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PRIVACY POLICY 

1. Scope of application and sources of processing

In compliance with the obligations deriving from national law (Italian Legislative Decree 30 June 2003 no. 196, Privacy Code, as amended) and Community law (General Data Protection Regulation no. 679/2016, GDPR), the Company Giusto Faravelli S.p.A., a sole shareholder company with registered office in Milan, Via Medardo Rosso 8, tax code and VAT no. 03224410153, in its capacity as Data Controller, hereby informs you of the methods and purposes of the processing of Personal Data collected while browsing on this website. The purpose of this privacy policy is to provide the utmost transparency in relation to the information collected by the website and the methods of its use.

This privacy policy concerns only Personal Data collected while browsing the websites:

• https://www.faravelligroup.com

• https://www.faravelli.it

• https://www.faravelli.de

https:// www.faravelli.cz

• https:// www.faravelli.com.cn

• https:// www.faravelli.us

• https:// www.faravelli.es

This website can generally be used without providing Personal Data which, if requested, will only be processed on the basis of consent expressed by you, the data subject. In any case, in the capacity of manager of these websites, Giusto Faravelli undertakes to protect the Personal Data collected and will ensure that the same are processed confidentially and in compliance with existing rules. However, Giusto Faravelli notes that the transmission of data via the Internet (for example, by email communication) is not always secure, as it is not possible to ensure complete protection against access by third parties. 

2. Data processed

2.1. Data collected by applications, used for Website functioning 
The applications in charge of the functioning of the websites listed in point 1. may collect, during browsing, some data not associated directly with you, the transmission of which is implicit in the use of internet communication protocols. The data collected may include, by way of example but without limitation, IP addresses, domain names and the type of browser of the computers used for the connection, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request and other parameters concerning the operating system and computer environment used by you.However, those data do not allow Giusto Faravelli to ascertain your identity and they are therefore to be considered anonymous.

2.2. Data collected by way of Cookies
Part of this website uses Cookies, which are text files deposited by the Website on your computer to allow the website itself to analyse the methods of use by users and to exchange information between the server and those users. No sensitive data are exchanged via cookies. The cookies created by Giusto Faravelli and by the companies used by the Controller to manage the services do not store Personal Data allowing for your identity to be traced and/or known directly. The cookies used by Giusto Faravelli do not represent a risk to privacy or to the integrity of the IT systems used by you when accessing the internet communication network or the Website. 

2.3. Data collected via Google Analytics 
Giusto Faravelli uses the statistical services known as Google Analytics, offered by Google LLC. Google Analytics facilitates the tracking of accesses to the Website and allows the Website administrators to generate and view data in aggregated and anonymous form, in order to understand how the Website is used by visitors and to produce statistics. Google Analytics requires, in order to function, the presence on the Website pages of a so-called tracking code. The purpose of this code is to identify, for the purposes indicated below, the pages visited by you during the browsing session on the Website. In addition to the pages visited, the data collected may also include, by way of example but without limitation, the domain names and type of browser of the computers used to connect to the Website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request and parameters concerning the operating system and the IT environment used by you. However, these data do not allow for your identity to be known and due to their nature and the methods of their processing, they are therefore to be considered anonymous

2.4. Data collected by completing forms for registration to the Newsletter service and sending of contact emails 
You are free to provide the personal data requested in the registration forms for the services (to send contact emails, information requests, to register to the newsletter). In particular, the optional, explicit and voluntary transmission of Personal Data by completing the specific Forms or by email to the contact addresses indicated on the website involves the acquisition by Giusto Faravelli of data provided by you, including your email address, required to respond to requests. For the purposes of registration to the Newsletter, the following Personal Data are requested and therefore processed by Giusto Faravelli:

- Name;
- Surname; 
- Company name; 
- Home nation; 
- E-mail; 
- Sectors of interest.

All of the aforementioned data are required for registration to our Newsletter, but only some of them are marked as mandatory and are therefore considered necessary to provide the requested service. If the mandatory Data are not provided, the requested service may not be provided and the related opportunities may not be used. 

2.5. Data collected with the use of “plugin” services 
Our Website uses plugin services provided by applications and social networks.

Facebook Plugins (Like button): The pages include the plugins of the Facebook social network, provider Facebook Inc, 1 Hacker Way, Menlo Park, California 94025, USA. Facebook plugins can be recognised by way of the Facebook logo or the “Like” button on our page. An overview of the Facebook plugins can be found here: https://developers.facebook.com/docs/plugins/The plugin establishes a direct connection between your browser and the Facebook server when browsing on the Giusto Faravelli Website. Facebook receives information regarding consultation of our website with your IP address. If you select the Facebook “Like” button when connected to your Facebook account, you can link the contents of the Website pages to your Facebook profile. This allows Facebook to associate the visit to the pages with your account. As provider of the pages, we do not have any knowledge of the content of the data sent or their use by Facebook. For further information, consult the Facebook privacy policy at the address https://de-de.facebook.com/policy.php. If you do not want Facebook to associate your visit to our pages with your Facebook account, please disconnect from your Facebook account. 

Twitter plugins: Our pages include functions of the Twitter service. These functions are provided by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. Using Twitter and the "Re-Tweet" function, the Websites visited by you are connected to your Twitter account and made known to other users. The data are also sent to Twitter. In the capacity of provider of the pages, we are not aware of the content of the data sent or how it is used by Twitter. For further information, consult the Twitter privacy policy at the address https://twitter.com/privacy. The Twitter privacy settings can be modified in the account settings at the address: https://twitter.com/account/settings.

Google Maps Plugins: Our pages use the Google Maps functions. The provider is Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The Google Maps API is used for the visual display of geographically information. When Google Maps is used, Google collects, processes and uses the data relating to use of the Maps functions by Website visitors. Further information on the processing of data by Google is available in Google’s privacy policy.

Instagram plugins: Our pages include functions of the Instagram service. These functions are provided by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are connected to your Instagram account, you can connect the contents of our pages to your Instagram profile by clicking on the Instagram icon. This allows Instagram to associate the visit to our pages with your account. In the capacity of provider of these pages, we are not aware of the content of the data sent or of how it is used by Instagram. For further information, consult the Instagram privacy policy: https://instagram.com/about/legal/privacy/

LinkedIn Plugins: Our website uses the functions of the LinkedIn network. The provider of the service is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time one of our pages which contains LinkedIn functions is visited, a connection is established to the LinkedIn servers. LinkedIn is informed that you have visited our Website. If you select the LinkedIn "Recommend" icon while you are connected to your LinkedIn account, LinkedIn is able to associate the visit to our Website with you and your account. As providers of the page, we do not know the content of the data sent and their use by LinkedIn. For further information, consult the LinkedIn privacy policy at the address: https://www.linkedin.com/legal/privacy-policy

XING Plugins: Our website uses the functions of the XING network. The provider is XING AG, Dammtorstraße 29-32 20354 Hamburg, Germany. Every time you access one of our pages that contains XING functions, a connection is established to the XING server. To our knowledge, the personal data will not be archived. In particular, no IP addresses are stored or usage behaviour assessed. Further information on data protection and the XING Share button is available in the XING data protection statement at the address: https://www.xing.com/app/share?op=data_protection.

YouTube Plugin: Our Website uses plugins from Google’s YouTube website. This Website is managed by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. If you visit one of our pages that has YouTube plugins, a connection is established with the YouTube servers. The YouTube server will be informed of which of our pages have been visited. If you access your YouTube account, YouTube may associate your browsing behaviour directly with your personal profile. You can avoid the association of data by disconnecting from your YouTube account while browsing on our website. Further information on how your data are managed is available in the YouTube privacy policy at the address: https://www.google.de/intl/de/policies/privacy

3. Purpose and legal basis of processing

3.1. Purpose of processing of data collected by way of the website applications, by cookies and by the service offered by Google Analytics 
Data collected by the Website are used for statistical purposes, to guarantee service continuity and to improve the internet website. Cookies allow some operations to be automated so that you can avoid some complex procedures; they are sometimes essential for the correct functioning of the Website. The data collected by Google Analytics are processed for the purpose of tracking and examining use of the Website, compiling reports on the activities of the same, which can be read by authorised operators, and providing other services relating to the Website activities and use of the Internet.

The legal basis of the processing is the legitimate interest of the Controller in the correct management of its internet website and the customisation of the website to improve your browsing experience and to analyse the effectiveness of the website, analysing the number of users and the consulted areas.  
The website uses technical and third party cookies. It does not use first party profiling cookies. 
The Website, in particular, uses technologies such as cookies to customise the contents and to analyse traffic to the website. Information on your use of the website is shared with our partners, which operate in the sector of social media and statistical data.
On this website, cookies are used to: 
• remember your preferences, also in relation to your consent to the use of cookies; 
• collect anonymous information on the pages visited and on how the visitor reached the website, with the aim of obtaining useful information to improve the organisation and presentation of the website contents (the "Google Analytics" service is used for this purpose);
• offer third party services such as, by way of example:
o The simplified sharing of our contents on your social networks (e.g. the buttons "Like” and "Share" of the Social Network) 
o The interactive geographical and road maps (e.g. Google Maps).

The statistical service known as Google Analytics allows for accesses to the Website to be tracked and for the Website administrators to generate and view data in aggregated and anonymous form in order to understand how the Website is used by visitors and to process statistics.

The Cookies used by the website and by Google Analytics do not, in any case, allow the identity of visitors to be tracked, and they do not allow the cross-referencing of the information collected with other information that is already known.
Google guarantees that it does not associate the IP address of the Website visitors with any other data relating to users that may be held by it, except where the users themselves use other services offered by Google which involve that association and for which the same have accepted the respective privacy rules prepared by Google itself.

In any case, the aforementioned association has been prohibited by the Controller, which has expressly established its settings within the Google Analytics account by anonymising the IPs and deactivating the authorisations relating to “Google Products and Services”, “Benchmarking”, “Technical Support” and “Account Expert”. 

3.2. Data collected by completing forms for registration to the Newsletter Service and sending of contact emails
If you provide data directly by completing the specific forms on the Website (registration to the newsletter) the processing is carried out by Giusto Faravelli based upon your free and informed consent, expressed specifically and documented in the form envisaged by law. 
In particular, personal data provided by you for the purposes of insertion into the newsletter list are processed, only subject to your specific and separate consent, exclusively to allow the Controller to send, to the email address communicated, the newsletter about the activities, products or services offered by Giusto Faravelli. 
The data collected when you send contact emails will be processed in order to respond to you and to provide the requested services to you. To offer the requested services, obviously, your fax and telephone numbers may also be used, in addition to your email address, if freely provided by you. It is therefore clear that if those data are not provided, the services requiring use of those data may not be provided.

4. Methods and duration of processing

4.1 Data collected through website applications, cookies and services offered by Google Analytics 
The data collected through website applications are processed using automated tools, in anonymous and aggregated form, for the purposes illustrated above and they will be processed exclusively for the time strictly necessary to pursue the above purposes. 
The processing of data collected by Google LLC is managed by way of IT and electronic tools with logics closely related to the purposes highlighted below and, in any case, so as to guarantee the security and confidentiality of the data. 
In order to function, Google Analytics uses cookies; the information on use of the Website generated by them are sent to Google and deposited on its servers in the United States. 
In relation to the purposes described above, the data are, therefore, aggregated with other data collected relating to other Website visitors. Their processing does not allow for your identity to be known or your identity to be traced in any way.
In any case, Google guarantees that it does not associate the IP address of the Website visitors with any other data relating to users that may be held by it, except where the users themselves use other services offered by Google which involve that association and for which the same have accepted the respective privacy rules prepared by Google itself. In any case, the aforementioned association and use of the above services are not considered to be connected to use or browsing of this Website, given that the Controller and its officers do not have direct or indirect access to the data collected and/or processed by Google while users are browsing on other websites.
In that regard, you are invited to read the Google Analytics Privacy Policy found at the link 
www.google.com/intl/it_it/analytics/learn/privacy.html

4.2. Data collected by completing forms for registration to the Newsletter service and sending of contact email
The processing of personal data provided by completing forms for registration to the newsletter and to manage responses to contact emails is carried out through their collection, recording, organisation, storage, consultation, use, erasure and destruction using IT tools, with logics closely related to the purposes highlighted above and, in any case, so as to guarantee the security and confidentiality of those data. To provide and manage the Newsletter, Giusto Faravelli uses the SendBlaster service offered by the Company eDisplay S.r.l. based in Milan, Via Palmanova 24. The data collected for that purpose are stored on secure servers of SendBlaster, which processes them on behalf of Giusto Faravelli in the capacity of Processor, as well as on the servers of Giusto Faravelli. In accordance with the SendBlaster privacy policy, data collected through the Giusto Faravelli website will never be used directly by SendBlaster, or sold by it to third parties. SendBlaster uses appropriately authorised operators to maintain the service and, in the exercise of that function, those operators may have access to your data. 
The data provided for registration to the newsletter service are processed by the Controller until otherwise notified by you. If consent to processing is withdrawn, the data will be immediately erased from all servers and applications on which they were recorded and archived and will no longer be stored. 

5. Nature of provision of data and consequences of lack of provision 

5.1. Data collected through website applications, cookies and the service offered by Google Analytics  
The collection by the Website of the data described above is necessary in order to allow you to browse on the website. According to the regulations in force, this website is not required to request consent for technical cookies and anonymised Google Analytics cookies, as they are necessary to provide the requested services. For all types of cookie, you may deny consent by one or more of the following methods:

• By modifying the configuration of the browser used to access the Website pages. (Whereby "browser" means any software used to access the Website pages.)
 • By modifying the settings used for third party services.

Both these solutions may prevent you from using or viewing parts of the Website. Below are links to the instructions for managing cookies for the most popular browsers:
• 
Chrome 
• Mozilla Firefox 
• Internet Explorer 
Safari 
• Safari iOS (mobile device) 
Opera 
• Xoom (Android and Motorola smartphone)

If your browser does not appear in the list or if the link is temporarily inaccessible, please refer to the specific guide incorporated therein or provided by the respective provider. Below is a list of links for managing preferences or cookie policies for the most popular services of the Website (our Partners whose third party cookies we install):

• Google Analytics
Facebook
• Twitter

You cannot, on the other hand, refuse the collection of other data by the Google Analytics software. If you do not agree, in whole or in part, with its presence on the Website pages, you are invited to leave the website, immediately ceasing your browsing. For the purposes of browsing on the website, the communication of personal data is not required, except for the anonymous data described above which are strictly necessary for the above purposes.

5.2. Data collected by completing forms for registration to the Newsletter service and sending of contact emails
The compilation of the forms involves the communication to Giusto Faravelli of Personal Data additional to the anonymous data required for simple browsing. Those data are used for the sole purpose of providing any requested services and they will be processed according to the specific policies prepared for that purpose and cited in the specific sections. The provision of data is optional. You may therefore decide not to provide any data or subsequently deny the possibility of processing data already provided: in that case, you may not receive the Services offered by the Controller. 

6. Access to data

The Data collected by the Website can only be accessed directly by the Controller.
The provider of the Hosting service is the company Boken s.r.l which may potentially have access to the Data, exclusively for technical reasons of need and urgency that require an intervention so as not to affect the Website functionalities and security.
The Personal Data collected through Google Analytics are transferred to the servers of Google LLC and processed there. Google may also transfer this information to third parties where required by law or where those third parties process the aforementioned information on behalf of Google. We note that the Website administrators or the Controller of data on the same cannot in any way, directly or indirectly, connect the data collected with your identity. 
The data provided by completing the forms contained on the Website are made accessible to employees ad collaborators of the Controller, in their capacity as internal processing officers and/or external processors or system administrators. In particular, the data provided for registration to the newsletter service are also accessible to the company SendBlaster which offers to the Controller the newsletter management service, and which manages the data on behalf of the Controller, in its capacity as external processor.

7. Communication of data without the need for express consent (pursuant to Art. 6 letter b) and c) GDPR) 
The Controller may communicate the data collected for the purposes illustrated above to judicial authorities, as well as to those entities to which the communication is mandatory by law for the conduct of those purposes. Those entities will process the data in their capacity of autonomous processing controllers. 

8. Dissemination of data 
The data indicated in point 1 and collected for the purposes indicated in point 2 will not be disseminated. 

9. Data transfer
Personal data collected by way of the Website are stored on servers located in the European Union. However, the Controller, where necessary, will have the right to move the servers even outside the EU. In that case, the Controller hereby guarantees that the transfer of data outside the EU will occur in conformity with applicable provisions of law, subject to signing the standard contractual clauses envisaged by the European Commission. Personal data collected via Google Analytics are transferred to the Google LLC servers and processed there.

10. Rights of the data subject 
In relation to the processing purposes, you are granted the exercise of the rights envisaged by Articles 15 et seq. of the GDPR, and in particular the right to:

• access, or obtain confirmation of the existence or otherwise of personal data relating to you, to know of its origin, as well as the logic and purposes on which the processing is based, the recipients or categories of recipients to which the data may be communicated, the determination of the storage period, if it can be defined; 
• rectify inaccurate data; 
• erasure (known as right to be forgotten), if the data are no longer necessary for the processing purposes, or if you have withdrawn consent to processing (if that consent is optional or there is no other legal basis for processing); 
• restriction, the right to obtain from the Controller the restriction of access to your personal data by all entities that have a service contract or an employment contract with the Controller; 
• portability, the right to receive in a structured, commonly-used and machine readable format the personal data relating to you, with the possibility of sending them to another Controller. That right does not apply to non-automated processing (for example, archives or paper records); in addition, only data processed with your consent are subject to portability and only if the data have been provided by you personally; 
• object, namely the right to object to the processing for reasons connected to your particular situation; 
• lodge a complaint with the Data Protection Supervisory Authority.

In addition, in accordance with Art. 7, paragraph 3 of the GDPR, you are granted the right to withdraw consent at any time; the withdrawal of consent does not prejudice the lawfulness of processing based upon consent prior to the withdrawal.

11. Methods of exercising rights 
You may, at any time, exercise your rights, indicated in the point above, by sending:
- a recorded delivery letter with notice of receipt to Giusto Faravelli S.p.A. Sole Shareholder Company, Via Medardo Rosso 8, 20159 Milan
- an email to the address privacy@faravelli.it 

12. Controller, processors and officers 
The Data Controller is Giusto Faravelli S.p.A., a Sole Shareholder Company with registered office in Milan, Via Medardo Rosso 8.
The updated list of processors and officers is kept at the Data Controller’s registered office. 






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