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Privacy Policy 1

Privacy Policy

(Art. 13 General Data Protection Regulation GDPR)

The processing related to the web services of the site/portal takes place at the headquarters of the aforementioned company and is only handled by the technical staff of the office authorized to process the data (e.g. Internet Area), or by any external Data Processors (outsourcers) for the performance of occasional or periodic technical operations (e.g. maintenance of the Databases).

The aforementioned data controller considers the "privacy" of its users to be of fundamental importance and guarantees that the processing of personal data through its website is carried out in compliance with the fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to protection of personal data. In this regard, the data controller has adopted and implemented a Privacy Policy for everything concerning the management methods of the site with reference to the processing of users' personal data.
Please read the following Privacy Policy and check it carefully periodically in order to check for any updates or revisions that may be necessary. The data controller informs that the personal data (hereinafter "Data") provided by you, or otherwise acquired as a result of or on the occasion of browsing our website/portal, may be processed, in compliance with European Regulation 2016/679 (GDPR).

Definition of "personal data"For the purposes of this Policy, "personal data" – as better specified in Article 4 of the GDPR – means "any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;". This Privacy Policy applies to personal data collected through the website and/or portal of the Data Controller of your data and/or the Company's email accounts. This Privacy Policy does not apply to personal data collected offline, except in cases where such personal data is combined with other personal data collected by the Data Controller of your online data. Furthermore, this does not apply to other websites owned by third parties, which can be accessed via hyperlink, due to the fact that the Data Controller of your data does not manage and control the content of such sites.
The following personal data may be collected by the Data Controller through its website and/or portal: name, surname, address, e-mail address, information grouped for statistical purposes only during the process of consulting the website and/or portal, other information provided voluntarily by the user through the online registration procedures or by filling in the appropriate fields, forms, information aimed at improving and facilitating navigation of the site.

Methods of data processingUsers can access different sections of the website without providing any personal information. The Data Controller processes and collects personal data online through its website and/or portal or other e-mail address of the Company; these processing operations are carried out, mainly in an automated manner, in the following ways:

1) Data provided voluntarily by usersThe Data Controller collects personal information and other data that are entered in the registration forms or released in the form fields of the website and/or portal, as well as forwarded to the Company by e-mail. Such data may concern information necessary to provide the services requested by the data subject (e.g. Newsletter) and/or to contact you (your name, postal address, email address, telephone number, user ID and password), or even your date of birth, professional credentials, hobbies and interests.

2) Browsing data collected through the use of electronic toolsThe computer systems and software procedures used to operate the website of the Data Controller of your data acquire, during their normal use, a series of personal information whose transmission is implicit in the use of Internet communication protocols (for example, the user's IP address or the domain name of the computer used to access the website, the URL of the requested resources, the time of the request or the time of the session, the method used to submit the query to the server, the size of the files received in response to the request, the numerical code concerning the status of the response given by the server and other type of information regarding the user's operating system and computer environment). The website and/or web portal of the Data Controller uses technologies such as cookies or similar for the purpose of collecting and/or transmitting personal data of users. The Data Controller uses these technologies exclusively for the purpose of obtaining statistical information on the use of the website and/or web portal (e.g. total number of visitors to the websites, number of visitors per single web page, name of the domain of origin of the visitors' internet service provider). In particular, the use of session cookies (those that are removed from the user's computer when the browser is closed) is strictly limited to the transmission of information referring to the user's session, which is of fundamental importance for safe and efficient navigation of the website and/or portal. The use of these session cookies also strictly excludes the use of other computer techniques that are potentially detrimental to the confidentiality of users' browsing and does not allow the acquisition of personal data identifying them.

Details on the processing of personal dataThe User's Data are collected to allow the Data Controller to provide its services, as well as for the following purposes: Statistics, Contacting the User, Interaction with social networks and external platforms, Registration and authentication, Social Applications, Payment Management, Interaction with support and feedback platforms, Infrastructure monitoring, Traffic optimization and distribution, Interaction with live chat platforms, Remarketing and Behavioral Targeting, Address management and sending of email messages, Display of content from external platforms, Commercial affiliation and Heat mapping. The types of Personal Data used for each purpose are set out in the specific sections of this document.

Purpose of the processing of the collected dataPersonal Data may be collected for the following purposes and using one or more of the following services:
- Social Applications
- Interaction with social networks and external platforms- Contacting the user, chats and feedback- Optimization and distribution of traffic, infrastructure monitoring- Remarketing and Behavioral Targeting- Statistics- Viewing content from external platforms- Registration and authentication

Purpose of the collection
The aforementioned data controller collects the personal data of its users necessary to carry out the operations of authorization, authorization and personalization of access to the various areas and related contents of the Company's website/portal. In addition, the aforementioned data controller acquires the data necessary to execute the contractual obligations assumed towards customers and deriving from the booking transactions. The execution of these obligations necessarily implies that the employees of the operational and commercial functions of Mediawest, as well as the employees of third-party service providers, have access to such data. The aforementioned data controller uses the personal data collected online for the purpose of offering products and services, controlling the authorized access system to monitor data security, evaluating job offers submitted by candidates (CVs); only at the specific request of the interested party, through the online registration form, the aforementioned data controller submits commercial offers and promotes marketing initiatives through its own "Newsletter". The aforementioned data controller, as the "Data Controller" of the related processing, informs that the data in question will be processed and used exclusively for the purposes highlighted in this Privacy Policy.

The personal data collected by filling in the forms on the website/web portal of the aforementioned data controller are processed in order to:

allow you access to the services provided by the website/portal and reserved for registered users, be able to contact you at your request to provide you with the specific information and assistance you need or for which you have requested our intervention. for the sending of commercial information and for marketing purposes both by automated means (e.g. email, fax, sms, mms, etc.) and by non-automated means (e.g. ordinary mail, telephone with operator, etc.) in relation to products and services of companies and/or commercial partners, with your express consent to carry out, with electronic tools, profiling activities, analysis of purchasing choices and market research in order to improve the offer of services and commercial information, making them more in line with your interests. This information may be supplemented by additional information provided at the time of any request for specific services.

Communication and/or dissemination of personal dataPersonal data will be accessible to the bodies and employees of the aforementioned data controller, formally appointed as Data Processors or Data Processors. The use and disclosure of personal data by external individuals and organisations acting on behalf of the aforementioned data controller are governed by contracts that provide for an adequate level of protection of personal data. These subjects are appointed as External Data Processors. Users' personal data will be used and released by the aforementioned data controller exclusively to individuals and organizations working on its behalf, in accordance with this Privacy Policy and in accordance with the explicit provisions of current legislation. The aforementioned data controller also manages the information contained on its website/web portal in collaboration with other service providers and web agencies, from which it may receive personal data relating to the users of such information. These online collaborations are regulated by specific contracts that presuppose an adequate level of protection of the personal data processed. In certain other cases, the aforementioned data controller may also be required to release the personal data of the users of its website/web portal, in execution of contractual obligations, in accordance with current legislation or to satisfy the request for services by the data subject; this information release activity may take place in the following cases:

- When online users have authorized the release of information;- When the aforementioned data controller needs to communicate information about users in order to offer services and satisfy the request of an online user;- When the aforementioned data controller needs to communicate the information to its partners who perform services for online users;- When the aforementioned data controller is required, by order of the judicial authorities, to release information about users, or in accordance with a local or international law, regulation or mandate.

In addition, other circumstances may arise, for example if the aforementioned data controller decides to sell, merge or acquire capital for commercial reasons. As part of these reorganization activities, personal data may be shared with current or potential acquirers. In these circumstances, the aforementioned data controller will obtain written guarantees that the personal data will be processed with an adequate level of protection and, in any case, in accordance with current legislation. Except in cases explicitly permitted by law, or provided for in this Privacy Policy, personal data will not be communicated or shared without the consent of the user concerned. The aforementioned data controller will not transfer, for a fee or free of charge, the personal data of its website users to unauthorized third parties.

Protection of personal dataIn accordance with the principle of minimization of processing enshrined in Article 5 of the GDPR, the aforementioned data controller guarantees that processing by electronic means is carried out by minimizing the use of personal data and identification data, limiting their use to cases in which they are strictly necessary for the achievement of the purposes for which they were collected. The aforementioned data controller also guarantees the adoption and observance of specific security measures to prevent the loss of data, any illicit or incorrect use of the same and unauthorized access. The user's data will be stored by the data controller for a maximum of two years from the last interaction with the user and until any cancellation order by the data subject, including data whose retention is not necessary in relation to the purposes for which they were collected, in compliance with the rights enshrined in Articles 15 – 21 GDPR and to be implemented in the manner referred to in the following paragraph "Your Rights". It is the responsibility of each individual user in charge to guarantee and verify the ownership and custody of their passwords and related access codes to web resources.

Consent to the processing of personal dataThe aforementioned data controller processes the data of its users/customers exclusively with their consent. However, if the user does not consent to the processing of data or requests the deletion of his/her data, it will not be possible to access the reserved areas of the Company's website/portal.

Optional nature of the provision of dataApart from what is specified for browsing data, the user has the right to provide or not the personal data contained in the request and/or registration forms of the website/web portal of the aforementioned data controller. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information pursuant to art. 58 GDPR, for the purpose of controlling the processing of personal data. In these cases, the response is mandatory under penalty of an administrative sanction.

Right of access to personal data and other rightsUsers of the website/web portal may always contact the Data Controller to assert their rights as provided for in articles 15 to 21 of the GDPR according to which:

- The data subject has the right to obtain confirmation as to whether or not personal data concerning him or her is being processed and, if so, to obtain access to personal data and the following information:a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular if they are recipients in third countries or international organisations; d) where possible, the envisaged retention period of personal data or, if this is not possible, the criteria used to determine such period; e) the existence of the right of the data subject to request from the controller the rectification or erasure of personal data or the limitation of the processing of personal data concerning him or her or to object to their processing; (f) the right to lodge a complaint with a supervisory authority; g) if the data are not collected from the data subject, all available information on their origin; h) the existence of automated decision-making, including profiling as referred to in Article 22(1) and (4) GDPR, and, at least in such cases, meaningful information about the logic used, as well as the importance and envisaged consequences of such processing for the data subject.

- The data subject has the right to obtain:• the updating, correction or, when interested, the integration of data• the cancellation of data concerning him/her for the reasons specifically provided for by Article 17 of the GDPR (right to be forgotten), the transformation into anonymous form or 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 or subsequently processed; The controller of your data, in the event that the personal data has been made public and is obliged to erase them at the request of the data subject, shall take reasonable measures, including technical measures, to inform those who are processing the personal data of the request of the data subject to delete any link, copy or reproduction of his or her personal data, except in the case in which this fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right. The data subject has the right to object, pursuant to art. 21 GDPR, in whole or in part:• for reasons related to your particular situation to the processing of personal data concerning you, even if pertinent to the purpose of the collection. The controller shall refrain from further processing the personal data unless it can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
• to the processing of personal data concerning him/her for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication.

In accordance with these provisions, and in addition to the other rights specified herein, the aforementioned data controller provides users of its website/web portal with the following possibilities:no collection of personal data:
The user may choose not to provide personal data online to the aforementioned data controller by deciding not to enter or release personal information in the registration forms or in the form fields of the web, or by not using any personalized service among those available on the Company's website/portal. Some of the contents and/or services of the site/portal are offered exclusively to users who provide personal information or who use personalized services.limitations of the use and communication of personal data for different purposes:Access to certain sections of content and/or services of the website of the aforementioned data controller may require the user's consent to use and release personal data for the purpose of implementing the contact list and/or to identify and offer additional services and promotions that are of interest to you. Users can limit the further processing that this information can be carried out by checking or choosing the options to be set at the time of data entry.

In addition, the information provided after the first registration can be modified or deleted by changing the settings previously entered in the registration form on the website/web portal of the aforementioned data controller, by accessing the appropriate "Newsletter" section on the home page. It is also possible for users to access their personal data, released and stored online and, where permitted, it is also possible to update and modify personal data online.

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