Privacy policy

Privacy policy of the site Regulation EU n. 2016/679 (GDPR)
Information on the processing of personal data according to EU Regulation no. 2016/679 (GDPR). The information must not be considered valid for other websites that may be consulted through links on the internet sites owned by the owner and not only for www.itinerario.info, which is not to be considered in any way responsible for third party websites.



Mr. Alex Huayanay, CEO of Essetre Srl, owner of Itinerario, with registered activity in Via Luigi Sacco 3 – 20146 Milano (MI) Italy, (hereinafter, ”Owner“), as data controller, informs you pursuant to art. 13 D.Lgs. 30.06.2003 n. 196 (hereinafter, ”Privacy Code“) and art. 13 EU Regulation n. 2016/679 (hereinafter, ”GDPR“) that your data will be processed in the manner and for the following purposes:

1. Object of the treatment
The Data Controller processes personal, identifying and non-sensitive data (for example, but not limited to, name, surname, company name, address, telephone number, e-mail address – hereinafter, ”personal data” or even ”data“) communicated by you on the occasion of registration / interaction / compilation of data on the website of the Owner:

• http://www.itinerario.info/
• (hereinafter, ”Site“) and specifically to take part in opinion polls and approval, fill out the registration form through the Website at events organized by the owner, fill out the contact form on the website of the Data Controller, the request on -line of clarifications or requests for support and for sending newsletters.

2. Purpose of the treatment
Your personal data are processed:

A) without your express consent (Article 24 letter a), b), c) Privacy Code and art.6 lett.b), e) GDPR), for the following Service Purposes:

• manage and maintain the Site or allow access to dedicated areas;
• allow you to use any of the Services requested by you;
• participate through the Website to initiatives organized by the Data Controller (for example, events);
• process a contact request;
• for administrative-accounting activities in general;
• fulfill the obligations established by law, by a regulation, by the community legislation or by an order of the Authority or by requests of the Italian or foreign government or by the Italian Chamber of Commerce;
• prevent or discover fraudulent activities or malicious activities harmful to the Site;
• exercise the rights of the owner, for example the right to exercise a right in court.

B) Only subject to your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Other Purposes:

• send you e-mail surveys of opinion and approval, newsletters and / or invitations to events or sign up for events of which it is part or that organizes the owner.

3. Processing methods and data retention period
The processing of your personal data is carried out by means of the operations indicated in art.4 of the Privacy Code and art.4 n.2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are processed either on paper or electronic and / or automated, through the use of a website hosted on the server of the data controller or on sites of external companies that allow the data controller to offer its services (such as for example, to offer online chat support or file files for the customer by providing his e-mail and name for the download). The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality report and for no more than 2 years from the collection of data for the Other Finances. In compliance with the provisions of art.5 paragraph 1 lettere) of Reg. UE 2016/679 the personal data collected will still be stored in a form that allows identification of data subjects for a period of time not exceeding the achievement of the purposes for which the personal data are processed.

4. Safety
The Owner has taken a variety of security measures to protect your data against the risk of loss, misuse or alteration. In particular: has adopted the measures referred to in Articles 32-34 of the Privacy Code and art.32 GDPR; uses the data encryption technology established by the AES Standards (BCrypt) and the protected data transmission protocols known as HL7 and HTTPS for safer communications.

5. Access to data
Your data may be made accessible for the purposes referred to in art.2.A) and 2.B):

• to employees and collaborators of the Data Controller, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
• to third-party companies or other subjects (web site provider, cloud provider, e-payment service provider, suppliers, hardware and software service engineers, shippers and carriers, credit institutes, professional offices, etc.) that perform outsourcing activities on behalf of the Data Controller, in their capacity as data controllers.

6. Data communication
Without your express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art.6 lett.b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art.2.A) to Supervisory Bodies, Judicial Authorities as well as to all the other subjects to whom the communication is obligatory by law for the accomplishment of the working purposes, such as in the registration phase of a web domain or the rent of a server on behalf of the client. It is however guaranteed that your personal data will never be made public on the website of the owner.

7. Data transfer
The management and storage of personal data will take place in Europe, on servers located in Italy, of the Owner and / or third-party companies also abroad, appointed and duly appointed as Data Processors for the use of the services requested. The personal data provided, may be transferred abroad within or outside the European Union, within the limits and under the conditions set out in Articles.44 and ss. of the 2016/679 EU Regulation, in order to comply with purposes related to the transfer.

8. Nature of providing data and consequences of refusing to answer
The provision of data for the purposes referred to in art.2.A) is mandatory. In their absence, we can not guarantee you neither the registration to the Site nor the services of the art.2.A). The provision of data for the purposes referred to in art.2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you can not receive e-mail invitations to events, newsletters and opinion polls and approval. In any case, you will continue to be entitled to the Services referred to in art.2.A).

9. Rights of the interested party
In your capacity as interested parties, you have the rights set forth in art.7 of the Privacy Code and art.15 GDPR and precisely the rights of:

• i. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
• ii. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art.5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;
• iii. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right;
• iv. to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, you also have the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

10. How to exercise rights
You can exercise your rights at any time by sending:

• a registered letter to the business office, with address declared in incipit;
• an e-mail to info (at) itinerario.info

11. Minors
This Website and the Services of the Data Controller are not intended for minors under the age of 18 and the Data. In the event that information on minors were unintentionally registered, the Data Controller will delete them in a timely manner, at the request of users.

12. Owner, manager and agents
The Data Controller / Data Processor (pursuant to articles 4, 24 and 28 of EU Reg. 2016/679) is Essetre Srl, (owner of Itinerario), in the person of Mr. Alex Huayanay, CEO of Essetre Srl, with registered activity in Via Luigi Sacco 3 – 20146 Milano (MI) Italy. The updated list of data processors and data processors is kept at the Data Controller’s headquarters.

13. Changes to this Information
This information may change. 

—— FURTHER POLICIES AND AGREEMENTS ——-

COPYRIGHT OF TEXTS AND CONTENT
Graphics, layouts, texts, videos and code of this site can not be replicated, even partially, on other websites, mailing lists, newsletters, paper magazines and cdrom without the prior authorization of the data controller, regardless of the purposes of profit.

LINK POLICY
The authorization, also to make links to our site, must be requested in writing by e-mail and is considered accepted only with a specific consent of the data controller, always in writing. Silence does not give rise to any authorization. The trademarks mentioned and the programs on the site are exclusive to their respective owners in compliance with the declared licenses.