Privacy policy

The holder of the treatment in accordance with current laws is the webpage administrator, Elena Merli, who can be contacted through the CONTACT section (link at the bottom of the page).

This webpage processes data mainly on the basis of user consent. The consent is given through the banner located at the bottom of the page, or through the use or consultation of the webpage, that is meant as conclusive behaviour. By using or consulting the webpage, visitors and users approve this privacy statement and consent to the processing of their personal data in relation to the methods and purposes described below, including any disclosure to third parties if necessary for the provision of a service. Further consents relating to the specific purpose of the service are collected through the contact or service request forms.

The provision of data and therefore consent to the collection and processing of data is optional. The user can refuse consent, and can withdraw at any time a consent already provided (via the banner at the bottom of the page or the browser settings for cookies, or the link to CONTACT). However, denying consent may make it impossible to provide certain services and the browsing experience on the webpage would be compromised.

The data for the webpage security and for the prevention of abuse and SPAM, as well as data for the analysis of site traffic (statistics) in aggregate form, are processed based on the legitimate interest of the data holder to protect the site and the users themselves. In such cases, the user always has the right to object to the processing of data.

The data provided for professional consultancy or assignments are processed on the basis of the fulfilment of a contract and the fulfilment of a legal obligation. In such cases, specific information is provided.

The processing of data collected by the webpage, in addition to the related, instrumental and necessary purposes for providing the service, is aimed at the following purposes:

• Statistical (analysis)

Collection of data and information in an exclusively aggregated and anonymous form in order to verify the correct functioning of the webpage. None of this information is related to the physical person-user of the site, and does not allow identification in any way. Consent is not required.

• Security

Collection of data and information in order to protect the security of the webpage (anti spam filters, firewalls, virus detection) and of users and to prevent or unmask fraud or abuse to the detriment of the website. The data are recorded automatically and may possibly also include personal data (IP address) which could be used, in accordance with the laws in force on the subject, in order to block attempts to damage the page itself or to damage other users, or in any case harmful activities or constituting a crime. These data are never used for the identification or profiling of the user and are periodically deleted. Consent is not required.

• Ancillary activities

They deal with communicating data to third parties who perform necessary or instrumental functions for the operation of the service (e.g. comment box), and with allowing third parties to carry out technical, logistical and other activities on our behalf. Suppliers have access only to personal data that is necessary to perform their duties, and undertake not to use the data for other purposes, and are required to process personal data in accordance with current regulations.

• Counselling and professional assignments

In case of spontaneous sending of data in order to request professional counselling or book professional assignment, the data will be used only for the purpose of evaluating the assignment and for the possible fulfilment of the same. In such cases, specific information will be provided.

This webpage collects users’ data in two ways.

• Data collected in an automated way

During the browsing by the users, the following information may be collected which is kept in the page's server (hosting) log files:

- internet Protocol address (IP);

• type of browser;
• parameters to connect to the page of the used device;
• name of the internet service provider (ISP);
• date and time of visit;
• visitor’s webpage of origin (referral) and exit webpage;
• possibly the number of clicks.

These data are used for statistical and analysis purposes, in an exclusively aggregated form. The IP address is used exclusively for security purposes and is not crossed with any other data.

• Data provided voluntarily

The site may collect other data in the event of voluntary use of services by users, such as commenting, communication services (contact forms, comment box), and will be used exclusively for the provision of the requested service:

• name;
• email address;
• any further data sent spontaneously by the user.

The data are processed at the headquarters of the data holder, and at the web hosting datacenter (Scaleway). The web hosting (Scaleway, www.scaleway.com/en/) is responsible for the treatment, processing the data on behalf of the owner. The web hosting name is to be found in the European Economic Area and it acts in accordance with European standards (privacy policy of Scaleway).

The data collected by the site during its operation are kept for the time strictly necessary to carry out the specified activities. Upon expiry, the data will be deleted or anonymised, unless there are additional purposes for the conservation of the same. The data (IP address) used for site security purposes (blocking attempts to damage the site) are kept for 30 days. The data for analytics purposes (statistics) are stored in aggregate form for 24 months. The data (name, surname, address, telephone number, e-mail address and copy of the bank transfer) necessary for the company’s declaration of income are kept for at least 5 years as required by the Danish revenue agency. The data is categorised into a dedicated billing program and google drive as well as stored in the PC workbooks. The data are provided directly by customers via e-mail to allow A Spasso con Elena to issue the invoice and receive the payment. Data is kept for at least 5 years as required by the Danish revenue agency. The data concerning the invoices issued can not be canceled until after 5 years, even upon request.

The data collected by the webpage are generally not provided to third parties, except in specific cases: legitimate request by the judicial authority and only in the cases provided for by law; if it is necessary for the provision of a specific service requested by the user; for performing security checks or site optimisation.

This webpage may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transmission is authorised on the basis of specific decisions of the European Union and of the guarantor for the protection of personal data, in particular decision 1250/2016 (Privacy Shield - here the information page of the Italian Guarantor), for which no further consent is required. The companies mentioned above guarantee their adhesion to the Privacy Shield.

We treat visitor/user data in a lawful and correct way, adopting appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of data. We are committed to protecting the security of your personal data when it is sent, using the Secure Sockets Layer (SSL) software, which encrypts the information in transit. The processing is carried out using IT and/or telematic tools, with organisational methods and with logic strictly related to the purposes indicated. In addition to the owner, in some cases, other categories of personnel involved in the organisation of the webpage or external subjects (such as third party technical service providers, hosting providers) may have access to the data.

In exchange for our seriousness and fairness, we demand the same treatment from users and customers. All information and materials made available on our services, communicated via e-mail, present in tourist programs and on our website-blog, are private and personalised for specific requests. It is not allowed to forward them to third parties without the explicit consent of A Spasso con Elena.