Last update: May 25th 2018
“Personal Data” (art. 4, n. 1 of Regulation): 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” (art. 4, n. 2 of Regulation): 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.
Registered office: Milano (MI), Corso Magenta, n. 56
Operational headquarters: Milano (MI), via Torri Bianche, n. 10
Avv. Luca Biffi
The computer systems and software procedures used to opertate this website, 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 subjects, but by their very nature they may allow to identify users through processing and association with data held by third parties.
This category of data includes IP addresses or domain names of the computers used by users who connect to the website, the addresses in the URI (Uniform Resourse Identifier) notation of the requested resources, the time of request, the method used to submit the request to the server, and other parameters related to the ioperating system and the user’s computer environment.
These data are used for the only purpose to obtaining anonymous statistical information on the use of the website and to check its correct functioning, to identify anomalies and abuses, and are immediately deleted after being processed.
These data may be used to ascertain responsibility in case of computer crimes.
Subject to user’s prior express consent and until that consent is withdrawn, any personal data that may be included in a customer relationship management system (CRM), may also be processed for marketing purposes, in other words, by way of example, for the sending of promotional and commercial communications related to services offered by FINCONS, as notification of events, both by automated means of contact (e.g. SMS, fax, e-mail and web applications) and by traditional means of contact (such as telephone calls with an agent and traditional mail).
You shall then be prompted via an online form on our website or by other procedures to provide your consent to the processing of your personal data for such purposes. If you withold or withdraw your consent to the marketing purposes described above, your data shall be processed only for the purposes referred to in the previous paragraph.
With regard to the e-mails that will be sent, the following actions performed by the user shall be tracked by means of technical cookies:
Any of user’s personal data thay may be collected in accordance with the method described above shall be processed only for technical reasons and, in particular, in order to confirm that the e-mail was properly sent and received, as well as to verify for statistical purposes, in aggregated form, any accessing of the website. The legal basis for the processing is the consent user has given FINCONS where appropriate.
User’s personal data and contact details shall be retained for no more than 24 months, given that user can withdraw consent at any time.
With regard to additional processings which are not mentioned in this policy, it is only about section “Job”.
*Recipients of Personal data
User’s personal data may be shared, for the purposes referred to above, with contractors** providing professional services in EU countries:
Controller’s Managers and Personnel;
IT services companies.
(**) the list of external personal data processors/recipients is available at the Controller’s heeadquarters.
Fincons website is not obliged to request consent for first-party technical and analytical cookies, as they are necessary in order to provide the services requested. They are therefore installed automatically by the website during the user's first visit to any page of the portal.
For other types of cookie, consent is requested via a pop-up banner: this implies active behaviour on the part of the user, meaning that the latter can give his or her consent by clicking on the "OK" button.
For all other types of cookies the user can give his or her consent by one or more of the following means:
certain parts of the Website correctly or using specific features offered by the Website (for example authentication and access to the restricted area of the website).
Nearly all internet browsers are set up to automatically accept cookies. The user can modify the predefined configuration (generally set to "medium" level) and disable Cookies, selecting from the form provided (generally entitled "Privacy") the highest level of protection. In all cases, the user also has the opportunity to delete individual Cookies from his or her computer by going to "Internet Options", Tools menu and selecting the "General" form and clicking the appropriate deletion button.
Below are more detailed instructions for managing cookies on the part of the user for the more common browsers. To delete Cookies from the internet browser of your smartphone/tablet, you should refer to the device's user manual.
In all cases, the user is advised to check his or her browser settings from time to time.
The website may contain third-party cookies and links to other websites: third parties have their own privacy information that differs from that adopted by Fincons website and which is unrelated to the latter.
Listed below are the links to the pages containing the information and specific instructions from third parties:
Some of user’s personal information may be shared with recipients that could be found outside the European Economic Area. Fincons ensures that the processing of their Personal Data by these recipients takes place in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another appropriate legal basis.
Children below the age of 14 cannot personally provide their personal data. Fincons declines any responsibilities for accidental personal data collection and false declarations provided by the minor. If an improper use by the minor is detected, Fincons will help parents or guardians enforce access and deletion rights.
In accordance with the Regulation, user has the following rights:
Right to access and obtain a copy of his/her personal information: user is entitled to request confirmation whether Fincons processes any personal information. Where this is the case, user may have access to his/her personal information and to certain information about how it is processed. In some cases user can ask Fincons to provide him/her with an electronic copy;
Right to correct user’s personal information: if he/she can demonstrate that personal information Fincons holds about him/her is not correct, user can ask that this information is updated or otherwise corrected;
Right to be forgotten/have data deleted: In certain circumstances user has the right to have his/her personal data deleted. User may make such a request at any time and Fincons will evaluate if his/her request should be granted, however this right is subject to any legal rights or obligations Fincons may have to retain data. For situations where in accordance with the law, Fincons determines that user’s request to have his/her personal information deleted must be granted, Fincons will do so without undue delay. Requests must be sent in writing to Fincons at the following address: firstname.lastname@example.org. In any case, user is always entitled to propose a complaint to the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulations, if you believe that the processing of your Personal Data is contrary to the law, as indicated at the following website:
The terms of this Policy may change from time to time. Fincons shall publish any material changes to this Policy through appropriate notices either on this website or contacting you using other communication channels.
Fincons Group AG - CHE-113.728.175 IVA