PRIVACY POLICY

Date of effect: 25 May 2018
The Privacy Policy explains how Effepierre Multiservizi Srl collects, controls, processes and uses the personal data of users of its own web services.
When we talk about “Website”, we mean our platforms, which include our websites, mobile apps, the communication we send or the services we provide, the social network sites or any other website that we offer and which is related to this Privacy Notice.

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We regularly update this Privacy Policy in order to clarify our practices and to reflect new or different privacy practices, such as when we add new services, functions or elements to the Site. If we make changes, we will inform you, by e-mail (sent to the e-mail address specified in your account), via notice on the Site or by other methods. When this version of the Privacy Notice has been adopted, you can check it with reference to the abovementioned “Date of effect”.

It is clear that, if you constantly use the Website, after we have sent a notice about the changes made to the Privacy Notice, the collection, control, processing and use of your personal data are subject to the update of the Privacy Notice. If you have any objections to our changes, you can modify your account settings or close your personal account as indicated here below.

1. Personal Data which we collect

When you use the Site, we will collect the following personal data:
● Authentication and identification information (e.g. name, e-mail address, and password). These information are necessary to answer to your information requests, to open your account and to connect to it. If you do not provide it, we may not be able to provide our services or answer to you;
● Basic personal details (e.g. name, date of birth and nationality);
● Contact details (e.g. address, telephone number and e-mail address). We need these information to provide our services and if you do not provide it (for example your postal address) we may not be able to deliver it;
● Information about your interactions with our staff (e.g. phone calls storage, instant messages on our site, email).
● In addition to contact data, we collect identity documents and personal licenses in order to ensure compliance with regulatory safety requirements and to improve the quality of our services, but only for some categories of our suppliers and business partners.
We will also collect personal data automatically when you interact with the Site through your computer, mobile devices or other devices. These personal data includes:

● Analytical data (e.g. information about downloads, app history and internet pages), which may include data collected from cookies and other types of device identifiers;
● details about the device (e.g. MAC address, IP address)
We will collect the personal data above mentioned during various stages of your relationship with us, when:
● you register, sign up or create an account on our sites;
● you open or reply to e-mails or messages on our part;
● you start a supply relationship as suppliers or subcontractors
● you purchase services from our company as customers.

2. Your choices

You can check the personal information you provide to us and limit the ways in which we communicate with you. You can check your emails, notifications, location information and preferences regarding subscription notifications by logging into your account through the Site.
● Notifications and location information. Your devices provide options to control notifications and our ways and times of tracking your geolocation. You can disable the use of certain location data through the settings of your devices or browser, for example by disabling “Location” services in the privacy settings for Apple iOS apps and on Android, or disabling the “Location” services for your device;
● Cookie. You can check how your browser handles cookies. You can also check how your mobile device or mobile browser shares information with us about how and where your devices are, as well as how the mobile browser handles cookies.

“Technical” cookies:

These cookies are functional to the web surfing and they guarantee the safe and efficient exploration of the site. Furthermore, Google Analytics cookies are used to collect only information, in aggregated form, on the number of the users and how they visit the site. These are third-party cookies collected and managed anonymously to monitor and improve the performances of the host site (performance cookies). For more information on the Google cookies policy, please click the link here below: http://www.google.com/intl/it_ALL/analytics/learn/privacy.html

“Analytical” cookies (performance cookie):

These cookies are used to collect and analyze the traffic and the use of the site anonymously. These cookies, even without identifying the user, allow, for example, to notice if the same user reconnects to the link at different times. They also allow you to monitor the system and improve its performance and use.

“Third-party cookies”:

Visiting a website you can receive cookies from the visited site (“owners”), and from the sites managed by other organizations (“third parties”). Third party cookies are those related to “social plugins” such as Facebook, Yuotube and Twitter. These are parts of the visited page generated directly by the abovementioned sites and integrated into the page of the host site. The most common use of social plugins aims to share contents on social networks.
The presence of these plugins involves the transmission of cookies to and from all the sites managed by third parties. The management of the information collected by “third parties” is regulated by the related information, please refer to them. To ensure more transparency and convenience, here below there are some links regarding different information and different modes for the cookies management:

Facebook information: https://www.facebook.com/help/cookies/

Twitter information: https://support.twitter.com/articles/20170514

Linkedin information: https://www.linkedin.com/legal/cookie-policy?trk=hb_ft_cookie

Youtube information: https://www.youtube.com/static?template=privacy_guidelines

Instagram information: https://www.instagram.com/about/legal/privacy/

The user can decide whether to accept cookies modifying the settings of the browser.

● Social Network. You can also control the personal data sharing with us when you connect to through social network or apps. Please refer to Section 8 here below, to the privacy policy and also website settings of social networks or apps, to determine how you can control our permissions and manage interactivity between us and your accounts on social networks or your mobile devices.

3. Your rights

You can have access, update, correct and delete your personal data by contacting us via email at info@effepierre.it. Keeping your personal information up-to-date allows us to respect your preferences and the most relevant services offered to you.

In accordance with current legislation, you may (i) request access to the personal data that we have; (ii) request to update, rectify, delete or block them; (iii) ask us to delete the personal data that we have; (iv) ask us to reduce the processing of your personal data; (v) require us to provide you or a third party a copy of determined personal data (as the “data portability” right). You may also raise objections to our use of your personal data indicated in this statement, including our marketing activities. You can also appeal to the Guarantor Authority.

4. How we use information (Purpose of processing)

We monitor and process the personal data provided, collected from other sources, and used for:

● create your accounts in our systems and to access them, which is necessary for us to provide our services to you.
● inform you and request further information during the supply of the services you request.
● inform you or request further information during the supply of the services we request
● conduct marketing, which can include:
– Analyze individual and group profiles and customers behaviors, in order to identify your interest in certain types of offers, products and services. We do this by analyzing your interactions with the Site and the other personal data that belong to you, to identify your interests, products and services bought by people with your similar interests, which helps us to understand which products and services you might be interested in. This is done to respond to our legitimate interests in understanding the products and services our customers are interested in and to provide the most relevant products to you and to our other customers;
– Send you relevant direct business messages and other communications via e-mail or via alerts on mobile devices with your approval. We will send you these messages either on the basis that you have agreed to receive them or, if permitted by the law, to respond to our legitimate interests in showing you which of our services are relevant to you;
● Answer to your questions and your requests, for example in the context of a customer service. This is done to honor our contractual obligations towards you, contained in the general conditions of the contract,
where such questions or requests are part of the purchase process or to comply with legal obligations and in all other cases, to respond to our legitimate interests in providing a good service to our customers;
● Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins and required information, including those on behalf of Business Partners, our affiliated companies in the EU. This happens to respond to our legitimate interests in order to manage effectively our relationships with you;
● Manage surveys, other promotional activities or events, in order to honor our contractual commitments with you indicated in the terms and conditions of those promotional events;
● Manage the daily needs of our business, such as the management of the Site, forums, compliances, data analysis, fraud prevention and the performance of our company’s obligations in compliance with current regulations;
● Comply with our legal obligations, settle disputes and implement our agreements. We do this where it is necessary to comply with the legal obligations we are subject to, or to respond to our legitimate interests in enforcing our legal rights and settling disputes, verifying payments and preventing fraud.

5. How and when we disclose Personal Data

We share your personal data as follows:
● with your approval;
● with non-affiliated Sales Partners and Third Party Vendors, so that they can sell, deliver and supply products or services purchased by you (e.g. deliver products or provide a port operator with your details so that they can confirm the bookings). We share the personal data with non-affiliated Business Partners and Third Party Vendors in order to honor our legal obligations, but they are not authorized to use your personal data except for the sale, delivery and/or supply of services purchased by you;
● To comply with legal systems and government requests, or to support audits, compliances and corporate governance functions, where it is necessary to comply with these legal requirements;
● to combat frauds and criminal activities and to protect our rights or those of our affiliates in the EU, our Business Partners and users, or those as part of legal proceedings that affect us and/or our affiliates in the EU, as part of our legitimate interests, to prevent frauds and to protect these rights; or
● in response to a subpoena or similar legal proceedings, including those in the presence of law enforcement authorities, regulators and courts, to the extent necessary to comply with such legal obligations.

6. Security of personal data

We have implemented an information security program that includes administrative, technical and physical controls designed to safeguard your personal data, including encryption technology according to the standards. However, no method of transmission over the Internet or electronic storage method is 100% secure. Therefore, we cannot guarantee its absolute security.

7. Storage of Personal Data

We will keep your personal information for as long as your accounts are active or as long as necessary to provide services. If you close your accounts, we will keep your personal data for a period that is necessary to continue our business effectively, to store your transactions for financial reporting purposes or for fraud prevention purposes, until these aims will cease to exist and to preserve them, as necessary, to comply with legal obligations, settle disputes and implement our agreements. All data in our processing systems are stored in EU territory.

8. Third Party Data Privacy Policy

This Privacy Policy focuses exclusively on the collection, processing and use (including divulgation) of personal data on our part through your interaction with the Sites and our applications. The other Websites

that can be accessed through the links on the Site may have their own privacy policies and practices for collecting, processing, use and divulge the personal data.

9. Contact us

If you have any questions or comments about our privacy practices or this Privacy Policy, and if you want to use any of the above rights or other rights that you may enjoy regarding your personal data, please contact us:

Writing a registered letter at:
Effepierre Multiservizi Srl
Via Madonna, 21
20037 Paderno Dugnano (Mi)
Send an email to:

info@effepierre.it