Privacy Policy 

REGULATORY FRAMEWORK

  • Directive 2002/58/EC – concerning the “processing of personal data and the protection of privacy in the electronic communications sector”;
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC (General Data Protection Regulation).

THE DATA CONTROLLER
Once visited this website, data related to identified or identifiable people may be processed.
The controller of said data processing is Victoria Torlonia SRL.

DATA PROCESSING VENUE AND DATA STORAGE PERIOD
The processing associated with the web services of this website takes place in the aforesaid head office of the Data Controller and are processed exclusively by explicitly authorised staff of the Data Controller or possibly by third parties occasionally tasked with maintenance operations, appointed Processor, pursuant to article 28 of the GDPR. The collected data shall – meaning each type of processed data – shall be stored only for the period necessary for meeting the specific targets indicated in the specific summary reports displayed on the website pages and arranged for specific services.

TYPE OF PROCESSED DATA

Browsing data
The IT systems and software procedures needed for the operation of this website shall acquire, during their regular operating, some personal data, whose transfer is implicit in the use of Internet communication protocols.
Such information is not collected to be associated with identified data subjects but, owing to their very nature, may – through processing and association with data held by third parties – lead to the identification of users.
This data category includes IP addresses or domain names of the computers used by the users to visit the website, the numbered URI (Uniform Resource Identifier) 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 response status given by the server (successful, error, etc.) and other parameters concerning the operating system and the user’s IT environment.
Such data are used only to obtain statistical and anonymous information regarding the use of the website and to check its correct functioning and are deleted immediately after being processed. Such data may be used to ascertain responsibilities in the event of possible cybercrimes perpetrate against the website: other than such a hypothesis, the data associated with web contacts are currently stored no longer than seven days.

Data provided voluntarily by users
The optional, explicit and voluntary provision of personal data by the user, in the registration forms available on this website entail the subsequent acquisition of the data provided by the sender, needed to provide the requested services. Specific summary reports shall be regularly displayed on the relevant pages of the website, set up for specific services on request.

COOKIES
Cookies are small text files containing a certain amount of information exchanged between an Internet website and the user’s device (usually the browser). They are mainly used to make websites operate more efficiently and to provide information to the website owners. Cookies may be either session-related or persistent. Session cookies are stored in the device for a brief period and are eliminated as soon as the user shuts down the browser. Their use is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) needed to enable a safe and efficient browsing of the website. Persistent cookies, on the other hand, are stored in the user’s device until a pre-established expiration date. Since they are not directly deleted when closing the browser, they remember the choices made by the user one’s website and collect information concerning the website pages visited by the user, the frequency of visits to the website and track the users’ browsing, in order to enhance the user’s browsing experience on the website.
Cookies, whether they are session or persistent cookies, can be first-party or third-party, depending on whether the party that installs the cookie on the user’s device is the manager of the website the user is visiting (first-party cookies) or a party other than said manager (third-party cookies).

Cookies used by this website
This website uses both first-party and third-party cookies, since it uses the Google Analytics services provided by Google Inc.
Google Analytics uses ‘cookies’ to collect and analyse information on how the users browse the websites they visit. For further information on Google Analytics cookies and their use by Google Inc. please check the report on cookie usage by Google, available at the following addresses:
http://www.google.com/intl/it/policies/technologies/cookies/
and https://developers.google.com/analytics/devguides/collection/analyticsjs/cookies-usage
Google Analytics’ privacy policy at the following address:
http://www.google.com/intl/en/analytics/privacyoverview.html

The table below displays a detailed breakdown of the cookies currently present on the website.

COOKIE NAME
DEFAULT EXPIRATION
TYPE
COOKIE DESCRIPTION
_dc_gtm_UA-# 
1 day
Third-party analytical technician
Statistical cookie used by Google Tag Manager to check Google Analytics’ upload of scripts
_ga 
Default expiration is 2 years
Third-party analytical technician
This cookie is associated with Google Universal Analytics and it is used to update Google Analytics services. It is used to differentiate users, assigning each one of them a randomly generated number which acts as client identifier. It is used to calculate the number of visitors of the page, sessions and data, in order to produce an analysis report.
_gat 
Default expiration is every 10 minutes
Third-party analytical technician
This cookie is associated with Google Analytics and it is used to speed up access requests.
_gid
Default expiration has been set to 2 years
Anonymous statistical cookie
This cookie registers a unique ID which is used to generate statistical data on how the visitor uses the website.
collect
Session
Anonymous statistical cookie
Technical anonymous cookie for sending Google Analytics data about the device used and the user’s behaviour.
_fbp
3 months
Marketing cookie
Facebook cookie used for marketing activities and sponsorship by third parties.
_gcl_au
3 months
Marketing cookie
Cookie used by Google AdSense to test the advertising efficiency of their services on different websites.
ads/ga-audiences
Session
Marketing cookie
Cookie used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites.
cid
2 months
adform.net marketing cookie
These allow to understand how users interact on the website, so as to send them advertising information, including on third-party websites.

Aside from the cookies listed in the table, this website also uses so-called session cookies (for example PHPSESSID, which concerns the working session), namely those cookies that are not permanently stored in the user’s device and are deleted when the browser is closed. Their use is very limited.

Managing cookies
Browsers typically allow the user to manage most cookies by adjusting the settings of the browser itself. However, the total or partial disabling of the so-called technical cookies may compromise the website’s operations. However, should the user wish to receive no type of cookie on their device, neither from this website, nor from other websites, they may raise the privacy protection level by modifying the security settings on their browser.

Mozilla Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie
Google Chrome: https://support.google.com/chrome/answer/95647?hl=it
Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
Safari 6/7 Mavericks: https://support.apple.com/kb/PH17191?viewlocale=it_IT&locale=it_IT
Safari 8 Yosemite: https://support.apple.com/kb/PH19214?viewlocale=it_IT&locale=it_IT
Safari su iPhone, iPad, or iPod touch: https://support.apple.com/it-it/HT201265

THIRD PARTY COOKIES
This website includes links for accessing other websites or social media buttons (widgets) for interacting with Facebook, Twitter, Instagram, Google+, LinkedIn, Pinterest, Gmail, Tumblr, OKNOtizie, Delicious, Digg, StumbleUpon. By clicking on the specific links you may, for example, share our content. We hereby inform you that Victoria Torlonia SRL does not control the cookies or other monitoring technologies of the websites to which this Policy does not apply.

OPTIONALITY OF DATA TRANSFER
Aside from what has been pointed out with reference to browsing data, users are free to provide their personal data or not. However, not providing them might make it impossible to obtain what has been requested.

PROCESSING MODALITIES
Personal data are processed including via automated tools. Specific security measures are put in place to prevent data loss, their illegal or improper use and unauthorised access. The Processor has taken all the minimum security measures envisaged by the law and complying with the major international standards, and it has also taken further security measures to reduce as much as possible all risks related to the confidentiality, availability and integrity of the personal data collected and processed.

SHARING, COMMUNICATING AND DISCLOSING DATA
The collected data may be transferred or disclosed to other companies for activities strictly linked to and instrumental to the operation of the service, such as the management of the IT system. Aside from such cases, personal data shall not be disclosed, unless otherwise provided for by the contract or by law, or unless a specific authorisation request is sent to the data subject.
In this regard, personal data may be disclosed to third parties, but only if:

  1. there is an explicit authorisation for sharing data with third parties;
  2. there is a need to share information with third parties in order to provide the requested service;
  3. it is necessary for complying with the requests of the judicial authority or with public security matters.

No data deriving from the use of the web service shall be disclosed.

DATA SUBJECT RIGHTS
The regulation protecting personal data explicitly set forth the specific rights of the individuals the rights refer to (so-called data subjects). In particular, pursuant to articles 15 and subsequent of EU Regulation 2016/679, the data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, the purpose and modality of the processing, the update, the rectifying, integration of data or their deletion, should their processing infringe the law or should one of the reasons set forth under article 17 of EU Regulation 2016/679 come about.

MODIFICATIONS TO THE CURRENT PRIVACY POLICY
Victoria Torlonia SRL periodically revises its privacy and security policy and, should it be necessary, shall modify it in accordance with the regulatory or organisational amendments, or with changes deriving from technological development. Should the policy be modified, a new version shall be published on this website page.

QUESTIONS, COMPLAINTS, SUGGESTIONS AND EXERCISE OF RIGHTS
Anyone who wishes to obtain further information, contribute by making suggestions or submit complaints as to the privacy policy and to the way our Company processes personal data or exercise their rights, as provided for by the personal data protection regulation, may contact the Data Controller, sending an email to info@victoriatorlonia.com.

GOVERNING LAW AND COURT HOLDING JURISDICTION
The interpretation and execution of these terms and conditions are governed by the Italian law. The Court of Rome, Italy, shall hold exclusive jurisdiction for any legal dispute connected to said conditions. Victoria Torlonia SRL shall have the right to seek urgent legal remedy with any Court, including abroad, in order to protect its interest and ensure that its rights are respected.