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Privacy & Cookie policy

Privacy & Cookie policy



REGULATORY FRAMEWORK

 

  • Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications).


 

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).


 

 

DATA CONTROLLER

 

When you visit and use our website, we may collect and process personal data, where personal data means any information relating to an identified or identifiable natural person (hereafter, referred to as “Data”). The Data Controller is Polihub S.c.a.r.l. with legal premises in Piazza Leonardo da Vinci 32, 20133, Milano (MI), Italy (hereafter referred to as the “Data Controller”).

 

 

TYPE OF DATA PROCESSED

 

Browsing data

 

The computer systems and software procedures used to run this website acquire personal data as part of their standard operations. The transmission of such Data is an inherent feature of internet communication protocols.

 

This information is not collected in order to be associated with identified interested parties (data subjects) but might, because of the type of information it is, allow users to be identified through processes of elaboration and association with data held by third parties.

 

This category of data includes IP addresses and/or the domain names of computers used by users who connect to this website, the URI (Uniform Resource Identifier) notation of the requested resources, the time of request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and IT environment.

 

These data are used for the sole purpose of computing anonymous statistics about the usage of the website and to check that it is working correctly, and are deleted immediately after being elaborated. The data could be used to ascertain liability in the event of any computer crimes against this website. With the exception of this possibility, web contact data are never stored for more than seven days.

 

 

Data provided by the user voluntarily

 

The Data that users provide optionally, explicitly and voluntarily when compiling registration forms on this site (among which, the “Contact Us” form, our newsletter subscription form and the “Work with Us” form) will then be collected and stored by us, in order for us to provide the service or services requested. Summary privacy statements and, when applicable, consent forms will be progressively presented or displayed on the website pages relating to the services requested.

 

 

Aggregated or anonymous data

 

Anonymisation is a technique applied to personal data in order to prevent a natural person (data subject) from being identified. Anonymised data do not fall within the scope of data protection legislation. We gather, elaborate and share aggregate data as statistical or demographic data for various purposes.  Aggregate data can derive from Data provided by the user but are not considered to be Data in that, as specified, they do not identify the data subject directly or indirectly. These data are used to improve the quality of our existing products/services, develop new functions, and for other general research purposes (for example, to check how frequently a visitor uses a given product or service, to calculate the percentage of users who access a given website function, etc.).

 

 

COOKIES



Cookies are small text files containing a certain amount of information which are placed on the user’s device when the user visits certain websites, generally by the user’s web browser. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may be either “session” cookies or “persistent” cookies. Session cookies are stored on the user’s device for only a short time and expire at the end of the browser session. Session cookies are strictly related to the transmission of session identifiers (consisting of random numbers generated by the server) which enable the user to navigate the site safely and efficiently. Persistent cookies are stored on a user’s device until a defined expiry date. As they are not deleted at the end of a browser session, they store the user’s preferences when using a site and can also be used to gather information on the webpages visited by the user, how frequently the user visits the site, and to trace the user’s browsing patterns, in order to improve the user’s experience of a website. Both session and persistent cookies can be “first-party” or “third-party” cookies, depending on who places them on the website. First-party cookies are set directly by the website that the user is visiting and third-party cookies are set by a domain other than the one the user is visiting.

 

 

Cookies used in this site

 

This website uses both first-party and third-party cookies, in that it uses Google Analytics functions, provided by Google Inc., as indicated further on.

 

This website uses Google Analytics and will anonymise user IP addresses using tools provided by Google. For more information, please see “Google Analytics Cookie Usage on Websites” at https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

For more information on Google Analytics cookies and how they are used by Google Inc., see “How Google Uses Cookies”, at

http://www.google.com/intl/en/policies/technologies/cookies/

and https://developers.google.com/analytics/devguides/collection/analyticsjs/cookies-usage

and “Google Analytics Privacy Policy”, at

http://www.google.com/intl/en/analytics/privacyoverview.html

and https://policies.google.com/privacy?hl=en-US

 

The table below gives details of the cookies currently present in our website.

 


COOKIE NAME EXPIRY DATE TYPE COOKIE DESCRIPTION
_ga Default expiry after 2 years Third-party analytics cookie Cookies used by Google Analytics to distinguish users, allocating to each a randomly generated number as an identifier; also used to calculate visitor and session numbers and other data for the site’s anonymised analytics reports.
_gid Default expiry after 24 hours Third-party analytics cookie Cookies used by Google Analytics to distinguish users, allocating to each a randomly generated number as an identifier; also used to calculate visitor and session numbers and other data for the site’s anonymised analytics reports.
_gat Default expiry every 10 minutes Third-party analytics cookie Cookies used by Google Analytics to speed up access requests.
cc_social Default expiry after 12 months Technical cookie Cookies used for tracking the preferences of all other cookies used in this site, according to the functions implemented; also enables users to change their preferences at any time.
cc_analytics Default expiry after 12 months Technical cookie Cookies used for tracking the preferences of all other cookies used in this site, according to the functions implemented; also enables users to change their preferences at any time.
cc_advertising Default expiry after 12 months Technical cookie Cookies used for tracking the preferences of all other cookies used in this site, according to the functions implemented; also enables users to change their preferences at any time.
Alongside the cookies listed in the table above, this site can use further session cookies, which are cookies that are not stored permanently on the user’s device and are eliminated when the browser session is closed.  Their use is very limited.

 

Cookie management

 

Most cookies can be controlled by changing the browser settings appropriately. However, if technical cookies are disabled totally or in part, website functionality may be impaired. In any case, should users not wish to receive any cookies on their device, whether from this website or from third party websites, they can raise their level of privacy protection by changing the privacy settings on their browser.

Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox

 

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

 

Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Safari 6/7/8: https://support.apple.com/en-us/HT205033

 

Safari on iPhone, iPad and iPod touch: https://support.apple.com/en-us/HT201265

 

 

LINKS TO OTHER WEBSITES

 

This site can contain links or references to access other websites, such as the social platforms Facebook, Instagram, Google+, Twitter and Pinterest. If you click on a social media share link, you can share our messages and content. Please note that the Data Controller does not control the tracking technologies on other websites, and this policy does not apply to these third-party websites.

 

 

LEGAL BASIS FOR PROCESSING

 

The Data Controller can lawfully process all Data conferred freely by users through forms contained within the website, in that the processing is necessary for the performance of a contract at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR), or is lawful in that the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6(1)(a) GDPR). Furthermore, the Data Controller can process the user’s Data when such processing is necessary for compliance with a legal obligation to which the Data Controller is subject (Article 6(1)(c) GDPR). More information on the legal basis for processing the Data are included within the specific privacy statements relating to each form through which data are gathered.

 

 

OPTIONAL CONSENT TO PROVIDING PERSONAL DATA

 

Apart from what is specified for the browsing data, you are free to provide your personal data. However, if you do not give your consent, it may be impossible for you to receive what you have asked.

 

Please note that we are not required to obtain your consent for the use of only technical cookies or third-party analytics cookies that are equivalent to technical cookies. If you disable technical cookies or prevent their use, this will impact your experience of navigating the site correctly and you may not be able to access the services, pages, functions or contents of the website itself. The Data Controller will ask for your specific consent for all other types of cookies (marketing and profiling cookies).

 

 

DATA PROCESSING PURPOSES

 

We process Data through various means, including automated tools. Data are processed in a manner that ensures appropriate security of the Data, including protection against unauthorised or unlawful processing and against accidental loss. The Data Controller has adopted appropriate safety measures set out in law, and taking inspiration from the main international standards, has adopted further safety measures to minimise risks concerning confidentiality, availability and integrity of Data gathered and processed.

 

 

DATA RETENTION PERIOD

 

Data will be processed via digital methods within the time strictly necessary to achieve the purposes for which the data were collected. Data gathered for the purposes of statistical analyses are anonymised. More information on the Data retention period is included in the specific privacy statements relating to each form through which data are gathered.

 

SHARING, COMMUNICATING AND DISSEMINATING DATA

 

Data can be transferred or communicated to other companies for purposes strictly connected to and essential for the functionality of the service, and can be, for example, the trusted suppliers who manage our computer system. Data provided by users who request brochures, leaflets, information material, etc. are used for the sole purpose of providing the service requested, and are communicated to third parties only if this is strictly necessary (companies that provide enveloping, labelling and delivery services). With the exception of these cases, Data will not be communicated to any other party, unless in the case of legal or contractual obligations, or by authorisation of the data subject.

Therefore, Data could be transmitted to third parties, but only and exclusively if:

 

  1. The data subject gives their explicit consent for their data to be shared.


 

  1. There is the need to share this information with third parties in order to provide the service requested.


 

  1. It is necessary in order to comply with requests from judicial or public safety authorities.


 

More information on the parties to whom we could communicate your Data are included in the privacy statements attached to every form on the website.

 

In any case, no data obtained from the web service will be disseminated.

 

THE RIGHTS OF DATA SUBJECTS

 

Legislation protecting Data expressively gives certain rights to the persons to whom the data refer (known as data subjects). In particular, under Regulation (EU) 2016/679, Article 15 et seq., every data subject has the right to obtain confirmation as to whether or not personal data relating to him or her are being processed, to know the source of the data, the purposes and methods of the processing, the right to obtain their integration, updating, rectification, or to obtain their cancellation if they are processed unlawfully, or on the grounds of a reason specified in Regulation (EU) 2016/679, Article 17, the right to data portability and to lodge a complaint with a supervisory authority.

 

Processing of personal data outside the EEA

 

Your Data will not be transferred outside the European Economic Area (EEA).

 

 

CHANGES TO THE CURRENT PRIVACY POLICY

 

The Data Controller verifies its policy on privacy and security periodically and, if appropriate, will review it in the light of changes to legislation, in matters of organisation or dictated by progress in technology. Whenever the policy is altered, the new version will be published on the website at this page.

 

 

QUESTIONS, COMPLAINTS, SUGGESTIONS AND EXERCISING YOUR RIGHTS

 

If you are interested in receiving more information, putting forward your suggestions, making a complaint or raising objections about the organisation’s privacy policies or the way our Company processes Data, or to exercise your rights under data protection legislation, please contact the Data Controller by writing to: PoliHub S.c.a.r.l. with legal premises in Piazza Leonardo da Vinci 32, 20133, Milano (MI), Italy, or send an email to: info@polihub.it

 

 

CONTACT FORMS

PRIVACY STATEMENT PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), we inform you that your personal data (first name, family name, email address and other personal data included in the contact form) will be processed by PoliHub S.c.a.r.l., as the Data Controller, to respond to your requests for information about the services we offer. The legal basis under Article 6(1)(b) GDPR is that the processing is necessary for the performance of a contract at the request of the data subject. After you have given your explicit and free consent, PoliHub will be able to send you periodic emails with content promoting and advertising our Company (“Newsletter”). You can withdraw your consent at any time, and will no longer be subscribed to our Newsletter. You are free to give us your personal data. If you do not give us your email address, PoliHub will be unable to give you the information you have requested.

Your personal data will be processed by persons authorised to process data under Article 29 of the GDPR, by which we mean PoliHub’s employees and/or collaborators. Your personal data can be communicated, and therefore known, to suppliers who act on our behalf to manage PoliHub’s computer system. Personal data will in any case always be processed within the European Union.

Your personal data will be retained for the time necessary to address your requests, and will then be deleted. Concerning subscription to our Newsletter, PoliHub will store your personal data for as long as you are interested in subscribing to our Newsletter. We will also remind you that, where applicable, you have the right to ask PoliHub for access to personal data and to rectify or cancel them or limit the processing that concerns them or to object to their processing, as well as your right to data portability. You can contact the competent supervisory authority to exercise your privacy rights.

To exercise your rights, write to us at: PoliHub s.c.a.r.l., with legal premises in Piazza Leonardo da Vinci 32, 20133, Milan (MI), Italy, or send an email to: info@polihub.it.

 

PRIVACY STATEMENT – NEWSLETTER

PRIVACY STATEMENT PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679

 

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), we inform you that your personal data (email address, job title and company) will be processed by PoliHub S.c.a.r.l., as the Data Controller, in order for you to subscribe to our service of periodic emails containing material promoting and advertising our Company (“Newsletter”). The legal basis under Article 6(1)(a) GDPR is that your free consent can be withdrawn at any moment. You are free to give us your personal data. If you do not give us your email address, PoliHub will be unable to put you on the mailing list for our Newsletter.

 

Your personal data will be processed by persons authorised to process data under Article 29 of the GDPR, by which we mean PoliHub’s employees and/or collaborators. Your personal data can be communicated, and therefore known, to suppliers who act on our behalf to manage PoliHub’s computer system. Personal data will in any case always be processed within the European Union.

 

PoliHub will retain your personal data for as long as you are interested in subscribing to our Newsletter. Please also remember that, where applicable, you have the right to ask PoliHub for access to your personal data and to rectify or cancel them, or limit the processing that concerns them or to object to their processing, as well as your right to data portability. You can contact the competent supervisory authority to exercise your privacy rights.

 

To exercise your rights, write to us at: PoliHub s.c.a.r.l., with legal premises in Piazza Leonardo da Vinci 32, 20133, Milan (MI), Italy or send an email to: info@polihub.it.

 

 

POLICY STATEMENT – DOWNLOADING SERVICES

PRIVACY STATEMENT PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679

 

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), we inform you that your personal data (email address, job title and company) will be processed by PoliHub S.c.a.r.l., as the Data Controller, in order to deliver the information brochures requested by you and published by PoliHub. The legal basis under Article 6(1)(b) GDPR is that the processing is necessary for the performance of a contract at the request of the data subject. With your explicit and free consent, PoliHub can send you periodic emails with content promoting and advertising our Company (“Newsletter”). You can withdraw your consent at any time, and will no longer be subscribed to our Newsletter. You are free to give us your personal data. If you do not give us your email address, PoliHub will be unable to deliver the brochures requested by you. We would also like to inform you that your personal data may be used for statistical purposes to help PoliHub analyse the services it offers. These statistics will be elaborated exclusively on aggregated data and cannot identify you in any way.

 

Your personal data will be processed by persons authorised to process data under Article 29 of the GDPR, by which we mean PoliHub’s employees and/or collaborators. Your personal data can be communicated, and therefore known, to suppliers who act on our behalf to manage PoliHub’s computer system. Personal data will in any case always be processed within the European Union.

 

Your personal data will be retained for the time necessary to supply the brochures you requested, and will then be deleted. Concerning your Newsletter subscription, PoliHub will store your personal data for as long as you are interested in subscribing to our Newsletter. We will also remind you that, where applicable, you have the right to ask PoliHub for access to personal data and to rectify or cancel them, or limit the processing that concerns them or to object to their processing, as well as your right to data portability. You can contact the competent supervisory authority to exercise your privacy rights.

 

To exercise your rights, write to us at: PoliHub s.c.a.r.l., with legal premises in Piazza Leonardo da Vinci 32, 20133, Milan (MI), Italy or send an email to: info@polihub.it.

 

 

PRIVACY STATEMENT – REGISTRATION TO EVENTS

Pursuant to Article 13 of Regulation (EU) 2016/679 (GDPR), your personal data necessary to attend the event organised by us will be processed by PoliHub S.c.a.r.l., as the Data Controller, to enable you to register and participate in our events. The legal basis under Article 6(1)(b) GDPR is that the processing is necessary for the performance of a contract at the request of the data subject. Furthermore, we wish to inform you that we may send customer satisfaction questionnaires on the organisation of our events to the email address you provided. The legal basis under Article 6(1)(f) GDPR is that the processing is necessary for the purposes of the legitimate interests pursued by the Data Controller, always keeping in consideration the rights and freedoms of the data subject. You are free to complete the questionnaire sent by us and can object to such processing of your data at any moment. In that case, PoliHub will stop sending you customer satisfaction questionnaires concerning events organised by us.

 

Your personal data will be processed per persons authorised to process data under Article 29 of the GDPR, by which we mean PoliHub’s employees and/or collaborators. Your personal data can be communicated, and therefore known, to suppliers who act on our behalf to manage PoliHub’s computer system. Personal data will in any case always be processed within the European Union.

 

Your personal data will be retained for the time appropriate to pursuing the purposes declared and which is coherent under the Italian Civil Code. Please remember that, where applicable, you have the right to ask the Data Controller for access to personal data and to rectify or cancel them, or limit the processing that concerns them or to object to their processing. Lastly, you have the right to lodge a complaint with the competent supervisory authorities.

 

Consent to the use of your image (video and photographs) – During events organised by PoliHub, Innovation District & Startup Accelerator, we may take contextual videos and photographs to promote our initiatives through our institutional channels. Photographs and videos will not be used in situations that could undermine personal dignity and decorum. The use and placement of images are to be considered provided for free. If you do not want to be photographed or filmed during an event, we respectfully ask you not to attend.

 

To exercise your rights, write to us at: PoliHub s.c.a.r.l., with legal premises in Piazza Leonardo da Vinci 32, 20133, Milan (MI), Italy or send an email to: info@polihub.it.

 

 

 

Last update: 2021-05-12 17:38:34


Ultimo aggiornamento: 2021-08-31 16:28:31