This page provides a description of the Management Procedure for the site in question with reference to the processing of personal data of those users who wish to consult it. This report is made also in accordance with Art. 13 art. of Decree Law n° 196/2003 and its subsequent amendments and integrations – the Code regarding protection of personal information for those who interact with the Headu srl web services that are accessible via telematics means, starting from the address: https://headu.com/
The report is made only for the https://headu.com/ site, and does not include other web sites possibly consulted by the user by means of links. The report also complies with Recommendation n. 2/2001 which the European authorities for the protection of personal data set up in the Group established by Art. 29 of Directive n° 95/46/CE, adopted on 17 May 2001 in order to identify several minimal requisites for the collecting of personal information on-line and, in particular, the procedures, times and nature of the information that data processing proprietors must provide to users when they interconnect with a web page, independently of the reasons for the interconnection.
PROPRIETOR OF THE DATA PROCESSING
Following the consultation of this site, data relative to identified or identifiable persons can be processed.
The “proprietor” of their processing is: Headu srl
LOCATION OF THE DATA PROCESSING
The processing connected with the web services of this site is carried out in the head offices of Headu srl, and are attended to solely by the technical personnel of the Office assigned to the processing, or else by persons possibly assigned for occasional maintenance operations. No data deriving from the web service can be communicated or divulged. The personal data supplied by users who send in requests for informative material (newsletters, documents, replies to queries, etc.) are utilised for the sole purpose of performing the service requested, and are communicated to third parties only in the case in which this is absolutely necessary.
During the course of their normal exercise, the computer services and the software procedures appointed for the functioning of this web site acquire personal data, the transmission of which is implicit in the use of the Internet protocols of communication. This is information that has not been collected in order to be associated with identified interested parties, but due to its very nature could – by means of processing and associations with data held by third parties – permit the identification of the said users. In this category of data are included IPaddresses or the names controlling computers utilised by users who are connected to the site, the addresses in URI (Uniform Resource Identifier) notations of the resources requested, the exact time of the request, the method used to submit the request to the server, the size of the file obtained by way of a reply, the numerical code indicated by the state of the reply given by the server (successfully received, error, etc.), and other parameters relative to the operative system and to the user’s computer-related environment. These data are utilised for the sole purpose of producing anonymous statistical information on the use of the site and for controlling its correct functioning, and are cancelled immediately after being processed. The data could be utilised for ascertaining responsibility in the case of hypothetical computer-related crimes to the detriment of the site. Except for this possibility, at present data on web contacts do not continue to cause damage to the site for more than seven days.
DATA SUPPLIED VOLUNTARILY BY THE USER
The optional, explicit and voluntary sending of e-mails to the addresses indicated in this site involve the subsequent acquisition of the sender’s address, which is necessary in order to answer requests, as well as of other possible personal information inserted in the letter. Informative specifications for purposes of succinctness will be reported progressively or visualised on the pages of the site organised for special services upon request.
No personal user data in this connection is obtained from the site. No use is made of cookies for the transmission of information of a personal nature, nor are so-called persistent cookies of any type utilised, nor systems for tracing users. The use of so-called “session” cookies (which are not memorised in persistent manner in the user’s computer, and disappear with the closing of the browser) is strictly limited to the transmission of a session identifier (consisting of casual numbers generated by the server) necessary for permitting a sure and efficient exploration of the site. The so-called session cookies utilised in this site avoid resorting to other computer-related techniques potentially detrimental to the reserved nature of user navigation, and does not permit obtaining user personal data that could possibly be identified.
OPTIONAL CONDITIONS OF THE CONFERMENT OF DATA
Except for what is specified for navigation data, the user is free to provide the personal data stipulated in the application forms to the guarantor or in any case indicated in contacts with the Office in order to solicit the sending of informative material or other communications. The failure to confer them may make it impossible to obtain what has been requested.
So as not to leave anything out, it should be remembered that in some cases (not the object of the ordinary management of this site) the Authorities can request news and information in accordance with art. 157 of Decree Law N° 196/2003 for the purpose of controlling the processing of personal data. In these cases, the reply is obligatory, pain of administrative sanction.
Personal data are processed with the use of automated instruments for the amount of time strictly necessary for achieving the purposes for which they had been collected. Specific safety measures are observed in order to prevent the loss of data, unlawful or incorrect use, and unauthorised access.
RIGHTS OF PERSONS CONCERNED
The persons to whom the personal data refer have the right in any moment whatsoever to obtain confirmation of the existence or non-existence of the said data and to learn of the contents and origin of these, control their correctness or updating, or else their adjustment (Art. 7 of Decree Law N° 196/2003). In accordance with the same Article, they have the right to request the cancellation, transformation in anonymous form, or blocking of data processed illegally, as well as to oppose in any case their processing for legitimate reasons. Requests must be addressed to Headu srl.