Privacy Policy

Information concerning the processing of personal data, in accordance with article 13 of Legislative Decree no. 196/20003

In accordance with D.Lgs. June 30, 2003, No. 196 and subsequent changes, we hereby supply you all due informations concerning the purposes and methods for your personal and sensitive data processing in our possession.

This information is not valid for other web sites which might be visited through links contained in all the web sites of data controller’s domain name. The data controller shall not be considered responsible for third parties’ web sites. 

This privacy policy is given pursuant to art. 13 d. lgs. 196/2003 and it’s inspired also to Recommendation n. 2/2001 adopted by Data Protection European Authorities on the 17th of May 2001, in order to identify minimum requirements for on line personal data collection, and in particular, methods of data processing, terms and nature of underwriting, and also in deference to European Directive 2002/58/CE, updated with Directive 2009/136/CE related to Cookies.

 

1. DATA CONTROLLER, pursuant to Article 28 of the Italian Data Protection Code is Sato Group - Via Oratorio S.Francesco n° 5, Tel. +39.090.2925510 Fax +39.090.2925520 info@satogroup.com, in person of its legal representative Dott. Matteo Colombo.

DATA PROCESSOR, pursuant to Article 29 of the Italian Data Protection Code, is the Head of Privacy Area.

 

2. CATEGORIES OF PROCESSED DATA 

Personal data and identification data.

Personal data shall mean any information related to natural person that is or can be identified, even indirectly, by reference to any other information, including a personal identification number . Identification data shall mean personal data allowing a subject to be identified directly (for example, name, surname, place and date of birth, address, email address, telephone number, etc.).

Surfing data

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. These pieces of information are not collected to be associated with identified interested parties, but, through elaborations and associations with data held by third parties, due to their own nature, may allow the user’s identification.

This data category shall including IP addresses or computers’ domain names used by users who surf the present website, the URI-mapped addresses (URI stands for Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, and so on) and other parameters related to the operating system and to the computing environment of the user. 

These data are exclusively used in order to obtain anonymous statistics related to website’s use and to control the correct functioning.  These data are immediately delete after processing.

Judgment defence

The User's Personal Data may be used by the Data Processor for legal defense in judgment or in the preparatory phases of the judgment, in order to defense Data Processor’s rights in case of improper use of this website or to solve matters related to an improper use of services provided by the Data Processor.
The data could be used to determine the responsibility in case of computer crimes against the website.

Maintenance - The User's Personal Data may be treated with additional methods and objectives related to system maintenance.

Data provided voluntarily by the user

Sending explicit voluntary and optional emails to the addresses listed on the present website entails the subsequent acquisition of the sender email address , necessary to reply to the user’s request, and also of any other personal data.

Specific policies - Specific policies  related to specific matters may be presented in the different pages of the present website, in connection with particular services or processing of data provided by the user. 

Cookies

The specific policy regarding cookies is available to the following link: cookies policy.

 

3. Purposes of data processing for which you grant consent where required (Article 23 D. Lgs. 196/03.)

Voluntarily-provided personal and sensible data shall be processed for following purposes, unless otherwise notified: 

• to surf the current internet website;

• to answer to your contact request and to send you the required information;

• for mailing list subscription;

• in dedicates areas, to fill in the form with the required personal data;

• for administrative and accounting activities in general. Data processing for administrative and accounting purposes are those related to organizational, administrative, financial and accounting activities regardless of the nature of data processed. In particular, internal organizational activities, those following contractual obligations’ fulfilment and information activities are related to these purposes.

 

4.Methods of data processing - Data Retention

The personal data processing will be carried out by electronic, automated and / or manual instruments, with methods and tools to ensure maximum security and confidentiality, by persons authorized to do so in compliance with the requirements of Art. 31 and following of D. Lgs 196/03. The personal data will be kept for a period not exceeding the purposes for which the data were collected and subsequently processed.
Data processing related to web services offered by this website will be physically hosted in Italy by Third Companies.

Labor Project srl uses the service "Cloud SaaS " hosted by third company, NWeb srl - email up in Milan and Cremona whose data centres are allocated in Italy. Thanks to reports Labor Project srl may know, for example: the number of unique visitors, the page openings, the unique “clickers” and clicks ; devices used to read the message ( IPhone , Blackberry , Nokia ... ); the operative systems used to read the message (Windows , Apple , Linux , Android ...); detail on the activity of individual users for at least 90 days; pending users who have not yet confirmed their subscription; emails sent by date / hour / minute and sending; email delivered and not delivered; forwarded emails; list of unsubscribed users for newsletters service; users who opened an email or clicked on a single link, in real time; users with some problems in displaying the message; link tracking , i.e. the number of clicks on the link of the message; click tracking, that is who clicks a link and which link has been clicked; graphical map of the links to view the area that has received most interest; quality benchmarks relating to the sector to compare, and possibly improve, the results of communications.

 

5.Nature of underwriting

With exception of what above specified concerning navigation data, the user is free to provide personal data. The provision of personal data is optional and discretionary, although it may be necessary for some specified services. The non-submittal of  personal  data marked with * may result the  impossibility to to get the required service provided by the Data Controller.

 

7 . Right to Access Personal Data and Other Rights

You can exercise your rights according to articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30th June 2003, by contacting the Data Controller, or the Data Processor – Head of Privacy Area -  at the following telephone number 031 704381, or by sending an email to info@satogroup.com

You have the right, at any time, to obtain confirmation of the existence of your data and ask for their content and origin, verify their accuracy or request their integration or updating , or correction (Article 7 of the Italian Data Protection Code). For the purposes of this Article you can ask the cancellation, the transformation into anonymous form or the arrest of the personal data processed in contravention of the law, and you can oppose for legitimate reasons to their treatment. In case you’ll contact the Data Controller you are required to provide your email address, name, address or phone number, in order to allow the Data Controller to manage your request.

To stop receiving automated direct marketing communications ( e-mail ) just use our auto deleting systems or send an e-mail to info@satogroup.com with the following subject" unsubscribe from automated message "  and you won’t be disturbed anymore.

 

8.Changes to the Privacy Statement

The Data Controller reserves the right to modify, update, add or remove portions of the current Privacy Policy at his discretion and at any time. We encourage you to periodically review this page for the latest informations on our privacy practices. To make this review easier for you, our privacy statement will contain the date of the publication on the website and updating. Using the website, after the changes post, will mean silent acceptation of the privacy policy.