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PRIVACY POLICY

1 - Information on the Website Privacy

  1. This section contains information on how to manage www.tpaspa.com in relation to the data processing of users of the site.

  2. This policy is also valid for the purposes of Article 13 of Regulation (EU) 2016/679 – on protection of subjects with regard to the processing of personal data and on the free movement of data – for all users who interact with www.tpaspa.com.

  3. This policy only applies to www.tpaspa.com and does not include any other website visited by the user through the use of links.

  4. Purpose of this document is to provide information as to the methods, timing, and nature of the information that the data controllers must provide to users when connecting to the web pages of www.tpaspa.com, regardless of the purpose of the connection itself, in compliance with the Italian and European law.

  5. This policy may undergo changes due to the introduction of new policies; the user is therefore invited to regularly check this page.

  6. In case the user is under the age of fourteen, pursuant to Article 8(1) of Regulation (EU) 2016/679, and Article 2.5 of Legislative Decree 196/2003, as amended by Legislative Decree 181/18, he shall have to legitimise his consent through the authorisation of parents or legal guardians.

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2 - Data Controller

  1. The data controller is the natural or legal person, the public authority, the service or other body that, alone or jointly with others, determines the purposes, conditions, and means of the processing of personal data. He also manages security profiles.

  2. In respect of this website, the data controller is Massimo Dell’Avo; for any clarification or exercise of his own rights, the user can contact him at the following e-address: massimo.dellavo@tpaspa.it.

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3 - Data processing location

  1. The location of the data processing generated by using www.tpaspa.com is Via Carducci 221, Sesto San Giovanni (MI).

  2. If necessary, the data associated with the newsletter service may be processed at the appointed location by the data controller or subjects appointed by him for this purpose at the relevant premises.

 

4 - Legal basis of the processing

  1. Processing of personal data by www.tpaspa.com is based on consent (pursuant to Article 6(1)(a) of EU Regulation 2016/679) that the user expressed by browsing and visiting this website, thereby accepting this policy.

  2. Consent is optional and can be revoked at any time by sending an e-mail to massimo.dellavo@tpaspa.it. It should be noted that, in the absence of consent, certain services cannot be provided and browsing may be compromised.

 

5 – Cookies

  1. This section describes how this site and third parties use cookies and similar technologies. Cookies are used in compliance with the relevant European (Directive 2009/136/EC amended Directive 2002/58/EC on Privacy and Electronic Communications) and Italian legislation (Personal Data Protection Authority Provision of May 8th, 2014, and subsequent clarifications as well as “Linee Guida Cookie e Altri Strumenti di Tracciamento” [Cookie and Other Tracking Tools Guidelines] of June 10th, 2021, No. 231).

  2. For complete information about cookies, visit our cookie policy page: www.tpaspa.com/cookie-policy.

 

6 – Type of data processing

  1. Processing of personal data is necessary for the purposes of the legitimate interests pursued by the controller in order to provide information on the activity of www.tpaspa.com pursuant to Article 6(1)(f) of EU Regulation 2016/679, in compliance with the provisions of the same Regulation.

  2. This website uses Log Files that store information collected automatically during user visits. The information collected is the following:

    • internet protocol address (IP)

    • browser type and device parameters used to connect to the website

    • name of the internet service provider (ISP)

    • date and time of visit

    • user’s referral and exit web pages

    • number of clicks.

  3. The above information is automatically processed and collected in an aggregate form only, in order to verify the correct functioning of the site, and for security reasons. This information will be processed in accordance with the legitimate interests of the data controller.

  4. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly include personal data, such as the IP address, that might be used, in accordance with applicable laws, to block attempts to damage the website itself or to cause damage to other users, or otherwise harmful activity or criminal offences. Such data are never used to identify or to profile the user, but only for the protection of the website and its users. This information will be processed in accordance with the legitimate interests of the controller.

 

7 – Data provided by the user

  1. This website allows users to submit their resume for a possible employment; in this case, the data provided by the user are voluntarily provided by him at the time of requesting service provision. In any case, the site does not automatically record the identification data sent.

  2. By entering any information, the user expressly accepts this privacy policy. All data acquired will be used exclusively to provide the service requested and only for the time needed to provide such service.

  3. Any information that users deem to make public through the services and tools made available to them are supplied by the user knowingly and voluntarily, thereby exempting this website from any liability regarding any violation of the law. Responsibility of the user is to verify that he is allowed to enter personal data of third parties, or content protected by national and international standards.

  4. The optional, explicit, and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender address, necessary to reply to requests, as well as any other personal data included in the message.

 

8 - Purpose of data processing

  1. The data collected by the site during its operation are used exclusively for the purposes indicated above and stored for the time strictly necessary to perform the specified activities, and in any case no longer than 6 months.

 

9 - Data Retention

  1. In accordance with the provisions of Article 5.1(c) of the Regulation, the information systems and computer programs used by www.tpaspa.com are configured as to minimise the use of personal and identification data; such data shall be processed only to the extent necessary for the purposes set out in this Policy.

  2. Data will be stored for the period of time strictly necessary to achieve the purposes actually pursued and, in any event, the criterion used to determine the retention period is based on compliance with the terms allowed by applicable law and the principles of minimisation of processing and limitation of retention.

  3. Data used for security purposes (blocking attempts to damage the site) are stored for the time strictly necessary to achieve the purpose indicated above.

 

10 - User’s rights

  1. The user is guaranteed the respect for his rights regarding personal data protection. In line with what is set out and affirmed by the GDPR, in relation to the processing of personal data, the user has the right to ask the Data Controller:

    • access: the user may ask for confirmation as to whether or not his data is being processed, as well as to request further clarification on the information referred to in this policy

    • rectification: the user may ask to have the data he provided rectified or integrated, if inaccurate or incomplete

    • erasure: the user may request that his data be erased, if they are no longer needed for the purposes of the site, in the event of withdrawal of consent or opposition to the processing, in the event of unlawful processing, or if there is a legal obligation to erase them or they refer to persons under the age of fourteen

    • restriction: the user may request that his data be processed only for storage purposes, to the exclusion of other processing, for the period necessary to rectify the data, in the event of unlawful processing for which erasure is opposed, in the event he needs to exercise his rights in court and the data retained by the Data Controller may be useful and, finally, in the event of an objection to the processing and a check is in progress on the prevalence of the legitimate reasons of the Controller over those of the user

    • objection: the user may object at any given time to the processing of his data, unless there are legitimate grounds on the part of the Data Controller to proceed with the processing that prevail over the user’s, for instance for his defence in court

    • portability: the user may ask to receive his data, or to have them transferred to another data controller indicated by him, in a structured format, commonly used, and readable by an automatic device

    • withdrawal: the user may withdraw his consent to the use of cookies (Cookie Policy) at any given time, since in this case it is the basis of the processing. In any event, withdrawal of consent does not affect the lawfulness of the processing based on the consent granted prior to such withdrawal.

  2. At any time, the user may request to exercise these rights to www.tpaspa.com by contacting the e-mail address: massimo.dellavo@tpaspa.it.

  3. Furthermore, the user has the right to lodge a complaint with the Italian Supervisory Authority (“Garante per la Protezione dei Dati Personali” [Personal Data Protection Authority]) in the event he believes his rights have been infringed upon by www.tpaspa.com, or if he deems the response of www.tpaspa.com to their requests unsatisfactory.

 

11 – Amendments to this document

  1. This document, which constitutes the privacy policy of this website, is published at the address: www.tpaspa.com/privacy-policy.

  2. It may be subject to modifications or updates. Users are invited to consult this page periodically in order to be always up to date on the latest legislative news.

  3. Previous versions of the document will still be available at this page.

  4. This document was updated on 21/02/2023 to comply with relevant regulatory provisions, and in particular in compliance with Regulation (EU) 2016/679.

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