy and cookie policy

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Resolfin.com‘s Privacy and Cookie Policy

Information for the processing of users’ personal data

(Code regarding the protection of personal data art. 13 leg. Decree 196/2003 – EU regulation 2016/679)

Data controller
Resolfin SRL – with registered office in Via Monterosa, 3, 00071 – Pomezia
Holder’s email address: info@resolfin.com

Introduction

The present information has the purpose of informing users about the processing methods of personal data that concern them. In line with the leg. Decree 196/2003 (hereinafter “Privacy code”) and (EU) regulation 2016/679 (hereinafter “GDPR”), we intend to guarantee the privacy and security of personal data for every visitor with what is prescribed in the present information. The present notice is intended as information that complies with art. 13 of the Privacy code and articles 13 and 14 of GDPR.

Type of processed data

The website offers informative and interactive contents. While visiting the site, we may acquire information about the visitor in the following ways:

Navigation data: The computer systems and software procedures responsible for the functioning of this website acquire, during their normal operation,
some personal data whose transmission is implicit in the use of Internet communication protocols. The following fall within this data category: IP addresses, type of browser used, the operating system, the domain name and website addresses that you have accessed, the information on the pages visited by the user within the site, the access time, the total stay on each single page, the analysis of the internal links and other parameters relating to the user’s operating system and computing setting.

Further data categories: It deals with all personal data provided by the visitor through the site, for example, registering and/or logging into a reserved area and/or a service and/or participating in one of the initiatives solely or in partnership with third persons, to ask for information, or telephoning our number to have direct contact with the customer service.

Processing purpose

PURPOSE
Providing the good and/or service requested by the user, managing the contracts made by the user and carrying out the relative administrative, accounting,
fiscal and legal requirements as well as fulfilling requests received from the user. To understand your user experience on our platforms, the products and services that we offer and ensure the correct functioning of the web pages and their contents. To send commercial communications about offers and/or promotions that the user may be entitled to, in the interest of the company controller or third party. Carrying out profiling activities, or rather the analysis and processing of information relating to users, their habits, their consumption choices and/or surfing experiences. This activity is also carried out through the use of technologies such as cookies (for more information, go to paragraph 14 of the present “Cookie Policy” information).

• JURIDICAL BASIS
The processing implemented for these purposes is required to fulfill the contractual obligations and don’t require specific acceptance from the interested party. The processing implemented for these purposes are based on the specific consent given by the user, except for commercial communications relating to products and/or services similar to those already purchased and/or subscribed by the user for which the processing is based on the legitimate interest of the controller. The processing implemented for these purposes is carried out with the specific consent given by the user, except for basic information analysis relating to your consumption preferences.

Circulation of data
For administrative purposes, we inform you that your data could be communicated by the controller to other companies linked with us. Furthermore, with your consent, your data could be communicated to third party companies where partnership agreements have been finalized: social networking and interactive platforms, retail, distribution, financial, insurance, automobile, services and humanitarian and charity organizations as well as telecommunication for commercial and/or promotional purposes.

Data transfer outside the EU
In accordance with art. 43 of the Privacy Code and art. 44 of GDPR, our company could transfer your personal data to third parties located in states which don’t belong to the European Union, or in other words, the European Economic Area. In this circumstance, we ensure the adoption of appropriate guarantees (such as the subscription of standard contractual clauses approved by the EU commission) with foreign companies who receive data;
these clauses guarantee a level of data protection which corresponds to the one establish by European law.

The roles and responsibilities in the privacy field
Your personal data is processed by our company, as the data controller. More detailed information on the names of those responsible for processing data can be requested by sending an email.

Methods of data processing
Personal data is mainly processed by using electronic procedures (Databases, CRM platforms, etc.) for the time strictly necessary to carry out the purposes that the data was collected for, and thus, in accordance with the principles of lawfulness, correctness, non-excessiveness and relevance provided for by the current privacy legislation.

Redirect towards external sites
The website can use external components such as social plug-ins. Social plug-ins are special tools which directly incorporate the social networking functionalities inside the website (e.g. Facebook’s
“like” function). All social plug-ins present on the site are marked by the respective property logo of the social network (e.g. Facebook, Google, Twitter, LinkedIn). When a page is visited on our site and you interact with the plug-ins (e.g. clicking on the “like” button) or you decide to leave a comment,
the corresponding information is passed on directly to the social network platforms from the browser and memorized by them. For information on the purposes,
types and methods of collecting, processing, using and conserving the social network platform’s personal data, as well as the ways through which you can exercise your rights, you can consult the privacy policy adopted by each single social network.

Connection towards/from third party websites
It is possible to connect to other websites through the links provided from this website, or for third party sites to connect to our website. The controller declines any responsibility regarding any eventual request and/or issuance of personal data to third party sites and the management of the authentication credentials provided by third parties.

Data conservation
We inform you that the data relative to the navigation log, if registered, will be kept by the controller for a period of 3 months. Furthermore, we inform you that the data inserted by you will be processed during the whole contractual period between us and kept exclusively for the period foreseen for legal requirements too,
should they be needed to defend or enforce a right or to fulfill any further legal obligations or authoritative orders.

Rights of the interested party
The referred subjects to the aforementioned personal data (so called “interested parties”), have the faculty to exercise their rights according to the methods and limits foreseen by the current privacy legislation. In relation to your personal data, you have the right to ask our company:
• The access: you can ask for confirmation as to whether your data is being processed and clarifications regarding the information, as well as, receive the data itself within the limits of reasonableness;
• The rectification: you can ask to change or add data provided to us or in our possession, should they be inaccurate;
• The removal: you can ask to remove your acquired data should they not be required for our purposes anymore or where there aren’t any disputes in progress, or in the case where you withdraw your consent or oppose the processing or, in cases of illegal processing, or when there is a legal obligation to remove;
• The limitation: you can ask for the limitation of the processing of your personal data when one of the conditions of art. 18 of GDPR is applied; in this case, your data won’t be processed without your consent, except for storage, and for what is stated in the same article in comma 2. • The opposition: you can oppose to the processing of your data at any moment based on legitimate interest, unless there are legitimate reasons to proceed with the processing which prevail, for example, to exercise or defend ourselves in the court of law; your opposition will always prevail on our legitimate interest to deal with your data for marketing purposes;
• The portability: you can ask to receive your data, or have them transferred to another data controller indicated by you, in a structured format and in common use and readable from an automatic device.
Furthermore, in accordance with art. 7, par. 3, GDPR, we inform you that you can exercise your right to withdraw your consent at any moment without affecting the lawfulness of the processing based on the previously given consent. Lastly, we inform you that you have the right to lodge a complaint before a control authority, which in Italy, is the guarantor for personal data protection. To exercise these rights, you can report problems or ask for clarifications regarding the processing of your personal data by sending an email to the contact details on this page. Furthermore, we would like you to know that it is possible to send your requests by post, by specifying the reason for the request.

Right to be forgotten
We inform you that the present information exclusively deals with the processing of the personal data provided or personal data that will be provided by you – by also buying our products and/or charged services or participating in our promotions and/or offers – and what will be acquired during the ongoing relationship and/or further relationships between you and us. If you wish to enforce the right to be forgotten in reference to your personal data, we remind you that the data controller is available and is the reference in order to exercise this right in art. 17 of GDPR, by writing an email to the address presented on this page.

Changes to the information
The eventual enforcements of new legislations in this sector, like the constant examination and update of the user services could bring about the need to change the methods and terms described in the present information. Thus, it is possible that this document changes over time. We invite you to periodically consult this page. We will publish any changes to the present information on this page and we will report them with a more visible notification, whenever there are important changes. The previous versions of the present information will, in any case, be stored in order for it t o be consulted.

Cookie Policy
What are Cookies? Cookies are packets of information sent by a web server (e.g. the site) to the user’s internet browser and automatically stored on the latter’s computer and automatically sent to the service during every access to the site. By default, all web browsers are set up to automatically accept c ookies. Typically,
cookies can be installed:
• directly by the controller and/or website manager (so called first party cookies);
• by partners who are indirectly involved with the user-visited website (so called third party cookies). Unless otherwise specified, we inform you that these cookies fall under the direct and exclusive responsibility of the site manager. Further information on privacy and their usage can be consulted directly on the sites of the respective web managers.

In combination amongst themselves too, this website can use the following types of cookies which have been classified on the basis of the privacy guarantor’s indications and the opinions issued by the European workgroup ex. art. 29 of GDPR:
• Sessions are cookies which aren’t stored in a persistent way on the user’s computer and are removed when the browser is closed. They are strictly limited to the transmission of session identifiers needed to consent the browsing of the site securely and efficiently by avoiding the need to turn to other computing techniques that are potentially prejudicial to the users’ browsing privacy.
• Persistent cookies are those which remain stored on the computer’s hard disk until their deadline or their removal by users/visitors. Through persistent cookies, the visitors who log into the site (or any eventual users who use the same computer) are automatically recognized on each visit. Visitors can set up the computer’s browser in such a way that they accept/refuse all cookies or view a warning every time a cookie is proposed to them, and decide whether to accept them or not. The user can change the predefined configuration and disable the cookies (or rather, block them definitively), by setting up a higher protection level.
• Technical cookies are used for authentication purposes, multimedia contents, such as flash players, or to consent the browsing language choice. Generally, it isn’t necessary to acquire the prior and informed consent of the user. Cookies that are used to statistically analyze the access/visits to the site fall within these types of cookies and are only exclusively used for statistical purposes and for the collection of information in aggregate form.
• Non-technical cookies are used for profiling and marketing purposes. Their use on terminals is forbidden if the user hasn’t been adequately informed beforehand and hasn’t given valid consent through the opt-in technique. In turn, these types of cookies are grouped on the basis of the functions they serve:
• Analytics are cookies used to collect and analyze statistical information on the access/ visits to the website. In some cases, they are associated to other information, such as, the credentials inserted to access the reserved areas (email address and password),  and they can be used to profile the user (personal habits, visited sites, downloaded contents, types of interactions carried out, etc.).
• Widgets are all the graphical components of a program’s user interface, which has the purpose of facilitating the user in the interaction of the program itself. For example, Facebook, Google+, Twitter cookies are widgets.
• Advertising are all cookies used to advertise within a site. For example Google and Tradedouble fall within this category.
• Web beacons are the fragments of code that allow a website to transfer or collect information through the request of a graphic image. The websites can use them for several purposes, such as the website’s usage analysis, the control and reporting activities on the ad and the customization of ads and contents.

The cookies present on the site
Technical cookies which don’t require consent
While browsing our site, we may install cookies on your device, particularly on your browser, or, we may let third parties install cookies which we feel are necessary to acquire,
or, let our partners acquire statistical information in an anonymous and aggregate form, in relation to your visit on our webpages. To be more precise,
the cookies mainly refer to the following statistical analysis services:
• Google Analytics: https: //support.google.com/analytics/answer/2763052?hl=it
• WebTrekk: https: //www.webtrekk.com/en/index/opt-out-webtrekk/
• Nielsen NetRatings: http: //uk.nielsennetpanel.com/pls/mguk/mgp_main.privacy_Policy
• Chartbeat: https: //chartbeat.com/privacy/
• Addthis: http: //www.addthis.com/privacy
• Comscore Analytics: http: //www.comscore.com/ita/Chi-siamo/Privacy-Policy

Cookies which require consent
Furthermore, when you give your consent through one of the simplified methods described in the information presented during your first access to the site, or you adhere to the instructions which follow, our website may install and/or let third parties indicated below install additional profiling cookies, where you can choose to partly or fully modify or remove the consent given through the links which follow:

Third party cookies
In regards the processing of your personal data, and subject to your consent, third party companies, known to our site, may implement cookies through clicks on the links for the provision or non-provision of the consent by following the relative indications, after having read the different information:
• Facebook: Through the site, whenever your consent is given, Facebook may process your personal data to allow you to have a browsing experience enriched with functionality and social network services. https: //www.facebook.com/policies/cookies/
• Twitter: Through the site, whenever your consent is given,
Twitter may process your personal data to allow you to have a browsing experience enriched with functionality and social network services https: //support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologiesimili-
da-parte-di-twitter
• Google+: Through the site, whenever your consent is given, Google+ may process your personal data to allow you to have a browsing experience enriched with functionality and social network services https: //policies.google.com/privacy?hl=it
• LinkedIn: Through the site, whenever your consent is given, LinkedIn may process your personal data to allow you to have a browsing experience enriched with functionality and social network services https: //www.linkedin.com/legal/cookie-policy?trk=%7Berror-page%7D-cookiepolicy
• Pinterest: Through the site, whenever your consent is given, Pinterest may process your personal data to allow you to have a browsing experience enriched with functionality and social network services https: //help.pinterest.com/en/articles/personalization-and-data
• Banca Sella: We may communicate your personal data to Banca Sella S.p.A. and to the relative group so as to: evaluate and manage the risks, by reporting, for example, eventual fraudulent activities detected on your account; Provide services to customers, such as account assistance or the resolution of disputes (for example, regarding invoicing or transactions); Help process card payments for our services which involve Banca Sella S.p.A.; help shipping and correlated services for purchases made via Banca Sella S.p.A.; https: //www.sella.it/bancaonline/
privacy/privacy.jsp
• Paypal: We may communicate your personal data to PayPal Inc. and to the relative group so as to: prevent,
detect, implement and ascertain potential irregularities, fraud and/or security violations and evaluate and manage the risks by reporting,
for example, eventual fraudulent activities detected on your account; provide services to customers, such as account assistance or to resolve disputes (for example, regarding invoicing or transactions); help process card payments for services which use PayPal for payments; help shipping and correlated services for purchases made via PayPal https: //www.paypal.com/it/webapps/mpp/ua/privacy-full
• Google Analytics: our site has activated Google Analytics and the advertising functions implemented are: reports on the demographic data and interests of Google Analytics. The activation of these advertising functions allows Google Analytics to collect traffic data via Google ads cookies and anonymous identifiers as well as data collected through the standard implementation of Google Analytics. Our site may collect and use the data coming from the ads based on the interests of Google or public data of Google Analytics third parties (for example, age, sex and interests) and the functions of the implemented Google Analytics based on the displayed adverts (e.g. remarking, reports on demographic data and interests of Google Analytics) for the sole purpose of statistics and public analysis. Data is collected and aggregated in anonymous form through proprietary software or third parties (e.g. Google Analytics). Our site and third party suppliers,
among which Google, use both proprietary cookies (like Google Analytics cookies) and third party cookies (like DoubleClick cookies) to inform, optimize and publish announcements based on previous visits by users on our site. It is possible to disable Google Analytics for ad display and customize the announcements of the Google Display network in the following ways:
• Using the ads settings: https: //www.google.it/settings/ads
• Through the components currently available for disabling Google Analytics for the web https: //tools.google.com/dlpage/gaoptout/ I give my consent that our site can install profiling cookies and place – for ourselves and/or for other reliable partners – the tools relating to marketing activities as described in the present information. I don’t give my consent that our site can install profiling cookies and place – for ourselves and/or other companies on our behalf – the tools relating to marketing activities as described in the p resent information. In regards the processing of personal data and subject to your consent, third party companies, unknown to our site, may implement cookies by connecting to this link and making use of the relative service which can customize your choices: http: //www.youronlinechoices.com/it/le-tuescelte How to disable cookies through the browser settings If you want, you can directly manage the cookies through the browser’s settings. Nevertheless, removing the browser’s cookies could eliminate the preference you have set up for our site and for this reason,
it would be suitable to periodically visit this page to recheck your preferences. It is possible to also visit the specific help page of the web browser that you are using for further i nformation and support:

• Internet Explorer
• Mozilla Firefox
• Safari
• Chrome
• Opera

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