Privacy policy
In this section, in accordance with the European legislation introduced by EU Regulation 679/2016 and with the Italian legislation (Legislative Decree no. 196/2003), information is provided regarding the processing of personal data of Users who consult the pages of the website www.conciergevolution.it (hereinafter: “Website”) or who use the services made available on it (hereinafter: “Users” or “Interested Parties”).
This information is provided exclusively for the Site and not also for any other websites that the user may consult via links within the Site.
Data Controller
The Data Controller of the personal data of users of the Site www.conciergevolution.it is the Company RBH Consulting s.r.l.s RBH Consulting srls with registered office in Via Terenzio 7 – postcode 00198 Rome and operational office in Via Carlo Alberto 37A – postcode 00185 Rome. VAT no 1671193002 – www.conciergevolution.it – e-mail: info@conciergevolution.it.
E-mail to contact the owner and request the deletion of your data, if collected, with your consent: info@conciergevolution.it.
A – Type of data processed
- Identification data
In accordance with the European legislation introduced by EU Regulation 679/2016, consultation of the Site may entail the processing of data capable of directly or indirectly identifying a natural person such as: name, surname, e-mail address, telephone number, IP address.
The Site does not require the Data Subject to provide so-called “special” data, i.e., in accordance with the provisions of the GDPR (art. 9), personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the person’s health or sexual life or sexual orientation. In the event that the service requested requires the processing of such data, the data subject will be informed in advance and asked to give his explicit consent.
- Browsing data
Browsing data are data acquired automatically by the systems and programmes responsible for the operation of the Site and are necessary for the use of web services [e.g. IP addresses, the browser used, the domain names of the systems used by users to connect to the web portal, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit 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].
This data is acquired even in the absence of registration with the Site or a request for information.
Surfing data are used exclusively in an aggregate manner to draw up anonymous statistics on consultation of the Website and to check its correct operation and do not allow the users concerned to be identified.
They may, however, be used to ascertain liability in the event of computer crimes committed against the website.
III. Data provided voluntarily by the user
Personal data provided voluntarily by the User (such as name, surname, telephone number, e-mail address) for the purpose of sending messages to the Website and/or making use of the services made available are used for the sole purpose of responding to the User’s needs and to comply with legal obligations.
The legal basis for such processing is the fulfilment of the services inherent to the requests made, as well as compliance with legal obligations.
The information that the User of the Site decides to make public by means of the services and tools made available to him/her, is provided by the User knowingly and voluntarily, exempting the Site from any liability in respect of any breach of law.
It is the User’s responsibility to check that he/she has permission to enter personal data of third parties or content that is protected by national and international regulations.
- Data collected through analytical cookies
The Site also acquires data relating to the User through the use of cookies.
For more information on the data processed through cookies, the types of cookies that are active and how to deactivate them, please refer to the cookie policy.
These cookies are used to track the User’s browsing preferences and to collect statistical data. The user can deactivate these cookies by accessing the settings of their browser, as indicated in the Site’s cookie policy.
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B – Purpose of processing
The personal data collected are used to
– allow Users to take advantage of the services made available on the Site
– allow the Company to analyse requests received and any reminders
– respond to requests for information and assistance made by the User on the Site
– obtain anonymous statistical information on the use of the web portal
– checking the proper functioning of the web portal;
– ascertaining liability in the event of hypothetical computer crimes to the detriment of the website;
– compliance with any other legal obligation not included in the above purposes.
Data may only be communicated following a request by the Judicial Authority within the terms of the law.
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C – Legal basis of processing
The legal basis for the processing of personal data is the performance of the services inherent to the relationship established by signing the Terms and Conditions, the consent of the data subject, compliance with legal obligations and the legitimate interest of the Data Controller in carrying out processing necessary for such purposes.
- Execution of a contract
The Controller processes Personal Data relating to the User when the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures.
- Consent of the data subject
The optional, explicit and voluntary sending of electronic mail, messages or any type of communication addressed to the addresses indicated on this Site entails the subsequent acquisition of the sender’s address, telephone number or any other personal data that will be used to respond to requests. Such processing is carried out on the basis of the consent of the person concerned.
It is ensured that such processing will be based on the principles of lawfulness, fairness, transparency, appropriateness, relevance and necessity referred to in Article 5(1) of the GDPR. Specific summary disclosures will be progressively reported or displayed on the pages of the sites set up for particular on-demand services.
III. Fulfilment of legal obligations
Personal data may be processed without the consent of the data subject in the event that the Data Controller needs to fulfil a legal obligation.
- Legitimate interest of the Controller
The Controller processes Personal Data relating to the User where the processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
- Optional provision of data
Apart from what is specified for the fulfilment of the contract or legal obligations, for cookies and for navigation data, the User is free to provide or not to provide his/her personal data. However, failure to provide the data may result in the impossibility of obtaining the service.
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D – Modalities and duration of processing
Personal data are processed using IT tools and in accordance with EU Regulation No. 679/2016.
The data processed will be stored for the time necessary for the purposes described in this information notice and, therefore, for the minimum time necessary or until explicitly requested by the data subject and in any case within the time limits imposed by law.
The Data Controller undertakes to adopt all appropriate security measures to prevent the loss and alteration of personal data, as well as any unlawful and unauthorised use thereof.
The data shall be processed exclusively by subjects authorised by the Data Controller, including possible data processors, representatives and public entities for the fulfilment of obligations provided for by law, who carry out their respective processing activities as autonomous data controllers.
The subjects authorised by the Data Controller who may process data include, by way of example: commercial and legal department collaborators, as well as third-party technical service providers, hosting providers and IT companies (this list is not exhaustive). The processed data will not, however, be disclosed to unspecified recipients.
The security of the information collected cannot be guaranteed against hacker attacks and, in general, against violations of the security rules put in place for data protection.
In the event of attacks or violations, however, the same will be communicated to those concerned and to the competent authorities in accordance with the law.
E – Place of processing
Processing relating to the services of the web portal is carried out by staff identified and expressly designated according to the specific purposes of the services requested and subscribed to.
For the processing in question, the Data Controller may avail itself of the help of external companies, forwarding agents, consultants, case managers, consortia, software and service providers operating, through identified and appointed personnel, within the scope of the intended purposes and in such a way as to guarantee maximum data security and confidentiality. In other cases, the personal data collected will not be disclosed to third parties, except with the express consent of the data subject, except in cases where disclosure to third parties is necessary to comply with obligations imposed by laws, regulations or provisions of supervisory authorities, or is essential to protect the rights of other users or of the website itself.
Personal data will be processed and stored, solely for the above-mentioned purposes and for safe keeping and storage, on remote servers operated by industry-leading providers who ensure compliance with high standards of data protection.
This may involve the transfer of data to countries outside the EU, where all or part of such servers may be located.
In particular, personal data may be transferred outside the European Union to the company “WordPress” (https://it.wordpress.org/about/privacy/), an e-commerce plug-in used by the Site operated by the Controller.
The processing and storage of the data by the aforementioned provider will take place to a third country that is “adequate” within the meaning of the decision taken by the European Commission, including in particular the decision for the adequacy of the protection provided by the Canadian Personal Information Protection and Electronic Documents Act or Privacy Shield certification (USA), or on the basis of a contractual obligation or standard contractual clauses approved by the European Commission, or binding corporate rules approved through the specific procedure set out in Article 47 GDPR.
For the transfer of data to non-EU countries, it is generally not necessary to wait for the national authorisation of the Garante. However, authorisation from the Garante will still be required if a data controller wishes to use specific contractual clauses that have not been recognised as adequate by a decision of the European Commission or administrative agreements concluded between public authorities.
F – Rights of data subjects
During processing, the data subject may exercise the following rights at any time
– to obtain confirmation as to whether or not such data exists and, if so, to know its content and origin
– verify the accuracy of the data; request the correction of inaccurate data, the integration of incomplete data or the updating of outdated data
– obtain the restriction of processing, where one of the hypotheses provided for in Article 18 GDPR applies;
– request the deletion of data processed in breach of the law, or in the presence of one of the other conditions set out in Article 17(1)(a), (b), (c), (e) and (f) GDPR
– to object in any case, for legitimate reasons, to their processing, or to object to their processing in the other cases provided for in Articles 21(2) and (3) and 22 GDPR;
– withdraw at any time their freely given consent to the processing of personal data for the purposes specified below;
– obtain the release of the personal data undergoing processing in a format compatible with standard IT applications, in order to allow their transfer to other platforms of your choice, without any impediment to the direct transmission of the processed data to another Data Controller, where such direct transmission is technically feasible (so-called right to data portability).
Requests concerning the exercise of the aforementioned rights should be addressed to the Data Controller by e-mail (romebesthouse@gmail.com).
In the event of failure or partial response by the Data Controller to the aforementioned requests, the data subject shall have the right to lodge a complaint with the Garante per la protezione dei dati personali (www.garanteprivacy.it) or take legal action within the terms and according to the procedures provided for under Articles 77 et seq. of EU Regulation 2016/679 (GDPR).
G – Updates to the policy
Future regulatory updates could lead to the modification of the current information notice, uploaded on the Site on __.__.2022.
In the event of a change, the Data Controller will give notice thereof on the Site.