PRIVACY & COOKIE POLICY

Why This Notice

This page describes how the website manages the personal data of users who consult it. This information is provided in accordance with Article 13 of Legislative Decree No. 196/2003 – Personal Data Protection Code (hereinafter the “Code”) and Article 13 of EU Regulation 679/2016 (hereinafter the “Regulation”). The information also draws inspiration from Recommendation No. 2/2001 adopted by the European Data Protection Authorities, gathered in the Working Party established under Article 29 of Directive No. 95/46/EC, on May 17, 2001. The recommendation identifies minimum requirements for the collection of personal data online, especially regarding the methods, timing, and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection. This notice is only applicable to the site www.massimilianoalfieri.it, and not for other websites accessed via links.

The data provided will be processed in compliance with the regulations mentioned above, in line with the principles of confidentiality and lawfulness that inspire our company, and only for the time necessary for which they were collected.

Please note that this document is published at www.massimilianoalfieri.it, represents the Privacy Policy of this site, and may be updated.

Rights on images and texts

All photographs and texts on this site are protected by copyright and remain the exclusive property of the owner of the site (or the author if different). Any form of reproduction, distribution, modification or use of the same is prohibited without prior written authorization. Unauthorized use may constitute a violation of current copyright regulations.

1. Data Controller

The data controller of your personal data is:

SORGIVA HOLDING S.P.A.
Headquarters: Via della Valletta 3 – 00060 Formello (Rome), Italy
VAT No. 11173241008

2. Personal Data

Personal data is provided directly by the user (hereinafter referred to as the “data subject”), voluntarily and explicitly by filling out specific forms on the website, and is necessary to fulfill requests for information and/or contact. For example, through the form “Send us a message”. Types of data provided: full name, email address, telephone number, and postal address.

3. Purpose of Processing

Primary purposes. The personal data provided with explicit and unequivocal consent by the user/data subject is used by SORGIVA HOLDING S.P.A. to fulfill any user requests collected via website forms, for statistical purposes related to website use, for managing and evaluating CVs, and to comply with laws, regulations, EU norms, and directions from authorized authorities or supervisory bodies.

Secondary purposes. With explicit and unequivocal consent, the data provided may also be used to send newsletters promoting the services of SORGIVA HOLDING S.P.A. and its partners. This may include communication by electronic or telematic means (e.g., email) in accordance with Article 130 of the Code.

4. Methods of Processing

Personal data is processed using automated and digital tools, only for the time strictly necessary to fulfill the purposes for which it was collected. Specific security measures are in place to prevent data loss, unlawful or improper use, and unauthorized access.

Web service-related data processing is carried out at the data controller’s premises.

5. Optional Provision of Data

The user is free to provide personal data via the forms on the website. Failure to do so may make it impossible to fulfill certain requests.

6. Data Retention Period

Personal data will be stored as specified under Article 13, paragraph 2 of the Regulation.

  • Personal data provided will be stored (in digital archives) as long as necessary for delivering the requested services, and then deleted.

  • Data related to CVs will be stored (digitally or in paper form) for up to 24 months and then deleted, unless otherwise requested by the data subject.

  • In all cases, data will be stored only as long as necessary and not beyond the purposes stated and legal obligations.

7. Data Communication and Disclosure

Personal data collected via the site forms will not be “disseminated” (i.e., made available to unspecified parties). Instead, it may be “communicated” (i.e., made known to specific parties), as follows:

  • Staff and collaborators as persons in charge of processing;

  • Third parties appointed by SORGIVA HOLDING S.P.A. for promotional, professional, or technical services, duly designated as external processors or controllers;

  • Affiliated third-party companies for newsletter services and specialist/official information activities, who will provide their own privacy information per Article 14 of the Regulation;

  • Postal services or courier companies for sending materials or improving the quality and range of services;

  • Public authorities entitled to access data under legal or regulatory obligations.

8. Transfer of Data Outside the EU

In accordance with Article 13, paragraph 1 of the Regulation, your personal data will not be transferred outside the European Union.

9. Data Subject Rights

Pursuant to Article 7 of the Code and Articles 13, 15, 18, 19, and 21 of the Regulation, you are entitled to:

  • Request access to, correction, deletion, or integration of your personal data;

  • Limit or object to the processing of your personal data, where applicable;

  • File a complaint with the Data Protection Authority if you believe your data has been unlawfully processed – website: www.garanteprivacy.it;

  • Withdraw your consent for both primary and secondary purposes at any time;

  • Exercise your rights without formal constraints – a response will be provided within 30 days, in writing unless you request otherwise;

  • Contact the data controller at any time: SORGIVA HOLDING S.P.A. – Via della Valletta 3, 00060 Formello RM – VAT: 11173241008 – Email: amministrazione@sorgiva.com.

Navigation Data

SORGIVA HOLDING S.P.A. informs you that the IT systems and software procedures used to operate this website collect certain personal data as part of their routine operations. This transmission is inherent to Internet communication protocols and is not intended to identify users, although identification could be possible via associations with third-party data.

Collected data may include IP addresses, domain names, URI addresses, request timestamps, request methods, response sizes, status codes, and user system/environment data.

This data is used solely to compile anonymous statistics on site usage and ensure proper operation and is deleted immediately after processing. It may be used to investigate any computer crimes against the site.

During each visit, the following info may be logged regardless of cookies: browser type, operating system, referring host/URL, and the requested page. This data is anonymized and aggregated for statistical analysis.

Session cookies are used solely for secure and efficient browsing and are not stored permanently.

10. Cookie Policy

(Provided under the provisions of the Italian Data Protection Authority ruling of May 8, 2014, published in Official Gazette No. 126, June 3, 2014, transposing EU Directives 2002/58/EC and 2009/136/EC)

Cookies are small text files that collect browsing information.

When you access this site, text files (cookies) may be sent to your device to gather information about your navigation.

Cookies are classified as:

  • Technical cookies – essential for proper site function and navigation. They can be session-based (temporary) or persistent (longer-lasting), including functional and analytics cookies. Analytics cookies are not essential.

  • Profiling cookies – used to track user preferences and interests, enabling targeted advertising. These are not essential for site use.

Cookies can be:

  • First-party (set by the site itself), or

  • Third-party (set by external domains).

Third-party analytics cookies anonymously track users to analyze traffic, pages viewed, time on site, demographics, and interests. These may come from external providers like Google Analytics.

Cookies from third-party software integrations (e.g., social media plugins) allow content sharing and social media interaction but are not essential.

Under current law (as per Legislative Decree 69/2012), technical cookies do not require consent.

If third-party analytics are used for statistics only, and IPs are anonymized and data not combined with other sources, no user consent is required.

Users can accept or reject cookies freely. However, rejecting essential cookies may impair or prevent some site functions.

Cookie preferences can be changed at any time via browser settings:

11. Cookies Used by www.massimilianoalfieri.it

Third-party Cookies

While browsing www.massimilianoalfieri.it, you may receive cookies from third-party websites. This happens when the site includes elements (e.g., images, links) that load content from external servers.

These cookies are set directly by third-party website operators and not managed by www.massimilianoalfieri.it.