Processing of personal data

Personal data controller and personal data processor

Arcoda srl, which has its legal headquarters at via del Brennero 139, 38121 Trento (ITALY), hereafter referred to as Arcoda or the controller, will process the personal data you provided through the www.arcoda.it website (hereafter the website) in compliance with applicable current privacy and personal data protection legislation, and this privacy policy.

Data Protection Officer (DPO)

The Data Controller has appointed a Data Protection Officer (DPO) who can be contacted at this email address: dpo@studiogadler.it.

Purpose and method of procession

Arcoda will process the personal information you provide us or which has been legitimately collected by the Controller (Personal Data). The following personal data in particular will be processed:

1. Contact information - name, surname, email address, telephone number and content of the message sent by you and other Personal Data that you may have provided during the communication. We will process this Personal Data in the case in which you make enquiries, request information or send us communications of any type. The processing of this Personal Data is necessary for us to provide a response to the communications received from you or to the requests that you have made. The provision of any further Personal Data by you is completely voluntary.
2. Navigation data - the IT and electronic communications systems and software procedures put in place to allow the Website to function, will, in the course of their normal work, collect certain data (e.g. access date and time, pages visited, name of the Internet Service Provider and Internet Protocol (IP) address you use to access the internet, the internet address from which you connect to our Website, etc.), the transmission of which is implicit in the use of web communications protocols or is pertinent to effective management or optimisation of the data or email sending system.
3. In the context of this privacy policy, Personal Data processing refers to any operation or group of operations carried out using automated processes and applied to Personal Data, such as collection, recording, organisation, structuring, conservation, adaptation or modification, extraction, consultation, use, communication through transmission, dissemination or any other available means, comparison or interconnection, restriction, erasure or destruction.
4. Please be informed that this Personal Data will be processed manually and/or using IT or electronic support.

Purposes and legal bases of processing

Arcoda will process your Personal Data for very specific purposes and only if there is a specific legal basis provided for under applicable personal data protection and privacy legislation. Specifically, Arcoda will process your Personal Data only when one or more of the following legal requirements has been met:

1. you have freely given your specific, informed, unambiguous and affirmative consent to the processing of said data;
2. the processing is necessary to the performance of a contract to which you are a party or to take pre-contractual measures at your request;
3. for the purposes of the pursuit of Arcoda’s legitimate interests;
4. Arcoda has a legal obligation to process said Personal Data.

Purposes for which your Personal Data can be processed by the Controller

1. To allow you to use all of the Website’s functionalities
2. To check that the Website is functioning correctly
3. To establish responsibility in the case of cyber crime
4. Performance of security controls required under law
5. Legitimate interest
6. To respond to a query or a request from the Data Subject
7. Implementation of pre-contractual measures adopted at the request of the Data Subject

The provision of your Personal Data is necessary in all instances in which processing is a legal requirement or necessary to the performance of a contract to which you are a party or to the implementation of pre-contractual measures adopted at your request. Any refusal on your behalf may make it impossible for Arcoda to perform the task for which your Personal Data has been collected.

The provision of your Personal Data, however, is voluntary for any further purposes and failure to give your consent in such cases will have no effect on the completion of the contract.  The obligatory or optional nature of the provision of data will be specified at the moment of its collection..

Personal Data Recipients

Your Personal Data may be made accessible for the abovementioned purposes, to:

• employees and staff of the Controller who, for that purpose, have been tasked with data processing, or to Arcoda Group companies in the European Union for the implementation of organisational, administrative, financial and accounting activities.
• to third party companies or other subjects to which the Controller outsources work required to allow the Website to function, in their role as external data processors.

Period for which your data will be held

Personal Data processed for the purposes described above will be held in compliance with the principles of proportionality and necessity, and, in all cases, until the purposes of the processing have been completed.

Rights of the data subject

Under articles 15 – 21 of EU Regulation 2016/679 (GDPR), you have the right in relation to the Personal Data you provide: tTo access and request a copy;t o request rectification; to request erasure; to obtain restriction of data processing; to object to the processing; to receive in a commonly-used structured form readable on an automatic device and to transmit without impediment said data to another Data Controller in the case that this is technically feasible.

You have the right to object at any time to the processing of Personal Data relating to you that is carried out in the pursuit of Arcoda's legitimate interests.

When you object to the processing of your Personal Data, the Controller will refrain from further processing your Personal Data, except where convincing legitimate reasons for continuing with the processing have been established or for the verification, exercising or defence of a right in a court of law.

To exercise your rights and withdraw your consent, please write an email to info@arcoda.it

For further information relating to your Personal Data, you can contact Arcoda’s Personal Data Protection Officer at this email address: dpo@studiogadler.it. You have the right to make a complaint to the relevant Personal Data protection authority.

Module to exercise the rights

To exercise the rights referred to in Articles 15 and following of GDPR please use the pdf module linked here: module to exercise the rights concerned.

Cookie policy

This Cookie Policy provides information for users on the way we use cookies and/or monitoring technologies to collect information given when they visit the www.arcoda.it website.

The Data Controller that processes the personal data gathered through the Website is Arcoda srl, which has its legal headquarter at via del Brennero 139, 38015 Trento (ITALY). Arcoda will process your personal data in compliance with the applicable personal data protection legislation.

What are cookies?

Cookies are small text files that websites send to users’ devices (e.g. computer, tablet, smartphone, notebook, etc.), where they are saved and then sent back to the same sites on the user’s next visit. Cookies may require the user’s prior consent.

Cookies allow the device on which they are stored to be identified for the entire period of their validity or registration. During visits to the Website, navigation data-related information received from the user’s device may be stored in cookies installed on the latter.

Cookies perform different functions and make navigating the Website more efficient by remembering the user’s preferences and enhancing their navigation experience. They can also help personalise the advertisements shown during navigation and the marketing activities aimed at the user, ensuring that they reflect his/her interests and preferences.

Cookie settings can be changed at any time. The following information provides further detail about the cookies used by the Website and the ways the settings relating to them can be managed.

Types of cookies used

When a user connects to the Website via their web browser, cookies may be installed on their device in order to enable the Website to recognise that device, ensuring the effective use of the Website for the lifetime of the cookies, and to collect information on accesses to the Website.

When navigating the Website, cookies may also be sent to the device from other sites or servers (i.e. “third parties”); these may contain certain elements (e.g. images, maps, sound, specific links to pages in other domains) present on the site being visited. With regard to this profile, these may be:

1. First party cookies, sent directly by Arcoda to the user’s device.
2. Third party cookies, which are sent by a third party but on Arcoda's behalf

Depending on the purpose of the cookies, these can be divided into:

Technical cookies: their use is strictly limited to the transmission of session-identifying data (numbers generated randomly by the server) necessary for the secure, efficient navigation of the website; these are not persistent cookies stored on the user’s computer but are erased when the browser is closed. These cookies are used for security reasons and to improve the service offered to users.

Arcoda uses the following Technical Cookies:

• PHPSESSID to keep track of the language chosen by the user. This cookie is deleted once the browser is closed.
• cc_cookie to keep your cookie settings and keep cookie consent window hidden. Expires after 6 months
• _ga is a Google Analytics cookie, and is used to distinguish unique users by assigning a randomly generated number. It is included on every page of the site and is used to create analysis of site visitor navigation, session data and campaign reports. It expires after 2 years.
• _ga_(container ID) is a Google Analytics cookie. Used to persist session state.

Profiling cookies create user profiles and are used to send out advertising messages that reflect the preferences expressed by the latter while surfing the web or to enhance their navigation experience. These cookies can be used for this purpose only with the user’s consent.

Cookie analytics: cookies which are used to analyse the number of users that visit the Website and the ways in which the Website is used, collecting the information in aggregate form. Arcoda does not uses these cookies.

The site makes use of the Google Analytics service. These cookies have been anonymised (i.e. the user's IP has been rendered anonymous), effectively transforming Analytics cookies from profiling cookies to technical cookies using the option provided by Google itself. Therefore, these cookies are assimilated to technical cookies and are processed in aggregate form to monitor the areas of the site that are most visited, improve the content of the site, facilitate its use by the user and monitor the proper functioning of the site.

Managing cookies using your browser settings

Almost all web browsers allow you to check which cookies are on your hard drive, block all cookies or receive a warning every time a cookie is installed. In some cases, however, failure to install a cookie may make it impossible to use some areas of the wbsite.

Below are the main ways in which the most popular browsers enable users to choose their cookie use options:

• Internet Explorer
• Chrome
• Firefox
• Safari

If you are using a mobile device, you should consult the instruction manual for information on how to manage cookies.