Privacy Policy di www. hvmfinance.it

This Website collects some Personal Data of its Users. This privacy statement is drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy applies exclusively to this Website.

Data Controller

HVM Finance

Dr. Alessandro Vannucci

Rubens Street 10

20148 Milan

info@hvmfinance.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies, Usage Data, phone number, email address, first and last name.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of the data. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website. Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation. Users who have doubts about which Data are mandatory, are encouraged to contact the Owner. Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Methods and place of processing of collected data

Processing methods

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of the Personal Data. The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessed by other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Owner. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to such processing. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• the processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the Owner.The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section on the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as about the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Owner by contacting him at the details indicated at the beginning.

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of the Processing of Collected Data

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Interaction with external social networks and platforms, Contacting the User, Displaying content from external platforms, Analytics, SPAM protection, Managing contacts and sending messages, Interaction with data collection platforms and other third parties, Registration and authentication,  Remarketing and behavioral targeting, Traffic optimization and distribution, and Interaction with live chat platforms.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Contacting the User

Contact by phone (This Website)

Users who have provided their telephone number may be contacted for commercial or promotional purposes related to this Website, as well as to satisfy support requests.

Personal Data collected: telephone number.

Contact form (This Website)

By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form’s header.

Personal Data collected: surname, email address, first name and telephone number.

• Managing contacts and sending messages

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User. These services may also allow us to collect data relating to the date and time of display of the messages by the User, as well as the User’s interaction with them, such as information on clicks on the links inserted in the messages.

• Interaction with data collection platforms and other third parties
• Interaction with external social networks and platforms
• SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc. (“Google”).

Personal Data collected: Cookies and Usage Data.

Place of processing: USA–
Privacy Policy.

• Registration and authentication

By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services. Depending on the following, registration and authentication services may be provided with the help of third parties. If this happens, this application will be able to access some Data stored by the third-party service used for registration or identification.

Direct registration (This Website)

The User registers by filling out the registration form and providing their Personal Data directly to this Website.

Personal Data collected: surname, email address, first name and telephone number.

• Remarketing e behavioral targeting

This type of service allows this Website and its partners to communicate, optimize and serve advertisements based on the past use of this Website by the User. This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to whom the remarketing and behavioral targeting activity is linked. In addition to the opt-out options offered by the services below, the User can opt out of receiving cookies related to a third-party service by visiting the Opt-out page of the Network AdvertisingInitiative.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. (“Facebook”). that connects the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA –
Privacy Policy  –  Opt Out.

• Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of the User’s behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.Google may use Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: USA –
Privacy Policy  –  Opt Out.

• Viewing content from external platforms

User Rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
• oppose the processing of their Data. The User can object to the processing of their Data when it takes place on a legal basis other than consent. Further details on the right to object can be found in the section below.
• access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
• obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
• obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
• receive your Data or have them transferred to another holder. The User has the right to receive their Data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain its transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User’s consent, on a contract of which the User is a party or on contractual measures connected to it.
• propose a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are informed that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the Rights of the User, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Cookie Policy

This Website uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.

Further information on the treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its possible establishment for the defense against abuse in the use of this Website or related Services by the User. The User declares to be aware that the Owner may be obliged to disclose the Data by order of public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Website and any third-party services used by it may collect system logs, which are files that record interactions and that may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Responding to “Do Not Track” requests

This Website does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Modifications to the present privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website and, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please therefore consult this page regularly, referring to the date of last modification indicated at the bottom.

If the changes affect treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Personal data is any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This information is collected automatically through this Website (including from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server,  the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Application,  with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Data Processor)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website(or this Application)

The hardware or software tool through which the Users’ Personal Data are collected and processed.

Service

The Service provided by this Website as defined in the relative terms (if any) on this site / application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie

Small portion of data stored within the User’s device.

Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including Articles. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies exclusively to this Website.

Latest update: May 14, 2018