High Grade Privacy and Cookie Policy
INFORMATION PURSUANT TO EE ART. 14 EU Regulation 679/2016 (“GDPR”) AND ITALIAN LEGISLATIVE DECREE “D. LGS. 30 JUNE 2003, N. 196” ON THE PROTECTION OF PERSONAL DATA
GENERAL INFORMATION
1. High Grade, based inOffice 3.2 Central House, 1 Ballards Lane Finchley – London N3 1LQ, conforms to the principles and provisions of the Ex art. 14 EU Regulation 679/2016 (“GDPR”) and Italian Legislative Decree 30 June 2003 no. 196 (“Code regarding the protection of personal data“), which provides provisions on the protection of persons and other subjects regarding the processing of personal data.
2. In compliance with the law, the processing of the personal data acquired by High Grade through requests regarding services offered will be based on the principles of correctness, lawfulness and transparency and the protection of your privacy and your rights.
3. Pursuant to Ex art. 14 EU Regulation 679/2016 (“GDPR”) and Article 13 of Italian Legislative Decree no. 196/2003, we therefore wish to provide the following information:
PURPOSE OF DATA TREATMENT
1. The processing of personal data provided by the Customer will be carried out to allow the provision and use of the services requested, as well as to provide for related invoicing and consequent tax obligations. The data provided may also be used for statistical reports on our activity, as well as for sending information and updates on the services offered, newsletters, commercial information regarding the services offered by High Grade or by related companies. Where necessary for the aforementioned reasons, the data may also be disclosed to third parties. The processing of data, in addition to related purposes instrumental and necessary for the provision of Services will be aimed at:
– entering data collected within company computer databases; communicating data to third parties in order to perform functions necessary or instrumental to the provision of the Services requested;
– collecting data and information in a general and particular manner according to the customer’s guidelines and preferences; sending information and commercial offers; sending advertising and informative material; carrying out commercial communications, including interactive ones; carrying out direct sales or placement of products or services.
– meeting the obligations established by law, regulations, community legislation, civil and tax laws.
2. Personal data may be transferred to countries of the European Union and to countries outside the European Union for the purposes indicated above.
3. We inform you that you may change your choices at any time by contacting High Grade at info@highgrade.it.
NATURE OF DATA HANDLING AND CONSEQUENCES OF DATA AUTHORIZATION OPT-OUT
1. The processing of data is carried out with procedures suitable to protecting the privacy of the customer and consists in their collection, registration, storage, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of the same, including the combination of two or more of the aforementioned elements. The data communicated by Clients will be processed mainly using electronic and IT tools and may be stored both on computer media and on paper and on any other type of suitable support, in compliance with minimum security measures. Operations may be performed with or without the aid of electronic or automated tools.
2. The provision of personal data by parties who intend to use the services of High Grade is optional, but failure to provide such data or subsequent cancellation may make it impossible to provide the services requested or prevent the continuation of a relationship, of proper performance and of any legal obligations, including fiscal.
3. Any failure or incorrect communication of the information indicated or the refusal of authorization to process data may have the following consequences:
– impossibility for the Company to provide the requested service;
– the impossibility for the data holder to guarantee the adequacy of the treatment for the contractual agreements for which it is performed;
– the possible failure to match the results of the treatment with respect to the obligations imposed by fiscal, administrative or labour regulations.
4. If the service is requested through the High Grade website, the Customer acknowledges that during the course of normal operations the IT systems and software procedures used to operate the site acquire some personal data whose transmission is implicit in the use of the communication protocols of the internet network. This information could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error etc.) and other parameters related to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning. These data could be used to ascertain responsibility in case of any computer crimes against the site or third parties. The Customer acknowledges that the operators of the telecommunications networks through which the service is provided can identify the user when he/she is connected to the Internet and that access information is contained in the electronic register of the operation of the Service (Log). The content of the Log is strictly confidential and may be rendered in an intelligible form and exhibited only upon request by the competent Authorities.
High Grade adopts appropriate security measures to prevent loss, subtraction, alteration or destruction of personal data provided by users. The Customer acknowledges that the security measures adopted cannot exclude the risk that the information transmitted through the Internet can be intercepted, manipulated or altered by unknown third parties.
SCOPE OF USING THE DATA, DIFFUSION AND CONSERVATION
1. The non-sensitive data acquired may be communicated in order to allow the provision of the requested Services or the fulfilment of contractual or legal obligations:
– to our partners, collaborators, employees, agents and suppliers, as part of their duties and/or any contractual obligations with them, concerning the commercial relationships with the interested parties;
– to all the subjects to whom the right of access to such data is recognized by virtue of regulatory provisions;
– to post offices, shippers and couriers for sending documentation and/or material;
– to all natural and/or legal persons, public and/or private (legal, administrative and fiscal consultancy, Judicial Offices, Chambers of Commerce, Chambers and Labour Offices, etc.), when communication is necessary or functional to carrying out our activity and for the purposes illustrated above;
– banking institutions for the management of collections and payments deriving from the execution of contracts.
IDENTIFICATION OF THE DATA HOLDER AND CONTROLLER
1. The data holder is High Grade, based in Office 3.2 Central House, 1 Ballards Lane Finchley – London N3 1LQ
2. The data controller for the treatment is High Grade through its legal representative pro tempore. The list of those responsible for processing personal data and third-party recipients of communications is available at the offices of the data controller.
COOKIES
1. On this Website we use cookies, technologies useful in improving navigation. This information serves to illustrate the features and purposes of the cookies and ways in which they may be optionally disabled.
2. What are cookies?
Cookies are small text strings that sites visited by the user send to the terminal (usually to the browser), where they are stored before being transmitted back to the same site on the next visit by the same user. While navigating on a site, the user may also receive cookies that are sent from different web sites or servers (so-called “third party”) to the terminal, on which certain elements may reside (such as, for example, images, maps, sounds, specific links to pages from other domains) on the same site being visited.
3. What types of cookies this Website uses and how can they be disabled
Within our website we use two different types of cookies: Technical and Third-Party.
Technical cookies
Technical cookies are those necessary for the correct functioning of the Website and the services offered. These can be divided into navigation cookies or session cookies that ensure normal navigation and use of the Website; analytics cookies in order to collect information – for statistical purposes in aggregated form – on the number of users and how they visit the site; customization cookies that enable the user, improving the service, to browse according to a number of selectable criteria (e.g. language selection, chosen product etc.).
Third-party cookies.
While navigating the Website the user may also receive, at their terminal, cookies from sites or other web servers (commonly known as “Third Party” cookies).
Third Parties (e.g. advertisers) may use their cookies to obtain information regarding actions in the Website and send advertising based on your interests.
By continuing to use the Website and its features you authorize us to use performance cookies in your navigation device.
Since the installation of cookies and other tracking systems operated by third parties through the services used within this Website may not be technically controlled by the data controller, any specific reference to cookies and tracking systems installed by third parties is to be considered as indicative. For complete information, see the privacy policy of any eventual third party service.
4. List of Third Party Cookies
For more information on third parties cookies relating to advertising and how to disable them, visit the following third party websites:
Facebook (informative/policy): https://www.facebook.com/help/cookies/
Twitter (informative/policy): https://support.twitter.com/articles/20170514
Instagram: https://www.instagram.com/legal/cookies/
Google+ (informative/policy): http://www.google.it/intl/it/policies/technologies/cookies/
To check, delete or block cookies with third-party advertising profiling visit the link: www.youronlinechoices.com
5. How to disable cookies
For an optimal navigation experience we recommended that you keep the use of cookies active: without them, various Website functions may be inhibited.
If you do not wish to receive and store cookies on your device you can change the security settings of your browser by accessing the links indicated below and following the information contained therein (in the case of use of different devices (computers, smartphones, tablets, etc.), be sure to organize each browser on each device according to your cookie preferences). By selecting the links below you can find specific instructions for some of the major browsers:
Microsoft Windows Explorer
http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
Google Chrome
https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
Mozilla Firefox
http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Apple Safari
http://support.apple.com/kb/HT1677?viewlocale=it_IT
Opera: http://help.opera.com/Windows/10.00/it/cookies.html
To learn more about cookies in general we recommend visiting www.allaboutcookies.org
To learn more about behavioural advertising and online privacy we recommend visiting www.youronlinechoices.com
Google Analytics
1. The pages of this Website also include certain components transmitted by Google Analytics, a web traffic analysis service provided by Google. Inc. (“Google”). This also involves third-party cookies collected and managed anonymously in order to monitor and improve the performance of the host site (performance cookies). Google Analytics uses cookies to collect and analyse anonymous information about the use of website behaviour.
For further information, please refer to the link below:
https://www.google.it/policies/privacy/partners/
To learn more about Google Analytics cookies please visit:
https://www.google.it/intl/it/policies/technologies/types/
2. Users can selectively disable the actions of Google Analytics by installing an opt-out component provided by Google on your browser. To disable actions by Google Analytics, please refer to the following link:
https://tools.google.com/dlpage/gaoptout
THE TRANSFER OF YOUR INFORMATION ABROAD
The personal data entered via this or other websites may be transferred to other countries by us or our agents in order to fulfil the contractual obligations and the mandatory requirements of intra-group communication and/or franchising.
REMARKETING AND BEHAVIORAL TARGETING
This Website may use third-party remarketing tools. In this case, some site pages may include code known as “remarketing code”. This code allows for the reading and configuring of browser cookies in order to determine the type of ad that will appear depending on your site visits, chosen navigational paths, pages visited, or the actions carried out within the site.
The remarketing lists created are stored in a Google server database that stores all cookie IDs associated with each list or interest category. The information provided can only identify your browser, as a third party is unable to identify the user with this information.
These tools allow for the running of custom ads based on user visits to our site.
This activity is done through tracking data and the use of cookies, information that is passed to partners for the purposes of remarketing and behavioural targeting activities.
AdWords Remarketing (Google)
AdWords Remarketing is a Remarketing and Behavioural Targeting service provided by Google Inc. that links activity on this site with the Adwords advertising network and Doubleclick cookies.
Personal data collected: Cookies and navigation data.
Location of data management: USA – Privacy Policy – Opt Out
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a Remarketing and Behavioural Targeting service provided by Facebook, Inc. that links the activity of this site to the Facebook advertising network.
Personal data collected: cookies and navigation data.
Location of data management: USA – Privacy Policy – Opt Out
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a Remarketing and Behavioural Targeting service provided by Facebook, Inc. that links the activity of this site to the Facebook advertising network.
Personal data collected: cookies and emails.
Location of data management: USA – Privacy Policy – Opt Out
DATA PROVIDED VOLUNTARILY BY USER
1. Through the Website you can submit request information. This allows users of the Website to provide High Grade with their own personal data. In the absence of the provision of such data, High Grade is unable to deliver the services available on the Website.
2. The data provided by users will be treated in compliance with the Code and according to the General Authorization of the Authority for the Protection of Personal Data No. 2/2016 of 12.15.2016, solely for the provision of services requested and to respond to communication and user questions in pursuit of the purposes connected with the fulfilment of the requests.
3. In particular, any sensitive data (i.e. data revealing racial or ethnic origin, religious beliefs, philosophical or other beliefs, political opinions, membership of political parties, unions, associations or organizations of a religious, philosophical or political nature, trade union membership or personal data disclosing health conditions or sexual preferences) provided by participants will only be used if essential for carrying out operations necessary to fulfilling obligations and, in any case, necessary for offering the service in question, according to Article. 1.2, Letter e) of the aforementioned General Authorization No. 2/2016.
4. Data processing will be carried out by means of operations, or a series of operations, as indicated in Article 4, Paragraph 1, Letter a) of the Code: collection, recording, organizing, storing, retrieving, processing, modification, selection, retrieval, comparison, use, interconnection, blocking, communication, diffusion, cancellation and destruction of data. Such operations may be performed with or without the aid of electronic or automated means. Such processing will be carried out by the data controller responsible for such processing.
5. The conferment of data is necessary for the successful fulfillment of the requests and, therefore, the refusal to provide such data to High Grade would result in the impossibility of providing the aforementioned service.
6. Data provided by users may be disclosed to third parties for those purposes necessary for the successful fulfillment of the requests. Data provided by participants will not be distributed without their express prior consent.
RIGHTS REFERRED TO IN EX ART 14 EU REGULATION 679/2016 (“GDPR”) AND ITALIAN ART. 7 OF D.LGS. No. 196/2003
1. Your rights regarding the processing of personal data may be exercised at any time against the data controller, pursuant to art. 7 of Italian Legislative Decree 196/2003. In particular, pursuant to Art. 7 of Italian Legislative Decree 30 June 2003, n. 196, we inform you that every interested party has the right to obtain confirmation of the existence or not of personal data concerning them, even if not yet registered, and their communication in intelligible form, as well as to obtain the indication:
a) of the origin of personal data;
b) of the purposes and methods of the processing;
c) of the logic applied in case of treatment carried out with the aid of electronic instruments;
d) of the identifying details of the holder, of the responsible and of the designated representative according to article 5, paragraph 2;
e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as the appointed representative in the territory of the State, managers or agents.
2. The interested party also has the right to obtain:
a) updating, rectification or, when interested, integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfilment proves impossible or involves a use of means manifestly disproportionate to the protected right. The interested party has the right to object, in whole or in part:
– for legitimate reasons to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
– to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.
The above rights are exercised with a request made without formalities to the holder or controller, including through a nominated person, who is to be provided with prompt appropriate feedback.
The request addressed to the holder or controller can also be sent by registered letter or e-mail to the address/number shown in the contact section of the website.
3. The Customer requesting the Service confirms that he has been informed in advance by the holder regarding:
a) the purposes and methods of data processing;
b) the mandatory or optional nature of the provision of data;
c) the consequences of any refusal to authorize treatment;
d) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents, and the scope of dissemination of such data;
e) the identification details of the holder and controller;
f) the rights referred to in art. 7 of Italian Legislative Decree n. 196/2003.