Privacy

Information on Personal Data Processing
21 Partners S.p.A. (hereinafter, “Company”) provides this information in accordance with Article 13 of Regulation (EU) 2016/679 (hereinafter “GDPR”), in relation to the protection of natural persons with regard to personal data processing, in order to let you understand the purposes and methods of processing of personal data that you may communicate when navigating this web site (hereinafter “Site”).
Please note that this information notice refers only to the Site and not to any third party web sites that may be reachable by the user using links present on this Site.

Categories of data processed
Navigation data
During their ordinary operations, the information systems and software procedures used to make this Site function acquire certain personal data whose transmission is inherent to the use of Internet communication protocols. This is information that is not collected to be matched with identified data subjects but which, due to its nature, could, through processing and association with data held by third parties, be used to identify the users. This data category includes, for example, IP addresses or domain names of the computers utilised by users who connect to the Site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method utilised to make the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error etc.) and other parameters relating to the user’s operating system and IT environment. These data are only used to gather anonymous statistical data about use of the Site and to check that it is working properly. They are cancelled immediately after processing.

Data provided voluntarily by Users
If email is sent voluntarily to the addresses appearing on the Site, the sender’s email address will be acquired – in order to respond to requests – as will any other personal data included in the message. Specific summary information notices are also provided or shown in sections of the Site relating to particular on request services and may be subject to the consent of the data subject.

Cookies
In accordance with the Order of the Personal Data Protection Authority no 229 of 8 May 2014 on the “Identification of simplified methods for the provision of information and the acquisition of consent to the use of cookies”, the Company informs users about the use of navigation cookies on this Site. This information notice refers solely to the Site and not to third party web sites that may be reachable by users following links present on this Site.

What are cookies?
Cookies are small files that are sent to the browser in use and saved on your device when you visit an Internet site like 21partners.com. Cookies enable the Site to function efficiently and improve performance. They provide information to the Site owner for statistical or advertising purposes, mainly in order to customise your navigation experience by remembering your preferences. The Site uses several types of first party cookies (prepared and managed by 21 Partners S.p.A.) and third party cookies (prepared and managed by third parties in accordance with their own privacy policies and not under the control of 21 Partners S.p.A.). The table below summarises the types of cookie used.

Cookie type Function
Technical cookies (session or navigation) Guarantee normal navigation and utilisation of the web site.  They are intended to optimise web site navigation while making it functional.
Functional cookies These are needed in order to provide services specifically requested by the user.
First party analytics cookies These are utilised and realised exclusively by 21 Partners S.p.A. in order to gather information, in aggregate and anonymous form, on the number of users and on how users visit the Site.
Third party analytics cookies
(e.g. Google Analytics)
21 Partners S.p.A. has adopted appropriate tools to ensure that processing with these cookies is performed for statistical purposes only.

Enabling and disabling cookies in a browser
Most browsers are configured to accept, control or even disable cookies by means of the available settings. We remind you, however, that the disabling of navigation or functional cookies may cause the Site to function unsatisfactorily and/or limit the service that we offer.
The following links should be followed to manage cookies in the following browsers:
Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
Safari: https://support.apple.com/kb/PH19255?locale=en_US
Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=fr&hlrm=en

Purposes and legal basis of processing, nature of data provision and consequences of refusal
The Company will process your data in order to facilitate navigation and to provide any services requested by you using the forms available on the Site. Other than as specified for navigation data and technical cookies, in the Site sections set up for particular services available at your request, you are free to provide your personal data for the purposes stated in the respective information notices. Refusal to provide such data may make it impossible to obtain the service requested.

Data retention period
Personal data collected through use of the Site shall be processed for the amount of time strictly necessary to fulfil the purposes for which the data were gathered and, at the end of this period, for the amount of time stated by applicable laws and regulations.
For further details, see the information notices for specific services.

Communication of data and categories of recipients
Solely for the purposes stated above, all data collected and processed may be communicated to internal figures authorised to act as data processors in light of their respective duties, as well as to external parties to whom it is necessary to communicate the data. If these recipients process data on behalf of the Company, they shall be designated as data processors by means of a specific contract or other legal document.
For further details, see the information notices for the specific services.

Transfer of data to a third country and/or to an international organisation
For strictly organisational requirements, some of your personal data might be transferred to non-EU countries because the Data Controller uses Cloud based services offered by service providers selected from those who provide appropriate guarantees, as required by Article 46 of the GDPR.

Rights of data subjects
You have the right (Articles 15-22 of the GDPR) to ask our Company to access your personal data and to amend them if inaccurate, to delete them or limit their processing if requirements are met. You may also obtain the portability of the data provided by you only if subject to automated processing based on your consent or on the contract. You also have the right to withdraw the consent given for processing purposes. This shall not affect the legitimacy of any processing performed up until that point. Finally, you have the right to complain to the relevant regulatory authority, the Garante per la protezione dei dati personali (“the Personal Data Protection Authority”).
For further details, see the information notices provided for specific services.

Data Controller
The controller of your personal data is 21 Partners S.p.A. which may be contacted at the following email address: 21partners@legalmail.it
Latest update: May 2018.

This information notice is subject to amendment. Therefore, we advise visiting this web page regularly and considering the most recent version of the information notice reported herein.