PRIVACY & COOKIE POLICY

L.Gobbi unipersonale srl with registered office in Via Vallecalda, 33 – 16013 Campo Ligure (GE) – Italy (hereinafter: “L.Gobbi “) is constantly striving to protect the online privacy of its users. This document has been prepared in accordance with Article 13 of the EU Regulation 2016/679 (hereinafter: “Regulation“) in order to allow you to know our privacy policy, to understand how your personal information is handled when you use our sites (L.Gobbi , hereinafter collectively “Site“) and, where appropriate, to give your express and informed consent to the processing of your personal data. The information and data provided by you or otherwise acquired as part of the use of the services of L.Gobbi , -such as: access to the restricted area of the Site, L.Gobbi , hereinafter ” Services“-, will be processed in accordance with the provisions of the Regulations and the obligations of confidentiality that inspire the activity of L.Gobbi .
According to the rules of the Regulations, the processing carried out by L.Gobbi will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality.

INDEX

1. Data controller
2. The personal data being processed
   1. Navigation data
   2. Special categories of personal data
   3. Data voluntarily provided by the data subject
   4. Cookie
3. Purpose of processing
4. Legal basis and mandatory or optional nature of processing
5. Recipients of personal data
6. Transfers of personal data
7. Retention of personal data
8. Rights of the data subject
9. Changes

1. DATA CONTROLLER

The owner of the processing carried out through the Site is L.Gobbi as defined above. For any information concerning the processing of personal data by L.Gobbi , including the list of data processors who process data, you may write to the following address: L.Gobbi Srl unipersonale – via Vallecalda, 33 – 16013 Campo Ligure (GE) – Italy

2. PERSONAL DATA BEING PROCESSED

As a result of browsing the Site, we inform you that L.Gobbi will process personal data that may consist of an identifier such as a name, an identification number, an online identifier or to one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity capable of making you identified or identifiable (hereinafter only ” PersonalData “).
The Personal Data processed through the Site are as follows:

A. NAVIGATION DATA

The computer systems and software procedures used to operate the Site 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 used by users who connect to the Site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit 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 are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site or third parties: except for this possibility, at present the data on web contacts do not persist for more than seven days.

B. DATA VOLUNTARILY PROVIDED BY THE DATA SUBJECT

In the use of some of the Services of the Site there may occur a processing of Personal Data of third parties sent by you to L.Gobbi . With respect to such hypotheses, you stand as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc. that may be received by L.Gobbi from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the applicable data protection regulations. In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it guarantees as of now – assuming all related responsibility – that this particular hypothesis of processing is based on a suitable legal basis under Article 6 of the Regulations that legitimizes the processing of the information in question.

C. COOKIE

Definitions, characteristics and enforcement
Cookies are small text files that sites you visit send and store on your computer or mobile device, to be transmitted back to the same sites on your next visit. It is precisely because of cookies that a site remembers the user’s actions and preferences (such as, for example, login details, language choice, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to said site or navigates from one page to another of it. Cookies, therefore, are used to perform computer authentication, session tracking and storage of information regarding the activities of users accessing a site, and may also contain a unique identification code that allows tracking of the user’s navigation within the site itself for statistical or advertising purposes. In the course of browsing a site, users may also receive cookies on their computer from sites or web servers other than the one they are visiting (so-called “third-party” cookies). Some operations could not be carried out without the use of cookies, which in certain cases are therefore technically necessary for the very operation of the site.
There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s computer for different periods of time: c.d. session cookies, which are automatically deleted when the browser is closed; c. d. persistent cookies, which remain on the user’s equipment until a predetermined expiry date.
According to the current legislation in Italy, the use of cookies does not always require the user’s express consent. In particular, “technical cookies,” i.e., those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. These are, in other words, cookies that are indispensable for the operation of the site or necessary to perform activities requested by the user.
Among technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Provvedimento Individuazione delle modalità semplificate per l’informativa e l’acquisizione del consenso per l’uso dei cookie of May 8, 2014 and subsequent clarifications, hereinafter only “Provvedimento“) also includes:

• “analytics cookies” where used directly by the site operator to collect information, in aggregate form, about the number of users and how they visit the site,
• browsing or session cookies (for authentication),
• functionality cookies, which allow the user to navigate according to a set of selected criteria (e.g., language, products selected for purchase) in order to improve the service rendered to the user.

For “profiling cookies,” vice versa, i.e., those aimed at creating profiles related to the user and used for the purpose of sending advertising messages in line with the preferences expressed by the user when surfing the Web, prior user consent is required.

Types of cookies used by the Site and the possibility of (de-)selection
The Site uses the following cookies that can be de-selected, except for third-party cookies for which you will have to refer directly to the respective cookie selection and de-selection methods, indicated by means of links:

• Technical cookies for navigation or session and strictly necessary for the operation of the Site or to enable you to take advantage of the content and services requested.
• Functionality cookies, i.e., used to enable specific Site features and a selected set of criteria (e.g., language) in order to improve the service rendered.

By disabling technical and/or functionality cookies, the Site may be unavailable or certain services or features of the Site may not be available or may not function properly, and you may be forced to change or manually enter certain information or preferences each time you visit the Site.

• Third-party cookies, i.e. cookies from sites or web servers other than that of L.Gobbi , used for purposes specific to said third parties. It should be noted that these third parties, listed below with the relevant links to their privacy policies, are typically autonomous data controllers of the data collected through the cookies they serve; therefore, you will have to refer to their personal data processing policies, disclosures and consent forms (selection and de-selection of the respective cookies), as specified in the aforementioned Measure. For the sake of completeness it is also pointed out that L.Gobbi does its utmost to be able to track cookies on its Site. These are updated on a regular basis in the table below, where we give transparency on the cookies directly sent by L.Gobbi and their purposes. With regard to third parties that send cookies through our Site, we provide below links to their respective privacy policies: to these third parties we devolve, as stated above, the responsibility of providing the information and collecting your consent, as required by the Provision. Said responsibility is to be referred not only to the cookies that the third parties send directly, but also to any additional cookies that are sent through our Site by virtue of the use of services from which the third parties themselves benefit. With respect to such cookies in fact, sent by service providers of the aforementioned third parties, L.Gobbi has no possibility of exercising any control and does not know their characteristics or purposes.

Below are links to information about third-party cookies:

Google: policies.google.com/technologies/

In detail, the cookies sent by L.Gobbi through the Site are listed below:

Cookies on the Site

Cookie-related settings

You may block or delete (in whole or in part) technical and functionality cookies through the specific functions of your Browser. Please be advised, however, that not allowing technical cookies may result in your inability to use the Site, view its content and take advantage of related services. Inhibiting functionality cookies may result in some services or certain features of the Site not being available or not working properly, and you may be forced to change or manually enter certain information or preferences each time you visit the Site.

The choices you make with respect to the Site’s cookies will in turn be recorded in a special cookie. Such a cookie may, however, not work properly in some circumstances: in such cases, we recommend that you delete unwelcome cookies and inhibit their use through the functionality of your Browsers as well.

Your preferences in reference to cookies will need to be reset if you use different devices or Browsers to access the Site.

How to View and Change Cookies through the Browser
You can authorize, block, or delete (all or part of) cookies through the specific features of your Browser. For more information on how to set preferences on the use of cookies through your Browser, you can refer to the relevant instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

3. PURPOSE OF PROCESSING

The processing that we intend to carry out, upon your explicit consent where necessary, has the following purposes:
a. To enable the provision of the Services you have requested, namely: access to the restricted area of the Site and the sending of the newsletter;
b. to respond to requests for assistance or information;
c. to fulfill any legal, accounting and tax obligations.

4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF PROCESSING

The legal basis for the processing of Personal Data for the purposes set out in Section 3 (a-b-c) is Article 6(1)(b) of the Regulations as the processing is necessary for the provision of the Services or for the acknowledgment of requests from the data subject. The provision of Personal Data for these purposes is optional but failure to provide it would result in the inability to activate the Services provided by the Site, acknowledge requests or evaluate CVs. With specific reference to the purpose 3.c and the related analysis of social profiles of a professional nature made freely available on the Internet referred to in section 2.b, the legal basis of the processing is Article 6(1)(f) of the Regulations, i.e. L.Gobbi’s legitimate interest in verifying any risks on the candidate’s suitability for the specific open position.
The purpose referred to in section 3.d represents a legitimate processing of Personal Data under Article 6(1)(c) of the Regulations. Once Personal Data is provided, the processing is indeed necessary to fulfill a legal obligation to which L.Gobbi is subject.

5. RECIPIENTS OF PERSONAL DATA

Your Personal Data may be shared, for the purposes set out in Section 3 above, with:
a. parties that typically act as data processors i.e.: i) persons, companies or professional firms that provide assistance and advice to L.Gobbi in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services; ii) parties with whom it is necessary to interact for the provision of the Services (e.g. hosting providers) iii) or parties delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks); (collectively “Recipients“);
b. Subjects, entities or authorities to whom it is obligatory to communicate your personal data by virtue of legal provisions or orders of the authorities;
c. persons authorized by L.Gobbi for the processing of Personal Data necessary to perform activities strictly related to the provision of the Services, who have committed to confidentiality or have an appropriate legal obligation of confidentiality (e.g. employees of L.Gobbi ).

6. TRANSFERS OF PERSONAL DATA

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area. L.Gobbi ensures that the processing of your Personal Data by these Recipients is done in compliance with the Regulation. Indeed, transfers may be based on an adequacy decision, Standard Contractual Clauses approved by the European Commission, or another suitable legal basis. More information is available from L.Gobbi by writing to the following address: L.Gobbi Srl unipersonale – via Vallecalda, 33 – 16013 Campo Ligure (GE) – Italy

7. DATA RETENTION

Personal Data processed for the purposes referred to in section 3(a-b) will be kept for the time strictly necessary to achieve those same purposes. In any case, since the processing is carried out for the provision of Services, L.Gobbi will process Personal Data no longer than the time allowed by Italian law to protect its interests (Art. 2946 c.c. et seq.).
Personal Data processed for the purposes set forth in section 3.d will be retained no longer than the time required by the specific applicable legal requirement or rule.
More information regarding the data retention period and the criteria used to determine this period can be requested by writing to the following address: L.Gobbi Srl unipersonale – via Vallecalda, 33 – 16013 Campo Ligure (GE) – Italy

8. RIGHTS OF INTERESTED PARTIES

Pursuant to Articles 15 et seq. of the Regulations, you have the right to request from L.Gobbi , at any time, access to your Personal Data, to have them rectified or erased or to object to their processing, you have the right to request the restriction of processing in the cases provided for by Article 18 of the Regulations, as well as to obtain in a structured, commonly used and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulations.
Requests should be addressed in writing to L.Gobbi at the following address: L.Gobbi Srl unipersonale – via Vallecalda, 33 – 16013 Campo Ligure (GE) – Italy.
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Garante per la Protezione dei Dati Personali), pursuant to art. 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.

9. CHANGES

This privacy policy is effective as of May 25, 2018. L.Gobbi reserves the right to modify or simply update its content, in part or in full, also due to changes in applicable legislation. L.Gobbi therefore invites you to visit this section regularly to become aware of the most recent and updated version of the privacy policy so that you are always up-to-date on the data collected and the use made of it by L.Gobbi.