Privacy Policy

This information is provided to users (hereinafter “interested parties”) who consult the website www.cittadinidellordine.com of Cittadini dell’Ordine S.p.A., pursuant to and in accordance with the provisions for the adaptation of the Privacy Code (as amended by Legislative Decree 101/2018) to the provisions of European Regulation 2016/679 on the protection of personal data (hereinafter “GDPR”). To immediately access the cookie policy you need to click here.

Ownership of the website cittadinidellordine.com

The owner of the website cittadinidellordine.com, which can also be reached through the relevant aliases or third-level domains (hereinafter “web”) is Cittadini dell’Ordine S.p.A., with registered office in Via Lancia 6/A – 39100 Bolzano (BZ) and administrative office in Via dell’Arrigoni, 60/120 – 47522 Cesena (FC) – C.F. and P. IVA 02415990213. Data Protection Officer (DPO) is Uomo & Ambiente S.r.l. Benefit Society, whose contact person Ing. Gianluigi Carbone can be contacted at the e-mail address privacy@cittadinidellordine.com.

Terms and conditions of use

Use of the website is conditional upon your acknowledgement, acceptance and compliance with the terms and conditions set forth below. In case of non-acceptance you are requested not to use the website or download any material from it.

Limits of web use and copyright

All material and content on the website is the property of Citizens of the Order and is protected by intellectual property rights in accordance with current copyright law. The documentation, images, content, software and any other elements of the website are the exclusive property of Citizens of the Order. Access to the website does not give the user the right to appropriate, reproduce, modify, distribute, republish, in any form, in whole or in part, the information contained therein. This is without prejudice to the ability to store and print such content for personal use only. The trademarks, logos and distinctive signs used on the website are the property of Citizens of the Order; they may not be used without the prior written consent of Citizens of the Order. Additional third-party trademarks and logos used on the Web are the exclusive property of their respective owners. Any use or reproduction in any form of these trademarks and logos is prohibited.

Limitation of liability

The contents of the website are published for informational use only about Citizens of the Order’s activities and products; they do not and cannot constitute an offer to sell, underwrite, or solicit of any kind. Although the website has been created with the utmost care and attention, Citizens of the Order assumes no warranty as to the completeness and accuracy of the information or for any material errors or omissions in the data contained therein.

Citizens of the Order disclaims any liability for any loss or damage due to or in connection with the use of the website, it also assumes no responsibility for any temporary inaccessibility of the website or if there is outdated information. Citizens of the Order reserves the right to intervene at any time and without notice to make changes, corrections, updates and improvements to the structure of the website and the information/documents contained therein.

Links

Citizens of the Order assumes no responsibility for the information and/or documents published by third parties on sites with which the website has an interactive link (hyperlink) or for the technical-operational methods adopted by such sites with particular reference to aspects of computer security and privacy protection. Users who decide to visit a site linked to this website do so at their own risk, assuming the burden of taking all due precautions. In any case, the existence of the link does not imply any form of sponsorship/authorization by Citizens of the Order. Under no circumstances, therefore, can Citizens of the Order be held liable for direct and/or indirect damages caused by the use and/or browsing of websites linked to this website.

Information (privacy policy) Website

This document describes how the website www.cittadinidellordine.com is managed with reference to the processing of personal data of those who interact with the services provided: the information is provided in accordance with Article 13 of the European Regulation (EU) 2016/679 (GDPR) only for the website in question and not also for other sites that may be consulted by the user through links, for which Cittadini dell’Ordine is in no way responsible. In order to offer the personalized and non-personalized services provided by its website, Cittadini dell’Ordine S.p.A., in its capacity as Data Controller, processes the personal data necessary for the provision of the same and guarantees, within the framework of the regulatory provisions, that the processing of personal data is carried out with respect for the fundamental rights and freedoms, as well as the dignity of the person concerned with particular reference to confidentiality, personal identity, right and protection of personal data. Specific additional and contextual information is provided on the pages of the site, prepared for particular services on request that provide forms (forms) for data collection.

Types of data processed

Personal data may be collected automatically while browsing and using the site and the services provided therein or may be entered voluntarily by the user. Among the personal data collected by the Owner independently or through third parties, there could be, by way of example but not limited to: IP address, date and time of visit, type of browser and device used, web page of origin and exit, etc.). Among the personal data transmitted by the user, there could be, by way of example and not limited to: identification data (company name or name, VAT number, city, registered office address(es), generalities i.e. first and last name of natural persons, etc.) and contact data (address or other personal identification elements, such as telephone, e-mail address, etc.) or even registration data functional to the creation and activation of one’s own account.

• Browsing and other data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers and terminals used by users, the addresses in URI/URL (Uniform Resource Identifier/Locator) notation of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. These data, necessary for the use of web services, are processed for the purpose of:

• Monitor the proper functioning of the site and the services offered;
• To derive statistical information on the use of services (most visited pages, number of visitors by time slot or daily, geographical areas of origin, etc.).

Browsing data persist for a maximum duration from time to time identified within the “cookie policy” (subject, however, to any need to ascertain crimes by the Judicial Authority). Any use of cookies – or other tracking tools – by this site or the owners of any third party services used by it, unless otherwise specified, is for the purpose of identifying the user and recording their preferences for purposes strictly related to the provision of the service requested by the user.

• Personal data voluntarily provided by the user

Personal data may be entered voluntarily by the user, in order to make their requests or to take advantage of the services provided by the website, by filling in forms (forms) or sending e-mail messages. The optional, explicit and voluntary sending of messages to contact addresses, messages sent by users to institutional profiles/pages on social media (where this possibility is provided for), as well as the completion and submission of forms on the website, involve the acquisition of the sender’s contact data, necessary to respond to requests, as well as all personal data included in the communications. Specific information is present on the pages containing the forms (forms) prepared for the provision of certain services. The user assumes responsibility for the personal data of third parties that may be published or shared through this website and guarantees that he/she has the right to communicate or disseminate them, releasing the Owner from any liability to third parties.

• Cookies and other tracking systems

No use is made of cookies for user profiling. The only processing carried out concerns the production of statistics, with pseudonymized data, on browsing the site www.cittadinidellordine.com. The configuration adopted, so as to exclude processing of identifying data, collects the following information:

• IP address, which is masked by resetting some bytes;
• operating system used;
• browser type;
• Type of device (PC, smartphone, etc.).

Use is made of session and/or persistent technical cookies, strictly limited to what is necessary for the safe and efficient navigation of the website.

Purposes of processing and purposes of cookies

Cookies used on the web are intended to perform computer authentication, session tracking and storage of technical information regarding the activities of users accessing a web page or website. With this in mind, some operations on the website could not be accomplished without the use of cookies, which are therefore technically necessary in such cases. These so-called technical cookies are useful because they can facilitate faster navigation and more effective use of the website (for example, they make it easier to carry out certain procedures when making online purchases, when authenticating to a restricted access area or when a website automatically recognizes the language you intend to use).

The www.cittadinidellordine.com website uses cookies to make site services simpler, faster and more efficient for the user viewing the web pages. Users accessing the site will receive very small amounts of information in their devices in use, whether computers or mobile devices, in the form of small text files, “cookies” precisely, stored in directories used by their browsers. The cookies used enable:

• Store browsing preferences;
• Avoid re-entering the same information multiple times;
• Analyze the use of services and content provided by the site to optimize the browsing experience.

Legal Basis

The personal data of users visiting the web pages of the website www.cittadinidellordine.com may be acquired through the use of cookies, for the purposes described above. The use of technical cookies consists of a processing carried out in the legitimate interest of the Owner; the lawfulness of processing attributable to the use of analytical or third-party cookies, on the other hand, is based on the provision of an explicit and unequivocal consent by the user (at the first access to the website). The personal data of users who access our website to take advantage of the services provided by it, are provided by the interested parties on a spontaneous and voluntary basis. In this context, the legal basis for processing is the following conditions:

• performance of a contract to which the data subject is a party or performance of pre-contractual measures taken at his or her request (information and commercial offers);
• Pursuit of the legitimate interest of the data controller (promotion of business activity to customers or potential customers, who explicitly request it);
• acquisition of consent.

Mandatory or optional nature of providing data

The personal data collected by this website, either independently or through third parties, consists of browsing data and personal data freely provided by the user. Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific informative texts that can be viewed at the forms (forms) of data collection. The user can refuse to give the Data Controller his browsing data. To do so, he must disable cookies by following the instructions provided by the browser in use. Disabling cookies may worsen navigation and may limit and/or prevent the use, in whole or in part, of the functionality of the site. Regarding the optional provision of data more information is made regarding the cookies on the site in the document “cookie policy” accessible both from this complete information and from the summary information contained in the banner published on the website.

The provision of data on the collection forms (forms) on this website is optional, except for those indicated as mandatory in order to allow the user to access the services offered. Failure on the part of the user to provide certain personal data may make it impossible to use all the features and services provided by this website or to obtain a response to his/her requests. The processing of data conferred spontaneously for the purposes just described is carried out in the absence of consent since it is strictly necessary to carry out the processing operations and to activate the services requested by the user. In accordance with the regulations in force, the interested party may, however, be required to give consent to the processing of their data (in cases where the stated purpose provides for it) by ticking the appropriate box in the specific form (form) of competence. This is without prejudice to the fact that the data subject may revoke any consent given at any time, without affecting the lawfulness of the processing based on the consent prior to the revocation.

Mode of treatment

Personal data will be processed by electronic means, including automated means, in accordance with the principles of lawfulness, necessity and relevance, taking safeguards to identify adequate security measures at any stage of the processing, having regard to the specific purposes of processing. In this regard, the anonymization of personal data and the removal of identifying data shall be carried out if there is no need to process the data in an identifiable form for the aforementioned processing purposes and, in any case, upon expiry of the retention period indicated in the following paragraph. The Data Controller does not carry out processing that consists of automated decision-making processes (such as profiling) on the data of users or those who interact with this website. Personal data will be processed by individuals expressly authorized and trained in personal data protection. Data may be accessed, incidentally, by ICT personnel and computer technicians (including outsourced) who oversee the operation of the computer system.

Data retention

The Data Controller keeps the data for the time necessary to obtain anonymous statistical information on the use of the site and to check its correct functioning. Personal data will be retained for the period necessary to pursue the above-mentioned purposes; in particular, personal data collected for purposes attributable to the legitimate interest of the Data Controller will be processed and retained until such interest is satisfied, without prejudice to an additional retention period imposed by law or by explicit request from the Authority. When processing is based on the consent of the data subject, the Data Controller may retain personal data for longer, until such consent is revoked (where requested by the data subject). Once the above retention period has elapsed and the purposes for which it was collected have ended, the data will be deleted or anonymized and processed only for statistical analysis.

Data recipients

The Data Controller does not disclose any personally identifiable data or information to third parties except, if necessary and to the extent strictly necessary, to those who intervene as suppliers for the provision of services inherent to the management of the website and for the consequent management of the contractual relationship and related administrative fulfilments, as well as to those who provide computer services or commercial electronic communications services. The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data. In addition to the Data Controller, in some cases, other parties involved in the organization of this website (sales/marketing personnel, system administrators, etc.) or external parties (technical service providers, hosting providers, IT service companies, companies specializing in the management, development and maintenance of websites, etc.) that we use exclusively for the provision of services related to the purpose pursued, which our organization, in order to ensure greater protection, has from time to time appointed as Data Processors (art. 28 of the GDPR) of the processing operations they put in place. The updated list of Data Processors can always be requested from the Data Controller.

Data Transfer

There are no plans to transfer personal data to a third country or international organization (Art. 13(1)(f) GDPR) outside the European Union (or the European Economic Area). However, the Controller may use web platforms for publishing and sharing audio/video material belonging to companies residing outside the EU. The Data Controller also reserves the possibility to use cloud services, in which case, the service providers will be chosen from those companies that can provide specific third country adequacy guarantees recognized through a decision of the European Commission or, in the absence thereof, suitable contractual or covenant-based guarantees to be provided by the data controllers involved (including Binding Corporate Rules “BCRs” and Standard Contractual Clauses “SCCs”).

Rights of the data subject

The data subject, to whom the personal data refer, is entitled to exercise his or her rights (under Articles 15-22 of the GDPR) at any time in order to obtain:

• confirmation as to whether or not personal data concerning him or her are being processed, as well as access to the data and the following information (purpose of processing, categories of personal data, recipients and/or categories of recipients to whom the data have been and/or will be disclosed, storage period);
• rectification of inaccurate personal data concerning him/her and/or supplementation of incomplete personal data, including by providing a supplementary statement;
• The deletion of personal data or the restriction of the processing of personal data (as a means of reacting to unlawful or improper processing) in the cases provided for by current legislation;
• The opposition to the processing (c.d. “opt out”) of the processing of personal data (as a manifestation of willingness to have a given data processing cease) in the cases provided for by the regulations in force (it is understood that this right does not exist where the legitimacy of the processing is based on consent since in this case the right to revocation prevails); it may extend to the processing of one’s own data for purposes related to marketing activities carried out by automated contact or through traditional means, being able to be exercised in whole or in part (e.g., to communications only by text message, e-mail or telephone or by objecting only to the sending of promotional communications carried out by automated means, etc.) or to processing that consists of automated decision-making processes (such as profiling, insofar as it is related to direct marketing purposes);
• the portability of data, pertaining to the data subject and provided by the data subject, in order in particular to request from the data controller the personal data concerning him/her and/or to request from the data controller the direct transmission of his/her data to another data controller (it is understood that this right applies only if the processing is based on contract or consent and is carried out through electronic processing) in the cases provided for by the applicable legislation.

Regarding the exercise of his or her rights, the data subject may address his or her requests through specific communication by mail addressed to the Data Controller (at the above address) or by sending communication to the e-mail address privacy@cittadinidellordine.com, specifying the subject of his or her request and the right he or she legitimately intends to exercise.

Right of complaint

Data subjects who believe that the processing of personal data relating to them occurs in violation of the provisions of the Regulations, have the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data) in the manner provided on the website www.garanteprivacy.it (pursuant to Article 77) or to take appropriate legal action pursuant to Article 79 of the Regulations themselves (GDPR).

Applicable law and jurisdiction

These conditions are governed by Italian law. Any dispute arising out of the interpretation, application or enforcement of these conditions shall be referred to the exclusive jurisdiction of the Court of Bolzano.