Privacy & Cookie Policy

Information regarding the processing of personal data

The following information is prepared in accordance with Article 13 of the EU Regulation 2016/679 (so-called GDPR, hereinafter referred to as the “Regulation”), in relation to the personal data of users collected when accessing the site and/or requesting information, as well as the manner and purpose for which they are processed.

1. Data Controller

The Data Controller of the processing carried out through the website creasi.it (hereinafter referred to as “Site”) is Creasi srl, with registered office in via Curiel, 21 – 46024 Moglia (MN). The Data Controller is available for any information concerning the processing of personal data by contacting him at creasi@creasi.it .

2. Types of Data Processed

Processing of Personal Data means any operation or set of operations, performed with or without the aid of automated processes, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.

The Personal Data collected and processed through the Site are as follows:

NAVIGATION DATA

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, 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 (successful, error, etc.) and other parameters relating to the user’s operating system and 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, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site or third parties.

DATA VOLUNTARILY PROVIDED BY THE DATA SUBJECT

Through the optional, explicit and voluntary sending of e-mail messages to creasi@creasi.it, or by filling in the contact form, the following personal data will be collected, in addition to the data voluntarily indicated by the User in the text of the message: first name, last name, e-mail address. A specific summary information and request for consent is provided in the prepared section.

Apart from what is specified for navigation data, the User is free to provide his/her personal data. Failure to provide them may result in the impossibility of obtaining what has been requested. For the sake of completeness, it should be mentioned that, in some cases (not subject to the ordinary management of this site), the Authority may request news and information in accordance with the Regulations, for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

Any use of Cookies – or other tracking tools – by this Site or the owners of third party services used by this Site, where not otherwise specified, is for the purpose of identifying the User and recording their preferences, as indicated in the specific Cookie Policy statement, subject to the explicit consent of the User where required.

The User assumes responsibility for third party Personal Data posted or shared through this Site and warrants that he or she has the right to disclose or disseminate it, releasing the Owner from any liability to third parties.

3. Method of treatment.

The Controller processes Users’ Personal Data by taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, categories of appointees involved in the organization of the site (employees, lawyers, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

4. Purposes of the Processing of Collected Data

User Data are collected to enable the Owner to provide its services and, upon specific consent where necessary, for the following purposes:

a) to enable the provision of the requested services and the subsequent operational, technical and administrative management of the relationship related to the provision of the Services and any communications related thereto;

(b) allow browsing and consultation of the Site;

(c) responding to requests for assistance or information, received by e-mail or telephone;

(d) fulfill legal, accounting and tax obligations;

(e) for the exclusive purposes of security and prevention of fraudulent conduct;

f ) carry out marketing activities and/or promote the services provided by the Holder, via e-mail or through the holder’s official profiles on social networks (Instagram, Facebook) unless you have objected to such processing initially or in subsequent communications.

5. Legal basis and mandatory or optional nature of processing

The legal basis for the processing of Personal Data for the purposes set out in Section 4 (a-b-c) is Article 6(1)(b) of the Regulations, as the processing is necessary for the provision of the contracted Services. The provision of Personal Data for these purposes is optional but failure to provide it would result in the inability to activate the Services requested.

The purpose referred to in Section 4 (d) represents legitimate processing of Personal Data within the meaning of Article 6(1)(c) of the Regulations. Once Personal Data is provided, the processing may indeed be necessary to comply with legal obligations to which the Controller is subject.

The processing referred to in Section 4(e) is also based on the legitimate interest of the Controller in detecting fraud and scams carried out against it, in accordance with Article 6(1)(f) of the Regulations.

The processing performed for the purpose described in Section 4(f) is based on the explicit granting of the User’s consent pursuant to Article 6(1)(a) of the Regulations. The provision of Personal Data for this purpose is entirely optional and does not affect the use of the Services. Should the User wish to object, at a later date, to the processing of his or her data for the purpose referred to in Section 4(f), he or she may do so at any time by sending a request by email.

6. Recipients of personal data

The Personal Data collected may be shared, for the purposes mentioned in Section 4, with:

(a) individuals who typically act as Data Processors viz:

1. persons, companies or professional firms that provide assistance and consulting services to the Owner in accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services;
2. Entities delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks).

(b) subjects, entities or authorities to whom it is obligatory to communicate your personal data under provisions of the law or orders of the authorities;

(c) employees and persons authorized by the Data Controller to process Personal Data, in order to carry out activities closely related to the provision of the Services, who have committed to confidentiality or have an appropriate legal obligation of confidentiality;

(d) business partners for their own, autonomous and separate purposes only after giving specific consent.

The full list of data processors is available by sending a request to creasi@creasi.it.

7. Transfers of personal data

Some of your Personal Data may be processed and/or transferred to recipients operating in countries outside the European Economic Area. Pursuant to Articles 45 and 46 of the Regulation, the Data Controller ensures that the processing of your Personal Data by these recipients will only take place in the presence of an adequacy decision adopted by the European Commission for the third country in which they operate or, in the absence thereof, by providing adequate guarantees of full compliance with the Regulation. In particular, the processing of Personal Data carried out in the U.S. will only be allowed to U.S. operators that have adhered to the Data Privacy Framework in force since 07/2023. More information is available from the Data Controller.

8. Data Retention.

Personal Data processed for the purposes set out in section 4(a-b-c) will be kept for the time strictly necessary to achieve the stated purposes. In any case, since the processing is carried out for the provision of Services, the Data Controller will retain Personal Data for as long as permitted by Italian law to protect its interests.

Personal Data processed for the purposes set forth in Section 4(d) will be retained for as long as required by the specific applicable legal requirement or rule.

For the purpose of Section 4 (e)(f), Personal Data will instead be processed until consent is revoked or until three years after the termination of the contractual relationship with the Data Controller.

More information regarding the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller.

9. Further information on treatment

9.1 Defense in court

The User’s Personal Data may be used for the defense by the Data Controller in court or in the preparatory stages of its possible establishment, from abuse in the use of the same or related services by the User.
The User declares that he/she is aware that the Data Controller may be required to disclose the Data at the request of public authorities.

9.2 Specific disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Site may provide the User with additional and contextual disclosures regarding specific services, or the collection and processing of Personal Data.

9.3 Information not contained in this policy

More information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact information.

9.4 Exercise of Rights by Users

The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or non-existence of the same at the Data Controller, to know its content and origin, to verify its accuracy or request its integration, deletion, updating, rectification, transformation into anonymous form or blocking of Personal Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing. Requests should be addressed to the Data Controller at the following address: creasi@creasi.it.

10. Changes to this Privacy Policy

This privacy policy is effective 03/2025.

The Owner reserves the right to update this Privacy Policy at any time in order to adapt it to the supervening law and to improve it also taking into account the suggestions transmitted by customers, collaborators and users. If changes to this Policy are substantial in the processing or may otherwise have a significant impact on data subjects, the Controller will take care to notify them appropriately.