Ricasoli Group is an investment company with a primary focus marketing performance and concierge services. Ricasoli Group considers the protection of personal data to be of fundamental importance, and wishes to ensure that the processing of such personal data, carried out through the Website (as defined below), takes place in full compliance with the safeguards and rights recognized by the applicable laws and regulations in the field of personal data protection, as applicable to Ricasoli Group from time to time (the “Privacy Laws”).
II. Data controller and other personal data recipients
Ricasoli Group. – with registered office in Senato street 29, Milan, Italy, in the person of its actual legal representative, assumes the role of data controller (the “Data Controller”) for the purposes of this Policy. The Data Controller indicates the following e-mail address for the appropriate communications: email@example.com. Your personal data may be shared with:
appointed personnel of Ricasoli Group and possibly its professionals who are committed to confidentiality or have an adequate legal obligation of confidentiality; subjects delegated and/or appointed by the Data Controller to carry out specific activities (including technical maintenance interventions on the systems); individuals, companies or professional firms that provide assistance and support to the Data Controller to ensure the proper functioning of the Website; subjects, bodies or authorities to whom the communication of your personal data is mandatory by virtue of legal provisions and/or orders of the competent authorities.
III.Type of data processed and purposes of the processing relating to navigation on the Website
The Website offers informative contents. While browsing the Website, information about the user can be acquired in the following ways:
The computer systems and software procedures used to operate the Website may acquire during their normal operation some data, the transmission of which is implicit in the use of Internet communication protocols.
This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and the addresses of websites from which access or exit was made, information on the pages visited by users within the Website, the access time, the time spent on the single page, the analysis of the internal path and other parameters relating to the operating system and the user’s IT environment. These technical/IT data
are collected and used exclusively in an aggregate and non-identifying manner and could be used to ascertain responsibility in the event of hypothetical computer crimes against the Website.
b.Data provided voluntarily by the user
This is all the personal data freely released by the user on the Website, for example, contacting Ricasoli Group via e-mail. This data will be processed exclusively to respond to the request in accordance with this Policy. The data will be kept for the time necessary to provide the requested information and to manage any disputes possibly arising from such request. Personal data voluntarily provided by the user will be communicated to third parties only if the communication is necessary to fulfil the user’s requests.
IV.Legal bases and Purposes of processing
The Data Controller processes personal data deriving from the navigation of the Website and those that the user has voluntarily provided in connection with the use of the Website itself. In particular, personal data may be used for the following purposes and in accordance with the following legal bases: guarantee and verify the correct functioning of the Website, as well as improve the user’s browsing experience. The data collected for the purposes specified above are processed mainly in an anonymized form. They are used solely for the purpose of obtaining statistical information on the use of the Website and to check its correct operation and are deleted every 6 months. The data could also be used to ascertain responsibility in case of hypothetical computer crimes against the Website. The legal basis for the processing of navigation data is the legitimate interest of the Data Controller to allow the correct use of the Website contents.
V. Methods of data processing and data retention
The processing of personal data is carried out mainly using electronic procedures and means, without excluding manual processing, for the time strictly necessary. Personal data will be processed by the Data Controller limited to what is necessary for the pursuit of the described purposes. The provision of users’ personal data is optional, but failure to provide them could make it impossible to guarantee a correct browser experience on the Website. Personal data is stored on servers located in Switzerland. For users located in the European Union, please note that Switzerland has been included by the EU Commission in the list of countries that provide for an adequate level of protection of personal data. Users’ personal data are processed by the indicated subjects, in accordance with the provisions of the Privacy Laws. In particular, to ensure the security of your data taking into account the state of the art and the implementation costs, as well as the nature, object, context and purposes of the processing, as well as the risk for users’ rights and freedoms, the Data Controller has adopted appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
VI. Rights of the data subjects
With reference to their personal data, users can exercise their rights enshrined by the
Privacy Laws, and within the limits included therein. To exercise such rights and/or to obtain more information on the processing activities, it is possible to contact the Data Controller by sending an e-mail to: firstname.lastname@example.org.
VII. Changes to the Policy and updates
This Policy is applicable to the Website from its publishing. This Policy is published in September 2021 and may be subject to changes over time. The entrance into force of new laws and/or regulations, as well as the constant examination and updating of the general conditions of use of the Website, may result in the need to revise this document. It is therefore possible that this Policy undergoes changes over time and we therefore invite each user to periodically consult this page.