PRIVACY

Privacy Policy

Information on the processing of personal data under Regulation (EU) 2016/679 (GDPR).

Pre-publication draft · Aruba hosting verified; log retention described according to the applicable service terms

2. Types of data processed

Browsing data

The IT systems and software procedures used to operate the website may acquire technical data whose transmission is inherent in the use of Internet protocols, such as IP address, date and time of the request, requested resource, browser, operating system and server response codes.

Data provided voluntarily

Sending messages to the email addresses published on the website or contacting the Controller by phone entails the processing of data provided by the user, such as name, contact details and the content of the request.

3. Purposes and legal bases

Data may be processed to ensure the operation and security of the website, respond to contact requests and comply with legal obligations. Depending on the circumstances, the legal bases are the Controller’s legitimate interest in service security, steps taken at the user’s request before entering into a contract, performance of a contract and compliance with legal obligations.

4. Processing methods

Processing is carried out using IT tools and, where necessary, manual methods, with appropriate technical and organisational measures. Data is not used for profiling or solely automated decision-making.

5. Cookies and tracking technologies

In its current configuration, the website does not use profiling cookies, advertising systems, third-party analytics or other tools intended to track users. If non-essential tools are introduced in the future, this policy will be updated and, where required, a prior consent management mechanism will be implemented.

6. Recipients of data

Data may be processed by the Controller and, where necessary, by technical providers used for hosting, email and services required to operate the website. Hosting is provided by Aruba S.p.A., which, for personal data processed in providing hosting services on behalf of the Customer, acts as a Data Processor under Article 28 GDPR in accordance with the applicable contractual terms. Data is not disclosed to the public.

7. Transfers outside the EEA

The website is hosted by Aruba S.p.A. Any transfers of personal data outside the European Economic Area connected with other technical services that may be used will be assessed and governed in accordance with the GDPR and applicable law.

8. Retention

Data received by email or direct contact is kept for the time required to handle the request and, where a contractual relationship arises, for the periods required by applicable law. Technical server logs may be processed for operation and security purposes. Aruba’s current Hosting service terms provide for relevant logs to be retained in accordance with applicable law and do not state one single public fixed retention period for ordinary website browsing logs. Such data will therefore be retained for the period necessary for the stated purposes and in accordance with Aruba service settings and terms, without prejudice to legal obligations or requests from competent authorities.

9. Data subject rights

Where provided by the GDPR, users may request access, rectification, erasure, restriction of processing, portability and objection, and may withdraw any consent without affecting the lawfulness of prior processing. Requests may be sent to l.pini@pinimodelli.com.

10. Complaint

Users may lodge a complaint with the Italian Data Protection Authority if they believe that their personal data is being processed in breach of applicable law.

11. External links

The website may contain links to external websites or services. The Controller does not control how third parties process personal data; users are encouraged to review the relevant privacy notices before using such services.

12. Updates

This policy may be updated following legal, technical or service changes. The version published on the website will show the date of the latest update.