Locatelli Partners S.r.l. S.t.p. with registered office in Via Corridoni, 15A – 20122 Milan (MI) and P.IVA 10696860963 (hereinafter: “Owner”), constantly strives to protect the online privacy of its customers.
This document has been prepared pursuant to Article 13 of the EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to learn about our privacy policy, to understand how your personal information is handled when using our website www.locatellipartners.com (hereinafter: “Site”) and, where applicable, to give your express and informed consent to the processing of your personal data. The information and data provided by you or otherwise acquired as part of the use of the services available through the Site will be processed in accordance with the provisions of the Regulations and the obligations of confidentiality that inspire the activities of the Data Controller.
According to the rules of the Regulations, the processing carried out by the Controller will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality.
The Owner of the processing carried out through the Site is defined in the premises. For any information inherent to the processing of personal data by the Data Controller, you may write to the Data Controller at the contact details given below.
Locatelli Partners S.r.l. S.t.p.
Via Corridoni, 15A – 20122 Milan, Italy
amministrazione@locatellipartners.com
As a result of browsing the Site, we inform you that the Data Controller will process personal data that may consist of an identifier such as a name, an identification number, an online identifier, or to one or more characteristic elements of your physical, physiological, psychological, economic, cultural, or social identity capable of making the data subject identified or identifiable (hereinafter: “Personal Data”).
The Personal Data processed through the Site are as follows:
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 is information that is not collected to be associated with identified interested parties, but which 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 connecting to the Site, the URI (Uniform Resource Identifier) notation addresses of the requested resources, the time of the request, the method used in submitting 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: except for this eventuality, at present the data on web contracts do not persist for more than 1 month.
In the use of some services of the Site (for example, through contact forms) there may be a processing of Personal Data of third parties sent by you to the Data Controller.
With respect to such hypotheses, you stand as autonomous data controller, assuming all the obligations and responsibilities of the law. In this sense, it confers on this point the widest indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc., that may be received by the Controller from third parties whose Personal Data have been processed through your use of the functions of the Site in violation of the applicable data protection regulations. In any case, should it provide or otherwise process Personal Data of third parties in the use of the Site, it hereby guarantees – assuming all related liability – that this particular hypothesis of processing is based on a suitable legal basis under Article 6 of the Regulations that legitimizes the processing of the information in question.
Cookies are small text files that sites visited by the user send and store on the user’s computer or mobile device, only to be transmitted back to the same sites on the next visit. It is precisely because of cookies that a site remembers the user’s actions and preferences (such as, for example, The user’s login information, language choice, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to the Site or navigates from one page to another of it.
Cookies, therefore, are used to perform computer authentication, session tracking, and storage of information regarding the activities of users accessing a site and may also contain a unique identifier code that allows tracking of navigation on a site, the user may also receive on his computer cookies from sites or web servers other than the one he is visiting (so-called “third-party” cookies).
Some operations could not be accomplished without the use of cookies, which in some cases are therefore technically necessary for the very operation of the site. There are various types of cookies, depending on their characteristics and functions, and these may remain on the user’s computer for different periods of time: so-called session cookies, which remain on the user’s equipment until a predetermined expiration date.
Under current Italian law, the use of cookies does not always require the user’s express consent. In particular, “technical cookies”, i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. These are, in other words, cookies that are indispensable for the operation of the Site or necessary to perform activities requested by the user.
Among technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Provvedimento Individuazione delle modalità semplificate per l’informativa e l’acquisizione del consenso per l’uso dei cookie of May 8, 2014 and subsequent clarifications, hereinafter: “Provvedimento”) also includes:
For “profiling cookies,” vice versa, i.e., those aimed at creating profiles related to the user and used for the purpose of sending advertising messages in line with the preferences expressed by the user in the context of web browsing, prior user consent is required.
Types of cookies used by the Site and options for (de-)selection
The Site uses the following cookies, which can be de-selected, except for third-party cookies for which you will have to refer directly to the respective cookie selection and de-selection methods indicated by links.
WARNING: Disabling technical and/or functionality cookies may result in the Site being unavailable or certain services or features of the Site not working properly, and you may be forced to change or manually enter certain information or preferences each time you visit the Site.
Third-party cookies
These are cookies from sites or web servers other than that of the Owner, used for purposes specific to said third parties. It should be noted that these third parties, listed below with the relevant links to their privacy policies, are typically autonomous data controllers of the data collected through the cookies served by them; therefore, you will have to refer to their personal data processing policies, disclosures and consent forms (selection and de-selection of the respective cookies), as specified in the aforementioned Measure.
For the sake of completeness we also point out that the Owner does its utmost to be able to track cookies on its Site. These are updated on a regular basis in the table below, where we give transparency on the cookies directly sent by the Owner and their purposes. With regard to third parties that send cookies through our Site, we provide below links to their respective privacy policies: to these third parties we defer, as already specified, the responsibility to provide the information and collect your consent, as required by the Provision.
Said responsibility is to be referred not only to the cookies that the third parties send directly, but also to any additional cookies that are sent through our Site by virtue of the use of services from which the third parties themselves benefit. With respect to such cookies in fact, sent by service providers of the aforementioned third parties, the Owner does not have the possibility to exercise any control and does not know their characteristics or purpose.
Below are links to the disclosures and consent forms of third parties serving cookies through the Site:
a. Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its advertising network.
Personal data collected: Cookies and usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield adherent subject.
b. Google Analytics con IP anonimizzato (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of locatellipartners.com, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads in its ad network. This Google Analytics integration anonymizes your IP address. Anonymization works by abbreviating within the borders of the member states of the European Union or other countries that are party to the Agreement on the European Economic Area the IP address of Users. Only in exceptional cases will the IP address be sent to Google’s servers and abbreviated within the United States.
Personal data collected: Cookies and usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield adherent subject.
c. Google Fonts (Google Inc.)
Google Fonts is a service that allows you to embed and display custom font styles and is operated by Google Inc.
Personal data collected: Cookies and usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield adherent subject.
d. Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc. Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.
Personal data collected: Cookies and usage data.
Place of processing: United States – Privacy Policy. Privacy Shield adherent subject.
Cookie-related settings
You may block or delete (in whole or in part) technical and functionality cookies through the specific functions of your Browser. Please be advised, however, that not allowing technical cookies may result in your inability to use the Site, view its content and take advantage of related services. Inhibiting functionality cookies may result in some services or certain features of the Site not being available or not working properly, and you may be forced to change or manually enter certain information or preferences each time you visit the Site.
The choices you make with respect to the Site’s cookies will in turn be recorded in a special cookie. Such a cookie may, however, not work properly in some circumstances: in such cases, we recommend that you delete unwelcome cookies and inhibit their use through the functionality of your Browsers as well.
Your preferences in reference to cookies will need to be reset if you use different devices or Browsers to access the Site.
How to view and change cookies through the Browser
You can authorize, block, or delete (all or part of) cookies through the specific features of your Browser. For more information on how to set preferences on the use of cookies through your Browser, you can refer to the relevant instructions:
The Controller will use your Personal Data, upon your specific consent where necessary, for the following purposes:
The legal bases for the processing of Personal Data for the purposes set forth in Section 3 above are:
Your Personal Data may be shared, for the purposes of Section 3 above, with the following persons and/or entities (collectively “Recipients”):
Your Personal Data is not transferred outside the European Economic Area.
Personal Data processed for the provision of services (3.a) will be kept for the time strictly necessary to achieve those same 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 rights and interests (Art. 2946 of the Italian Civil Code).
Personal Data processed to comply with legal obligations (3.b) will be retained as long as required by the specific obligation or rule of law or applicable regulation. Personal Data processed for marketing purposes (3.c) will be processed until your consent is revoked.
More information regarding the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller at the contact details given below.
Pursuant to Articles 15 et seq. of the Regulations, you have the right to ask the Data Controller, at any time, for access to your Personal Data, to rectify or erase them or to object to their processing, you have the right to request the restriction of processing in the cases provided for by Article 18 of the Regulations, as well as to obtain in a structured, commonly used and machine-readable format the data concerning you, in the cases provided for by Article 20 of the Regulations.
Requests should be addressed in writing to the Holder at the following address:
Locatelli Partners S.r.l. S.t.p.
Via Corridoni, 15A – 20122 Milan, Italy
amministrazione@locatellipartners.com
In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Garante per la Protezione dei Dati Personali), in accordance with Article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.
The Site is intended for persons over the age of 16 and parental consent is required until the age of 16. We ask that individuals under the age of 16 not provide Personal Data through the Site. We reserve the right to request proof of parental consent at any time to allow the processing of Personal Data relating to minors.
The Owner reserves the right to modify or simply update its content, in part or in full, including due to changes in applicable legislation. The Holder will inform you of such changes by means of a notice published on the Site. The Holder therefore invites you to visit this section regularly to become aware of the most recent and updated version of the privaci policy so that you are always up to date on the data collected and the use made of it.