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Affidia Srl SB, with registered offices at via San Lazzaro 17, Trieste (“Affidia”), is committed to protecting the online privacy of the users of this website (“”). As such, this Privacy Policy has been written in order to allow you to understand Affidia’s policy regarding your privacy, as well, as how your personal information will be handled when using the Website. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to Affidia over the Website, or which is otherwise gathered via the Website, in the context of the use of Affidia’s services (“Services”) as better defined in Section 3 below, will be processed by Affidia in a lawful, fair and transparent manner. To this end, and as further described below, Affidia takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.


1. Data controller and Data Protection Officer
2. Personal Data processed
a. Name, contact details and other Personal Data
b. Other persons’ Personal Data
c. Browsing data
d. Cookies
3. Purposes of processing
4. Grounds for processing and mandatory or discretionary nature of processing
5. Recipients of Personal Data
6. Transfer of Personal Data
7. Retention of Personal Data
8. Data subjects’ rights
9. Amendments

1. Data controller and Data Protection Officer

Affidia, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the Website.
To get in touch with Affidia’s Data Protection Officer, please contact:

2. Personal Data processed

When you use the Website, Affidia will collect and process information regarding you (as an individual) which allows you to be identified either by itself, or together with other information which has been collected. Affidia may also be able to collect and process information regarding other persons in this same manner, if you choose to provide it to Affidia.
This information may be classified as “Personal Data” and can be collected by Affidia both when you choose to provide it (e.g., when you subscribe to the newsletter or request other services provided by Affidia over the Website or simply by analysing your behaviour on the Website.
Personal Data which can be processed by Affidia through the Website are as follows:

a. Name, contact details and other Personal Data

Whenever you communicate with Affidia through the contact details provided in the Website, Affidia may collect additional information which you choose to provide.

b. Other persons’ Personal Data

As mentioned in the previous section, certain areas of the Website (like Contacts) include free text fields where you can write messages to Affidia. These messages and content may (inadvertently or not) include Personal Data related to other persons.
In any situation where you decide to share Personal Data related to other persons, you will be considered as an independent data controller regarding that Personal Data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Affidia against any complaints, claims or demands for compensation for damages which may arise from the processing of this Personal Data, brought by the third parties whose information you provide through the Website.
As Affidia does not collect this information directly from these third parties (but rather collects them, indirectly, from you), you must make sure that you have these third parties’ consent before providing any information regarding them to Affidia; if not, then you must make sure there is some other appropriate grounds on which you can rely to lawfully give Affidia this information.

c. Browsing data

The Website’s operation, as is standard with any websites on the Internet, involves the use of computer systems and software procedures, which collect information about the Website’s users as part of their routine operation. While Affidia does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information, or by using other information collected – as such, this information must also be considered Personal Data.
This information includes several parameters related to your operating system and IT environment, including your IP address, location (country), the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the Website, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on.
These data are used to compile statistical information on the use of the Website, as well as to ensure its correct operation and identify any faults and/or abuse of the Website. Save for this last purpose, these data are not kept for more than 7 business days.

d. Cookies

– Definitions, characteristics, and application of standards
Cookies are small text files that may be sent to and registered on your computer by the websites you visit, to then be re-sent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.
Cookies are used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., “third-party cookies”).
There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their pre-set expiration period passes.
According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used on a website. In particular, “technical cookies” – i.e. cookies which are only used to send messages through an electronic communications network, or which are needed to provide services you request – typically do not require this consent. This includes browsing or session cookies (used to allow users to login) and function cookies (used to remember choices made by a user when accessing the website, such as language or products selected for purchase).
On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and to send advertising messages in line with the preferences revealed by users while browsing websites – typically require specific consent from users, although this may vary according to the applicable law.

– Types of cookies used by the Website
The Website uses the following types of cookies:
Browsing or session cookies, which are strictly necessary for the Website’s operation, and/or to allow you to use the Website’s content and Services.
Analytics cookies, which allow Affidia to understand how users make use of the Website, and to track traffic to and from the Website.
Affidia also uses third-party cookies – i.e. cookies from websites / web servers other than the Website, owned by third parties. These third parties will either act as independent data controllers from Affidia regarding their own cookies (using the data they collect for their own purposes and under terms defined by them) or as data processors for Affidia (processing personal data on Affidia’s behalf). For further information on how these third parties may use your information, please refer to their privacy policies:
• Google Analytics and advertising cookies

– Cookies present on the Website
In detail, the cookies present on the Website are as follows:
Technical name: AFFIDIA
Data Controller: jsessionid
Cookie type, function and purpose: platform session cookie used by sites with JavaServer Pages (JSP). The cookie is used to maintain an anonymous user session by the server
Duration: until the end of browser.

– Cookie settings
You can block or delete cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. We inform you however that not allowing technical cookies could make it impossible to use the website, view its contents and use the relative services. Inhibit functional cookies may mean that some services or certain functions of the Site are not available or do not work properly and you may have to change or manually enter some information or preferences each time you visit the website.
The choices made regarding the website’s cookies will in turn be recorded in a special cookie. This cookie may, however, in some circumstances not function properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use also through the functionality of your browsers.
Your preferences in relation to cookies will have to be reset if you use different devices or browsers to access the site.
How to view and modify cookies through the Browser
You can authorize, block or delete (in whole or in part) cookies through the specific functions of your Browser.
For more information on how to set the preferences for cookies via your browser, please refer to the following instructions:
– Internet Explorer
– Firefox
– Chrome
– Safari

You may also provide set your preferences on third-party cookies by using online platforms such as AdChoice.
CAUTION: If you block or delete technical and/or function cookies used by the Website, the Website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

3. Purposes of processing

Affidia intends to use your Personal Data, collected through the Website, for the following purposes:
– To verify your identity and assist you, in case you lose or forget your login / password details for any of Affidia’s registration services, to allow you to create and maintain a registered user profile, to send you newsletters you have subscribed to as a service (containing only informative content), to finalise purchase orders and deliver products bought on the Websites and to provide any other Services which you may request (“Service Provision”);
– For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, over the phone, through push notifications / pop-up banners, instant messaging, through an operator, through Affidia’s official social media pages, […], regarding Affidia’s products and services (“Marketing”);
– To create a profile of you as a Website user, through the use of profiling cookies and by collecting and analysing information on the preferences you select and choices you make in the Website, as well as your general activities on the Website. This profile will be used to give you information about other websites / services which Affidia believes you may be interested in, and to show you information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
– For compliance with laws which impose upon Affidia the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
– To prevent and detect any misuse of the Website, or any fraudulent activities carried out through the Website (“Misuse/Fraud”).

4. Grounds for processing and mandatory / discretionary nature of processing

Affidia’s legal bases to process your Personal Data, according to the purposes identified in Section 3, are as follows:
Service Provision: processing for these purposes is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Affidia your Personal Data for these purposes; however, if you do not, Affidia will not be able to provide any Services to you. The same applies to the newsletter service that arises from your specific request by entering an e-mail address and which you can revoke at any time by following the instructions provided in Paragraph 8 of this Policy.
Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Affidia for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from Affidia). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
Compliance: processing for this purpose is necessary for Affidia to comply with its legal obligations. When you provide any Personal Data to Affidia, Affidia must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the Website (for potentially criminal purposes).

5. Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):
– Persons, companies or professional firms providing Affidia with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of Affidia;
– Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
– Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
– Persons authorised by Affidia to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Affidia);
– Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.

6. Transfers of Personal Data

Affidia does not transfer your data out of the European Economic Area.

7. Retention of Personal Data

Personal Data processed for Service Provision will be kept by Affidia for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Affidia may continue to store this Personal Data for a longer period, as may be necessary to protect Affidia’s interests related to potential liability related to the provision of the Services.
Personal Data processed for Marketing and Profiling will be kept by Affidia from the moment you give consent until it is withdrawn. Where it is not withdrawn, consent will be renewed at fixed intervals. Once consent is withdrawn (or not given, following a renewal), Personal Data will no longer be used for these purposes, although it may still be kept by Affidia, in particular as may be necessary to protect Affidia’s interests related to potential liability related to this processing.
Personal Data processed for Compliance will be kept by Affidia for the period required by the specific legal obligation or by the applicable law.
Personal Data processed for preventing Misuse/Fraud will be kept by Affidia for as long as deemed strictly necessary to fulfil the purposes for which it was collected and therefore until the moment in which Affidia will be required to keep them to protect themselves in court to communicate said data to the competent authorities.

8. Data subjects’ rights

As a data subject, are entitled to exercise the following rights before Affidia, at any time:
– Access your Personal Data being processed by Affidia (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
– Correct or update your Personal Data processed by Affidia, where it may be inaccurate or incomplete;
– Request erasure of your Personal Data being processed by Affidia;
– Request the restriction of the processing of your Personal Data;
– Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Affidia, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
– Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Affidia from processing your Personal Data; or Withdraw your consent to processing (for Marketing and Profiling).
You can withdraw the consent to the Marketing sent by e-mail by sending an e-mail in response to the e-mail received. The same method can be used to interrupt the receipt of the Affidia newsletter, where the request was made as a Service.
In any case, you always have the right to lodge a complaint with the competent Control Authority (Guarantor for the Protection of Personal Data) if you believe that the processing of your Personal Data is contrary to the legislation in force.

9. Amendments

This Privacy Policy entered into force on 18/04/2019.
Affidia reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Affidia will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Website. Affidia therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Affidia collects and uses Personal Data.





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