Cookies & Privacy policy

1. PRIVACY POLICY

Information pursuant to art. 13 of the EU General Data Protection Regulation 2016/679 (GDPR)

A. Data Controller and contacts

The Data Controller of this website is Studio Ghitti & Associati (SGA), with registered office in Bergamo – Via Zelasco n. 1, contactable at the following e-mail address: This email address is being protected from spambots. You need JavaScript enabled to view it..

B. Types of personal data processed

When browsing the Site or using the Services, the following types of personal data are processed:

1. Browsing data

Data automatically acquired by the Site's computer systems, such as IP addresses, domain names, URIs of the resources requested, time and methods of requests, size of the files obtained and other parameters relating to the user's operating system and device.

These data are used to:

• ensure the proper functioning of the Site;
• obtain aggregated and anonymous statistical information;
• ascertain any liability in the event of wrongdoing.

2. Data provided voluntarily by the user

Information provided by the user to browse the website and apply voluntarily by sending his/her curriculum vitae. In this case, the data that may be processed include personal data, contact details and any information contained in the CV (please do not include data in the CV that is not relevant to the selection purpose, unless strictly necessary).

C. Purposes and legal bases of the processing

Personal data are processed for the following purposes, based on the relevant legal ground:

• Management of the Site and Services: enables navigation and use of the Site's features. Legal basis: performance of pre-contractual measures (Art. 6(1)(b) GDPR).
• Handling user requests: to respond to requests for information or contact. Legal basis: performance of pre-contractual measures (Art. 6(1)(b) GDPR).
• Personnel selection: to assess applications received through the Site. Legal basis: performance of pre-contractual measures (Art. 6(1)(b) GDPR).
• Compliance with legal obligations: to comply with regulatory obligations or requests from authorities. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
• Website Improvement: aggregate statistical analysis and improvement of services. Legal basis: legitimate interest of the Data Controller (Art. 6(1)(f) GDPR).

The provision of data is optional; however, failure to provide it may make it impossible to deliver the Services.

D. Data retention periods

The processing is carried out using IT and/or telematic tools, in compliance with the principles of lawfulness, fairness, transparency and data minimisation. Data will be stored according to the following criteria: for the time necessary to provide the requested services; to comply with legal obligations; for applications, for a period generally not exceeding 12 months, unless otherwise required. At the end of the retention period, the data will be deleted or anonymised.

E. Recipients of personal data

Personal data may be shared with:

• Authorized personnel: Employees and collaborators bound by confidentiality obligations.
• Data Processors: Third parties managing the technical and operational activities of the Site (the full list is available upon request).
• Competent bodies or authorities: In the cases provided for by law.

F. Transfer of data outside the EU

No data transfers outside the EU territory are envisaged. If necessary, the data may be transferred to recipients in countries outside the European Economic Area; in this case such transfers will be carried out in compliance with the GDPR, using guarantees such as Standard Contractual Clauses or adequacy decisions of the European Commission.

G. Rights of the data subject

The data subject has the right to access, rectify, or delete personal data; restrict or object to processing; request data portability; lodge a complaint with the Italian Data Protection Authority (art. 77 GDPR).

To exercise these rights, you may contact the Data Controller using the contact details provided in this Privacy Policy.

H. Changes to the Privacy Policy

Any changes will be published on the Site and will take effect immediately. Users are encouraged to review this section periodically to stay informed of any changes.

2. COOKIE POLICY

Definitions, characteristics and application of the legislation

Cookies are small text files that the websites visited by the user send to and store on their computer or mobile device, to then be transmitted back to the same websites upon the next visit. Thanks to cookies, a website remembers the user's actions and preferences (such as login data, chosen language, font size, other display settings, etc.) so that they do not have to be entered again when the user returns to that website or browses from one page to another. Cookies are therefore used to perform computer authentication, session monitoring, and storage of information regarding the activities of users accessing a website and may also contain a unique identification code that enables tracking of the user's navigation within the website for statistical or advertising purposes. While browsing a website, users may also receive on their computer cookies from websites 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 functioning of the website itself.

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: so-called session cookies, which are automatically deleted when the browser is closed; and so-called persistent cookies, which remain on the user's device until a predetermined expiry date.

Under the legislation currently in force in Italy, the use of cookies does not always require the user's express consent. In particular, "technical cookies" do not require such consent, namely those used solely for the purpose of transmitting a communication over an electronic communications network, or strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies essential for the operation of the website or necessary to perform activities requested by the user.

Among the technical cookies that do not require express consent for their use, the Italian Data Protection Authority (see the Provision "Identification of simplified procedures for the information notice and acquisition of consent for the use of cookies" of 8 May 2014 and subsequent clarifications, hereinafter the "Provision") also includes:

• navigation or session cookies (for authentication purposes),
• functionality cookies, which allow users to browse according to a series of selected criteria (for example, language, selected products for purchase) in order to improve the service provided, 
• "analytics cookies" where used directly by the website operator to collect aggregated information on the number of users and how they visit the website itself.

Conversely, "profiling cookies," namely those intended to create user profiles and used to send advertising messages in line with the preferences expressed by the user while browsing the web, require the user's prior consent. 

Types of cookies used by the Website

We have classified the cookies we use according to their purpose as follows:

1) TECHNICAL COOKIES:

a. functionality cookies

b. analytics cookies

2) THIRD-PARTY COOKIES

1) TECHNICAL COOKIES:

a.  FUNCTIONALITY COOKIES

We use these cookies to provide services or remember your settings, in order to improve your visit and browsing experience on our website. The installation of such cookies does not require the user's prior consent.

Here is a list of the cookies:

b. ANALYTICS COOKIES

These cookies collect anonymous information on how our website is used and allow us to better understand users and improve the functioning of the website, as well as make content more interesting and relevant to users' preferences. Analytics cookies are considered technical cookies where they are used directly by the website operator to collect aggregated information on the number of users and how they visit the website itself: the installation of such cookies does not require the user's prior consent. Analytical cookies are sent either by the Website itself or by third-party domains external to the Website, in our case by Google Analytics.

Here is a list of these cookies:

2) THIRD-PARTY COOKIES

"Third-party" cookies are related to services provided by third parties: they are used for various purposes such as analyzing the performance of marketing campaigns and/or delivering personalized advertising on our website and partner websites. This activity is called retargeting and is based on browsing activities, such as searched destinations, viewed facilities, and more.

The third party provides these services in exchange for information relating to the user's visit to our website. Consequently, third-party cookie providers are also required to comply with the applicable legislation. For this reason, we refer users to the web pages of the third-party websites, where users can find cookie consent forms and related privacy notices: in our case, this concerns Google Analytics.

Google Analytics, a web analysis service provided by Google, Inc. ("Google©"), uses cookies for its operation, and the information generated by the cookie regarding visitors' use of the Website is transmitted to Google and stored on Google's servers. Google uses this information for the purpose of tracking and examining the use of the Website, compiling reports on website activity for Website operators, and providing other services related to website activity and Internet usage. Google may also transfer this information to third parties where required by law, or where such third parties process the information on Google's behalf.

You may refuse the use of cookies by selecting the appropriate settings on your browser, but this may prevent you from using all the features of the Website. By using this Website, you consent to the processing of your data by Google in the manner and for the purposes set out above.

For more information on data usage and processing by Google, please refer to the information available at: http://www.44c28697135b262bde92280084af3f1f-gdprlock/privacypolicy.html.

Here is a list of these cookies:

Social plugins

These "social buttons" are visible on our website to allow content sharing through social networks, including LinkedIn. Cookies are placed by these platforms on our website to allow them to collect information about your browsing activities. At present, the website only features the LinkedIn plug-in (for further information on cookie management and LinkedIn's privacy policy, please refer to the relevant sections of the website https://www.f54db463750940e0e7f7630fe327845e-gdprlock/).

Web beacons

Web beacons are tiny invisible images that SGA may use in its newsletters. These images allow the identification of statistical information regarding newsletter usage and enable SGA to improve this service. If you wish to prevent such statistical information from being collected, you must disable HTML in your email system so that SGA newsletters are read only as text. All newsletters sent by SGA also contain a link allowing recipients to unsubscribe.

Your choices regarding cookies

You may select a feature whereby your computer will warn you whenever a cookie is being set, or you may choose to disable all cookies. You can select these features through your browser settings. Each browser is slightly different, so we invite you to consult your browser's "Help" menu to identify the correct way to modify cookie settings.

If you choose to disable cookies, you will not have access to many features that make your experience on our website more efficient, and some of our services may not function properly. 

Your online preferences through interprofessional websites

We invite you to visit the website Youronlinechoices, promoted by professional digital advertising companies grouped within the European Digital Advertising Alliance (EDAA) and managed in Italy by the Interactive Advertising Bureau Italia (http://www.iab.it/).

There, you can learn about the companies participating in this platform and choose to accept or reject the cookies they use to tailor advertisements likely to be displayed on your device based on your browsing information: http://www.youronlinechoices.com/it/

Best regards,

SGA – Studio Ghitti & Associati