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PRIVACY

In accordance with Articles 13 and 14 of General Regulation (EU) 2016/679 (“GDPR”)

This information is provided exclusively for the website https://zencluster.cloud and not for other websites that may be consulted by the user through links.
Its purpose is to provide information on the processing of personal data provided by users at the time of connection and while browsing the Zencluster web pages.
The Data Controller reserves the right to make changes to this policy due to regulatory changes or to its own privacy policy by advertising it to users on the site; the user is therefore invited to periodically check this page. In case of non-acceptance of the changes made to this Privacy Policy, the interested party may request the Data Controller to delete their personal data. Unless otherwise specified, the previous Privacy Policy will continue to apply to personal data collected up to that moment.
If the user is less than 14 years of age, he or she will have to give his or her consent to the services of the information society pursuant to art. 8.1 GDPR and art. 2-quinquies co.1 of Legislative Decree no. 196 of 30 June 2003, as last amended by Legislative Decree 101/2018 (Privacy Code), and will have to legitimise his or her consent to the use of the services of the information society through the authorisation of his or her parents or legal guardian.

1 – DATA PROTECTION

Your personal data will be processed by Sogetel s.r.l., with registered office in Italy, via G. A. Resti 63, 00143 – Rome, Italy, data controller (hereinafter also referred to as the “Titolare” or “SOGETEL“), in full compliance with the provisions dictated by (i) EU Regulation 2016/679 (hereinafter referred to as the “GDPR“), (ii) Legislative Decree No. 196/2003 s.m.i., as last amended by Legislative Decree No. 101/2018 (“Privacy Code“) and (iii) by the provisions of the Guarantor Authority for the protection of personal data (hereinafter, jointly, the “Privacy Law“); this treatment will also be based on principles of correctness, lawfulness, transparency and protection of your privacy and your rights.

2 – NATURE AND CATEGORIES OF THE PERSONAL DATA PROCESSED

The personal data subject to processing by the Data Controller are data of a common nature provided by the user when navigating on the website zencluster.cloud and/or when registering in the reserved areas of the site, except for the application of any specific information.
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.
In particular, like all websites, this site also makes use of log files in which information collected automatically during users’ visits is stored. The information collected could be the following:

      • Internet protocol (IP) address;
      • type of browser and device parameters used to connect to the site;
      • name of the internet service provider (ISP);
      • date and visiting hours;
      • web page of the visitor’s origin (referral) and exit;
      • eventually the number of clicks.

The above information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the owner.
For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with the laws in force, to block attempts to damage the site itself or to cause damage to other users, or in any case harmful or criminal activities. Such data are never used for the identification or profiling of the user, but only for the protection of the site and its users, such information will be treated according to the legitimate interests of the owner.
The information that users of the site will consider to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability for any violation of the law. It is the user’s responsibility to verify that he or she has permission to enter personal data of third parties or content protected by national and international regulations.

With specific reference to Cookies, the Zencluster website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small strings of text used to store certain information that may concern the user, his/her preferences or the Internet access device (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user’s expectations, offering a more personalized browsing experience and storing the choices made previously.
A cookie consists of a small set of data transferred to the user’s browser from a web server and can only be read by the server that made the transfer. It is not executable and does not transmit viruses.
Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent some or all cookies from being saved. However, in this case your use of the website and the services offered may be affected. To proceed without changing the options for cookies, simply continue browsing.

Below are the types of cookies that the site uses:

I- Technical Cookies

There are numerous technologies used to store information on your computer, which is then collected by the sites. Among these, the best known and most widely used is HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications over an electronic network or to the provider to provide the service requested by the customer.
The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of your internet browser. Such deactivation may slow down or prevent access to certain parts of the site.
The use of technical cookies allows the safe and efficient use of the site.
The cookies that are inserted in the browser and retransmitted through Google Analytics or through the statistical service of bloggers or similar are technical only if used for site optimization purposes directly by the site owner, who can collect information in aggregate form on the number of users and how they visit the site. Under these conditions, for analytics cookies, the same rules on information and consent apply as for technical cookies.
From the point of view of duration, we can distinguish temporary session cookies that are automatically deleted at the end of the browsing session and are used to identify the user and therefore avoid login to each page visited and permanent cookies that remain active in the PC until expiry or cancellation by the user.
Session cookies may be installed in order to allow access and stay in the reserved area of the portal as an authenticated user.
They are not stored permanently but only for the duration of navigation until the browser is closed and disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the safe and efficient exploration of the site.

II- Third-Party Cookies

We distinguish between cookies sent to your browser directly from the site you are visiting and third-party cookies sent to your computer from other sites and not from the one you are visiting.
Permanent cookies are often third party cookies.
Most third party cookies are tracking cookies used to identify online behavior, understand your interests and then customize advertising proposals for you.
Analytical third party cookies may be installed. They are sent by third party domains outside the site.
Third party analytics cookies are used to detect information about user behavior on Zencluster. The detection takes place anonymously, in order to monitor performance and improve the usability of the site. Third party profiling cookies are used to create profiles relating to users, in order to propose advertising messages in line with the choices made by the users themselves.
The use of these cookies is governed by the rules prepared by the third parties themselves, therefore, users are invited to read the privacy policy and the instructions to manage or disable the cookies published on the relevant web pages.

III- Profiling Cookies

Profiling cookies are those that create profiles related to the user and are used to send advertising messages in line with the preferences expressed by the user when surfing the web.
When these types of cookies are used, the user must give explicit consent.
The user can also manage cookies through the settings of his browser. However, deleting cookies from your browser may remove the preferences you have set for the site.

Below you will find instructions and links to the cookie management guides of major desktop browsers:

For browsers other than those listed above, you should consult the relevant guide to find out how to manage cookies.

This site also incorporates plugins and/or buttons for social networks in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so that no cookies are set when you access the page, in order to safeguard your privacy. Cookies are only set, if so provided by social networks, when the user makes effective and voluntary use of the plugin. Please note that if you are logged into the social network, you have already consented to the use of cookies transmitted through this site when you subscribe to the social network.
The collection and use of information obtained through the plugin is governed by the respective privacy policies of social networks, to which please refer:

 

3 – PURPOSE AND LEGAL BASIS

The legal basis of the processing is identified in the provision of its services by the Owner, in the management and facilitation of the website, in the management of reserved areas on the site (e.g. https://app.zencluster.cloud/zc/subscription), in your consent, where required and given, to the processing of your personal data.
The processing of your personal data by the Owner is aimed at pursuing the following purposes:

      • processing of information requests: if you decide to contact us using the appropriate e-mail addresses or telephone contacts made available on the site zencluster.cloud, for example through the contact details made available in the “Contacts” area or other contact details in the areas of the site, the personal data provided by you may be processed by the Data Controller to process your request and provide you with the necessary information (legal basis: (pre)contractual purposes);
      • enrolment in the newsletter service (legal basis: contractual purpose, where consent is not required for additional marketing purposes);
      • to manage and respond to requests for information sent by the site’s contact forms (legal basis: (pre)contractual purpose);
      • profiling purposes (legal basis: consensus);
      • direct marketing purposes (legal basis: consent);
      • for the security and proper functioning of the site (legitimate interest);
      • getting anonymous statistics on the use of the website: most visited pages, origin of the visit, time of visit, geographical origin, type of device, operating system and browser used (legitimate interest).

 

4 – NATURE OF PERSONAL DATA CONFERENCE

Apart from that specified for navigation data, the user is free to provide personal data (e.g. to ask for information material or other communications). Failure to provide them may make it totally or partially impossible to obtain what has been requested.

5 – METHODS OF PROCESSING

The Owner carries out the processing of personal data by computer and/or telematic means and with organizational and logical methods strictly related to the pursuit of the purposes indicated in this information notice, as well as adopting appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of personal data, their loss and illicit and incorrect use.
However, the Owner cannot guarantee its users that the measures adopted for the security of the site and the transmission of data and information on the site are able to limit or exclude any risk of unauthorised access or dispersion of data by devices pertaining to the user. For this reason, users of the site are advised to ensure that their computer is equipped with appropriate software for the protection of network data transmission (e.g. updated antivirus software) and that their Internet Provider has taken appropriate measures for the security of network data transmission.

6 – PERIOD OF STORAGE OF PERSONAL DATA

Personal data are kept for the time strictly necessary to achieve the purposes for which they were collected and processed on the basis of the purposes set out in section 3 (“Purpose and legal basis”) of this information document.
Personal data will be kept for the period of time strictly necessary to achieve the above mentioned purposes. In any case, the period of retention of personal data is not longer than 2 years for marketing purposes and 12 months for profiling purposes, unless the deletion of personal data for these purposes occurs earlier for the withdrawal of consent by the person concerned.
Personal data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the purpose.

7 – COMMUNICATION OF PERSONAL DATA

The data collected will not in any way be disclosed or communicated to third parties, except in the cases provided for by the information and / or the law and, in any case, in the manner permitted by it. The data will be processed within the limits and for the purposes described by the owner’s employees and some data processing may also be carried out by third parties, appointed as external data processors, which the owner uses or may use in the management/maintenance of the website and information systems or for the management of contractual relations with the user, the provision of services offered and for organizational needs of its activities, as well as to subjects appointed as external data processors who offer services of sending e-mails and/or support and marketing advice and/or in carrying out market studies. The list of Data Processors may be requested from the Data Controller by sending an e-mail to the address indicated in article 10 below.

8 – DIFFUSION OF PERSONAL DATA

The personal data of the interested party are not subject to disclosure.

9 – TRANSFER OF PERSONAL DATA ABROAD

This site may share some of the data collected with services located outside the European Union. In particular, with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, so no further consent is required. The above mentioned companies guarantee their adherence to the Privacy Shield.
Personal data will not be transferred to third countries that do not comply with the conditions set out in Article 45 et seq. of EU Regulation 2016/679.

10 – RIGHTS OF THE INTERESTED PARTY

The interested parties may exercise their rights recognized by law and, in particular, the right to obtain access to their personal data and their portability (art. 15 and art. 20 GDPR), rectification and/or integration (art. 16 GDPR), cancellation (art. 17 GDPR), limitation of processing (art. 18 GDPR), right to revoke consent (art.7 GDPR) and/or to request compensation and/or to oppose the treatment (art. 21, paragraphs 1 and 2, GDPR), subject to the limits set out in Legislative Decree No. 101/2018, art. 2-undecies (Restrictions to the rights of the data subject) and art. 2-duodecies (Restrictions for reasons of justice). These rights may in fact be subject to certain exceptions and/or limitations (e.g. in order to protect public interests such as the prevention and detection of crimes). Data subjects also have the right to lodge a complaint with the Supervisory Authority, Guarantor for the protection of personal data (Piazza Venezia, 11 – 00187 Rome – PEC: protocollo@pec.gpdp.it).
Where the processing of personal data is based on consent, even where personal data is processed for marketing purposes, the data subject may at any time revoke such consent by sending an e-mail specifying the purpose for which the consent is to be revoked to the address referred to in Article 10 below.
The withdrawal of consent shall not affect the lawfulness of any processing activity based on it prior to its withdrawal.

11 – COMMUNICATIONS AND EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

In order to contact the Owner and to exercise the rights referred to in section 10 (“Rights of the interested party”), you may send a written request, made without formality, to the Owner by sending a communication to the following e-mail address: privacy@sogetel.it.

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