Information on the processing of personal data.

Articles 13 and 14 EUROPEAN REGULATION No. 679/2016 L.D. 196/2003 amended by L.D. 101/2018 To all Interested Parties This policy describes how the website is managed with regard to the processing of personal data of users who consult it, as well as the data processing practices through this website. In compliance with Article 13 (for data collected from the data subject) and Article 14 (for data not collected from the data subject) of Regulation (EU) 2016/679 (henceforth GDPR), the following information is rendered to the Users of this Website, which refers exclusively to the processing carried out through said Website and not through other websites that may be visited through links within this website, for which it is suggested that they read the relevant policies made by the respective Data Controllers. This Website and any services offered through the Website are restricted to individuals who are eighteen years of age or older. Therefore, the Data Controller does not process personal data related to individuals under the age of 18. Upon request of such Users, the Data Controller will promptly delete all personal data involuntarily collected from them.

1. Data Controller

Data Controller Essay Group s.r.l. a single shareholder, based in Via Gazzo 33 – 35035 Mestrino (PD), Tax Code and VAT No. 04579340284, (hereinafter “Data Controller”). The Data Controller reserves the right to appoint a web agency or consultant as the Data Processor of personal data managed for the purposes of technical support, maintenance, technical management and the like of this Website, whose references may be communicated upon request to the above addresses. The Data Controller and Data Processor also process Users’ data through their own in-house appointees, specially designated with instructions to authorized processors.

2. Category of data processed and sources of origin

• Browsing data (the computer systems and software procedures used to operate this website acquire, in the course of their normal operation, some personal data whose transmission 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 addresses of websites from which access or exit was made, information on the pages visited by users within the website, the time of access, the length of time spent on the individual page, internal path analysis, and other parameters related to the user’s operating system and computer environment. These technical/informational data are collected and used only in an aggregated and anonymous manner. This data is processed for the purpose of enabling and monitoring proper use of this website as well as to obtain anonymous statistical information on its use, and is deleted immediately after processing.
• Cookies, on which we invite you to read our Cookie Policy 
• Data voluntarily given by the user, including:

– Common data (identification, biographical, billing and similar data – Only exceptionally special data (art. 9 GDPR) – Only exceptionally criminal data (art. 10 GDPR) Sources: browsing, other websites, cookies and the like; user; public sources. We may primarily process browsing data as well as cookies. We may also process data provided voluntarily by the user, e.g. through the contact form or by sending an e-mail communication, including common personal data (identification, biographical, billing, and the like) and exceptionally special data within the meaning of Art. 9 GDPR or criminal data within the meaning of Art. 10 GDPR in the narrow limits insofar as this is made necessary by the request for information received and subject to the consent of the data subject. The data could come from automatic or voluntary sources, as well as from public sources. For example, they could come from user’s browsing, which could bring information about previous consultations of other websites, including in particular cookies and other similar technologies. Data may also be given voluntarily by the user or related parties. Other data could come from public sources, such as those processed as part of research and from viewings, public databases and the like.

3. Purpose of processing

The personal data of the Users of the Website’s Users, as described above, will be processed in the manner and form prescribed by GDPR, in order to carry out the Website’s own functions, with particular, but not exclusive, reference to navigation of pages and the procedures described therein of data collection, contact form, possible registration process/access restricted area, newsletter subscription and the like. Specifically, personal data provided to the Data Controller will be processed for the following purposes:

• to follow up on specific requests made to the Data Controller by the User through the Website and its communication tools (contact forms, information request forms and the like);
• for communications of an informative nature related to the services of the same Data Controller, following the request for information through e-mail messages or filling out the contact form and other communication tools;
• for possible registration for events organized by the Data Controller and other related activities (e.g., verification of participation, notices regarding any updates or changes to the event, etc.);
• for other purposes ancillary or related to those indicated above and otherwise within the scope of the Website’s activities;

The data provided generically will be processed, including as a result of automatic collection during navigation, for the sole purpose of ascertaining and controlling access to the Website. This also applies to technical cookies, to be understood as session, functionality or analytics cookies that meet the requirements specified by the Guarantor. In particular, regarding the latter, it is clarified that they can be assimilated to technical cookies where these are made and used directly by the Website. In any case, for said analytics cookies, the Website, also in accordance with the clarifications of the Guarantor, has provided for the anonymization of IP addresses and the amendment to the processing of data; the collection and use of said browsing data (without prejudice to the anonymization of IP addresses) allow the monitoring of the Website’s performance and allow the improvement of the service offered, proposing to the User a better browsing experience. Please refer to the appropriate Cookie Policy for more information.

4. Legal basis of the processing

The processing of personal data is based on the fulfillment of contractual or pre-contractual obligations inherent to the request made by the User (e.g. requests for information about the services carried out by the Data Controller, requests for estimates, etc.), as well as, where necessary, on consent through the free and conscious filling out of the appropriate information fields in the form dedicated to the collection and conferment of data and the ticking of the appropriate checkbox where provided. It should be noted that the filling out of appropriate fields provided in forms for the request for information is inherent to the request itself and that therefore this implies the fulfillment of a pre-contractual or contractual obligation, depending on the context. Consent may be required later for further data processing. A specific privacy policy will be present wherever it is needed (different policy from this one). In any case, processing is also based on legitimate interest, including the right to information, for which please refer to the next paragraph.

5. Legitimate interest of the Data Controller

The processing of personal data is also based on the legitimate interest of the Data Controller, such as the exercise of its rights in the context of information society, the performance of contractual services and the implementation of direct marketing operations (in the manner, by the means and within the timeframe provided by the regulations).

6. Compulsoriness of contribution

The provision of browsing-related data by Users, for the above purposes, depends on the degree of privacy you have enabled or disabled via your browser. In some cases, disabling it may affect browsing on this Website. For certain forms of this Website, the provision of navigation data and/or the use of technical cookies are mandatory for the proper functioning of this Website. The provision of some of your own data is in any case necessary for the very structure of the Website and its procedures. Instead, any request for other optional data will be preceded by an approval checkmark. The provision of all other data is optional, in accordance with the type of information the User wishes to provide to the Website. Notwithstanding the above, for example, the provision of the e-mail account is necessary to be able to respond to the request made via contact form, as well as the other mandatory data indicated therein with an asterisk. Other data are optional. Failure to provide the data necessary for the requested action (e.g., of the e-mail account via form for requesting information by this means) makes it impossible for the Data Controller to process the request. PROVISIONS APPLICABLE TO ALL PROCESSING In any case, even where the data subject has given consent to authorize the Data Controller to pursue all the purposes mentioned in the points above, the data subject will still remain free at any time to revoke it. It is specifically and separately informed, as required by Article 21 of the Regulations, that the data subject has the right to object at any time to the processing of personal data carried out for the above purposes and that, if the data subject objects to the processing, the personal data may no longer be processed for these purposes.

7. Possible recipients of personal data

The data may be disclosed to companies related to, connected with or controlled by the Data Controller, as well as to consultants, or even to third parties operating, also on behalf of the Data Controller, for the fulfillment of the services related to the purposes indicated in this information, both intra-EU and extra-EU (in the latter case, it will be exclusively subjects adhering to the regulations in force). Browsing and similar data (for which refer to the above), as well as profiling cookies also from third parties (for which refer to the Cookie Policy of this Website), which will be disclosed to the respective third parties concerned, where they do not handle them directly as Data Controllers. In any case, the data may be communicated to Data Processors, as well as to persons authorized to process and duly instructed, always within the scope of the purposes of processing. For brevity, the detailed list of these figures is available from our office.

8. Storage period

Data voluntarily provided by the Data Subject will be retained until expressly revoked by the Data Subject, including by action on his/her browser, cookie cleaning, express request or otherwise manifested. Browsing data will be stored, in accordance with the principle of proportionality, in a form that allows the identification of the Data Subject for a period of time not exceeding that necessary for the purposes for which it was collected or subsequently processed. Excluded from the above time limits are cases in which it is necessary to retain the data for an additional period of time to defend or enforce a right or to fulfill any legal obligations or orders of the Authorities.

9. Rights of the interested party

Each Data Subject has the right of access, rectification, cancellation (oblivion), limitation, reception of notification in case of rectification, cancellation or limitation, portability, objection, and not to be subject to automated individual decision-making, including profiling, pursuant to Articles 15 to 22 of the GDPR. These rights can be exercised in the forms and terms set forth in Article 12 GDPR, by written notice sent to the Data Controller (see section 10). The Data Controller will render an appropriate response as soon as possible but no later than 1 month after receipt of the request.

10. Right to withdraw consent (How to exercise rights)

You can revoke consent, where provided, at any time and/or exercise your rights by sending: – a registered letter with return receipt to the undersigned with an express request (see the address on the letterhead); – an e-mail to web@essaygroup.it.

11. Complaints

Each Data Subject has the right to lodge a complaint pursuant to Art. 77 et seq. of the GDPR with a supervisory authority, which for the Italian state is identified in the Garante per la protezione dei dati personali. The forms, methods, and time limits for filing complaint actions are provided for and governed by current national legislation. The complaint is without prejudice to administrative and jurisdictional actions, which for the Italian state can be brought alternatively to the same Guarantor or to the competent Court.

12. Profiling

Personal data provided through browsing this website and any completion of forms posted therein may be subject to profiling by third-party providers through third-party cookies. Profiling allows such third-party providers, autonomous Data Controllers of their respective personal data processing for profiling purposes, other than the Data Controller of this website, to assess certain personal aspects of the Interested Party related in particular to his/her preferences, interests, tastes with reference to the pages consulted and the activities carried out, in order to allow such autonomous and different Data Controllers to offer the Interested Party a more specific service targeted to his/her needs. For more information, the User is invited to read the cookie policy.

13. Data Controller, D.P.O. (R.P.D), Appointees/Authorized Persons, Data Processors.

Below we provide you with some information that it is necessary to bring to your attention, not only in order to comply with the obligations of the Law, but also because transparency and fairness towards the interested parties is a founding part of our activity. Data Controller. The Data Controller of your personal data is Essay Group s.r.l. a single shareholder, which is responsible to you for the lawful and correct use of your personal data and which you can contact for any information or request at the following addresses: phone +39 049 9004134, e-mail: info@essaygroup.it. Appointees/Authorized Persons. An up-to-date list of the Appointees/Authorized Processors is kept at the Data Controller’s office. Data Processors For brevity, the detailed list of these figures is available from our office.

14. Social media plug-ins

This website may contain plug-ins from some social media (e.g., Facebook). Social plug-ins are special tools that allow social network functionality to be embedded directly within the website (e.g., Facebook’s “like” function) and are marked with the logo of the respective social platform. When you visit a page on this website and interact with the plug-in (e.g., by clicking the “like” button) or decide to leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform (in this case, Facebook) and stored by it. For information on the purpose, type and manner of collection, processing, use and storage of personal data by the social network platform, as well as how to exercise your rights, please see the social network’s privacy policy.

15. Links to third-party websites

From this website it is possible to connect through special links to other third-party websites. The Data Controller disclaims any responsibility with regard to the possible management of personal data by third party websites and with regard to the management of authentication credentials provided by third parties.

16. Cookies

Cookies are packets of information sent by a web server (e.g., the website) to the user’s Internet browser, automatically stored by the user on the computer and automatically sent back to the server each time the website is accessed. For any information on the characteristics, types, how to use them, and how to remove, delete or disable cookies on the website, please refer to the specific Cookie Policy. Data Controller Essay Group s.r.l. a single shareholder  How to contact us ESSAY GROUP Ltd. welcomes comments regarding this privacy policy. Please contact us at the following address: info@essaygroup.it.