Privacy Policy

Cookie & Privacy Policies

COOKIE POLICY (ENG)

With this document, pursuant to art. 13 of EU Reg. 679/2016 (so-called Privacy Regulation) and art. 122 of Legislative Decree 196/2003 (so-called Privacy Code), as well as in accordance with the provisions of the General Provision of the Privacy Guarantor of 8 May 2014 and the Guidelines on cookies and other tracking tools issued by the Privacy Guarantor on 10 June 2021 as well as the Privacy Regulation (Article 95, in particular), the Data Controller provides you with the following information relating to the cookies used on the Site.

Specifically, the following cookies are used:

FFID – g=m7utmheak1c8k26qph85t3v4

Technical cookies:

These are used for the sole purpose of "carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide such service". They are used to carry out navigation or to provide a service requested by the user. They are not used for other purposes and are normally installed directly by the owner of the website. Without these cookies, some operations could not be performed or would be more complex and/or less secure. They can be divided into: (i) navigation or session cookies, which ensure normal navigation and use of the website (allowing, for example, purchases or authentication to access restricted areas); they are, in fact, necessary for the proper functioning of the site; (ii) analytics cookies, similar to technical cookies when used directly by the site operator or to collect information, in aggregate form, on the number of users and how they visit the site, in order to improve the site's performance; (iii) functionality cookies, which allow the user to navigate based on a set of selected criteria (for example, language, products selected for purchase) in order to improve the service provided. Session Cookies

What are cookies?

A "cookie" is a small text file created on the user's computer when they access a particular site, with the purpose of storing and transporting information. Cookies are sent from a web server (the computer running the website being visited) to the user's browser (Internet Explorer, Mozilla Firefox, Google Chrome, Opera, etc.) and stored on the user's computer; they are then sent back to the website on subsequent visits.

Types of cookies used by the Site

As listed in the table above, the Site only uses technical cookies owned by the Data Controller. Pursuant to Article 122 of the Privacy Code, the Provision of the Italian Data Protection Authority of 8 May 2014, the Guidelines on Cookies and Other Tracking Tools issued by the Italian Data Protection Authority on 10 June 2021, and the Privacy Regulation (Article 95, in particular), your consent is not required. Therefore, your consent will not be collected via a banner.

Processing Methods

: Processing is carried out using automated tools that ensure security, in relation to the purposes for which they were collected, as well as to prevent unauthorized access by third parties and, in any case, in compliance with the provisions of national and European legislation. Processing is carried out by the Data Controller, the Data Processors, and the Data Processors delegated for this purpose. No dissemination is carried out.

Disabling Cookies.

In addition to what is indicated in this document, you can manage your cookie preferences directly within your browser and prevent, for example, third parties from installing them. Through your browser preferences, you can also delete previously installed cookies, including the cookie that may have saved your consent to the installation of cookies by the Site.

Managing Settings.

Each browser has different procedures for managing settings. You can obtain specific instructions through the links below.

Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&p=cpn_cookies

Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie

Apple Safari: https://www.apple.com/legal/privacy/it/cookies/

For information on the cookies stored on your terminal and to disable them individually, please refer to the link: http://www.youronlinechoices.com/it/le-tue-scelte

COOKIE POLICY (EN)

Pursuant to article 13 of Regulation EU 679/2016 (General Data Protection Regulation) and section 122 of Legislative Decree 196/2003 (Italian Data Protection Act), as well as the provisions of the General Order of the Data Protection Supervisor dated 8th May 2014 and the guidelines for cookies and other tracking tools issued by the Data Protection Supervisor on 10th June 2021, as well as by the GDPR (in particular, article 95), the Controller hereby provides you with the following information about the cookies used on the website.

More specifically, the following cookies are used:

Cookie:

FFID – g=m7utmheak1c8k26qph85t3v4

Technical cookies:

These are used for the sole purpose of “carrying out the transmission of a communication over an electronic communications network, or as strictly necessary in order to provide an information society service explicitly requested by the subscriber or user”. They are used for browsing or to provide a service requested by the user. They are not used for additional purposes and are normally installed directly by the website owner. Without the use of these cookies, some operations could not be carried out or would be more complex and/or less secure. They can be divided into: (i) browsing (or session) cookies allowing normal website browsing and use (for example, to enable purchasing or user authentication when logging in to a secure area); indeed, they are needed for the website to function properly; (ii) analytics cookies, similar to technical cookies when used directly by the site administrator or to collect information, in aggregate form, on the number of users and how they visit the site in order to improve performance; (iii) functional cookies that enable the user to browse according to a set of selected criteria (eg language, items in shopping basket) in order to improve the service provided. Session cookies

What are cookies?

A cookie is a small text file placed on the user's computer when visiting a certain website in order to store and convey information. Cookies are sent by a web server (that is the computer on which the website visited is running) to the user's browser (Internet Explorer, Mozilla Firefox, Google Chrome, Opera, etc.) and stored on the latter's computer; therefore, they are resent to the website when a subsequent visit is made.

Cookie types used by website

As per list provided in the table above, the website uses its owner's own technical cookies for which, pursuant to section 122 of the Italian Data Protection Act, Order of the Data Protection Supervisor dated 8th May 2014 and guidelines for cookies and other tracking tools issued by the Data Protection Supervisor on 10th June 2021, as well as the GDPR (in particular article 95), your consent is not required. Therefore, obtaining your consent through a banner is not necessary.

Processing methods

Data processing takes place by automated means, designed to ensure, with regard to the purposes for which it has been collected, its security, as well as prevent unauthorized access by third parties and, in any event, in accordance with the provisions of national and European legislation. Processing is carried out by the Controller, Processors and persons specifically authorized to perform processing. No dissemination takes place.

Disabling cookies

In addition to the advice given herein, you may also handle your cookie preferences directly within your browser and, for example, prevent their installation by third-parties. Using the browser preferences, you can delete previously-installed cookies, including, where applicable, the one in which permission for the Website to install cookies is saved.

Settings management

Each browser has different procedures for managing settings. Use the links below in order to obtain specific instructions.

Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&p=cpn_cookies

Mozilla Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie

Apple Safari: https://www.apple.com/legal/privacy/it/cookies/

To obtain details of cookies stored on your device and turn them off individually, please follow the link: http://www.youronlinechoices.com/it/le-tue-scelte

IN ACCORDANCE WITH ART. 13 EU REGULATION 679/2016 (“PRIVACY REGULATION”)

Protecting the security and privacy of your personal data is important to Newronika SpA, with registered office at Via Dante n. 4, 20121 – Milan (MI), email: admin@newronika.it (hereinafter, the “Data Controller”), which acts in compliance with the laws currently in force regarding the protection and security of personal data. We trust that the information below will help you understand what type of data the Data Controller typically collects, how it is used and safeguarded, and with whom it is shared.

Pursuant to art. 13 of EU Regulation 679/2016 (“Privacy Regulation”), we therefore wish to inform you that the processing of your personal data will be based on principles of fairness, lawfulness, and transparency, protecting your privacy and your rights and in compliance with current legislation regarding the security and protection of personal data.

In particular, we inform you of the following:

a. Source of personal data.

The personal data in our possession are those provided by you at the time of registration and/or when you submit a request for information about our products/services, through the "Contact Us" section on our website. All personal data will be processed in compliance with the Privacy Code and subsequent amendments, the Privacy Regulation, and the confidentiality obligations that have always guided the Data Controller's activity. b.

Legal basis and purpose of processing.

The purposes for which we will process your data are as follows:

b.1) Purpose of managing your requests.

By processing the data you provide, we will be able to respond to your requests for information regarding the characteristics and nature of the products/services you have expressed interest in, or similar products/services if those you are interested in are temporarily or permanently unavailable, or any initiatives undertaken by the Data Controller.

In this case, the legal basis for this processing is the implementation of pre-contractual measures adopted at your request.

c. Processing methods.

Data will be processed using electronic means that are suitable to guarantee, in relation to the purposes for which they were communicated and collected, their security, as well as to prevent unauthorized access by third parties and, in any case, in compliance with the provisions of national and European legislation.

d. Nature of the provision.

The provision of data in relation to the purpose referred to in point b.1 is mandatory as a necessary requirement to be able to respond to your requests. Failure to provide this information will result in your refusal to receive information about our products in which you have expressed interest.

We invite you not to provide, when using the service, sensitive/special data, i.e., data that may reveal, among other things, your racial or ethnic origin, religious beliefs, political opinions, membership in political parties, trade unions, associations, and organizations of a religious, philosophical, political, or trade union nature, as well as your health. Any sensitive data provided will be immediately deleted.

e. Data Subjects and Data Disclosure

Your personal data may be disclosed to the Data Controller's employees and/or collaborators tasked with carrying out activities necessary for the Data Controller to achieve the processing purposes referred to in paragraph b.1) above.

They may also be disclosed to IT and logistics service providers involved in the operation of the Site, outsourced service providers, professionals, and consultants.

These individuals, formally appointed by the Data Controller as Data Processors, Data Processors, and/or System Administrators, will process your data in compliance with and exclusively for the purposes indicated in this policy and under the Data Controller's control and supervision.

Your data may also be disclosed to third-party suppliers, such as shippers and/or agents, who will process them as Data Processors appointed by the Data Controller or, as applicable, as independent Data Controllers. The complete and updated list of parties to whom your data has been disclosed can be requested from the Data Controller, whom you can contact by writing to the email address indicated in point h).

f. Dissemination of data

The Data Controller will not disseminate your personal data.

g. Transfer of data abroad

Your personal data will be transferred to countries outside the EEA (European Union, Iceland, Liechtenstein, and Norway).

h. Rights of the interested party

Finally, we inform you of the possibility of exercising the rights granted to you by law at any time, which we list below:

• access the data provided;

• obtain the rectification of the data provided, its deletion, transformation into anonymous form, blocking of data processed in violation of the law, or limitation of the processing of data concerning you;

• object to data processing;

• withdraw your consent;

• obtain the portability of your data;

• obtain confirmation of the existence or otherwise of the same data, know its content and origin, verify its accuracy or request its integration or updating, know the purposes and methods of processing, the logic applied in the case of processing carried out with the aid of electronic tools, the identification details of the owner, managers, persons in charge and the DPO, if one is designated;

• lodge a complaint with the supervisory authority (Privacy Guarantor);

• object to an automated decision-making process concerning natural persons, including profiling;

• obtain, without undue delay, communication of a breach of your personal data.

Requests should be sent:

- by email, to the address: admin@newronika.it;

- or by post, to the address: via dante n. 4, 20121 - Milan (MI).

i. Data retention period.

The data you provide for purpose b.1 above will be retained for the time necessary to process your request for information and, subsequently, for the time necessary to execute the contract, should the latter be concluded following your request for information. Subsequently, the data you provide may be retained for a period of ten years in order to comply with legal obligations and, in particular, the obligations set forth in Article 2214 of the Italian Civil Code.

If, for any reason, the retention of your personal data is no longer justified based on assessments carried out that take into account the principles of necessity, proportionality, adequacy, and relevance of the processing, the Data Controller will promptly delete or anonymize your data.

l. Data Controller

The Data Controller is Newronika SpA, with registered office at Via Dante n. 4, 20121 – Milan (MI), email: admin@newronika.

PRIVACY NOTICE PURSUANT TO ARTICLE 13 OF REGULATION (EU) 679/2016 (GENERAL DATA PROTECTION REGULATION)

Protecting the security and privacy of your personal data is important for Newronika SpA, whose registered office is at via Dante 4, 20121 – Milan (MI), e-mail: admin@newronika.it (hereinafter the “Controller”), that acts in compliance with personal data protection and security legislation. We trust that the information provided hereafter will help you to understand the type of data that the Controller usually collects, how such data is used and protected and with whom it is shared.

Therefore, pursuant to article 13 of Regulation (EU) 679/2016 (General Data Protection Regulation), we wish to advise you that your personal data will be processed lawfully, fairly and in a transparent manner, safeguarding your confidentiality and rights and in compliance with current personal data security and protection legislation.

More specifically, we would advise as follows:

a. Source of the personal data

The personal data in our possession is that which you provided when registering and/or when forwarding a request for information about our products/services using the 'Contact us' section at our website. All personal data will be processed in accordance with the Data Protection Act as amended and supplemented, the GDPR and the confidentiality obligations that have always been the cornerstone of Controller's work.

b. Purpose of and legal basis for processing

We will process your data for the following purposes:

b.1) For the purpose of handling your requests

By processing the data you have provided, we will be able to answer your requests for information regarding the specifications and nature of products/services in which you have shown an interest, or similar products/services, when those in which you have expressed an interest are temporarily unavailable or have been discontinued, or should the Controller run a promotion.

In this case, the legal basis for such processing is in order to take steps at your request prior to entering into a contract.

c. Processing methods

Data processing will take place using electronic means, designed to ensure, with regard to the purposes for which it has been disclosed and collected, its security, as well as prevent unauthorized access by third parties and, in any event, in accordance with the provisions of national and European legislation.

d. Reason for supplying data

Providing data for the purposes specified under b.1 is mandatory since necessary in order to be able to deal with your requests; in the event of your refusal to provide these details, you will not be able to receive information about our products in which you expressed an interest.

While using the service, we would ask you not to disclose sensitive/special data, i.e. data that could reveal, amongst other things, racial or ethnic origin, beliefs, political opinions, membership of religious parties, trade unions, associations and organizations with a religious, philosophical, political or trade union aim, as well as health status. Any sensitive data received will be deleted immediately.

And. Data processors and data disclosure

Your personal data may be disclosed to employees and/or assistants of the Controller to whom it has assigned the task of carrying out the activities needed to achieve the processing purposes specified under b.1) above.

It may also be seen by suppliers of IT and logistics services needed to operate the site, outsourcing service providers, professionals and consultants.

Formally appointed by the Controller as Processors, persons authorized to process personal data and/or System Administrators, these parties will process your data in compliance with and solely for the purposes specified herein under its/his control and supervision.

Your data may be disclosed to third party suppliers, for example couriers and/or agents, who will process it, in the capacity of Processors appointed by the Controller or, as the case may be, independent Controllers. The full, up-to-date list of parties to whom your data has been disclosed may be requested by the Controller who you may contact by writing to the e-mail address given under h).

f. Data dissemination

The Controller will not engage in dissemination of your personal data.

g. Cross-border transfer

In order to manage the service, your personal data will be transferred to countries outside the EEA (European Union, Iceland, Liechtenstein and Norway) based on the provisions of the supplier DPA or 2021 Standard Contractual Clauses. All transfers of Personal Data to a third country shall be subject to the appropriate security measures specified by Article 46 of the GDPR and such transfers and security measures shall be documented in accordance with Article 30(2) therein.

h. Data subject's rights

In conclusion, we would advise you of the possibility of exercising, at any time, your legally-recognized rights as set out hereafter:

• to access the data provided;

• to obtain rectification of the data provided, its erasure, rendering anonymous, prevention of access to unlawfully-processed data or restriction of processing of data that concerns you;

• to object to the processing of data;

• to withdraw your consent;

• to obtain portability of your data;

• to obtain confirmation as to whether or not this data exists, know its content and source, verify its accuracy or request it be completed if incomplete or updated, know the purposes and method of processing, the logic involved when processing with the aid of electronic means, details of the Controller, Processors, persons authorized to process personal data and, if appointed, the DPO;

• to submit a complaint to the supervisory authority (Data Protection Supervisor);

• to oppose automated individual decision-making, including profiling;

• to obtain, without undue delay, notification of a breach of your personal data.

Applications should be submitted:

- by e-mail to: admin@newronika.it;

- or by post to the address: via Dante n. 4, 20121 - Milan (MI).

the. Data storage period

The data you have supplied as regards purpose b.1 above will be stored for the time required to handle your request for information and, subsequently, the time required for the performance of the contract if entered into following your request for information. Subsequently, the data you have provided may be stored for a period of ten years in order to comply with statutory requirements and, in particular, the provisions of section 2214 of the Italian Civil Code.

Where, for any reason, there is no justification for continued storage of your personal data based on assessments made that consider the principles of proportionality, necessity, adequacy and relevance of the processing, the Controller shall arrange for its deletion or anonymisation without delay.

the. Data Controller

The Controller is Newronika SpA whose registered office is at via Dante 4, 20121 - Milan (MI), e-mail: admin@newronika.it.

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