POLICY COOKIES

WHAT ARE "COOKIES"
Cookies are files of text and numbers that are installed in the memory of one's browser while browsing a website via any device that allows connection to the Internet (pc, smartphone or tablet).
Individuals through Cookies can be associated with online identifiers produced by the devices, applications, tools and protocols they use, examples of cookies are IP addresses, temporary markers or other identifiers. Such identifiers can leave traces that, particularly when combined with unique identifiers and other information received by servers, can be used to create profiles of individuals and identify them.

The information encoded in cookies can include personal data, such as an IP address, user name, unique identifier, or e-mail address, but it can also contain non-personal data, such as language settings or information about the type of device a person is using to browse the site.

Cookies can therefore perform important and diverse functions, including tracking sessions, storing information about specific configurations regarding users accessing servers, facilitating the enjoyment of online content etc. They can, for example, be used to keep track of items in an online shopping cart or information used to fill out a computer form.

Cookies can be stored permanently on the device used for browsing (so-called "persistent cookies"), until a predetermined expiration date (minutes, days, years), or they can be automatically deleted when the browser is closed (so-called "session cookies").
Cookies can be installed by the website visited by the user (the so-called "first-party cookies"), or they can be installed by other websites (the so-called "third-party cookies").

TYPES OF COOKIES AND THEIR PURPOSES

1) Cookies and other technical identifiers (art. 122 c. 1 Legislative Decree 196/03)
They are The cookies that allow the transmission of a communication on an electronic communication network so those that allow the navigation of the site DOES NOT REQUIRE THE CONSENT of the USER

2) First and third party analytics cookies
First and third-party analytics cookies are those used to ensure and facilitate the activities strictly necessary for the operation of the Site for the normal navigation of the site and allow its related functionalities (such as allowing, for example, to authenticate to restricted areas, to save the browsing session, browsing preferences, to save products in the shopping cart, to remember some selected criteria such as language, to manage the distribution of traffico, etc.) and to collect some information in aggregate (anonymous) form about users.
They are equated with technical cookies (and therefore NO USER CONSENT is required) only when:
- they are used only to produce aggregate statistics and in relation to a single site or mobile application;
- at least the fourth component of the IP address is masked for those of third parties;
- the third parties refrain from combining such analytics cookies with other processing (customer files or statistics of visits to other sites, for example) or passing them on to third parties.

3) Profiling cookies and other tracking identifiers with NON-TECHnical function.
They are used to trace specific actions or recurring behavioral patterns in the use of the offered functionalities (groups) back to determined, identified or identifiable subjects in order to group the different profiles within homogeneous clusters of different width, so that it is also possible to modulate the provision of the service as well as to send targeted advertising messages, i.e. in line with the preferences expressed by the user in the context of web browsing.
Among these third-party cookies, there are those that allow users to interact with social networks (Facebook, Twitter, YouTube, Vimeo, etc.) and in particular to share site content through these channels.

COOKIES USED ON THE SITE
The site does not use profiling cookies for the purpose of sending advertising messages;

1) Cookies and other technical identifiers

2) First- and third-party analyitycs cookies assimilated to technical cookies

3) Profiling cookies and other tracking identifiers with NON-TECHnical function

It should be noted that third-party cookies fall under the direct and exclusive responsibility of the third party itself. It follows that third-party cookie providers are also obliged to comply with the relevant regulations. For this reason we refer to the links to the web pages of the third party's site, where the user can find the forms for collecting consent to cookies and their related disclosures.

DISCLOSURES. Ex Art 13 AND 14 REG UE/679/2016.

This information is provided pursuant to Art. 13 et seq EU Reg. 679/2016, exclusively for the website https://softgenia.com and not also for other websites that may be consulted by the user through links available on the website itself.

The texts, information, and other data published or accessible through forums on this website are for informational purposes only and do not have an official character, except where otherwise provided for under current legislation.

Softgenia Srl assumes no responsibility for services offered by third parties with which the Site has activated a link, and for any other content, information or anything else contrary to the laws of the Italian State present in the resources of third parties linked to the attached links.

DATA CONTROLLER
The Data Controller is Softgenia Srl, based in Viale Montenero, 70 Milan, P.Iva n. 13220190964 Registration R.E.A. of MI - 2710671. Pec softgeniasrl@onepec.net

DATA PROTECTION OFFICER
The Data Protection Officer is Eleonora Cerofolini, based in Mercato San Severino Province: SA, P.Iva n. IT04846501213 contactable at the email address leandra_ele@libero.it

LEGAL BASIS OF THE PROCESSING.
The legal basis related to the management of cookies is exclusively the CONSENT of the USER.

OBJECT-PURPOSES AND MODALITIES OF THE PROCESSING
In the tables above are detailed for each cookie, the object, purpose and mode of processing.

DATA ACCESS AND COMMUNICATION
The data collected using cookies may be processed by employees and collaborators of the Owner in their capacity as authorized processing subjects and/or system administrators.

The data may also be processed by our firm that performs on our behalf tasks of a technical, graphic and reporting nature, which Softgenia Srl has appointed as external data processor ex art 28 GDPR.

PLACE OF PROCESSING
The management and storage of personal data will take place on servers located within the European Union of the Data Controller and/or third party companies appointed and duly appointed as Data Processors. Currently, our servers are located in Italy. The data will not be transferred outside the European Union. It is in any case understood that the Data Controller, should it become necessary, will have the right to move the location of the servers to Italy and/or the European Union and/or countries outside the EU. In this case, the Data Controller assures you as of now that the transfer of data outside the EU will take place in accordance with the applicable legal provisions by entering, if necessary, into agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided for by the European Commission and requesting your explicit consent.

The Processing of Personal Data will take place at the premises of the data controller as well as at OVHCloud's servers https://www.ovhcloud.com/it/personal-data-protection/- located in France.

TRANSFER AND DISSEMINATION OF DATA
Softgenia Srl does NOT make any transfer of data, nor dissemination of the same.

RIGHTS OF THE DATA SUBJECT

As a data subject, you have the rights set forth in Article 15 of the GDPR, namely the rights to:
A) Obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet registered, and their communication in intelligible form;
B) To obtain the indication:
- Of the origin of the personal data;
- Of the purposes and methods of the processing;
- Of the logic applied in case of processing carried out with the aid of electronic instruments;
- Of the identification details of the data controller, the data processors and the designated representative pursuant to Article 5, paragraph 2 Privacy Code and Article 3, paragraph 1, GDPR; and of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as designated representative in the territory of the State, data processors.
C) Obtaining:
- The updating, rectification or, when interested, the integration of data;
- The cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected or subsequently processed;
D) Object, in whole or in part:
- For legitimate reasons to the processing of personal data concerning him/her, even if pertinent to the purpose of collection;
- Where applicable, you also have the rights under Articles 16-21 GDPR (Right to rectification, right to be forgotten, right to restrict processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority.

E) To revoke any consent to the processing of your data, at any time, without affecting the lawfulness of the processing based on the consent given before revocation.

As provided by the Data Protection Authority, consent given for the conduct of marketing activities with automated contact methods (by way of example sms, mms, fax, phonics, e-mail, web applications) also extends to traditional contact methods (paper mail or telephone call with operator). Similarly, your objection to the conduct of marketing activities using automated contact methods also extends to traditional contact methods. This is without prejudice to your right to provide consent or to exercise your right to object in relation to only one of the two ways of carrying out marketing activities.

To exercise your rights, you may send a message to the e-mail box softgeniasrl@onepec.net
Without prejudice to any other administrative or jurisdictional recourse, You have the right to lodge a complaint with a Supervisory Authority if You believe that the processing concerning You violates the EU Privacy Regulation. We will comply within 30 days of receipt of your request. In case of non-compliance with Your request, in the same 30 days, We will inform You of the reasons for the non-compliance and of the possibility of proposing a complaint to a Control Authority, which for the Italian territory is the Guarantor for the Protection of Personal Data according to the modalities provided on the website www.garanteprivacy.it