This document was drafted pursuant to art. 13 of EU Regulation 2016/679 (hereafter “Regulation”) in order to let you know our privacy policy, to understand how your personal information is handled when you are using our website.

Definitions

“Personal Data” (art. 4, n. 1 of Regulation): any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Processing” (art. 4, n. 2 of Regulation): any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

Data Controller and contacts

Registered office: Milano (MI), Corso Magenta, n. 56
Operational headquarters: Milano (MI), via Torri Bianche, n. 10
Tel.: +(39).039.657081
E-mail: privacy@finconsgroup.com

Data Protection Officer
Avv. Luca Biffi
Tel: +(39).039.657081
E-mail: dpofincons@finconsgroup.com

 

Navigation Data

The computer systems and software procedures used to opertate this website, 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 subjects, but by their very nature they may allow to identify users through processing and association with data held by third parties.

This category of data includes IP addresses or domain names of the computers used by users who connect to the website, the addresses in the URI (Uniform Resourse Identifier) notation of the requested resources, the time of request, the method used to submit the request to the server, and other parameters related to the operating system and the user’s computer environment.

These data are used for the only purpose to obtaining anonymous statistical information on the use of the website and to check its correct functioning, to identify anomalies and abuses, and are immediately deleted after being processed.

These data may be used to ascertain responsibility in case of computer crimes.

 

Other purposes of the processing of Personal Data

Subject to user’s prior express consent and until that consent is withdrawn, any personal data that may be included in a customer relationship management system (CRM), may also be processed for marketing purposes, in other words, by way of example, for the sending of promotional and commercial communications related to services offered by FINCONS, as notification of events, both by automated means of contact (e.g. SMS, fax, e-mail and web applications) and by traditional means of contact (such as telephone calls with an agent and traditional mail).

You shall then be prompted via an online form on our website or by other procedures to provide your consent to the processing of your personal data for such purposes. If you withold or withdraw your consent to the marketing purposes described above, your data shall be processed only for the purposes referred to in the previous paragraph.

With regard to the e-mails that will be sent, the following actions performed by the user shall be tracked by means of technical cookies:

– actual receipt of the e-mail;
– opening of the e-mail;
– any action carried out (such as clicking on a link contained in the e-mail).

Any of user’s personal data thay may be collected in accordance with the method described above shall be processed only for technical reasons and, in particular, in order to confirm that the e-mail was properly sent and received, as well as to verify for statistical purposes, in aggregated form, any accessing of the website. The legal basis for the processing is the consent user has given FINCONS where appropriate.

User’s personal data and contact details shall be retained for no more than 24 months, given that user can withdraw consent at any time.

With regard to additional processings which are not mentioned in this policy, it is only about section “Job”.

*Recipients of Personal data

User’s personal data may be shared, for the purposes referred to above, with contractors** providing professional services in EU countries:

Controller’s Managers and Personnel;
IT services companies.
(**) the list of external personal data processors/recipients is available at the Controller’s headquarters.

 

List of cookie in this site

Google Analytics with anonymized IP

These are profiling cookies but with anonymized IP

• __utma. Duration: persistent. Count the number of user visits
• __utmb and __utmc. Duration: ends at the end of the session. It is used to calculate the duration of visits by users
• __utmt. Duration: 10 minutes. It is used to set the rate of requests for the service
• __utmv. Duration: persistent. It serves Google to classify the user for personalized reports in Google Analytics
• __utmz. Duration: 6 months. It is used to calculate the origin of the visitor.

WordPress Platform

• wordpress_test_cookie. Duration: ends at the end of session. It tests that the browser accepts cookies.

Cookie Policy

Cookies are text files, or parcels of information sent from a web server (the website www.finconsgroup.com) to the user’s browser, which are memorised on the computer and automatically returned to the server every time the website is accessed.

There are various types of cookies, some used to make using the website more efficient, others to enable certain functions. For example, cookies can:

• memorise entered preferences;

• prevent users from having to re-enter the same information several times during their visit, for example username and password;

• analyse use of the services and contents provided by the website visited in order to optimise the browsing experience and services offered.

Types of Cookies used by the Fincons website

The types of cookies used by the Fincons website are listed below, grouped according to their reasons for use.

Technical Cookies

This type of Cookie allows certain sections of the Website to function correctly and are essential in order to allow the user to browse the Website and use its features. There are two categories of technical cookies:

• persistent: once the browser has been closed these are not cancelled, but last until a pre-defined expiry date;

• session: these are automatically cancelled each time the browser is closed.

These cookies, always sent by the “finconsgroup.com” domain, are necessary for the correct visualisation of the website and, in relation to the technical services offered, will therefore always be used and sent (unless the user modifies the settings in his or her browser). Included in this category are the persistent cookies used to allow the user to register with the website and access its restricted area.

The aforementioned cookies used by the website avoid the need to use other data processing techniques which could potentially reduce the confidentiality of the users’ navigation of the website, and do not permit the acquisition of identifying personal information regarding the user.

 

Functionality Cookies

Cookies in this category are used to memorise certain settings selected by the user, in order to remember their preferences during future visits.

These cookies can have the duration of a session but they are generally persistent and sent from the “finconsgroup.com” domain. They may also be used when providing a service not explicitly requested by, but provided to the user.

The information gathered by these cookies is anonymous and cannot track the user’s behaviour on other websites.

Included in this category, for example, are cookies used primarily to memorise the user’s preferences regarding the country of origin and therefore the language in which the text of the website is viewed.

 

Performance Cookies

The cookies in this category (which also include so-called “cookie analytics”) are used to gather information regarding use of the website.

The Fincons website uses this information to obtain anonymous statistical analyses in order to improve use of its website and to adapt its contents to the desires of its visitors. This type of cookies gathers information anonymously regarding the user’s activity and how he/she arrived at the website.

Analytical cookies may be sent from the website itself (so-called “first-party” cookies) but they are generally sent from third party domains / websites (so-called “third-party” cookies).

Included in this category, for example, are Web Analytics, where the data gathered is limited to use of the website by the user and the number of accesses to the website, in order to manage the performance and structure of the website. These cookies are generally persistent.

 

Cookies to integrate products and software functions from third parties

This type of cookies integrates functions developed by third parties into the pages of the website such as icons and preferences expressed on social networks (e.g. Facebook, Twitter) in order to share the contents of the website or for the use of third party software services (such as software to generate maps and other software offering additional services). These cookies are sent by third party domains and partner websites, which therefore offer their features within the pages of the website.

Third party cookies for marketing / retargeting.

The cookies in this category are only third-party and are used to create user profiles in order to send advertising messages or present advertising banners for the website when the user is browsing on other websites, in line with the preferences demonstrated by the user within the pages of the website.

Fincons website does not use first-party profiling cookies.

• Web beacons: also called “tracking pixel”, “gif 1 × 1”, “gif single-pixel”, “pixel tags”, or “action tags” are the graphic images, which generally do not exceed the size of 1 pixel x 1 pixels that are used in order to collect anonymous information on how to use the users and to offer personalized content. They also allow to identify the types of browsers, the words entered into search engines by visitors to reach the site and the names of the domains of the sites that refer traffic to the site. Web beacons present in e-mail communication and let you know if a user has received, opened or clicked on a link provided with the e-mail received.
• Flash Cookies or Local Shared Objects (LSOs): websites can use Flash content, displayed in their pages to store some information about the device. As with HTTP, local shared objects Cookies can be used by websites to gather information about the paths taken by Internet users on the navigation between web sites. The online banks or advertisers can use local shared objects for tracking purposes.
• Google AdSense: Google AdSense is a Google Inc. managed program that allows Google network advertisers to serve ads on its website gaining in the number of exhibitions the advertisement or clicks made on them. And ‘possible access to the information at the address: http://www.google.com/adsense/localizedterms .

 

User’s consent

Fincons website is not obliged to request consent for first-party technical and analytical cookies, as they are necessary in order to provide the services requested. They are therefore installed automatically by the website during the user’s first visit to any page of the portal.

For other types of cookie, consent is requested via a pop-up banner: this implies active behaviour on the part of the user, meaning that the latter can give his or her consent by clicking on the “OK” button.

For all other types of cookies the user can give his or her consent by one or more of the following means:
• via specific browser settings used to browse the pages that form the Website (see the following section);
• via modifications to the settings for the use of third party services.

Please note that certain areas or features of the website rely on the use of cookies, meaning that disabling cookies using one of the solutions indicated above could prevent the user from visualising certain parts of the Website correctly or using specific features offered by the Website (for example authentication and access to the restricted area of the website).

 

How to manage the Cookies used by Fincons website through browser configuration

Nearly all internet browsers are set up to automatically accept cookies. The user can modify the predefined configuration (generally set to “medium” level) and disable Cookies, selecting from the form provided (generally entitled “Privacy”) the highest level of protection. In all cases, the user also has the opportunity to delete individual Cookies from his or her computer by going to “Internet Options”, Tools menu and selecting the “General” form and clicking the appropriate deletion button.

Below are more detailed instructions for managing cookies on the part of the user for the more common browsers. To delete Cookies from the internet browser of your smartphone/tablet, you should refer to the device’s user manual.

Chrome

1. Click on the (“Settings”) menu in the browser’s toolbar next to the window for inserting the url when browsing.
2. Select “Settings”.
3. Click on “Show Advanced Settings” at the end of the list.
4. In the “Privacy” section click on the “Contents settings” button.
5. In the “Cookie” section it is possible to modify the following settings regarding Cookies:
• Allow local data to be set
• Keep local data only until you quit your browser
• Block sites from setting any data
• Block third-party cookies and site data
• Manage exceptions for certain websites
• Delete some or all Cookies

Mozilla Firefox

1. Click on the (“Settings”) menu in the browser’s toolbar next to the window for inserting the URL when browsing.
2. Select “Options”
3. Select the “Privacy” panel
4. In the “Tracking” section it is possible to modify the following settings regarding Cookies:
• Tell sites that I do not want to be tracked

5. In the “History” section it is possible:
• By enabling “Use custom settings for history” choose to accept third party Cookies (always, from the most visited sites or never) and to conserve them for a determined period of time (until they expire, until I close Firefox or ask me every time)
• Remove individual stored Cookies

Internet Explorer

1. Click on the “Tools” button and select “Internet Options”
2. Click on the “Privacy” tab and in the “Settings” section, move the slider to the desired action for Cookies:

• Block all Cookies
• Allow all Cookies
• Selecting which sites to allow Cookies from: move the cursor to an intermediate position in order neither to block nor allow all Cookies, then click on “Sites”, in the “Website address” insert a website then press “Block” or “Allow”

Safari

1. Click on Safari, select Preferences and click on Privacy
2. In the Block Cookies section specify how Safari must accept Cookies from websites.
3. To view which websites have stored Cookies click on Details

In all cases, the user is advised to check his or her browser settings from time to time.

How to manage the Cookies via modifications to the settings when using third-party services

The website may contain third-party cookies and links to other websites: third parties have their own privacy information that differs from that adopted by Fincons website and which is unrelated to the latter.

Listed below are the links to the pages containing the information and specific instructions from third parties:

https://policies.google.com/?hl=it

https://www.linkedin.com/legal/privacy-policy

https://www.facebook.com/privacy/explanation

https://www.youtube.com/static?gl=IT&hl=it&template=terms

https://help.twitter.com/it/rules-and-policies/twitter-cookies

https://help.salesforce.com/articleView?id=pardot_basics_cookies.htm&type=5

Users are advised to take careful note of the information and policies regarding the use of cookies produced by third parties and as stated above also in order to be aware of any modifications made to them by the various suppliers independently of Fincons.

 

Personal Data transfer

Some of user’s personal information may be shared with recipients that could be found outside the European Economic Area. Fincons ensures that the processing of their Personal Data by these recipients takes place in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis.

 

Child’s consent disclaimer

Children below the age of 14 cannot personally provide their personal data. Fincons declines any responsibilities for accidental personal data collection and false declarations provided by the minor. If an improper use by the minor is detected, Fincons will help parents or guardians enforce access and deletion rights.

 

Data subject rights

In accordance with the Regulation, user has the following rights:

Right to access and obtain a copy of his/her personal information: user is entitled to request confirmation whether Fincons processes any personal information. Where this is the case, user may have access to his/her personal information and to certain information about how it is processed. In some cases user can ask Fincons to provide him/her with an electronic copy;

Right to correct user’s personal information: if he/she can demonstrate that personal information Fincons holds about him/her is not correct, user can ask that this information is updated or otherwise corrected;

Right to be forgotten/have data deleted: In certain circumstances user has the right to have his/her personal data deleted. User may make such a request at any time and Fincons will evaluate if his/her request should be granted, however this right is subject to any legal rights or obligations Fincons may have to retain data. For situations where in accordance with the law, Fincons determines that user’s request to have his/her personal information deleted must be granted, Fincons will do so without undue delay.
Requests must be sent in writing to Fincons at the following address: privacy@finconsgroup.com.
In any case, user is always entitled to propose a complaint to the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulations, if you believe that the processing of your Personal Data is contrary to the law, as indicated at the following website:

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524.

 

Changes to this Policy

The terms of this Policy may change from time to time. Fincons shall publish any material changes to this Policy through appropriate notices either on this website or contacting you using other communication channels.