Privacy and cookie policy

 

PRIVACY POLICY PURSUANT TO ART. 13 OF EU REGULATION 2016/679

Last updated: 20 October 2026

With this privacy policy, FINCONS, as Data Controller pursuant to Article 4 of Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”), informs (pursuant to Article 13) all visitors to this website of how their personal data will be used and processed.

Definitions

“Personal data” (pursuant to Article 4(1) of Regulation (EU) 2016/679) means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” (pursuant to Article 4(2) of Regulation (EU) 2016/679) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Who is the Data Controller and how can I contact them?

Company name: FINCONS

Registered office: Via Torri Bianche 10, Vimercate (MB), Italy

Telephone: +39 039 657081

E-mail: privacy@finconsgroup.com

Data Protection Officer

Davide Romano

Telephone: +39 039 657081

E-mail: dpofincons@finconsgroup.com

Processing of data required for browsing

In the course of their normal operation, the IT systems and software procedures used to run this website acquire certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected in order to be associated with identified data subjects but, by its very nature, could make it possible to identify users through processing and association with data held by third parties.

The information that may be collected includes IP addresses, the type of browser or operating system used, URI (Uniform Resource Identifier) addresses, the domain name and addresses of the websites from which the user accessed or exited the site (referring/exit pages), the time of the request to the server, the method used and information on the response received, further information on the user’s browsing on the site (see also the section on cookies) and other parameters relating to the user’s operating system and IT environment.

These data may also be used to establish liability in the event of any computer crimes committed against the site.

Processing of data for other purposes

Personal data are collected following contact with Fincons and are entered into our CRM by our staff where the user has expressed an interest in our initiatives, services or products (e.g. during business meetings, events or conferences, or by completing a form on our website). The data entered in this way may include the user’s name, e-mail address, job title, department, and the projects and initiatives associated with them.

Unless and until otherwise notified, personal data will be processed for marketing purposes, for example to send promotional and commercial communications about products and services offered by Fincons as part of co-marketing activities and to inform users about Fincons events, using both automated means of contact (e.g. e-mail) and traditional means (such as telephone calls made by an operator and ordinary post).

With regard to the e-mails sent, the following user actions will be tracked by means of technical cookies:

  • actual delivery of the e-mail;
  • opening of the e-mail;
  • any action taken (e.g. clicking on a link contained in the e-mail);

These tracking data will be processed solely for technical reasons, in particular to confirm that the e-mail has been correctly sent and received, and to check, for statistical purposes and in aggregate form, whether the site has been accessed.

The legal basis for the processing is Fincons’ legitimate interest in promoting its own products and services.

Personal and contact details will be kept for the duration of the business relationship and in any case for no longer than 24 months. Users retain the right to ask at any time to stop receiving our promotional communications by objecting to the processing as described in the section “Exercising the rights of the data subject”. Objecting also stops the e-mail tracking described above.

Any further processing carried out through this website and not described in this notice relates exclusively to the “Job” section and is described in the specific privacy notice provided there.

*Categories of recipients

For the purposes indicated, data may be disclosed to the parties and/or categories of parties listed below, or to companies and/or persons, including external ones, providing services on behalf of the Data Controller, which may also be located outside the European Economic Area (see the section “Transfer of Personal Data”). For greater clarity, the different types of recipients** are listed below:

  • Departments and offices of the Data Controller;
  • IT service companies;
  • Hosting, content delivery and website monitoring service providers;
  • CRM and marketing automation service providers;
  • Advertising platforms and social networks acting as independent controllers or joint controllers, limited to data collected through the trackers to which the user has consented (see the section “List of cookies”).

(**) A list of external recipients/processors, including in relation to other processing carried out by the Data Controller, with further details useful for their identification, is available from the Data Controller.

List of cookies

A cookie is a small piece of data (text file) that a website, when visited by a user, asks the browser to store on the device in order to remember information about the user, such as their preferred language or login details. These cookies are set by us and are called first-party cookies. We also use third-party cookies – i.e. cookies from a domain other than that of the website being visited – for our advertising and marketing efforts. In particular, we use cookies and other tracking technologies for the following purposes:

Necessary

This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Cookie PolicyCookie Policy

Activities that do not fit the above categorizations

Agile CRM (Agile CRM Inc.)

These cookies may be set through our site by our marketing automation and CRM partners to identify users, track page navigation, and manage contact interactions. They are used to build a profile of your interests, automate marketing communications, and enhance lead generation by delivering a personalized user experience. They do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, activity tracking and personalized promotional messaging will not be operational.

Trackers duration: up to 24 months

Kalì platform

It is an advanced multichannel publishing platform delivered as a SaaS (Software as a Service) solution and used by some of the most important Italian and international companies and public administrations.

KLT s a cookie that collects, transmits and processes data exclusively anonymously in order to track the effectiveness in terms of usability of the objects on the Site.

Achxxxxxxxxxx is a cookie used to memorize the state of the accordion relative to a “directory box” (open / closed) to present it in the same situation when the page is reloaded

Trackers duration:

klt: duration of the session
achxxxxxxxxxx: duration of the session

User consent

Under current legislation, the Fincons website is not required to request consent for technical cookies (“Necessary” category), as they are strictly necessary for the operation of the site and the provision of the services requested. These cookies are therefore installed automatically when the user first visits any page of the portal and cannot be disabled via the preferences panel. All other Trackers (“Experience”, “Measurement” and “Marketing” categories), including statistics tools provided by third parties, are installed only with the user’s prior consent.

For all other types of cookies, consent is requested via a pop-up banner displayed on the first visit to the site. Consent requires active behaviour on the part of the user, who can use the banner to:

  • accept all cookies by clicking the “Accept All Cookies” button;
  • reject all cookies other than technical cookies by clicking the “Reject All” button or by closing the banner using the “X” icon;
  • choose which categories of cookies to enable by clicking “Cookies settings”: in the panel that opens, the user can switch each category on or off and confirm the choice with the “Save and continue” button, or use the “Accept all” or “Reject all” buttons.

If the user makes no choice, no Trackers other than technical ones are installed.

Users can manage cookies:

  • through specific settings of the browser used to view the pages of the Site (see the following section);
  • by changing their settings when using third-party services.

Please note that some areas or features of the Site rely on the use of Cookies; disabling Cookies using any of the above methods may therefore prevent the user from correctly viewing certain parts of the Site or from using specific features offered by the Site (such as authentication and access to the restricted area of the site).

How to manage Cookies used by the Fincons website through browser settings

Almost all Internet browsers are set to accept cookies automatically. Users can change the default configuration (generally set to “medium”) and disable cookies by selecting the highest level of protection in the relevant tab (usually labelled “Privacy”). Users can also delete individual cookies from their computer by selecting “Internet Options” from the Tools menu, opening the “General” tab and clicking the delete button.

More detailed instructions for managing Cookies in the most common browsers are given below. To delete cookies from the Internet browser on a smartphone/tablet, please refer to the device’s user manual.

Chrome

  1. Click the menu (“Settings”) in the browser toolbar next to the address bar.
  2. Select “Settings”.
  3. Click “Show advanced settings” at the bottom of the list.
  4. In the “Privacy” section, click the “Content settings” button.
  5. In the “Cookies” section, you can change the following Cookie settings:
    • Allow local data to be set
    • Keep local data only until you quit your browser
    • Block sites from setting Cookies
    • Block third-party Cookies and site data
    • Manage exceptions for certain websites
    • Delete one or all Cookies

Mozilla Firefox

  1. Click the menu (“Settings”) in the browser toolbar next to the address bar
  2. Select “Options”
  3. Select the “Privacy” panel
  4. In the “Tracking” section, you can change the following Cookie settings: Tell websites I do not want to be tracked
  5. In the “History” section you can: by enabling “Use custom settings for history”, choose to accept third-party Cookies (always, from visited sites or never) and keep them for a set period (until they expire, until Firefox is closed, or ask every time); remove individual stored Cookies

Internet Explorer

1. Click the “Tools” button and select “Internet Options”

2. Click the “Privacy” tab and, in the “Settings” section, move the slider to the desired Cookie setting: • Block all Cookies

• Allow all Cookies

• Select the sites from which to accept Cookies: move the slider to an intermediate position so as neither to block nor to allow all Cookies, then click “Sites”, enter a website in the “Address of website” box and click “Block” or “Allow”

Safari

1. Click Safari, select Preferences and click Privacy

2. In the Block Cookies section, specify how Safari should accept Cookies from websites.

3. To see which sites have stored Cookies, click Details

In any case, users are advised to also check their browser’s own instructions from time to time

How to manage Cookies by changing settings when using third-party services

The Site may contain third-party Cookies and links to other websites: these third parties have their own privacy policies, which differ from that of the Fincons website and for which Fincons is not responsible.

Below are links to the pages containing the third parties’ privacy notices and specific instructions.

https://policies.google.com/?hl=en

https://www.linkedin.com/legal/privacy-policy

https://www.facebook.com/privacy/explanation

https://www.youtube.com/static?hl=en&template=terms

https://help.twitter.com/en/rules-and-policies/twitter-cookies

https://help.salesforce.com/articleView?id=pardot_basics_cookies.htm&type=5

Users are advised to read carefully the privacy notices and cookie policies drawn up by the third parties referred to above, also in order to be aware of any changes made to them by the respective providers independently of Fincons.

Transfer of Personal Data

Some Personal Data are shared with recipients who may be located outside the European Economic Area. Fincons ensures that the processing of users’ Personal Data by these recipients complies with the GDPR. Transfers may be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission, or on another appropriate safeguard provided for by the GDPR. In particular, transfers to the United States are based on the European Commission’s adequacy decision of 10 July 2023 on the EU-U.S. Data Privacy Framework, for providers that have joined it, or on the Standard Contractual Clauses. Users can obtain information on the safeguards adopted and request a copy by writing to privacy@finconsgroup.com.

Notice regarding children under 14

Children under the age of 14 may not provide personal data themselves. FINCONS shall in no way be liable for any collection of personal data or for any false statements provided by a minor and, in any case, should such use come to light, FINCONS will facilitate the exercise of the right of access and erasure submitted by the legal guardian or the person exercising parental responsibility.

Exercising the rights of the data subject

Under the GDPR, users have the right to:

access and obtain a copy of their personal data: users have the right to request confirmation as to whether Fincons is processing any of their personal data. If so, they may access their personal data and certain information about how it is processed. In some cases, they may ask Fincons to provide an electronic copy of their data;

right to rectification of personal data: where users can show that the personal data we hold about them are inaccurate, they may request that such data be updated or rectified;

right to be forgotten/right to erasure: in certain circumstances, users have the right to have their personal data erased.  Requests may be submitted at any time and Fincons will assess whether they can be granted. However, this right is subject to legal rights or obligations that may require Fincons to retain the data.  Where it is established, in accordance with the law, that a request for erasure of personal data must be granted, Fincons will proceed without delay;

right to restriction of processing: in the cases provided for in Article 18 of the GDPR (for example, for the period needed to verify the accuracy of contested data), users may request that their data be stored only and not further processed;

right to data portability: for data processed by automated means on the basis of consent or a contract, users may receive the data concerning them in a structured, commonly used and machine-readable format and request that it be transmitted to another controller;

right to withdraw consent: users may withdraw their consent at any time, for example for cookies and other non-technical Trackers, as described in the section “User consent”. Withdrawal does not affect the lawfulness of processing carried out before withdrawal;

right not to be subject to decisions based solely on automated processing: Fincons does not take decisions based solely on automated processing, including profiling, which produce legal effects concerning users or similarly significantly affect them.

Right to object. Users may object at any time, without having to give reasons, to the processing of their data for direct marketing purposes, including related profiling, by clicking the unsubscribe link in each communication or by writing to privacy@finconsgroup.com. They may also object, on grounds relating to their particular situation, to other processing based on Fincons’ legitimate interest.

Requests must be sent in writing to Fincons at the following address: privacy@finconsgroup.com.

In any event, users always have the right to lodge a complaint with the competent supervisory authority (the Italian Data Protection Authority – Garante per la protezione dei dati personali) pursuant to Article 77 of the GDPR if they believe that the processing of their Personal Data infringes the applicable legislation, following the procedures set out by the Authority at the following web address:

http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524

Changes to this Policy

The date of the last update of this notice is shown at the top of the document.

FINCONS may also amend and/or supplement this privacy policy, including as a result of any subsequent legislative changes.