Privacy and Cookies Policy EN

This privacy police has been drafted so as to set out the main methods used to manage the website www.Testori.it and all the website owned and managed by Testori S.p.A., including, for example, the one the User is currently accessing (hereinafter the “Website”), with reference to the processing of Users’ personal data (hereinafter the “Netizen” or “Data Subject”); this document also includes the processing performed on other websites, possibly consulted by the User through the use of links on the Website.

This document is a general outline giving information concerning the criteria used for the correct and lawful processing of personal data performed through or on the Website. The before mentioned criteria are set out in detail to the User within the Statement published on the Website itself, aimed at specifying the methods and goals of the processing for what concerns the specific services and/or information of all natures.

 This privacy policy has been drafted in compliance with the articles 13 and 14 of the European Regulation no. 679/2016 (hereafter GDPR), the outlines set forth within the Recommendation no. 2/2001 adopted on 17th May 2001 by the Group of European Data Protection Supervisor (EDPS) for the processing of personal data, provided for under article 29 of the EEC Directive no. 95/46/CE, with the art. 122 of Legislative Decree no. 196/2003 and with the General provision no. 229 adopted on May 2004 concerning cookies, so as to identify a series of minimum requirements for the gathering of personal data online, and more precisely, the methods, the timing as well as the nature of the information the holders of the processing shall have to supply to the Users when the latter is surfing on their website, independently from the reasons for which they are consulting the website.

HOLDER OF THE DATA PROCESSING

Testori S.p.A., having its registered office in Testori S.p.A. con sede in Novate Milanese (Milano – Italia) Largo Testori 5, mail privacy@Testori.it, Tel +39 0235231, is the Holder of your personal data processing.
 

THE DATA PROTECTION OFFICER

Testori S.p.A., although not obliged, has appointed an external Data Protection Officer (hereafter DPO), reachable at the e-mail address dpo@testori.it.

THE GATHERING OF THE DATA

 The Users acknowledge the fact that the use of these Websites implies the processing of their, direct or indirect, personal data. Therefore, we collect direct and/or indirect data through our Website www.testori.it.

The data supplied on a voluntary basis.

The optional and voluntary supply of an e-mail address to addresses listed on the Website involves the later acquisition of the sender’s address, as well as any other personal data inserted in the communication necessary to answer to and fulfil the requests.

Moreover, you may forward your data to us by filling in specific online forms drafted by Testori S.p.A. so as to take advantage of the services offered by the Websites themselves. A summary of all the specific information is published within the site-pages through which the data is collected so as to supply the requested services. Your personal data include, but are not limited to, your name(s), surname, e-mail address, your company and your telephone number.
You are the sole responsible for the correctness of the data supplied during the registration phase and the filling in of these forms, and as such, as of now, undertake to update the personal data supplied on a regular basis.

Policy Cookies

This policy, available from any web page, is adopted in accordance with the following rules and provisions: - Article 13 of EU Regulation 2016/679; - Provision of the Italian Data Protection Authority No. 229 of 8 May 2014 (Identification of simplified procedures for information and acquisition of consent for the use of cookies); - Provision of the Italian Privacy Authority No. 231 of 10 June 2021 (Guidelines on cookies and other tracking tools) integrating Provision No. 229 of 2014 and providing important clarifications in order to facilitate data controllers in the correct application of the current regulatory framework; - Recommendation No. 2/2001 of the Group Article 29 concerning the minimum requirements for the online collection of data in the EU ; - of the Directive 2009/136/EC, amending Directive 2002/58/EC (the so-called e-Privacy Directive), concerning the processing of personal data and the protection of privacy in the electronic communications sector; - WP 29 Guidelines of 10 April 2019, ratified by the European Data Protection Board and replaced by the Guidelines 05/2020 on consent under Regulation 2016/679 adopted on 4 May 2020. The following text explains 'what cookies are' and how they are
used on this website.
 

What are cookies?

 A "cookie" is a text file that a website sends to your computer or any other device connected to the Internet in order to uniquely identify your browser or to store information or configurations in it.
This site does not use passive tracking tools such as fingerprinting but it does use active identifiers such as cookies.


Does this website use cookies?
Yes, this website uses cookies to improve your browsing experience and to provide services and functionality to its users. You can restrict or disable the use of cookies; however, without cookies some or all of the website's functions might be unusable.


What type of cookies are in this website?


1. Strictly necessary technical cookies
These cookies are essential to accomplish the activities requested by the user. For example, to store information provided by the user while browsing through the website or to manage the "login" status during his/her visit.

This site uses technical cookies, automatically installed following the access to the site, for the specific purposes indicated with regard to each of them.

Technical cookies: these cookies include browsing or session cookies which are solely designed to enable the communication to be carried out over an electronic communications network, or to the extent strictly necessary for the provider of an IT service explicitly requested by the contracting party or user to provide such a service, or functional cookies which enable the user to browse according to a set of selected criteria which, inter alia, do not contain personal data (e.g. language, choices regarding certain types of non-technical device type cookies) so as to improve the service provided to the user.
 

• Technical cookies, absolutely necessary.

These cookies do not allow the acquisition of personal data identifying the user. At any time, the user is free to accept or refuse the use of cookies by changing the settings of his/her browser. If the user visits the website from different computers at different workstations, he/she must verify that each browser is set correctly. The user can easily delete any of the installed cookies in the cookie folder by following the procedures provided for by the browser in use.

Technical cookies used by this site expire once the browser is closed, except for those containing the user's choice of non-technical cookies, which expire after 6 months. These cookies do not allow the acquisition of personal data identifying the user.
 

2. Third-Party Analytical Cookies

 Firstly, it should be noted that for the proper processing of non-technical cookies, which involve the processing of personal data, albeit indirectly, it is necessary to collect a valid consent.
 

• Google Analytics

Google Analytics cookies collect information on a user's pattern of activity on a website. This website uses the Google Analytics system to collect and analyse traffic data. The data collected include the number of visitors, the source from which they came and the visited pages. Google Analytics cookies might allow third party profiling. Please note that we do not own such profiling. Google Analytics cookies are installed on this website without the user's prior consent, as the Google Analytics code has been placed with anonymized IP. The third party can only access the data in aggregated form. Therefore, Testori acquires this information in aggregate and anonymous form for the sole purpose of analysing the most interesting sections of the site and improving its offer through the site. For the above-mentioned analytical cookies, it is not necessary to collect the user's consent if they do not directly or indirectly reveal any personal data.

 

To disallow Google Analytics cookie tracking, please visit http://tools.google.com/dlpage/gaoptout.
For any further information on the processing of personal data of the Google Analytics component (purpose: aggregate statistical analysis of web traffic) please refer to Google's privacy policy. Please click here for more information. Google Analytics reference pages: Cookie Policy – Opt Out.

 

 3. Third-party Functional Cookies

                   • YouTube

This website might include videos from YouTube, owned by Google, to offer multimedia content to the user. YouTube cookies might allow third party profiling. Please note that we do not own this profiling. Google reference page: Cookie Policy Google


4. Advertising or Profiling Cookies

This website does not use profiling or advertising cookies. However, third parties might also set cookies when you interact with Testori's services. These third parties are search engines, measurement and analytics providers, social media and companies providing ad services. These third parties use cookies in delivering advertising content, including interest-based advertising, to assess the effectiveness of their ads. These cookies do not fall within the scope of Testori's data processing activity, so we ask you to raise your level of attention by reading the cookie policy of the relevant entities and, if you wish, to follow the procedures indicated therein to disable them.

What to do in case of links to other sites?

Surfing the Testori website allows access, via links, to other websites managed by third parties. These sites might collect your personal details. Testori does not control the websites managed by these subjects and cannot be held responsible for their conduct. The provisions aimed at protecting the privacy and security of personal data processed on the websites linked to or from the Testori website are not regulated by this privacy policy. Testori, therefore, is not responsible for the privacy conduct of these sites.

 

How to give/revoke consent and manage preferences?

The user can manage his/her consent and change cookie preferences on this website via the cookie banner, which once closed can be retrieved by clicking on the footer link on this website. The user can also manage cookie consent and preferences via the above-mentioned third-party links, directly via his/her device or web browser settings. The reiteration of the consent request when prior consent has failed is an unlawful activity which Testori shall not carry out.

If you previously refused to give your consent, the consent acquisition banner may be resubmitted to you in the following cases:



                1. Where at least six months have elapsed    
                   since your refusal;

                2. If the processing conditions have              
                    significantly changed, in which case the  
                    banner also serves the purpose of
                    informing you about those changes (e.g.
                    in the event of third-party changes);
          
                3. When the site administrator cannot be               
                    aware of the fact that a cookie has             
                    already been previously stored on the
                    device in order to be transmitted during  
                    a subsequent visit by the same user to
                    the site that generated it (e.g.       
                    hypothesis in which the user chooses to
                    delete the cookies legitimately installed
                    on his/her device while the                    
                    Administrator cannot keep track of the  
                    will to maintain the  
                    default settings and, therefore, to
                    continue browsing without being
                    tracked).

How to control third-party cookie settings.


You can find information on how to manage cookies in some of the most popular browsers at the following addresses:
 

Google Chrome
Mozilla Firefox
Apple Safari
Microsoft Internet Explorer
Microsoft Edge
Brave
Opera

More information and details on the different types of cookies, how these work, and their characteristics can be found on www.AllAboutCookies.org and on www.aboutcookies.org.

 

Mobile Devices
 

In addition, you can manage some mobile application tracking tools by deactivating them through the appropriate device settings, such as mobile advertising settings or tracking settings in general (the user can refer to the device settings to find the relevant one). If you want to delete cookies from your smartphone/tablet's internet browser, please refer to your device's user guide. Surfing data The IT system and the software procedures used for the functioning of the website automatically acquire some personal data, which are then usually transferred following the use of the Internet communication protocols. This information is not gathered to be associated to identified users, but that due to their nature may allow the identification of the User through the elaboration of and in connection to the data held by third parties. The aforesaid category includes the IP addresses and/or the domain names of the computers used by the Users connecting to the website, the user agents, the URI (Uniform Resource Identifier) addresses of the requested resources, the type of web browser used, the moment in which the connection to the site is made, the pages containing the link through which you were connected to the website you are accessing (e.g. www.Testori.it), the time at which the request is made, the method used to forward the request to the server, the dimension of the file obtained as an answer, the numeric code indicating the state of the answer given by the server (positive, error, etc.) and any other parameter involving the Users’ operating system and their IT environment. These data are solely used or the purpose of retrieving anonymous statistical information involving the use of the website, for the management of the internal system, to identify any problems concerning the server, for the website’s administration and to check its correct functioning and shall immediately be erased after their processing. We shall also take advantage of this information to collect demographic data involving the origin of the internet service suppliers of the users surfing on our site.

The data may also be used to investigate any responsibilities in case of hypothetical IT crimes performed against the Website: without any prejudice for this possibility, at present the data concerning the webconnections are not kept in a permanent manner.

OPTIONAL GRANTING OF THE DATA

Exclusion made of the specific information contained in the data involving the surfing on the Website, the User shall always be free to grant his/her personal data for the aims for which he/she is connecting to the Website (for instance, request of information or documents through the filling in of a form). Nevertheless, the denial of consent to grant the data could jeopardize the possibility to fulfil the User’s requests.

 

METHOD OF DATA PROCESSING AND STORAGE
 

 Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Once this deadline has elapsed, the data will be deleted or transformed into an anonymous form, unless their further conservation is necessary to fulfill legal obligations or to comply with orders issued by Public Authorities and/or Supervisory Bodies. Where necessary, the processing carried out by the Holder/Data Controller on personal data collected from the website of the Holder/Data Controller may be based on automated decision-making processes that produce legal effects or that significantly affect the data subject, such as, for example, the processing carried out use of profiling cookies. Appropriate technical and organizational security measures are observed to prevent damage, whether material or immaterial (e.g. loss of control of personal data or limitation of rights, discrimination, theft or identity usurpation, financial loss, unauthorized decryption of pseudonymization, prejudice to reputation, loss of confidentiality of personal data protected by professional secrecy or any other significant economic or social damage). No data deriving from web services is finally disseminated.

PLACE OF DATA PROCESSING

The processing of the personal data involving the performance of the web services of the Website you are accessing (e.g. www.testori.it is performed within Testori S.p.A.’s registered office by the Company’s technical personnel responsible of the processing itself (IT Systems staff, Marketing staff, , etc.), by the Subject appointed by the Company to manage the Website, check its correct functioning and implement the security measures. The data may also be processed by third parties appointed to perform occasional maintenance operations.

 

DATA DISCLOSURE

The communication and/or possible disclosure of the personal data shall solely occur in compliance with the provisions set forth within the GDPR: that is to say, prior consent of the Interested Party/Data Subject or in compliance with the Law, as provided for by article 6 and article 7 of the GDPR. The disclosure of the aforesaid data may, for instance, be made upon request of Government Entities and/or Bodies or any third party, also, but not limited to, in compliance with the orders of any Judicial Authority if provided for or allowed by the Law.

THIRD PARTIES

 Testori S.p.A. may take advantage of third parties for the management of the websites and the technologic matters. These third parties shall have to comply with the legislations in force and shall act as autonomous holders of the processing. In case these third parties shall have to perform activities, which could potentially involve the processing of personal data, they shall be the specific external responsible for what concerns the Privacy or the external Privacy Responsible. In order to pursue the purposes described, or in the event that this is indispensable or required by law or by authorities with the power to impose it, the Controller reserves the right to communicate the data to recipients belonging to the following categories:
‐ subjects who perform IT maintenance or similar services;
‐ Authorities, Supervisory Bodies and, in general, public or private subjects with functions of public relevance (eg: Prefecture, Police Headquarters, Judicial Authorities, in any case only within the limits in which the conditions established by applicable law are met);
‐ subjects that perform data acquisition, processing and processing services;
‐ subjects that carry out documentation archival and data-entry activities;
‐ subjects who provide assistance to the Interested Party/Data Subject;
‐ Professional firms or Companies in the context of assistance and advise services;
‐ subjects who release support in the activities referred to in the various privacy policies on the Website.
The Data may also be known, in the exercise of the duties assigned, by the Holder/Data Controller's staff, including interns, temporary workers, consultants, employees of companies external to the Holder/Data Controller, all specially appointed to process the data

Social Plug in

Our web pages may contain social network plug-ins (e.g. FaceBook.com, managed by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, United States ("Facebook"). If you access one of our web pages equipped with a similar plug-in, the Internet browser connects directly to the social network and the plug-in is displayed on the screen thanks to the connection with the browser. Before using these plug-ins, please consult the privacy policy of these social networks on their official pages.

 

OTHER EXTERNAL TOOLS

 Testori Websites may contain external tools for specific activities of the sites themselves. These external Plug-ins that could be integrated into the Website allow those who might be interested to make requests to the Holder or to be able to take advantage of specific services, such as, for example, to schedule an appointment with an expert to carry out an in-depth analysis on their own issues interest  Personal data, collected for example by filling in an adhesion form, are typically common data. The provision of personal data is optional, but necessary to allow the use of the service requested by the Netizen. The use of personal data by the Holder will be intended for this purpose. Before using the external Plug-ins integrated on the Website, please consult the Plug-in Provider's Privacy Policy, by consulting its official web pages.


 

LINKS AND OTHER WEBSITES

 Browsing on Testori Websites also allows you to access other websites, managed by third parties, through the links published within its Website. The aforesaid sites may collect and gather personal information about you. Testori in no manner controls the sites managed by third parties and can thus never be considered as being responsible for their conduct. The provisions protecting the privacy and the security of the personal data processed on the sites connected to or linked to the Testori Website are not covered by and/or included in the Privacy Policy. Moreover, Testori shall in no manner be held responsible for these third parties’ websites conducts in relation to privacy matters.

SECURITY MEASURES

The security of the User’s data is essential for Testori. Specific security measures are complied with so as to prevent the loss of data, illegal use of or incorrect use of as well as non-authorized access to the aforesaid data, in accordance with the provisions of art. 32 of the GDPR. Anyhow, Internet’s nature, being a global means of communication, does not guarantee the absolute security of your data and information during the communication phase on the Internet, or during the memorization and/or archiving within our systems. Third parties, such as hackers, may in fact get to know this information. In the same manner, the forwarding by means of e-mail or through the “contact us” instrument, and/or any other similar instrument or function contained on our Websites, may not be safe as third parties could steal your data.
The clients and the collaborators of Testori Group are solely allowed to access the Reserved Sections prior previous subscription and registration to the Website itself. Among the functions of the Websites the clients and the collaborators of Testori Group may also have the possibility to create an account with a Username and a password. The Netizen shall have the obligation to keep the password and his/her account secret and shall be held responsible, in compliance with the limits provided for by the regulations in force, for the access and the use of Websites performed and made by the User, or the legal or natural person using his/her password, independently from the fact whether the said access was authorized by or on behalf of the User, or the circumstance wherein the subject which made the access is a User’s employee or official. The User herewith as of now undertakes to: (a) immediately notify Testori, by forwarding a communication to the e-mail address: privacy@testori.it, any and all non-authorized uses of the password and/or account and/or any other possible security linked breaches, and (b) guarantee to logout of the account at the end of each session. Furthermore, the User herewith also undertakes to protect his/her password, check the access and the use of his/her account, notify his/her request to Testori any and all requests to cancel his/her account from this Website. Nevertheless, Testori herewith waives all responsibilities, exception made of the mandatory regulations under the Italian Legislation, for what concerns all losses, claims and/or damages deriving from or related to the non-compliance of these provisions, as well as for what concerns the disclosure of any personal data and information following mistakes and/or non-authorized or unlawful acts or deeds performed by third parties during or after their communication.

TRANSFER OF EXTRAUE DATA

No extra EU transfer of data related to our Netizens is foreseen. Where necessary and in limited cases, for the pursuit of the aforementioned purposes, the data of the Interested Party/Data Subject may be transferred abroad, to non-EU countries/organizations that guarantee a level of personal data protection deemed appropriate by the European Commission with its own decision, or in any case on the basis of other appropriate guarantees, such as the Standard Contractual Clauses adopted by the European Commission and of which Testori has availed itself since 2010. A copy of any data transferred abroad, as well as the list of non-EU countries/organizations to which the Data have been transferred, may be requested from the Holder/Data Controller by submitting a request to the organizational unit responsible for replying to the Data Subject by ordinary mail sent to the Holder/Data Controller's registered office or by e-mail sent to privacy@testori.it.
 

THE RIGHTS OF THE INTERESTED PARTY/DATA SUBJECT

Pursuant to articles 15 to 22, the GDPR Regulation confers to the Interested Parties/Data Subjects the possibility to exercise specific rights. In particular, the interested party can obtain: a) confirmation of the existence of processing of personal data concerning him and, in this case, access to such data; b) the correction of inaccurate personal data and the integration of incomplete personal data; c) the cancellation of personal data concerning him, in cases where this is permitted by the Regulations; d) the limitation of the treatment, in the hypotheses provided for by the Regulations; e) the communication, to recipients to whom personal data have been transmitted, of requests for rectification/deletion of personal data and limitation of processing received by the interested party, unless this proves impossible or involves a disproportionate effort; f) the receipt, in a structured format, of common use and legible by automatic device, of the personal data provided to the Holder/Data Controller, as well as their transmission to another data controller, at any time, including termination of any relationship entertained with the Data Controller. The Interested Parties/Data Subjects also has the right to object at any time to the processing of personal data concerning him/her: in such cases, the Holder is obliged to refrain from further processing, subject to the provisions permitted by the GDPR. Where consent is required for the use of your data for promotional purposes you may deny it without this refusal having any consequence on your main request. If you have given your consent you can always revoke it by using the same modalities of release or email below. The revocation does not affect previous treatments. Requests can be submitted by ordinary mail sent to the Holder/Data Controller's office or by e-mail sent to the address privacy@testori.it. The Interested Party/Data Subject also has the right to lodge a complaint with the Privacy Guarantor. See: www.garanteprivacy.it.

 AMENDMENTS TO THE PRIVACY POLICY

Testori S.p.A. withholds the right to amend and/or update this Privacy Policy at any time and undertakes to inform the Users of this website by means of the Privacy amendments or updates of this webpage. Any amendment or update of the Privacy Policy shall enter into force as soon as they are published on this Website. The access to and/or use of this Website following the published amendment of the Privacy Policy shall imply the explicit acceptance of the aforementioned Policy.

QUESTIONS AND/OR COMMENTS

For any and all comments and/or remarks involving this Privacy Policy please feel free to contact Testori S.p.A. at the following e-mail address: privacy@testori.it and/or at its registered office based in Novate Milanese (Milano – Italia) Largo A. Testori, 5.