I – INFORMATION RELATING TO THE PRIVACY POLICY OF THE SITE

  1. This section contains information related to the privacy methods of martingalerisk.com with reference to the processing of data for users of martingalerisk.com
  2. This information also has value for the purposes of art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of article 13 of EU Regulation no. 2016/679, relating to the protection of individuals with regard to the processing of personal data as well as the free movement of such data, for the subjects who interact with and can be reached at the address corresponding to the home page:

www.martingalerisk.com

  1. It is imperative to note that, the information is provided only for martingalerisk.com and not for any other websites that may be consulted by the user through links contained therein.
  2. The purpose of this document is to provide information on the methods, times, and nature of the information that the data controllers must provide to users when connecting to the web pages of martingalerisk.com regardless of the purpose of the connection itself, according to Italian and European legislation.
  3. Information may undergo changes due to the introduction of new rules in this regard, therefore the user is invited to periodically read this page.
  4. If the user is under 16, pursuant to art.8, c.1 EU regulation 2016/679, he will have to legitimize his consent through the authorization of the users legal guardian.

II – DATA PROCESSING

1- Data Controller

  1. The data controller is the authentic or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. The data controller also works with security profiles. In regard of this website, the data controller is: Martingale Risk Italia S.r.l. with headquarters in Largo del Nazareno, 15 – 00187 Rome which can be contacted by phone at no. 06.3265282, email at info@martingalerisk.com or pec at martingalerisk@legalmail.it.

2 – Responsible for data processing

  1. The controller is the authentic or legal person, public authority, service or other body that processes personal data on behalf of the data controller.
  2. Pursuant to article 28 of EU regulation no. 2016/679, upon appointment of the data owner and the site data controller.

3 – Location of data processing

  1. The data processing generated by the use of martingalerisk.com occurs at Largo del Nazareno, 15 – 00187, Rome.
  2. If necessary, the data connected to the newsletter service can be processed by the data controller or by individuals appointed by the data controller for internal purposes at the relevant office.

III – COOKIES

1 – Forms of Cookies

  1. The martingalerisk.com site uses cookies to aid the user’s browsing experience and to make it more intuitive: cookies are small strings of text used to store information that may concern the user, his preferences, or the accessed device to the internet (computer, tablet, or mobile phone) and are mainly used to adapt the functioning of the site to the user’s expectations, offering a personalized browsing experience by the method of remembering the choices previously made by the user.
  2. A cookie consists of a reduced set of data transferred to the user’s browser by a web server and can only be read by the server that made the transfer. It is not an executable code and it does not transmit viruses.
  3. Cookies do not record any personal information and any identifiable data will not be stored. If desired, you can prevent the cookies from saving all together. However, in this case, the use of the site and the services offered may be compromised. To proceed without changing the cookie options, it is necessary to simply continue browsing.

Below are the forms of cookies that the site uses:

2 – Technical cookies

  1. There are numerous technologies used to store information on the user’s computer, which are then collected by the site. Among these, the best known and most used is that of HTML cookies. They are used for navigation and to facilitate user access and use of the site. They are necessary for the transmission of communications on the electronic network or to the supplier to provide the service requested by the customer.
  2. The settings to manage or disable cookies may vary depending on the internet browser used to navigate the site. In any case, the user can manage or request the general deactivation or cancellation of cookies by changing the settings of the user’s internet browser. This deactivation may slow down or prevent access to some parts of the site.
  3. The use of technical cookies ensures safe and efficient use of the site.
  4. The cookies placed in the browser and retransmitted through Google Analytics or through the statistics services of bloggers or similar- are technical only if used for the purpose of optimizing the site directly by the owner of the site, who can collect information in aggregate form on the number of users and the manner in which they visit the site. Under these conditions, the same rules apply to analytics cookies, in terms of information and consent, provided for technical cookies.
  5. Temporary session cookies may be deleted.

IV – DATA PROCESSED

1 – Data processing mode

  1. Like all websites, this site also uses log files in which information collected automatically is stored during user visits. The information collected could be the following: internet protocol address (IP); type of browser and device parameters used to connect to the site; name of the internet service provider (ISP); date and time of visit; web page of origin of the visitor (referral) and exit; the number of clicks.
  2. The aforementioned information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed based on legitimate interests of the owner.
  3. For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage the site itself or to cause damage to other users, or in any case harmful activities or to constitute a crime. The data is never used for the identification or profiling of the user, but only for the purpose of protecting the site and its users, such information will be processed based on legitimate interests of the owner.
  4. If the site allows the inclusion of comments, or in the case of specific services requested by the user, including the possibility of sending Curriculum Vitae for possible working relationship, the site automatically detects and records some identification related to the data of the user, including, but not limited to, the email address of the user. The data is intended voluntarily provided by the user at the time of the request to provide the service. By entering a comment or other information, the user expressly accepts the listed privacy information, and in particular agrees that the contents inserted are freely disseminated also to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary for the provision of the service.
  5. Information that users of the site deem to make public through services and tools made available to them, are provided by the user knowingly, and voluntarily, exempting the site from any responsibility for any violation of the laws. It is up to the user to verify that they have permission to enter the personal data of third parties or content protected by national and international standards.

2 – Purpose of data processing

  1. The data collected by the site during its operation are used for the purposes indicated above and for the following purposes
  • Purposes related to the data request for marketing and/or advertising activities by sending newsletters.
  • Purposes related to the management and delivery of the products and services offered by Martingale Risk.
  • Purposes based on the consent of the interested party for the communication of their data to any partner of the Data Controller for the performance of contractual obligations.
  1. Data retention will be carried out for the period strictly necessary to achieve the aforementioned purpose and in any case retention will not exceed 10 years.
  2. The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated purpose.

3 – Data provided by the user

  1. As indicated above, the optional, explicit, and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.
  2. Specific summary information will be reported or displayed on the pages of the site prepared for particular services on request.

4 – Support in configuring your browser

  1. The user can also manage cookies through the settings of the user’s browser. However, deleting cookies from the browser may remove the preferences that it has set for the site.
  2. For further information and support, you can also visit the specific help page of the web browser you are using:

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

– Safari: http://www.apple.com/legal/privacy/it/

– Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Opera: http://www.opera.com/help/tutorials/security/cookies/

5 – Social Network Plugin

  1. This site incorporates plugins and/or buttons for social networks, in order to allow ease in the sharing of content on your favorite social networks. These plugins are programmed, so as not to set any cookies when accessing the page, to safeguard users’ privacy. If necessary, cookies are set, if so provided by social networks, only when the user makes effective and voluntary use of the plugin. It should be remembered that if the user browses being logged into the social network then he has already consented to the use of the cookies conveyed through this site when registering with the social network.
  2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which please refer to:

Facebook: https://www.facebook.com/help/cookies

Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter

Google+: http: //www.google.com/policies/technologies/cookies

Linkedin: https://www.linkedin.com/legal/cookie-policy

V- USER RIGHTS

  1. 13, c. 2 of EU Regulation 2016/679 lists the rights of the user.
  2. The site intends to inform the user of the existence:

– of the right of the interested party to request access to personal data from the holder (art.15 EU Regulation), their updating (art.7, co. 3, lett. A) Legislative Decree 196/2003), the rectification (art.16 EU Regulation), integration (art.7, co. 3, lett. a) of Legislative Decree 196/2003) or the limitation of the processing that concerns him (art.18 EU Regulation) or oppose, for legitimate reasons, their treatment (art.21 EU Regulation), in addition to the right to data portability (art.20 EU Regulation)

– the right to request cancellation (Article 17 of the EU Regulation), transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is unnecessary for the purposes for which the data are were collected or subsequently processed (art. 7, co. 3, lett. b) of Legislative Decree 196/2003)

– the right to obtain certification that operations of updating, rectification, integration of data, cancellation, blocking of data, transformation have been brought to the attention, also regarding their content, of those to whom the data has been communicated or widespread, except in the case where this fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right (art.7, co. 3, lett. c) of Legislative Decree 196/2003)

  1. Requests can be addressed to the data controller, without formalities, or using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to the address: info@martingalerisk.com
  2. If the treatment is based on art. 6, paragraph 1, lett. a) – express consent for use —or on art. 9, paragraph 2 lett. a) – express consent to the use of genetic, biometric, health-related data, which reveal religious, philosophical or trade union beliefs, which reveal racial or ethnic origin, political opinions – the user has the right to revoke consent at any time without prejudice to the lawfulness of treatment based on the consent given before the revocation.
  3. Likewise, in case of violation of the law, the user has the right to file a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for monitoring the processing in the Italian State.

6.For a more thorough examination of the rights that compete with you, see arts 15 and following. of EU Regulation 2016/679 and art. 7 of Legislative Decree 196/2003.

 

  1. SECURITY DATA PROVIDED

 

  1. This site processes user data in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction. The treatment is carried out using IT and/or telematics tools, with organizational methods, and with logic strictly related to the purposes indicated.
  2. In addition to the owner, in some cases, categories of agents involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers, hosting provider, IT companies, communication agencies).