PRIVACY POLICY

Your data is safe

For 25+ years, Luigi Norsa & Associati has guided public and private organizations through expert complex crisis and issue management services.

PRIVACY POLICY

Your data is safe

For 25+ years, Luigi Norsa & Associati has guided public and private organizations through expert complex crisis and issue management services.

Privacy Policy

Dear User, Luigi Norsa & Associati (hereinafter also “Company” or “Controller”) informs you, in compliance with current legislation on personal data protection and, in particular, pursuant to EU Regulation 2016/679 (GDPR) and Legislative Decree 196/2003 (Personal Data Protection Code, so-called “Privacy Code”), that the personal data provided by you or otherwise acquired within the scope of the activity carried out in relation to the Site www.luiginorsa.com (hereinafter “Site” or “Website”) may be subject to processing, in compliance with the obligations of lawfulness, transparency, proportionality, security, and confidentiality provided for by current legislation.

The Site is owned by Luigi Norsa & Associati. This privacy policy is provided solely for this Site and not for third-party websites that may be consulted by the User via links.

Index

Data Controller
Purposes and methods of processing
Nature of data provision and consequences of refusal
Place of data processing
Types of data processed/specific processing
Data retention period
Subjects and categories of subjects to whom personal data may be communicated or who may become aware of it as data processors or persons in charge – scope of data dissemination
Rights of data subjects
Right of revocation and objection

Art. 1. Data Controller

The Data Controller is Luigi Norsa & Associati (Tax ID/VAT No.: 12862950156), Tel.: +39 3471058825, E-mail: info@luiginorsa.com.

Art. 2. Purposes and methods of processing

Following the consultation of this Site and the use of one or more services, data relating to identified or identifiable natural persons may be processed. The personal data acquired, always in compliance with current legislation, will be processed exclusively for the following purposes:

a) access and use of the Site, its features, and requested services; creation of a personal account and potential purchase of paid services, or for the execution of the requested service and/or one or more contractually agreed operations; b) fulfillment of obligations provided for by law and the European Union; c) operational and/or management needs internal to the Data Controller and inherent to the services and/or products offered through the site; d) provision of the newsletter service; e) carrying out surveys aimed at verifying the degree of satisfaction regarding the services offered.

In the event of explicit and optional expression of consent by the data subject, the data collected for the purposes referred to in paragraph 1 may also be processed for direct marketing and/or promotional purposes by the Controller, in particular for sending information, commercial, or advertising material relating to the services and/or products offered through the Site, including via email, SMS, MMS, and fax. In this sense, the aforementioned expression of consent may determine, depending on what you have expressed: a) the sending of commercial information by Luigi Norsa & Associati, connected to the activities carried out by the same and/or by third parties; b) the sending of commercial information by third parties, connected to the activities carried out by Luigi Norsa & Associati and/or by third parties.

The data will be processed lawfully, fairly, and in proportion to the purposes referred to in the preceding paragraphs. Data processing will take place using suitable tools to guarantee security and confidentiality and may be carried out using paper-based tools and/or automated tools designed to store, manage, and transmit the data itself.

Art. 3. Nature of data provision and consequences of a refusal to respond

The provision of personal data is mandatory only for the purposes referred to in Art. 2, paragraph 1, letters a), b), c), and d), specifically to guarantee the use of the site, the related services requested by the user, or for the fulfillment of legal obligations, for which appropriate information may be provided in the manner and terms established by law. Any refusal to the relative processing may prevent the stipulation or execution of contractual relationships, fulfillments, or related legal obligations. It will still be possible to consult the Site without providing any personal data, but certain features may not be available and certain services may not be provided.

The provision of personal data and the release of consent for the relative processing for the purposes referred to in Art. 2, paragraph 1, letters d) and e) and Art. 2, paragraph 2 is optional. In the absence of explicit consent, such services will not be provided, and the User will not receive the newsletter or requests aimed at verifying the degree of satisfaction relating to the services offered (Art. 2, paragraph 1, letters d and e), including the commercial information indicated above (Art. 2, paragraph 2), without further consequences.

If the user does not intend to provide their consent for such purposes, they may still use the Site and services for the purposes referred to in Art. 2, paragraph 1. In particular, the consequences of any refusal to respond or to provide consent will always be made explicit and connected to each service rendered: by way of example, any refusal to the relative processing may prevent consultation of the Site and its features (in the case of cookies), receipt of the newsletter (in the case of the newsletter service offer), or receipt of advertising material (in the case of Art. 2, paragraph 2). Therefore, the User will be adequately informed through the methods provided for each specific case, but in any case, they may consult the Website even if they deny consent to the processing of personal data, where requested; in this hypothesis, certain features or characteristics of the site may be disabled.

Art. 4. Place of data processing

The processing connected to the web services of this Site is carried out at the headquarters of Luigi Norsa & Associati, subject to explicit exceptions, and is handled only by technical personnel authorized for processing following explicit indication by the Controller.

Art. 5. Types of data processed/specific processing

Depending on the service rendered, personal data of different types may be processed, as specified in this article.

5.1 Navigation Data

The computer systems and software procedures used to operate this Website acquire, during 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 interested parties; however, by its very nature, it could, through processing and association with data held by third parties, allow users to be identified. This category includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit 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, and other parameters relating to the operating system and the user’s IT environment. The above data will be used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning; they will be deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this possibility, currently, web contact data does not persist for more than seven days. Regarding cookies, please refer to par. 5.4.

5.2.1 Data voluntarily provided by the user (communications and Site registration)

The optional, explicit, and voluntary sending of communications via contact forms or via email to the addresses on the Site, or the data provided during registration on the Site, entails the subsequent acquisition of said data by Luigi Norsa & Associati, including the email address, the consent to receive any response messages to requests, and the use of the data provided to carry out the received assignments. The personal data thus provided will be used for the sole purpose of satisfying or responding to the transmitted requests and will be communicated to third parties only if this is necessary for that purpose. Data retention will take place with times and methods not exceeding the achievement of the purposes connected to the processing carried out. Any specific information notices prepared for particular services requested by the user will be reported on the relevant pages of the Site, and the related processing activities will be carried out subject to the voluntary and optional provision of consent by the data subject, where necessary, as provided for in the following Art. 4.

5.2.2 Data voluntarily provided by the user (to receive communications for marketing and/or commercial promotion purposes)

Each interested party may voluntarily provide their personal data to Luigi Norsa & Associati in order to receive commercial or promotional communications however named, in digital or paper form. Only in the case where email coordinates are provided by the interested party in the context of the sale of a service, the email address thus provided may be used for the direct sale of further similar services, pursuant to Art. 130, paragraph 4, Legislative Decree 196/2003, without the need for express and prior consent (so-called “soft spam”). Every communication, in any case, will remind the interested party of the possibility to revoke consent at any time and without further formalities. Data deletion may occur upon explicit request of the interested party.

5.3 Newsletter

The Luigi Norsa & Associati newsletter is sent via email to those who explicitly request it by filling out the appropriate form on the website www.luiginorsa.com, possibly selecting specific items of interest via the filters provided by the Site, and authorizing Luigi Norsa & Associati to process their personal data for the aforementioned purpose. Consent: The provision of data is mandatory only for the purpose of receiving the newsletter, and any refusal will result in the impossibility of using the service, without further consequences. Purpose: The personal data provided by users will be used for the sole purpose of sending the newsletter and will not be disclosed to third parties. Methods: The collected data will be processed using IT tools; in order to prevent loss, illicit or incorrect use, or to prevent unauthorized access to the site, specific security measures are adopted. Unsubscribing from the service: To stop receiving the newsletter, simply select the unsubscribe link present at the end of each email, or send a specific request to the email address info@luiginorsa.com. Cancellation is managed automatically, so further newsletters may be received for a period subsequent to such request, in any case not exceeding 72 hours from forwarding, provided their sending was planned prior to the receipt of the cancellation request.

5.4.1 Cookies

What are they?

Cookies are information stored by the browser when visiting a website using any suitable device (such as a PC, tablet, or smartphone). Each cookie may contain a unique identification code associated with various data (e.g., the name of the server it comes from, a numerical identifier, etc.), which can be stored by the system for the duration of a session (usually until the browser is closed) or for long periods.

What are they for?

Cookies are used for different purposes depending on their type: some are strictly necessary for the correct functionality of a website (technical cookies), while others optimize performance to offer a better user experience or allow statistics to be acquired on site usage (such as analytics cookies). Other types, such as profiling cookies, allow the display of personalized advertising based on the user’s browsing data.

Consent:

Any provision of user consent is stored by the Agency, insofar as it is responsible, using a technical cookie lasting 12 months. The user is informed both through the brief notice (banner displayed until consent is given or denied, as explained in paragraph 5.4.4. “How to disable cookies?”) and through this extended policy; furthermore, paragraph 5.4.3 indicates links to third-party privacy policies, also for the purpose of disabling them (where directly available through them).

How to disable them?

It is possible to disable cookies both through browser settings (par. 5.4.4. “How to disable cookies?”) and through mechanisms made available by some third parties (par. 5.4.3 “Cookies used on the site”).

5.4.2 General types of cookies used on the site

Technical cookies (first party): Technical cookies necessary for the functioning of the site are present, as well as to store the user’s consent to the use of cookies. They have the following purposes: session maintenance; functioning of the cart and purchase order; calculation of prices and price lists; display in Italian, English, or Japanese; display and shipping prices according to the shipping nation; insertion and processing of search filters; storage of user consent to the use of cookies. Analytical cookies (second party): Used for aggregate analysis of site visits, through the use of a third-party service. Profiling cookies (third party): Used to create profiles relating to the user and used to send advertising messages in line with the preferences expressed by the same during web browsing, through the use of a third-party service.

5.4.3 Cookies used on the site

First-party cookies: Technical cookies necessary for the functioning of the site are present, having the following purposes: session maintenance; functioning of the cart and purchase order; calculation of prices and price lists; display in Italian, English, or Japanese; display and shipping prices according to the shipping nation; insertion and processing of search filters (duration: session). There are also cookies for the purpose of storing the user’s consent to the use of cookies (duration: 12 months).

Analytical cookies:

Google Analytics

Profiling cookies:

Google Inc.

Microsoft: https://privacy.microsoft.com/en-us/privacystatement

Criteo: https://www.criteo.com/privacy/ (also for disabling – opt-out)

Yandex: https://yandex.com/legal/privacy/

DoubleClick: https://www.doubleclick.net

BatBing: https://www.bing.com

Facebook

Twitter: https://twitter.com/en/privacy

Pinterest: https://policy.pinterest.com/en/privacy-policy and https://policy.pinterest.com/en/cookies

5.4.4 How to disable cookies?

Browser control: Commonly used browsers (e.g., Microsoft Internet Explorer/Edge, Firefox, Google Chrome, Opera, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: it is a generally and widely supported function. Therefore, cookies can easily be deactivated or disabled by accessing the options or preferences of the browser used, with the possibility of deactivating only third-party cookies; in general, these options will only affect the browser and device in use, unless options to unify preferences across different devices are active. Specific instructions can be found on the options or help page of the browser itself. Disabling technical cookies, however, may affect the full and/or correct functioning of various sites, including this site.

Normally, browsers currently used:

– Offer the “Do not track” option, which is supported by some websites (but not all). In this way, some websites may no longer collect certain navigation data;

– Offer the option of anonymous or incognito browsing: in this way, data will not be collected in the browser and browsing history will not be saved, but navigation data will still be acquirable by the operator of the website visited;

– Allow stored cookies to be deleted in whole or in part, but in the event of a new visit, they will normally be installed where such possibility has not been blocked.

Links to the support pages of the most popular browsers (with instructions on disabling cookies on such browsers) are indicated below:

Firefox (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)

Microsoft Edge (https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09)

Safari (iOS) (https://support.apple.com/en-us/HT201265)

Chrome (https://support.google.com/chrome/answer/95647?hl=it)

Opera (https://help.opera.com/en/latest/web-preferences/#cookies)

Third-party cookies: Third-party cookies can be disabled both via the method described above and by referring to each third party (following the links indicated in the previous paragraph). Online tools: On the site http://www.youronlinechoices.com/ it is possible not only to acquire further information on cookies but also to verify the installation of numerous cookies on one’s browser/device and, where supported, also disable them.

Art. 6. Data retention period

The data provided will be stored for the times prescribed by law and, in any case, for the time strictly necessary to follow up on the activities for which they were collected and/or until the revocation of the consent given for the purposes referred to in Art. 2, paragraph 2, or in any case until an express request by the User provided in this sense. The personal data collected will in any case be stored for no longer than twenty-four months for the marketing purposes referred to in Art. 2, paragraph 2 (subject to any amendments and/or additions to the relevant legislation on personal data protection which will be expressly communicated).

Art. 7. Subjects and categories

Subjects and categories of subjects to whom personal data may be communicated or who may become aware of it as data processors or persons in charge – scope of data dissemination. The processing of data provided by the User or otherwise acquired within the scope of our activity may also be carried out by subjects who are recognized the right to access personal data by law, regulations, or European Union standards.

For the purposes referred to in Art. 2, where necessary and only with prior explicit consent, the acquired personal data may be communicated to third parties: (i) on whose collaboration Luigi Norsa & Associati may and/or must rely for the fulfillment of the aforementioned purposes; (ii) within the limits strictly relevant to the execution of the assignments received from the interested party. The data acquired via the web, or in any case deriving from the web services provided, may be communicated to technological and instrumental partners used by the Controller for the provision of the services requested by Users.

The Controller prepares and makes available to interested parties a list communicating the personal data collected for the aforementioned purposes, which may be provided following a specific request sent to the Controller, at the contacts indicated on the Site and in this policy.

Art. 8. Rights of data subjects

The data subject is the identified or identifiable natural person to whom the personal data being processed refers.

We inform you that the data subject is recognized the right to access at any time the data concerning them processed by the Controller (right of access), in order to verify the correctness and lawfulness of the processing carried out. The data subject may also exercise all rights recognized by current national and European legislation on personal data protection (from Legislative Decree 196/2003 and from EU Reg. no. 2016/679 and subsequent amendments and additions): in particular, they may request at any time the correction and update of incorrect or inaccurate data, the limitation of the processing carried out, and the cancellation of the same (right to be forgotten), as well as propose a complaint to the Guarantor Authority for the protection of personal data. With reference to personal data processed by automated means, the data subject is finally recognized the right to receive in a structured and commonly used format the data concerning them and to transmit them, possibly, to another data controller (right to data portability).

Any request regarding the processing of personal data and any communication relating to the exercise of one’s rights may be addressed to the Controller using the appropriate “Contact” form on the Site or by sending a communication via email to the address info@luiginorsa.com.

Art. 9. Right of revocation and objection

Each interested party is also recognized the right to revoke the consent given at any time, without prejudice to the lawfulness of the processing carried out by the controller prior to such revocation. The interested party is also always recognized the possibility to object to the processing of data concerning them if carried out for direct marketing purposes referred to in Art. 2, paragraph 2; in this case, your data will no longer be subject to processing for such purposes (right of objection).

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