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HOME / PRIVACY POLICY AND COOKIES INFORMATIVE NOTICE

PRIVACY POLICY AND COOKIES INFORMATIVE NOTICE



 
I
Informative notice to clients and users of the Amicucci Group
Amicucci Formazione S.r.l. and Amicucci Creativity S.r.l., with registered office in Civitanova Marche (Macerata) Via Alessandro Volta no. 5/9 – post code 62012 (hereinafter, the "Companies") informs you that it holds your data as personal data in accordance with GDPR 679/2016 and which will proceed to being processed for the purposes and with the methods indicated below.

By processing of personal data we mean any operation or series of operations, carried out even without the aid of electronic tools, concerning the collection, registration, organisation, structuring, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other format for making data available, comparison, interconnection, limitation, cancellation or destruction, even if not registered in a database.

The client acknowledges that this informative notice fulfils the obligation to comply with Article 13 of the GDPR 679/2016 towards the client and users who participate in the use of the Company’s services and to whom the client will release the information contained herein and to acquire the necessary consent on its behalf.
Therefore, we hereby inform you that such data will be processed manually and/or with the support of IT or telematic means for the following purposes.

A. Primary purposes of the processing of personal data and legal basis of processing.

A.1 Pre-contractual and contractual purposes for fulfilment of the contract.

Firstly, the processing of personal data requested that the client is required to indicate, pursues the purposes of making it possible to stipulate a contract with the client for the provision and use - even by individual users of the client - of training products and services (both in classroom sessions and distance learning on FAD e-learning platforms, (hereinafter the "Contract") and to allow the Companies to fulfil their obligations and, before the conclusion of the Contract, according to the defined modalities, the processing of the client's personal data may also pursue pre-contractual purposes, such as responding to specific requests from the Client concerned, for example, and for greater transparency towards the client, the primary purposes of processing related to fulfilment of the Contract (in each phase) can be for the specific purpose of: supply of products and the required training services, maintenance and technical assistance related to these services, management of complaints and/or disputes, prevention/repression of fraud and any illegal activity, storage of personal client and user data, use of personal data for communications regarding the performance of the established contractual relationship, etc.

A.2 Purposes of fulfilment of obligations under the law, regulations or EU regulations.

Secondly, personal data will also be processed to fulfil the obligations established by law, regulations or community legislation and for civil, accounting and tax purposes.

A.3 Purpose to permit the registration of the client on websites for carrying out distance training activities pursuant to the Contract.

Access to and browsing of websites or other electronic and/or telematic platforms (including mobile platforms) where companies provide their training services even at a distance are free but the possibility of benefiting from the aforesaid services is only permitted after client and authorised user registration. The registration process consists in completing a form in which the client (and users authorised by the same) is required to indicate his/her personal data - some of which has to be entered compulsorily - for the activation of authentication credentials (login + password) with which the party concerned can access all areas and training services reserved for registered users.

Therefore, further primary purposes of processing are represented by the need to allow the completion of the required prior registration procedure (also on-line) and the creation of an account and to allow the operators of the websites and platforms of the Companies (or third parties) to generate and subsequently conduct technical and administrative management (including the purpose of providing support and technical assistance upon request) of accounts, client IDs, activation codes, passwords and similar authentication credentials generated during the registration process. These primary and main purposes of data processing of registered clients (and authorised users by the same) include allowing them to benefit, where it is possible to do so, from remote services of pre and post-contractual assistance for the management of each contractual, administrative, technical or legal profile. Regarding this processing, the purpose is also to manage any type of request for assistance - technical, commercial and/or contractual - received by the Companies and reply to clients.

B. Communication and dissemination of personal data for the pursuit of primary processing purposes.

In all the cases described above - and according to the applicable provisions of the Privacy Code - the Concessionaire may communicate personal data to third parties who provide services whose communication is necessary for the performance of the services the Contract concerns [for example: companies that provide services for the management of financial transactions; suppliers of services for installation, assistance and maintenance of IT and telematic systems and systems and of all functionally related services necessary for the performance of the services the Contract concerns; sub-contracting companies for the services necessary for the implementation of the contract management service and management of training services; persons, companies or professional firms that provide assistance, consultancy or collaboration with the Companies in accounting, administrative, legal, tax and financial matters relating to the Contract; companies and institutional parties involved in fraud prevention; service providers aimed at the verification, accuracy and validity of the personal and fiscal data of the client and authorised users of the same.

Furthermore, for the pursuit of the primary purposes, the data may be disclosed to any other third party when the communication is mandatory by law (for example: investigation of telematic platforms by judicial police or requests from the Judicial Authority) or to properly fulfil contractual services (e.g.: credit institutes for profiles related to collections and payments), pre-contractual or post-contractual (e.g.: technical assistance and request for support or sending of complaints submitted by the client).

The following are the parties or categories of parties that my become aware of the personal data of the user appointed officers or agents:

  • Company staff;
  • External suppliers that provide the Company with support services, appointed as data processors;
  • Professionals and consultants (e.g.: law firms, accountants, audit companies), appointed as data processors.
Personal data will not be disclosed by the companies, it being agreed that where the client - for example in the use of training services on electronic platforms - proceeds to the dissemination of personal data of authorised users, this processing will be carried out directly as an independent data controller by the client.

B.1. Compulsory or optional nature of consent for the pursuit of the primary purposes regarding the processing of personal data.

In all the cases described above in sections A and B (for disclosure to third parties) - and according to the applicable regulations of the GDPR - the Companies are not obliged to acquire specific consent to processing in relation to clients and users. In fact, all the above-mentioned processing pursues primary purposes, excluding the need to acquire the specific consent of the party concerned, either because the processing is necessary to fulfil an obligation under the law, regulations or Community legislation, or because the processing is necessary to fulfil obligations arising from a contract to which the party concerned is party or to fulfil, before the conclusion of the contract, specific requests of the party concerned.

Where the client does not intend to provide the personal data requested and necessary on the basis of the above, it will consequently be impossible to proceed with the execution of the Contract and the activation of training services, making it impossible to register and use all the services for which registration and/or the provision of data are technically and contractually obligatory.

 
C. Purpose of the processing of personal data - Purposes of a promotional, advertising and marketing nature.

Personal data collected (from clients and users) may also be processed, either in hard-copy format (e.g.: filling out forms, coupons and similar hard-copy files at the Company's physical premises and subsequently used electronically on the official websites of the Company) using automated/IT methods, for the following purposes: sales promotion, advertising communication, solicitation and purchasing behaviour, market research, surveys (also by telephone, online or by filling out forms), statistical processing (in identifying format) , and marketing in a broad sense (including prize events, games and competitions or other reward initiatives not included in the subject referred to in Presidential Decree 430/2001) for the offer of products and/or services relating to the Companies.

By granting consent these promotional, commercial and marketing purposes in a broad sense of processing (including the consequent management and administrative activities) are specifically acknowledged and expressly authorises the Data Controller to process the data for the specific purpose.

 
C.1 Communication and dissemination of personal data for the pursuit of secondary processing purposes.

For the purposes referred to in point C, the Companies hereby specify that the data could also be communicated to third-party commercial partners. The consent to processing for marketing purposes by the data controllers - where provided by the party concerned - does not also cover the different and further marketing processing represented by the communication to third parties of the data for the same purposes.
To proceed with such external communication (currently not carried out by the Companies, but possible in the future), further, separate, additional, documented, express and completely optional informed consent is required.

C.2 Compulsory or optional consent for the pursuit of promotional, advertising and marketing purposes.

Note, particularly, the fact that the provision of personal data to the companies and the provision of consent to processing for marketing purposes and separate consent regarding disclosure to third parties for processing for marketing reasons (should this be carried out in the future) for the purposes and with the methods described above are absolutely optional and optional (and in any case may be revoked without formalities even after the provision of services by sending an e-mail to dpo@amicucciformazione.com) and failure to confer it will not result in any consequences other than the impossibility for the Companies and any third parties to continue with the above-mentioned marketing activities.

In case of refusal to marketing consent, there will not be any interference and/or consequence on the contractual or other relationships in force.

D. Data retention and security measures.

The data will be kept for the period of time defined by the relevant legislation, mainly on servers at the offices of the Companies and/or on servers of external suppliers. In any case, the retention period for the client's data will only be the time necessary to pursue the above-mentioned purposes and will be the same as the duration of the service relationship between the client and the Company, without prejudice to the need for contractual, administrative or tax. accounting or legal obligations following termination of the relationship. As soon as the above-mentioned obligations are fulfilled, the data will in any case be deleted, subject to storage according to the different legal terms of the document and/or document containing the data.

We also inform you that this data will be collected, processed and stored in full compliance with the provisions of the GDPR 679/2016 and - for the companies Europcar International SASU and Europcar Information Services - based on applicable local regulations.

The data will also be processed in full compliance with the self-regulation rules regarding the processing of personal data contained in the deontological codes currently in force. E. Data Controller and Data Processors.

The following are the identifying details of the Companies as the data controllers of the client’s data (in some cases the Companies may be joint data controllers of the same data and the processing, in other cases they can assume the status of independent and separate data controllers):
Amicucci Formazione S.r.l.
Amicucci Creativity S.r.l.
Administrative Office: Civitanova Marche (Macerata) Via Alessandro Volta n.5 / 9 - Postal Code 62012
PEC: amicucciformazione@pec.it
The Data Controller has appointed a DPO in the person of Luciani Eleonora to whom to apply to exercise the rights of the GDPR 679 / 2016: dpo@amicucciformazione.com The updated list of data processors can be found at the indicated location.

F. Exercise of rights by clients.

At any time it will be possible - without any formality - to exercise the rights referred to in Articles 15 to 22 of the GDPR 679/2016.

 
II
Disclaimer for use of audio video content
Pursuant to Article 13 of the GDPR 679/2016, we inform you that the personal data will be processed and stored by AMICUCCI FORMAZIONE SRL with registered office in VIA ALESSANDRO VOLTA 5/9 - CIVITANOVA MARCHE (MC). We also inform you that your personal data will be processed in compliance with the methods defined in article 5 of the GDPR 679/2016 which provides that the data must be processed in a lawful, correct and transparent way in relation to the party concerned; collected for specified and legitimate purposes and subsequently processed in a way that is not incompatible with these purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; exact and, if necessary, updated; kept in a format that allows the identification of data parties for a period of time not exceeding the achievement of the purposes for which they are processed; processed in such a way as to ensure the adequate security of personal data, including protection, through appropriate technical and organisational measures, against unauthorised or unlawful processing and from accidental loss, destruction or damage. We inform you that your data will be processed only with your consent, which is free and optional. Failure to consent will make it impossible to carry out what the specified activities. AMICUCCI FORMAZIONE SRL carries out the processing directly, through parties in its own organisation, or using external parties for the realisation of the previously mentioned purposes. These parties will process your data in accordance with the instructions received as outsourced operators or agents. The complete list of the above-mentioned parties can be requested directly from AMICUCCI FORMAZIONE SRL, with registered office in VIA ALESSANDRO VOLTA 5/9 - CIVITANOVA MARCHE (MC), which is the data controller. Your data will be kept until consent is revoked.

We also inform you that as the party concerned you have the right to access, rectify, delete, limit, or oppose processing, as well as the possibility of withdrawing consent at any time without prejudice to the lawfulness of the processing and to submit a complaint to the Authority pursuant to Articles 15 to 22 of GDPR 679/2016, addressing the request to the Data Controller.
 
III
Application information and curricula
Pursuant to Article 13 of the GDPR 679/2016, we inform you that the data provided to us by filling out this form will be processed by Amicucci Formazione Srl to evaluate your candidacy. We also inform you that the personal data referred to you will be processed in compliance with the methods defined in Article 5 of the GDPR 679/2016 which provides that the data must be processed in a lawful, correct and transparent way towards the party concerned;
collected for specified and legitimate purposes and subsequently processed in a way that is not incompatible with those purposes; adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed; exact and, if necessary, updated; kept in a format that allows identification of data parties for a period of time not exceeding the achievement of the purposes for which they are processed; processed in such a way as to ensure adequate security of personal data, including protection, through appropriate technical and organisational measures, against unauthorised or unlawful processing and from accidental loss, destruction or damage. The provision of data is based on the consent of the party concerned and it is free and optional. Failure to consent will make it impossible to register, make purchases and/or access the reserved area. Your data will be kept for 1 year from receipt of your application. Our company carries out the processing directly, through parties in its own organisation, or by availing itself of parties external to the company for the realisation of the purposes previously indicated. These parties will process the data in accordance with the instructions received from the Company as outsourced or appointed agents. The complete list of the above-mentioned parties can be requested directly from Amicucci Formazione based in Civitanova Marche (MC) Via Alessandro Volta 5/9, which is the data controller. Your data will not be disseminated. We also inform you that as the party concerned you have the right to access, rectify, delete, limit, oppose processing as well as the possibility of withdrawing consent at any time without prejudice to the lawfulness of the processing and to submit a complaint to the Authority pursuant to Articles 15 to 22 of the GDPR 679/2016, addressing the related request to Eleonora Luciani as Data Protection Officer (DPO) at the following address dpo@amicucciformazione.com
 
IV
Privacy information on the operation of cookies
Below we inform you in a transparent manner about the operation on this website www.skilla.com (hereinafter referred to as the "Site") of so-called cookies.

Definition of “cookies”. Cookies are short fragments of text (letters and/or numbers) that allow the web server to store in regard to the client (the browser, e.g. Internet Explorer, Chrome, Firefox, Opera, etc.) information to be reused during visits to the site (session cookies) or later, even after days (persistent cookies). Cookies are stored, according to user preferences, by the single browser on the specific device used (computer, tablet, smartphone).

Similar technologies, for example web beacons, transparent GIFs and all forms of local storage introduced with HTML5, may be used to gather information on user behaviour and use of services.

A cookie cannot retrieve any other data from the user's hard drive or transmit computer viruses or acquire email addresses. Each cookie is unique to the user's web browser. Some of the functions of cookies can be delegated to other technologies. With the term 'cookies' we refer to cookies and all similar technologies.

Based on the characteristics and use of cookies, various types of cookies can be distinguished:

Technical cookies strictly necessary. These cookies are essential for the proper functioning of a website that are used to manage various services related to websites (for example, logins or access to the reserved functions in the sites). The duration of cookies is strictly limited to the work session or they may have a longer period of stay in order to remember the choices of the visitor. Deactivation of strictly necessary cookies may compromise the user experience and navigation of the website. Analytics cookies and services. These cookies are used to collect and analyse traffic and the anonymous use of a website. These cookies, even without identifying the user, allow, for example, detecting whether the same user returns to connect at different times. They also allow you to monitor the system and improve its performance and usability. The deactivation of these cookies can be performed without any loss of functionality and will be discussed later in detail.

Profiling cookies (not operational on this site). These are permanent cookies for the identification (anonymously or not) of user preferences and improve their browsing experience. For more information on these cookies not used by the website, visit the appropriate section on the website www.garanteprivacy.it/cookie

Purposes of the processing and purposes of technical session cookies. The cookies used on the Site are for the sole purpose of performing computer authentication or the monitoring of sessions and the storage of specific technical information concerning users accessing the servers of the Data Controller that manages the Site. In this view, some activities on the Website cannot be performed without the use of cookies, which in such cases are therefore technically necessary. For example, access to any areas of the Site and the activities that may be carried out therein would be much more complex to carry out and less secure without the presence of cookies that allow identifying the user and maintaining identification in the context of the session.

Pursuant to Article 122, section 1, of the Privacy Code (in the formulation currently in force following the entry into force of Legislative Decree 69/2012), "technical" cookies can be used even without the consent of the party concerned. Among other things, the same European body that brings together all the Privacy Authorities of the various Member States (the so-called "Article 29" Group) has clarified in Opinion 4/2012 (WP194) entitled "Exemption from consent for use of cookies" that they are cookies for which it is not necessary to obtain the prior and informed consent of the user:
  • 1. cookies with data compiled by the user (ID session), the duration of a session or persistent cookies limited to a few hours in some cases;
  • 2. authentication cookies, used for authenticated services, for the duration of a session;
  • 3. security cookies focused on users, used to identify authentication abuses, for a limited persistent duration;
  • 4. session cookies for multimedia players, like cookies for "flash" readers, lasting for one session;
  • 5. session cookies for load balancing, lasting for one session;
  • 6. persistent cookies for the personalisation of the user interface, the duration of a session (or not much longer);
  • 7. cookies for sharing content through third party social plug-ins for members of a social network that have logged in.

The Data Controller therefore informs you that only technical cookies (such as those listed above) are used on the Website to navigate, since they allow essential functions such as authentication, validation, management of a browsing session and prevention of fraud and allow, for example: identification of whether the user has had regular access to areas of the site that require prior authentication or user validation and management of sessions related to various services and applications or data retention for secure access or fraud control and prevention functions.

For the highest level of transparency, we list below a series of technical cookies and cases of specific activities on the Site:
  • cookies directly implanted in the user's/contracting party's terminal (which will not be used for other purposes) such as session cookies, authentication cookies, cookies for multimedia content like flash players that do not exceed the duration of the session, cookies for personalisation purposes (for example, the choice of navigation language, call ID and password complete with the typing of the first characters, etc);
  • cookies used to statistically analyse access/visits to the site (so-called "analytics" cookies) that exclusively pursue statistical purposes (and not even profiling or marketing purposes) and collect information in aggregate format without the possibility of identifying individual users. In these cases, since the current legislation requires that analytics cookies be provided to the person concerned with a clear and adequate indication of the simple ways to oppose (opting-out) their system (including any mechanisms of anonymization of cookies), we would like to specify that you can deactivate the analytics cookies as follows: open your browser, select the settings menu, click on the internet options, open the privacy tab and choose the desired cookies blocking level. If you wish to delete cookies already saved in memory, simply open the security tab and delete the history by checking the "delete cookies" field.

Cookies belonging to third parties By visiting a website you can receive cookies from sites managed by other organisations ("third parties") that may reside in Italy or abroad.

An example of this on most websites is the presence of YouTube videos, Google APIs, use of Google Maps, and the use of "social plugins" for Facebook, Twitter, Google+ and LinkedIn. These are parts of visited pages generated directly by the above-mentioned sites and integrated into the page of the host site. The most common use of social plugins is aimed at sharing content on social networks in order to increase the visitors’ user experience.

The presence of these plugins involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by "third parties" is managed by the relative information to which reference is made. To ensure greater transparency and convenience, the following are the web addresses of the various informative notices and methods for managing cookies, specifying that the data controller is not responsible for the operation on this website of third-party cookies.

Google informative notice: on the use of data regarding the link http://www.google.com/policies/technologies/cookies/ and informative notice with a link http://support.google.com/analytics/answer/6004245
Google (configuration): the general out-out guide for Google services (Maps, YouTube…) is available on the following website http://support.google.com/accounts/answer/61416?hl=it
Facebook informative notice: https://www.facebook.com/help/cookies/ and https://it-it.facebook.com/about/privacy/cookies
Facebook (configuration): access your account. Privacy section. Or follow the various guides on the website, for example https://support.mozilla.org/en-US/kb/disable-third-party-cookies
Twitter informative notice: https://support.twitter.com/articles/20170514
Twitter (configuration): https://twitter.com/settings/security and https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter
Linkedin informative notice: https://www.linkedin.com/legal/cookie-policy
Linkedin (configuration): https://www.linkedin.com/settings/
Google+ informative notice: http://www.google.it/intl/en/policies/technologies/cookies/
Google+ (configuration): http://www.google.it/intl/en/policies/technologies/managing/

Analytics cookies

The Site uses the Google Analytics service but the intervention is planned to make the IPs anonymous with the tools offered by Google. See the Google Cookie Information Notice for Google Analytics at the following link http://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage usage and explore the method by which Google - third party - uses the your users' data at https://support.google.com/analytics/answer/6004245.

As clarified by the General Provision of the Privacy Code on cookies of 8 May 2014, analytics cookies are assimilated to technical cookies when used directly by the site operator to collect information, in aggregate format, on the number of users and how they visit a site: these are functions and purposes of processing on this Site.

You can still opt-out by visiting the website http://tools.google.com/dlpage/gaoptout?hl=en and exercising the opting out function. You can also deny consent and block third-party cookies through plugins for browsers, searching on Google "block and delete third-party cookies", there are many guides that differ depending on the operating system and browser used.

Responsibility for the operation of Third Party Cookies

Reference is made in this regard to the provisions of the General Provision of the Privacy supervisory authority on cookies of 8 May 2014:
“There are many reasons why it is not possible for publishers to have an obligation to provide information and to obtain consent for the installation of cookies in the context of their sites, even for those installed by" third parties ". Firstly, the publisher should always have the tools and the economic and legal capacity to take charge of the obligations of third parties and should therefore also be able to check, from time to time, the correspondence between what was declared by the third parties and the purposes they really pursue through the use of cookies. This is made very difficult by the fact that the publisher often does not directly know all the third parties who install cookies through their sites and, therefore, even the logic underlying the related processing. Moreover, not infrequently, there are parties that act as concessionaires between the publisher and the third parties, making it very difficult for the publisher to control the activity of all the parties concerned. Third-party cookies may then be modified over time by third-party suppliers and it would be impractical to ask publishers to keep track of these subsequent changes”.

As indicated by the Privacy supervisory authority, this site does not have the ability to control third-party cookies where third-party services are used (YouTube, Google Maps, "social buttons") which are the sole responsibility of third parties.
In addition, the user is reminded to delete and block the operation of cookies at any time, also using plugins for the browser and changing the settings as indicated in the various manuals contained in browsers.

Mandatory or optional consent for the operation of cookies that do not pursue marketing purposes.

It is not mandatory to acquire consent to the operation of only technical or third-party cookies or analytics similar to technical cookies. Their deactivation and/or denial of their operation will make it impossible to properly browse the site and/or the inability to use the services, pages, features or content available therein.

Data Controller and Data Processors.

The identifying details of the Company as Data Controller of the data party are as follows:

Amicucci Formazione S.r.l.
Registered office: Via Alessandro Volta 5/9 – 62012 Civitanova Marche - Macerata
Tel. +39. 0733 886401
e-mail: info@amicucciformazione.com

The updated list of data processors (if appointed) can be found at the headquarters of the above-mentioned company.

Exercise of rights by the party concerned.

With particular reference to users' rights regarding cookies, some links are provided below for additional information:

AboutCookies.org: for more information about cookies and how they affect the browsing experience.
Youronlinechoices.com: for more detailed information on cookies, best practices and the use of targeted advertising through the use of cookies. The Cookies section on www.garanteprivacy.it/cookie to know the best practices provided by the supervisory authority for the protection of personal data.

At any time, it is possible - without any formality - to exercise the rights pursuant to Article 7 of the Privacy Code (also using the specific application request format made available by the supervisory authority on www.garanteprivacy.it), which is shown in full below. The exercise of these rights is not subject to any format constraints.

At any time, it is possible - without any formality - to exercise the rights referred to in Articles 15 to 22 of the GDPR 679/2016.

Would you like more information?

Call us on 0733 886401
or send us an email

I the undersigned state to having read the Information Notice and give specific consent

to the processing of personal data for the Marketing Purposes (Paragraph C of the Information Notice).

  to the communication to third parties for the Marketing Purposes (Paragraph C.1 of the Information Notice).