PRIVACY NOTICE
pursuant to Articles 13 and 14 of the Regulation (EU) 2016/679



Oltrefrontiera Progetti S.r.l. respects the persons with whom it comes into contact and processes personal data for the performance of its activities, in compliance with EU Regulation 2016/679 on the protection of personal data (hereinafter “Regulation” or “GDPR”) and with the current national law including the Legislative Decree no. 196/2003 as amended by the Legislative Decree no. 101/2018 (hereinafter “Privacy Code”) and D. Lgs.101/2018, any provisions issued by the Supervisory Authority, where applicable, and the Workers’ Statute (L. 300/1970). To confirm this commitment and to implement the rules that protect the processing of personal data, we provide below the information that allows you to exercise, easily and in an informed manner, your rights under current legislation in force.

Data Controller (who determines the purposes and means of the processing of personal data)
Oltrefrontiera Progetti S.r.l., with registered office in Milan, Corso Venezia no. 36, tax code and registration number in the Register of Companies of Milan, Monza, Brianza, Lodi: 02776890135.

Definitions
The terms “Processing”, “Data Controller”, “Data Processor”, “personal data” (including “special categories of personal data”), “Data Subjects”, “third parties”, “recipients”, “third countries”, “personal data breach”, “supervisory authorities”, are used in the sense and with the meaning attributed to them by the current provisions of the legislation on personal data to which reference is made.
In particular, pursuant to Article 4 of the GDPR, “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “Personal data” means any information relating to an identified or identifiable natural person (“Data Subject”).

Data source (what is the origin of the processed personal data)
The data are collected through the computer systems and software procedures used to operate and optimize the website http://www.oltrefrontieraprogetti.it.

Type of personal data (which are the data subject to the processing activity)
We mainly process the following types of so-called common personal data that concern you as a user of the website:

• IP address and other parameters relating to the operating system and computer environment of the user
• data provided by you during the contact phase.

Purposes (what is the purpose of personal data processing)
We will process your data in order to:
a) make the website accessible by enabling basic functions such as navigation and page visualization. The following are used for this purpose: i. Technical cookies
b) recall information that affects the way the website behaves or looks, as the preferred language. The following are used for this purpose: i. Functional cookies;
c) handle any requests you may have;
d) collect information on the use of the site. Analytical cookies are used for this purpose: these are Google Analytics cookies that collect information about your use of the site. This information is not collected to be associated with identified individuals, but, by their very nature, could, through processing and association with other data held – even by third parties – allow the identification of users of the site;
e) to allow you to share the contents of the site through social networks. They are used for this purpose: Social media cookies: these are third-party cookies that allow users to interact with social networks (e.g. Instagram, Facebook) and share site content through those social media networks.

Legal basis of processing (lawfulness of processing)
The processing of personal data for the purposes indicated under letter b) and d) of the abovementioned paragraph are based on your consent, and the purposes indicated under letter a) and c) are based on the execution of pre-contractual measures taken at your request or of a contract to which you are a party.

Need to provide the data (what does the refusal to provide the data involve)
The provision of your data is necessary for the pursuit of the purposes indicated, the failure, partial and / or inaccurate provision of data during contact will not make it possible to give response to any of your requests.
If you object to the registration of certain cookies, some functions of the web pages may not be performed correctly.

Processing methods (how personal data are processed)
Your personal data will be processed with electronic and manual systems, according to the principles of fairness, integrity and transparency provided by applicable law and protecting the confidentiality of your data through technical and organizational security measures to ensure an adequate level of security (for example, preventing access to unauthorized persons except in cases required by law, or ensuring the ability to restore access to data in the event of physical or technical incidents).

Categories of Recipients (to whom personal data are communicated)
We do not disclose your personal data to unspecified third parties but, in order to achieve the purposes indicated, we may disclose them to specific categories of recipients who have an engagement or have a legal obligation to confidentiality, including authorized and duly trained employees; contractors, consultants and third-party service providers (e.g. providers of the website; providers of ICT tools and services), who process your personal data in their capacity of Data Processors on behalf of Oltrefrontiera Progetti S.r.l.; Autonomous Controllers, public or private, to whom the communication of data is instrumental or mandatory (e.g. judicial authorities); other third parties in the context of a corporate transaction such as a sale, transfer, reorganization, merger or acquisition.
Your personal data are mainly processed within the European Union. However, this site may share some of the data collected with services located outside the European Union, in particular with Google, regarding the service of Google Analytics. The transfer, in this case, is authorized by specific decisions of the European Union and the Supervisory Authority, in particular the decision 1250/2016 on Privacy Shield. Google guarantees its compliance with the Privacy Shield. In the event of further transfers outside the European Union, the Data Controller hereby ensures that such transfers will be made in accordance with the applicable legal provisions, subject to verification of the existence of an adequacy decision by the Commission of the personal data protection system of the non-EU country importing the data, or the adoption of binding corporate rules or the adoption of the standard contractual clauses provided for by the European Commission.
For any further information on the transfer of your personal data, you can send an email to the address: [email protected].

Rights (which rights can exercise)
You may exercise, at any time, the rights provided for by the Regulation (Articles 15-21) and by the national law in force, including:
• to receive confirmation as to whether or not the personal data are being processed and where is the case having access (right of access);
• to update, amend, and/or rectify the personal data (right to rectification);
• to request the erasure or the restriction of processing of the data processed unlawfully or to those whose retention is not necessary anymore for the purposes of collection (right to be forgotten and right to limitation);
• to oppose the processing (right to object);
• when the processing is carried out on that basis, to withdraw the consent, without any effect on the lawfulness of processing;
• to receive the personal data provided to the Data Controller and transmit those data to another Data Controller (right to data portability);
• to lodge a complaint to the Supervisory Authority or filing an appeal to the Judicial Authority in the event of unlawful data processing;

To exercise these rights and obtain further information on the processing of your personal data, you can send an email to [email protected].

Retention period (for how long the personal data shall be stored)
The data will be retained for the time necessary to fulfil the purposes indicated (e.g. for the duration necessary to manage your request, for the duration of the session of navigation on the website), except for legal obligations and the need to ascertain, exercise or defend a right in court. Once the above mentioned retention terms expire, the personal data will be destroyed, deleted or made anonymous, compatibly with the technical procedures of cancellation and backup.

Learn more about the cookies used and how to disable them
Without prejudice to your right to refuse to consent the use of technical and of pre-installed cookies to remember your preferred settings, the user can oppose the registration of cookies on his hard disk by configuring his browser to disable cookies. Below are the methods offered by the main browsers:
– Internet Explorer > http://windows.microsoft.com/it-it/windows7/how-to-manage-cookies-in-internet-explorer-9
– Chrome > https://support.google.com/chrome/answer/95647?hl=it
– Firefox > https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
– Safari > http://support.apple.com/kb/HT1677?viewlocale=it _IT

In particular, the site uses Google Analytics Cookies > https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
The user can selectively disable (opt out) the collection of data by Google Analytics by installing on his/her browser the appropriate component provided by Google (opt out) > https://tools.google.com/dlpage/gaoptout

With regard to social cookies, if the user decides to share some content through one or more social networks (Facebook, Instagram, Pinterest) the site may access some information if the user has activated the sharing of account data with third party applications. You can disable the sharing of your account data with third party applications by accessing your account settings. For more information, please visit the website of the social network(s) you are a member of.

If you object to the registration of certain cookies, some functions of the web pages may not be performed correctly. Useful information to limit the functionality of cookies can be found at the following link: http://www.youronlinechoices.com/ Further information on the cookies used by the site and their characteristics are given in the table below.

Cookie Name Type of Cookie (analytical, profiling, technical) Duration of the Cookie First Party Third Party
_ga Analytical 2 years No Yes
_unam Functional 1 year No Yes
_smToken Technical Session Yes No