I – INFORMATION REGARDING THE WEBSITE'S PRIVACY POLICY

1. This section contains information on how Toorxprofessional manages the processing of Toorxprofessional user data.
2. This policy also applies for the purposes of Article 13 of Legislative Decree No. 196/2003, Personal Data Protection Code, and for the purposes of Article 13 of EU Regulation No. 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, for individuals who interact with Toorxprofessional. It can be accessed at the address corresponding to the home page:
   • http://www.toorxprofessional.it
3. This information is provided only for Toorxprofessional and not for other websites that may be consulted by the user via links contained therein.
4. The purpose of this document is to provide information about the methods, timing, and nature of the information that data controllers must provide to users when they connect to the Toorxprofessional web pages, regardless of the purpose of the connection itself, in accordance with Italian and European legislation.
5. This policy may be subject to change due to the introduction of new regulations in this regard. Users are therefore advised to check this page periodically.
6. If the user is under 16 years of age, pursuant to Article 8, paragraph 1 of EU Regulation 2016/679, they must legitimize their consent through the authorization of their parents or guardians.

II – DATA PROCESSING

1 – Data Controller

1. The data controller is the natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of personal data processing. It also deals with security profiles.
2. With regard to this website, the data controller is: Garlando S.p.A., with registered office in VIA REGIONE PIEMONTE 32 - ZONA INDUSTRIALE D 1 - 15068 POZZOLO FORMIGARO (AL) - VAT number: 01055180069 - Office of the Register of Companies at the Chamber of Commerce of Alessandria - REA 138588 - Share capital €2,035,000.00 fully paid up. For any clarification or to exercise your rights , you can contact them at the following email address: contact@toorxprofessional.it.

2 – Data controller

1. The data processor is the natural or legal person, public authority, service, or other body that processes personal data on behalf of the data controller.
2. Pursuant to Article 28 of EU Regulation No. 2016/679, upon appointment by the data controller, the data processor for the Toorxprofessional website is: IVANO USAN.

3 – Data processing location

1. The processing of data generated by the use of Toorxprofessional VIA REGIONE PIEMONTE 32 - ZONA INDUSTRIALE D 1 - 15068 POZZOLO FORMIGARO (AL).
2. If necessary, data related to the newsletter service may be processed by the data controller or by persons appointed for this purpose at the relevant office.

III – COOKIES

1 – Types of Cookies

1. The Toorxprofessional website uses cookies to make the user's browsing experience easier and more intuitive: cookies are small text strings used to store certain information that may concern the user, their preferences, or the device used to access the Internet (computer, tablet, or cell phone) and are mainly used to adapt the functioning of the website to the user's expectations, offering a more personalized browsing experience and storing the choices made previously.
2. A cookie consists of a small amount of data transferred to the user's browser from a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.
3. Cookies do not record any personal information and any identifiable data will not be stored. If you wish, you can prevent some or all cookies from being saved. However, in this case, the use of the site and the services offered may be compromised. To proceed without changing your cookie settings, simply continue browsing.

Below are the types of cookies used by the website:

2 – Technical cookies

1. There are numerous technologies used to store information on the user's computer, which is then collected by websites. Among these, the best known and most widely used are HTML cookies. They are used for navigation and to facilitate access and use of the website by the user. They are necessary for the transmission of communications over electronic networks, i.e., for the provider to deliver the service requested by the customer.
2. The settings for managing or disabling cookies may vary depending on the internet browser used. In any case, users can manage or request the general deactivation or deletion of cookies by changing the settings of their internet browser. Such deactivation may slow down or prevent access to certain parts of the site.
3. The use of technical cookies allows for the safe and efficient use of the website.
4. Cookies that are placed in the browser and transmitted via Google Analytics or via the statistics service of bloggers or similar are technical only if used for the purpose of optimizing the site directly by the owner of the site itself, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, as those provided for technical cookies.
5. From the point of view of duration, a distinction can be made between temporary session cookies, which are automatically deleted at the end of the browsing session and are used to identify the user and thus avoid having to log in to each page visited, and permanent cookies, which remain active on the PC until they expire or are deleted by the user.
6. Session cookies may be installed in order to allow access to and remain in the reserved area of the portal as an authenticated user.
7. They are not stored permanently but only for the duration of the browsing session until the browser is closed, and they disappear when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server, which are necessary to enable the safe and efficient exploration of the site.

3 – Third-party cookies

1. In relation to their origin, cookies sent to the browser directly from the website you are visiting are distinguished from third-party cookies sent to your computer from other websites and not from the one you are visiting.
2. Persistent cookies are often third-party cookies.
3. Most third-party cookies are tracking cookies used to identify online behavior, understand interests, and then personalize advertising offers for users.
4. Third-party analytical cookies may be installed. These are sent from domains belonging to the aforementioned third parties external to the site.
5. Third-party analytical cookies are used to collect information on user behavior on Toorxprofessional. The collection is anonymous, in order to monitor performance and improve the usability of the site. Third-party profiling cookies are used to create user profiles, in order to offer advertising messages in line with the choices expressed by the users themselves.
6. The use of these cookies is governed by the rules set by the third parties themselves. Therefore, users are invited to review the privacy policies and instructions for managing or disabling cookies published on the relevant web pages.

4 – Profiling cookies

1. Profiling cookies are those that create profiles relating to the user and are used to send advertising messages in line with the preferences expressed by the user when browsing the web.
2. When these types of cookies are used, the user must give explicit consent.
3. Article 22 of EU Regulation 2016/679 and Article 122 of the Data Protection Code shall apply.

IV – DATA PROCESSED

1 – Data processing methods

1. Like all websites, this site also uses log files in which information collected automatically during user visits is stored. The information collected may include the following:
   • Internet Protocol (IP) address;
   • type of browser and parameters of the device used to connect to the site;
   • name of the internet service provider (ISP);
   • date and time of visit;
   • web page from which the visitor came (referral) and exited;
   • possibly the number of clicks.
2. The aforementioned information is processed automatically and collected in aggregate form only for the purpose of verifying the correct functioning of the site and for security reasons. This information will be processed based on the legitimate interests of the data controller.
3. For security purposes (spam filters, firewalls, virus detection), automatically recorded data may also include personal data such as the IP address, which could be used, in accordance with applicable laws, to block attempts to damage the site itself or to cause damage to other users, or in any case harmful activities or activities constituting a crime. This data is never used to identify or profile the user, but only to protect the site and its users. This information will be processed based on the legitimate interests of the owner.
4. If the website allows comments to be posted, or in the case of specific services requested by the user, including the possibility of sending a CV for a possible employment relationship, the website automatically detects and records certain identifying data of the user, including their email address. This data is voluntarily provided by the user when requesting the service. By entering a comment or other information, the user expressly accepts the privacy policy and, in particular, consents to the content entered being freely disclosed to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary to provide the service.
5. The information that users of the site decide to make public through the services and tools made available to them is provided by the user knowingly and voluntarily, exempting this site from any responsibility for any violations of the law. It is up to the user to verify that they have permission to enter personal data of third parties or content protected by national and international regulations.

2 – Purpose of data processing

1.  The data collected by the website during its operation is used for the purposes indicated above and for the following purposes:
   • request for data for marketing and/or advertising purposes by sending newsletters
2. Data will be stored for the period strictly necessary to achieve the above-mentioned purpose and in any case for no longer than 5 years.
3. Data used for security purposes (blocking attempts to damage the site) is stored for the time strictly necessary to achieve the aforementioned purpose.

3 – Data provided by the user

1. As indicated above, the optional, explicit, and voluntary sending of emails to the addresses indicated on this website entails the subsequent acquisition of the sender's address, which is necessary to respond to requests, as well as any other personal data included in the message.
2. Specific summary information will be progressively reported or displayed on the pages of the website dedicated to particular services on request.

4 – Support in configuring your browser

1. Users can also manage cookies through their browser settings. However, deleting cookies from your browser may remove the preferences you have set for the site.
2. For further information and support, you can also visit the specific help page of the web browser you are using:
   • Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
   • Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
   • Safari: http://www.apple.com/legal/privacy/it/
   • Chrome: https://support.google.com/accounts/answer/61416?hl=it
   • Work: http://www.opera.com/help/tutorials/security/cookies/

5 – Social Network Plugins

1. This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard the privacy of users. Cookies are only set, if required by social networks, when the user actually and voluntarily uses the plugin. Please note that if the user browses while logged into the social network, they have already consented to the use of cookies conveyed through this site at the time of registration with the social network.
2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which reference should be made:
   • Facebook: https://www.facebook.com/help/cookies
   • Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter
   • Google+: http://www.google.com/policies/technologies/cookies
   • Pinterest: https://about.pinterest.com/it/privacy-policy
   • AddThis: http://www.addthis.com/privacy/privacy-policy
   • LinkedIn: https://www.linkedin.com/legal/cookie-policy

V. USER RIGHTS

1. Article 13, paragraph 2 of EU Regulation 2016/679 lists the rights of the user.
2. The Toorxprofessional website therefore intends to inform users about the existence of:
   • the right of the data subject to request the controller to access personal data (Article 15 of the EU Regulation), update them (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003), correct them (Article 16 of the EU Regulation), integrate them (Article 7, paragraph 3, letter a) Legislative Decree 196/2003) or the restriction of processing concerning him or her (Article 18 of the EU Regulation) or to object, on legitimate grounds, to their processing (Article 21 of the EU Regulation), in addition to the right to data portability (Article 20 of the EU Regulation);
   • the right to request the deletion (Art. 17 EU Regulation), anonymization, or blocking of data processed in violation of the law, including data that does not need to be stored for the purposes for which it was collected or subsequently processed (Art. 7, para. 3, letter b) Legislative Decree 196/2003);
   • the right to obtain confirmation that the updating, rectification, integration, erasure, blocking, and transformation of data have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in cases where this proves impossible or involves a manifestly disproportionate effort compared to the right being protected (Art. 7, para. 3, letter C) of Legislative Decree 196/2003);
   •  Requests can be addressed to the data controller, without formalities, or alternatively, using the form provided by the Italian Data Protection Authority, or by sending an email to: contact@toorxprofessional.it
3. If the processing is based on Article 6(1)(a) – express consent to use – or Article 9(2)(a) – express consent to use genetic, biometric, health-related data, data revealing religious or philosophical beliefs or trade union membership, data revealing racial or ethnic origin, political opinions – the user has the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.
4. Similarly, in the event of a violation of the law, the user has the right to lodge a complaint with the Italian Data Protection Authority, which is the authority responsible for monitoring data processing in Italy.
5. For a more detailed examination of your rights, please refer to Articles 15 et seq. of EU Regulation 2016/679 and Article 7 of Legislative Decree 196/2003.

VI – DATA TRANSFER TO NON-EU COUNTRIES

1. This website may share some of the data collected with services located outside the European Union. In particular, with Google, Facebook, and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The above-mentioned companies guarantee their adherence to the Privacy Shield.
2. Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 et seq. of the EU Regulation.

VII. SECURITY OF DATA PROVIDED

1. This website processes user data in a lawful and correct manner, adopting appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated.
2. In addition to the owner, in some cases, categories of persons involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the data.

VIII. CHANGES TO THIS DOCUMENT

1. This document, published at:
   http://www.toorxprofessional.it/privacy-policy/constitutes the privacy policy of this website.
2. It may be subject to changes or updates. In the event of significant changes or updates, users will be notified accordingly.
3. Previous versions of the document will still be available on this page.
4. The document was updated on May 22, 2018, to comply with the relevant regulatory provisions, and in particular in accordance with EU Regulation 2016/679.