Privacy Policy

 

1) FOREWORD

PRIVACY POLICY AND COOKIE POLICY

This page illustrates how the site is managed with regard to the processing of personal data of users who consult it.

When you browse our website or use our services, we collect information and personal data about you. For this reason, in accordance with the provisions of Regulation (EU) 2016/679 Of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation “GDPR”), we have created the following document (hereinafter “Privacy Policy”) for the purpose of describing to you what personal data we collect, the purposes and methods of processing it, and the security measures we take to protect it.

This Privacy Policy represents the information that is provided pursuant to Art. 13 et seq. GDPR to those who interact with the web services of Maxwell & partners (hereinafter the Company), accessible by electronic means from the address: https://www.maxwellandpartners.com corresponding to the home page of the official website of the Company.

The information is provided only for the Company’s website and not also for other websites that may be consulted by the user through links.

The policy is prepared in accordance with Recommendation WP260, which the European Data Protection Authorities, meeting in the Group established by Art. 29 of Directive No. 95/46/EC (the “WP Article 29”), have adopted to identify the requirements necessary to achieve the goal of transparency under Regulation 2016/679 and Recommendation WP251rev.01 of WP Article 29 about making decisions based solely on automated processing, including profiling, under Regulation 2016/679 as amended and adopted on February 6, 2018, to the extent that data controllers must implement measures and procedures for the processing of personal data received or obtained from users when they link to web pages, regardless of the purposes of the link.

2) TYPES OF DATA PROCESSED

Browsing data: session only

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 information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses 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 response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information about the use of the site and to check its correct operation and is deleted immediately after processing. The data could be used to ascertain liability in case of hypothetical computer crimes against the site.

Data required to access the website:

Browsing our website does not require the creation of a personal account.

Data voluntarily provided by the user:

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message. If you need to collect, process and communicate to us information referring to third parties, you must do so in accordance with the provisions of the GDPR and, therefore, you must give them prior notice of the purposes and methods of processing and, if necessary, you must collect their free and express consent before processing.

Through our website you can also sign up to receive the company newsletter that will keep you informed of the Company’s activities. This is done by filling out the appropriate section in which to indicate your name and email address.

3) PURPOSE OF PROCESSING

The above information is necessary to access our website and view our services. This information is mandatory and a refusal to provide it would prevent you from accessing the site, requesting and using the services provided through it.

Data voluntarily provided for newsletter subscription will only be used for this purpose and will not be given to third parties.

4) DURATION OF TREATMENT

Data provided for newsletter subscription will be kept in the company database unless requested to be deleted. This request must be made by direct communication, or through the unsubscribe link provided in each newsletter you receive.

5) THE “OWNER” OF THE TREATMENT

The “owner” of the personal data processing is the company Maxwell & Partners, with registered office in Milan, Via Paganini, 4, email address: info@maxwellandpartners.com.

6) SCOPE OF DATA DISCLOSURE

Your personal data will only be processed by individuals who have been previously appointed as data processors or managers. In particular, your personal data may be disclosed to the following categories of external parties: professional or technical service providers and legitimate recipients under the law.

Should we be involved in a reorganization, acquisition or sale of our company or parts of it, we will disclose your data to the third parties involved in the process. Any third party who as part of this procedure is a recipient of your data may use it within the limits set by this Privacy Policy. To receive the updated list of the responsible persons, as well as the list of recipients of your personal data, and possibly to revoke your consent to the processing of your personal data, taking into account the corresponding consequences on the possible non-performance of some of our services, please contact us by sending an email to the following address: info@maxwellandpartners.com

7) INFORMATION COLLECTED THROUGH COOKIES AND OTHER TECHNOLOGIES

Cookies are small files sent by websites visited by users and stored on the device used to access those sites. When users visit the same site again, the browser reads the cookies stored on the device and relays the information back to the site that originally created the cookies. Our website also uses various types of cookies and other technologies to read and store information on your device in order to, for instance, perform statistical analysis, personalize and facilitate your browsing experience, and, prior consent of the user, offer you advertising based on your interests. We do not use cookies that can potentially start programs on your devices or send viruses to your devices, or even establish control over your devices.

In accordance with the provisions of the order of May 8, 2014 of the Data Protection Authority, together with the document of June 5, 2015 prepared by the Authority to provide clarifications on the implementation of the cookie legislation, we inform you that this information is also an extension of the short banner already displayed when connecting to the website. In particular, our Services adopt:

– Technical cookies, which are necessary for the operation of the website, including the provision of the Services offered by them.

This category of cookies includes analytics, session and functionality cookies, which are used by the owner to, for instance, collect information, in aggregate form, about the number of users and how they visit the website itself, to save your browsing preferences, such as the language, or even to recognize the user who returns to the website;

– Third-party profiling cookies, aimed at creating profiles related to the user and used for the purpose of sending and displaying advertisements in line with the preferences expressed by the user while browsing.

The above cookies can be:

– temporary, when they are automatically deleted when the connection is terminated;

– permanent, when they remain stored in the user’s hard drive unless the user himself deletes them;

– first-party, when they are set up and managed directly by the site operator;

– Third-party, when they are managed by a domain different from the one visited by the user.

While the use of technical cookies does not require the user’s consent, the use of profiling cookies always requires the user’s explicit consent.

The website may contain applications and materials (“APIs”) that use data from your open accounts on social networks such as Facebook, Linkedin, etc. An API could, for example, be created in order for you to post comments directly to the social network you are subscribed to. When you use such an API, your personal information is transmitted to the social network site. This data is governed by the privacy policy of that social network. An API may also be created to obtain information and content related to you, your friends, your user ID, and other types of content drawn from the social network you use. Such information and content will not be captured unless you have given your consent on the social network site. Where such consent is given, the aforementioned information will be used in accordance with this Privacy Policy, the API rules of that social network, and the adoption of appropriate security measures to prevent the loss of or undue access to personal data transmitted through the API in compliance with WP Recommendation 242 rev.01 of WP Article 29 regarding the right to data portability as amended and adopted on April 5, 2017.

8) MODE OF TREATMENT

Personal data are processed by automated means for the time strictly necessary to achieve the purposes for which they were collected.

Adequate technical and organizational security measures are observed to prevent data loss, illegal or incorrect use and unauthorized access, in compliance with applicable regulations. Our organizational security measures include contractual means with any contractor (e.g., service providers) or agent to ensure the protection of the security and confidentiality of your personal data in accordance with the provisions dictated by the GDPR.

8) RIGHTS OF DATA SUBJECTS

The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or non-existence of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or rectification (Art. 15 and 16 GDPR).

The data subject has the right to request the deletion of personal data concerning him or her, as well as the restriction of the processing of such data in the cases provided for by the GDPR, and to object to their processing in any case, unless the data controller demonstrates the existence of legitimate grounds for doing so (Articles 17-18 and 21 GDPR). The right to object to the processing of personal data may be exercised at any time in the case of processing for direct marketing purposes including profiling as far as it is related to such direct marketing. On the other hand, the data subject has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way, except with his or her explicit consent or the need to enter into or perform a contract with the data controller (Art. 22 GDPR). Finally, the individuals to whom the personal data refer have the right to receive such data in a structured, commonly used, machine-readable format and that the data be transmitted to another data controller without hindrance (Art. 20 GDPR). The data subject also has the right to file a complaint with the competent authority.

Inquiries regarding the exercise of your rights under Articles 15-22 GDPR should be addressed to Maxwell & partners, please contact us via the contact information provided in Section 5 of this Privacy Policy.