Privacy policy

Privacy policy of www.strategysrl.eu

Strategy Automation S.r.l.
Via E. Fermi, 30 – Settimo Milanese – 20019 – Italia
P.IVA: 06818490960 – REA:MI 1917342
E-mail: info@strategysrl.eu

Types of Data collected

Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies, Usage Data, company name, email, first name, last name, phone number, mobile phone number, province, and municipality.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information displayed before the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all data requested by this Application is mandatory. If the User refuses to provide such data, it may be impossible for this Application to provide the Service. In cases where this Application indicates that certain data is optional, Users are free to refrain from communicating such data, without any consequence on the availability or functionality of the Service.

Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller.

The possible use of Cookies – or other tracking tools – by this Application or by third-party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disclose them, holding the Data Controller harmless from any liability towards third parties.

Methods and location of data processing

Methods of Processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
The processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other individuals involved in the organization of this Application (administrative, commercial, marketing, legal staff, system administrators) or external entities (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data. These external entities may also be designated as Data Processors by the Data Controller, if necessary. An up-to-date list of Data Processors can always be requested from the Data Controller.

Legal basis for processing
The Data Controller processes Personal Data relating to the User if one of the following conditions is met:

  • The User has given consent for one or more specific purposes;
    Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply where the processing of Personal Data is governed by European Data Protection legislation.
  • The processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
  • The processing is necessary to comply with 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 in the exercise of official authority vested in the Data Controller;
  • The processing is necessary for the pursuit of the legitimate interests of the Data Controller or a third party.

It is always possible to request the Data Controller to clarify the specific legal basis for each processing operation, and in particular to specify whether the processing is based on the law, a contract, or is necessary for the conclusion of a contract.

Location
The Data are processed at the Data Controller’s operating offices and at any other location where the parties involved in the processing are located. For further information, please contact the Data Controller.
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 location of the processing, the User may refer to the section regarding the details of Personal Data processing.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the United Nations, as well as information regarding the security measures adopted by the Data Controller to protect the Data.
In the event of any of the transfers described above, the User may refer to the respective sections of this document or request information from the Data Controller by contacting them using the contact details provided at the beginning of this document.

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

When the processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is withdrawn. Additionally, the Data Controller may be required to retain 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, Personal Data will be deleted. Therefore, once this period expires, the rights to access, deletion, correction, and data portability can no longer be exercised.

Purposes of Data Processing

The User’s Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Statistics, Displaying content from external platforms, Managing addresses and sending email messages, Spam protection, and Contacting the User.

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

Details on the processing of Personal Data

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

Contacting the user

  • Download Links: sending the user links to download files they have requested.
  • Contact Forms: by filling out the contact forms with their Data, the user consents to their use to respond to requests.

Remarketing and Behavioral Targeting
This type of service allows this Application and its partners to communicate, optimize, and serve advertisements based on the past use of this Application 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 involved in the remarketing and behavioral targeting activities.
In addition to the opt-out options offered by the services listed below, the User may opt-out from receiving cookies related to a third-party service by visiting the opt-out page of the Network Advertising Initiative.

  • AdWords Remarketing (Google Inc.)
    AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the DoubleClick Cookie.
    Personal Data collected: Cookies and Usage Data.
    Location of processing: USA – Privacy PolicyOpt Out.

Statistics
The services in this section allow the Data Controller to monitor and analyze traffic data and track the User’s behavior.

        • Google Analytics (Google Inc.)
          Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google.
          Google may use the Personal Data to contextualize and personalize ads in its advertising network.
          Personal Data collected: Cookies and Usage Data.
          Location of processing: USA – Privacy PolicyOpt Out.

        • Google AdWords Conversion Tracking (Google Inc.)
          Google AdWords Conversion Tracking is a statistics service provided by Google Inc. that links data from the Google AdWords network with actions taken within this Application.
          Personal Data collected: Cookies and Usage Data.
          Location of processing: USA – Privacy Policy.

        • Google Tag Manager (Google Inc.)
          Google Tag Manager is a statistics service provided by Google Inc.
          Personal Data collected: Cookies and Usage Data.
          Location of processing: USA – Privacy Policy.

        • Google Analytics with Anonymized IP (Google Inc.)
          Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Application, compile reports, and share them with other services developed by Google.
          Google may use the Personal Data to contextualize and personalize ads in its advertising network.
          This integration of Google Analytics anonymizes the User’s IP address. The anonymization works by shortening the IP address within the European Union Member States or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to Google’s servers and shortened within the United States.
          Personal Data collected: Cookies and Usage Data.
          Location of processing: USA – Privacy PolicyOpt Out.

        • Facebook (Facebook Inc.)
          Facebook is a social media and social networking platform.
          Personal Data collected: Cookies and Usage Data.
          Location of processing: USA – Privacy Policy.

Displaying content from external platforms

This type of service allows for content hosted on external platforms to be displayed directly on the pages of this Application and to interact with it.
In the event that such a service is installed, it is possible that, even if Users do not use the service, it may collect traffic data related to the pages on which it is installed.

YouTube Video Widget (Google Inc.)
YouTube is a video content display service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
Location of processing: USA – Privacy Policy.

Vimeo Video (Vimeo, LLC)
Vimeo is a video content display service managed by Vimeo, LLC that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
Location of processing: USA – Privacy Policy.

Google Maps Widget (Google Inc.)
Google Maps is a map display service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
Location of processing: USA – Privacy Policy.

Fonts.com Web Fonts (Monotype Imaging Holdings Inc.)
Fonts.com Web Fonts is a font style display service managed by Monotype Imaging Holdings Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Usage Data and various types of Data as specified by the service’s privacy policy.
Location of processing: USA – Privacy Policy.

Google Site Search (Google Inc.)
Google Site Search is an embedded search engine service managed by Google Inc. that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
Location of processing: USA – Privacy Policy.

User Rights

Users can exercise certain rights regarding the Data processed by the Data Controller.

In particular, the User has the right to:

  • Withdraw consent at any time. The User can withdraw their previously given consent to the processing of their Personal Data.
  • Object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided in the section below.
  • Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data being processed.
  • Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
  • Obtain restriction of processing. When certain conditions are met, the User can request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose except for storage.
  • Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Data Controller.
  • Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format, and, where technically feasible, to have it transferred without hindrance to another controller. This provision applies when the Data is processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party, or related pre-contractual measures.
  • File a complaint. The User can file a complaint with the competent personal data protection authority or seek judicial action.

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of public authority 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.

It is noted that, if their Data is processed for direct marketing purposes, Users can object to the processing without providing any justification. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to Exercise Rights

When Personal Data is processed in the public interest, in the exercise of public authority 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.

It is noted that if their Data is processed for direct marketing purposes, Users can object to the processing without providing any justification. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

Cookie Policy

This Application uses Cookies. To learn more and view the detailed notice, the User can consult the Cookie Policy.

Ulteriori informazioni sul trattamento

  • Difesa in giudizio
    I Dati Personali dell’Utente possono essere utilizzati da parte del Titolare in giudizio o nelle fasi preparatorie alla sua eventuale instaurazione per la difesa da abusi nell’utilizzo di questa Applicazione o dei Servizi connessi da parte dell’Utente.
    L’Utente dichiara di essere consapevole che il Titolare potrebbe essere obbligato a rivelare i Dati per ordine delle autorità pubbliche.
  • Informative specifiche
    Su richiesta dell’Utente, in aggiunta alle informazioni contenute in questa privacy policy, questa Applicazione potrebbe fornire all’Utente delle informative aggiuntive e contestuali riguardanti Servizi specifici, o la raccolta ed il trattamento di Dati Personali.
  • Log di sistema e manutenzione
    Per necessità legate al funzionamento ed alla manutenzione, questa Applicazione e gli eventuali servizi terzi da essa utilizzati potrebbero raccogliere Log di sistema, ossia file che registrano le interazioni e che possono contenere anche Dati Personali, quali l’indirizzo IP Utente.
  • Informazioni non contenute in questa policy
    Ulteriori informazioni in relazione al trattamento dei Dati Personali potranno essere richieste in qualsiasi momento al Titolare del Trattamento utilizzando gli estremi di contatto.
  • Risposta alle richieste „Do Not Track”
    Questa Applicazione non supporta le richieste “Do Not Track”.
    Per scoprire se gli eventuali servizi di terze parti utilizzati le supportino, l’Utente è invitato a consultare le rispettive privacy policy.
  • Modifiche a questa privacy policy
    Il Titolare del Trattamento si riserva il diritto di apportare modifiche alla presente privacy policy in qualunque momento dandone informazione agli Utenti su questa pagina e, se possibile, su questa Applicazione nonché, qualora tecnicamente e legalmente fattibile, inviando una notifica agli Utenti attraverso uno degli estremi di contatto di cui è in possesso il Titolare . Si prega dunque di consultare regolarmente questa pagina, facendo riferimento alla data di ultima modifica indicata in fondo. Qualora le modifiche interessino trattamenti la cui base giuridica è il consenso, il Titolare provvederà a raccogliere nuovamente il consenso dell’Utente, se necessario.

Definitions and Legal References

  • Personal Data (or Data)
    Personal data means any information that, directly or indirectly, including in connection with any other information, such as a personal identification number, can identify or make a physical person identifiable.

    Usage Data
    This refers to information collected automatically through this Application (also by third-party applications integrated into this Application), including: the IP addresses or domain names of computers used by the User connecting to this Application, URI (Uniform Resource Identifier) addresses, request times, methods used to forward the request to the server, the size of the file obtained in response, numerical codes indicating the response status from the server (success, error, etc.), the country of origin, the browser and operating system characteristics used by the visitor, various time-related aspects of the visit (e.g., the duration spent on each page), and details related to the route followed within the Application, particularly regarding the sequence of pages viewed, parameters related to the operating system and the User’s IT environment.

    User
    The individual who uses this Application, who, unless otherwise specified, coincides with the Data Subject.

    Data Subject
    The natural person to whom the Personal Data refers.

    Data Processor (or Processor)
    The individual, legal entity, public authority, or any other body that processes personal data on behalf of the Controller, as described in this privacy policy.

    Data Controller (or Controller)
    The individual or legal entity, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of processing personal data and the tools used, including security measures related to the operation and use of this Application. Unless otherwise specified, the Data Controller is the entity responsible for this Application.

    This Application
    The hardware or software tool through which the User’s Personal Data is collected and processed.

    Service
    The service provided by this Application as defined in the relevant terms (if any) on this site/application.

    European Union (or EU)
    Unless otherwise specified, any reference to the European Union in this document is extended to all current member states of the European Union and the European Economic Area.

    Cookie
    A small piece of data stored within the User’s device.

    Legal References
    This privacy policy is drafted based on multiple legal frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.
    Unless otherwise specified, this privacy policy applies solely to this Application.

Last revision: July 15, 2024