Privacy Policy

BACKGROUND

This Privacy Policy is intended to describe how Leedia Srl manages and processes the personal data of users who visit this website.


This is an information that was prepared pursuant to:
Legislative Decree n. 196/2003 (Code regarding the protection of personal data), updated and modified by the Legislative Decree n. 101/2018;
European Regulation n. 679/2016 (GDPR – General Data Protection Regulation).


The information is prepared to inform users who interact with the web services provided by Leedia Srl, Via Primaticcio 8 Milano 20146, Italy.


The information is also inspired by Recommendation no. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. 29 of directive no. 95/46 / CE, adopted on May 17, 2001 to identify some minimum requirements for the collection of personal data online, and, in particular, the methods, times and nature of the information that the data controllers must provide to users when they link to web pages, regardless of the purpose of the link.

DEFINITIONS


Personal data
Personal data is information that allows you to identify a natural person directly or indirectly (such as: name, surname, email, telephone number).

User
For the purposes of this information, the “user” is defined as the natural person who browses and uses this site.
While browsing this site, a notice will appear to the user asking him to authorize the tracking of his “cookies”.
By authorizing the tracking of “cookies”, the user usage data will be anonymized (“anonymized cookies”), not allowing this website to identify the user directly.

Interested
If the user who visits this site authorizes the processing of his personal data (by filling out a contact form), the same will be defined as “interested”, or the person to whom the personal data refer.

Usage data
This is the information that this site automatically collects without directly identifying users.
In particular, data concerning the use of this site are:
the IP addresses or domain names of the computers used by the user who connects with this Site
addresses in URI (Uniform Resource Identifier) notation
the time of the user’s request
the method used to submit the request to the server
the country of origin of the user
the features of the browser and operating system used by the user
the duration of the user’s visit on the pages of this site
the user’s visit path within the Site, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment

Holder of the treatment
The natural or legal person who decides how the personal data of the interested parties will be used. The data controller establishes the methods of use of users’ personal data and guarantees their protection together with the Data Protection Officer (DPO).

Data Protection Officer (DPO)
The natural or legal person who makes sure to protect users’ personal data, through the adoption of technical prevention measures and through the adoption of internal codes of conduct.

Data Processor (or Responsible)
The natural or legal person who is authorized by the Data Controller to process Personal Data, to the processing of the personal data of the interested parties.

This site
All web pages and virtual space used for publishing content.

Cookie
Fragment of code that collects data within the device used by the user for navigation.

DATA CONTROLLER AND DATA PROTECTION OFFICER
The owner of the treatment of this site is Leedia Srl. Your contact details are:
mail: rdp@leedia.com;

The data protection officer (DPO) is Pirro Carlotta. Your contact details are:
mail: rdp@leedia.com;

REGULATORY SOURCES

COMPLIANCE WITH EU REGULATION No. 679/2016 – GDPR (GENERAL DATA PROTECTION REGULATION)
This Privacy Policy complies with EU regulation no. 679/2016 better known as “GDPR” (General Data Protection Regulation).
This website and the data controller respect consideration no. 82 and no. 83 of the EU European regulation n. 679/2016 better known as “GDPR” (General Data Protection Regulation).

REGISTER OF TREATMENT ACTIVITIES
This website and the data controller, in accordance with the provisions of art. 30, paragraph no. 1, of the EU regulation no. 679/2016, created the “Register of treatment activities”. The “Register of processing activities” possesses the requirements indicated in art. 30, paragraph no. 1 (letters: a, b, c, d, e, f, g) of the EU European regulation n. 679/2016. Pursuant to art. 30, paragraph no. 3 of EU regulation no. 679/2016, the “Register of processing activities” is kept in writing and in electronic / digital format. The “Register of processing activities” in electronic format is kept in a management software covered by cryptography which cannot be accessed by users and third parties. In the event of a request for access by the competent authorities, this website and the data controller, in accordance with the provisions of art. 30, paragraph no. 4 of the EU European regulation n. 679/2016, will make the register available to the supervisory authority.

This website and the data controller have implemented adequate technical and organizational measures to ensure an adequate level of risk security in accordance with the provisions of art. 32, paragraph no. 1 (letters: a, b, c, d, e, f, g) of the EU European regulation n. 679/2016.

WE THEREFORE INVITE YOU TO VIEW OUR PRIVACY POLICY, HEREINAFTER ILLUSTRATED

PRIVACY POLICY


Scope of data communication
The personal data provided may be disclosed to third parties to fulfill legal obligations, in execution of orders from legitimate public authorities or to enforce or defend a right in court.


Type of data processed and purpose of the treatment
Navigation data:
During normal operation, the IT systems and software procedures used to operate this site acquire some personal data which are then implicitly transmitted 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 who connect to the site, the addresses in URI (Uniform Resource Identifier) notation 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 operating system and the user’s IT 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 and are deleted immediately after processing.


Data voluntarily provided by users / visitors:
If users / visitors, by connecting to this site, send their personal data to access certain services, or to make requests by e-mail, this entails the acquisition by the data controller of the sender’s address and / or of others any personal data that will be processed exclusively to respond to the request, or for the provision of the service. The personal data provided by users / visitors will be communicated to third parties only if the communication is necessary to comply with the requests of the users / visitors themselves.


Processing methods and data retention period
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected.
As soon as the practice is defined, or as soon as the consultancy relationship with the customer is interrupted, personal data is kept for a period of 12 months.
Once the 6-month period has elapsed, the personal data of former customers or former employees are permanently deleted.


Security measures for data retention
This site and Leedia Srl observe specific security measures to prevent data loss, illicit or incorrect use and unauthorized access.
To ensure data retention in maximum security conditions, this site and Leedia Srl use management software with access authentication.
This system prevents access to unauthorized parties and prevents reading of the collected data.

Place of data processing
The treatments connected to the web services of the site indicated above, take place both at the Leedia Srl headquarters, and at the company headquarters and / or at the headquarters of the hosting and / or website management company and are only handled by technical personnel of the Office in charge of the treatment, or by any persons in charge of occasional maintenance operations.
No data deriving from the web service is communicated or disclosed. The personal data provided by users who request dispatch of informative material are used only to perform the service or provision requested and are communicated to third parties only if this is necessary for this purpose.

Rights of the interested parties
The subjects to whom the personal data refer (also defined with the term “interested”) have the right at any time to obtain confirmation of the existence or otherwise of the same data and to know its content and origin, verify its accuracy or request its integration or updating, or correction.
Pursuant to the GDPR, the interested party has the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose in any case, for legitimate reasons, to their treatment.
The subjects to whom the personal data refer have the right to:
Revoke consent to treatment;
Obtain confirmation or not of the existence of personal data;
Know to whom your data are transmitted;
Obtain the correction, cancellation, integration of your data;
Propose a complaint to the Privacy Guarantor;
Know if the data is subject to profiling;
Transfer your data to another provider (portability law).

If you want to ask for more information on the processing of your data or if you want to exercise one of the previously mentioned rights, you can send an email to the following address: rdp@leedia.com.


On what legal basis we process your data
When we process your personal data for the purposes indicated in this Notice, we rely on one or more of the following legal bases:

Consent: we ask for your consent to use your data, to update you on our content, to send you information about our services and for profiling (i.e. to analyze the interests and behavior of visitors to our site and to improve our marketing campaigns) .
Contractual scope: when you enter into a contract of any type with us, your personal data will be processed to pursue the purposes of the service you have purchased.
Legal obligations: when strictly necessary, we will process your personal data to comply with a legal obligation, an order imposed by the supervisory authority, a binding tax assessment.

INFORMATION ON COOKIES

What are cookies?
Cookies are pieces of information that a server can send to your PC, smartphone or tablet when you visit a website or use a social network. The same server that sent them, then, can read and record the cookies that are on your PC, smartphone or tablet to obtain various types of information.
Cookies have different functions: in many cases they are useful because they make navigation easier and faster, as happens with technical cookies, used for example to save language preferences or a shopping cart. In other cases, however, cookies are used to monitor users while browsing; so-called profiling cookies record information about what you buy or you may want to buy, analyzing your readings, your hobbies, your travels, to personalize the advertising that is shown to you when you open the email or browse on a social network. Then there are third-party cookies, that is, information that is recorded by sites other than those you have visited and which is used for profiling purposes.
Further information can be found on the website of the Privacy Guarantor.
We remind you that by clicking on the authorization buttons on the short information banner, you declare that you have read and accepted the privacy policy and the cookies policy, thus consenting to the use of the cookies on this site.


Types of cookies we use
Two types of cookies can be used on the site: ‘session cookies’ and ‘persistent cookies’:
The ‘session cookies’ are temporary cookies that remain on the device until the moment you leave the site.
The ‘persistent cookie’ remains on your device for longer or until it is manually deleted.

The cookies used by the site
Technical cookies
Technical cookies are those whose use does not require the user’s consent. These cookies are essential to allow you to browse a website and use all its features. Without these cookies, which are absolutely necessary, a website could not provide some services or functions and navigation would not be as easy and easy as it should be. A cookie of this type is also used to store a user’s decision on the use of cookies on the website. Other technical cookies are those that allow, for example, the saving of language or shopping cart preferences.
WordPress cookies
This site was developed on the wordpress platform, therefore it uses cookies implemented by the aforementioned platform. The cookies stored concern those who have registered an account on the wordpress blog and those who comment on the articles.
The cookies used by wordpress are:
wordpress_ [hash]
wordpress_logged_in_ [hash]
wp-settings- {time} – [UID]
cookie_notice_accepted (is the cookie used to store a user’s decision on the use of cookies on the website)
All these cookies are persistent and are released to ensure a better browsing experience on this site.

Profiling cookies
This site uses cookies of this type. Advertising cookies are installed to show site visitors content related to their preferences. They can therefore be used to display advertising content targeted to the person’s interests. Cookies of this type work in collaboration with third-party sites and can keep track of past browsing on pages on different domains. Cookies of this type usually keep track of the user’s IP address in addition to other information, some of which may be personal.

Third party cookies
These cookies are used in order to collect information on the use of the site made by users anonymously such as: pages visited, time spent, origins of the traffic of origin, geographical origin, age, gender and interests for statistical and marketing campaigns. These cookies are sent from third-party domains external to the site.


Google analytics cookie with anonymized IP
Our pages use third-party performance cookies of Google Analytics with anonymized IP (service offered by Google, Inc.) to allow us to collect anonymously and examine the behavior of visitors during the use of the site and to improve its usability and user experience. They are defined anonymous as they cannot be used to identify specific individuals.
Through the use of the Google Analytics panel, it is possible to understand if the visits were made by new or returning visitors by checking how the pages were navigated (entry, exit links, movement between pages, residence times, geographical origin, etc.).
For more information about Google Analytics, you can consult the sites:
https://www.google.it/policies/privacy/partners/
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
It is possible to disable the action of Google Analytics through the tools provided by Google. For information on this, consult the site:
https://tools.google.com/dlpage/gaoptout
The cookies used by Google Analytics are:
_ga (persistent – 2 years)
_utma (persistent – 2 years)
__utmb (session)
__utmt (session)
__utmz (session)
_gat (persistent – 10 minutes)

How to check or delete cookies
Most browsers are configured to accept, control or possibly disable cookies through the settings. For more information on cookie management visit the appropriate links:
Internet explorer
Chrome / windows phone
Safari / IOS
Firefox

For more information on cookies and to manage cookie preferences (first and / or third party) you can also visit the platform www.youronlinechoices.com.

Social network buttons and widgets
To ensure that the contents of a site can be shared on social networks by site visitors, it is possible to integrate the tools (widgets) made available to the social networks themselves into the pages.
These tools (usually blocks of code inserted in the pages of the host site) can collect third-party cookies installed by social networks (for example Facebook, Twitter, YouTube, etc.); the site does not share any information with these widgets.
For further information regarding the cookies of the main social networks, you can visit the sites:
Privacy Facebook
Instagram Privacy
Privacy Youtube
Privacy Twitter
Privacy LinkedIn
Privacy Pinterest
Privacy Whatsapp
Privacy Telegram

Consent to the use of cookies
We remind you that if you do not consent to the use of cookies or if you decide to disable the cookies we use, these choices may affect your browsing experience on this site (some web pages may be incomplete).

SECURITY PROTOCOLS
This website uses the “https” (Hypertext Transfer Protocol Secure) secure communication protocol.
The “https” protocol is used to guarantee secure communication between two IT devices connected to the Internet.
In this way, if you fill in one of the contact forms on our site, your message will be transmitted within an encrypted connection, through asymmetric encryption (thanks to the TLS – Transport Layer Security and SSL – Secure Sockets Layer protocols).
The “https” protocol guarantees:
– authentication of the website visited;
– the protection of privacy (confidentiality or confidentiality);
– the integrity of the data exchanged between the communicating parties.
We use the “https” protocol to protect your data through a two-way encryption of communications between a client and a server.
This allows us to protect your data from possible operations of:
– eavesdropping ? action by which the private conversation between the parties is secretly intercepted without their consent;
– opertampering ? literally “tampering or alteration of communication”, an action by which the contents of a web communication are falsified.
In practice, the “https” protocol guarantees that:
– the user is communicating exactly with the desired website (as opposed to a fake site);
– the contents of communications between the user and the website cannot be intercepted or altered by third parties.

PROFILING AND MARKETING ACTIVITIES
Leedia Srl, through this website, carries out marketing and profiling activities.
The marketing and profiling activities are carried out only towards people who have expressed their consent to the processing of personal data.
The marketing activities are aimed at making Leedia Srl services and contents known to the interested people who have given their consent to data processing.
Profiling activities are carried out to measure the results of marketing campaigns; these activities consist in the collection and processing of the data of users interested in a service to divide them into groups based on their behavior.
To carry out marketing and profiling activities, Leedia Srl uses the following tools.

Facebook Pixel
This website uses a script called “Facebook Pixel”.
We use this tool for the collection of statistical data that allow us to measure the effectiveness of paid advertising.
Thanks to the Facebook Pixel we can understand the actions that people perform on our website. The data we collect is used for:
Make sure that the adverts are shown to the right people;
Create audiences to target advertisements;
Take advantage of the additional advertising tools of the platform on which we advertise.
We use the Facebook Pixel to carry out remarketing and retargeting activities; thanks to these activities we use cookies without identifying you. In this way, your browsing data is not linked to your identity and your personal data.
The data collected thanks to the Facebook Pixel are used only by us and by external professionals who support us in marketing and online advertising.


Linkedin Insight Tag
This website uses a script called “Linkedin Insight Tag”.
The LinkedIn Insight Tag is a piece of code, in light “JavaScript” language, which adds a cookie to users’ browsers every time they visit the site.
Thanks to this tool we can register when a Linkedin member performs a certain action on our website (such as booking a service or leaving the email).
We use this tool for the collection of statistical data that allow us to measure the effectiveness of paid advertising.
Thanks to the Linkedin Insight Tag we can understand the actions that people perform on our website. The data we collect is used for:
Make sure that the adverts are shown to the right people;
Create audiences to target advertisements;
Take advantage of the additional advertising tools of the platform on which we advertise.
We use the Linkedin Insight Tag to carry out “remarketing” and “retargeting” activities; thanks to these activities we use cookies without identifying you. In this way, your browsing data is not linked to your identity and your personal data.
The data collected thanks to the Linkedin Insight Tag are used only by us and by external professionals who support us in online marketing and advertising activities.

Twitter tag Universal Website
This website uses a script called “Twitter tag Universal Website”.
The Universal Website Twitter tag is a piece of code, in light “JavaScript” language, which adds a cookie to users’ browsers every time they visit the site. Thanks to this tool we can record when a Twitter member performs a certain action on our website (such as filling out a contact form or leaving the email). We use this tool for the collection of statistical data that allow us to measure the effectiveness of paid advertising.
Thanks to the Universal Website Twitter tag we can understand the actions that people perform on our website. The data we collect is used for:
Make sure that the adverts are shown to the right people;
Create audiences to target advertisements;
Take advantage of the additional advertising tools of the platform on which we advertise.
We use the Universal Website Twitter tag to carry out “remarketing” and “retargeting” activities; thanks to these activities we use cookies without identifying you. In this way, your browsing data is not linked to your identity and your personal data.
The data collected thanks to the Twitter tag Universal Website are used only by us and by external professionals who support us in marketing and online advertising.

PURPOSE OF TREATMENT
In this section we will explain what our processing purposes are and how we use your data.

Marketing and profiling purposes
Our company, Leedia Srl, carries out marketing activities aimed at collecting personal data and contact data of people interested in investment and personal finance services or people interested in purchasing commercial products.

Our company, Leedia Srl, carries out in its own interest and in the interest of third-party customers, marketing campaigns and “lead generation” campaigns through some advertising platforms on the web.

If you fill in one of the contact forms, present in one of your web pages of our site, your data will be processed for marketing purposes, for direct marketing purposes, and for profiling purposes.

The marketing activity consists in the collection of commercial contacts interested in the purchase of some service products, who are willing to be contacted by email or by phone.

The direct marketing activity consists in the collection of commercial contacts interested in some products or services, who are willing to be contacted, by email or by telephone, directly and without the intervention of intermediaries.

The profiling activity consists in the analysis of the data collected, through automated or non-automated tools, in order to foresee aspects concerning professional performance, economic situation, health, preferences or personal interests, reliability or the behavior, location or movements of the interested party, insofar as this analysis activity produces legal effects that concern the person to whom the personal data refer.

Purpose of collection and internal classification
Our company, Leedia Srl, collects the personal data of users interested in purchasing a product or service in order to collect and classify them in internal databases.

If you fill out one of our contact forms, present in one of our web pages, your data will be entered in spreadsheets (available via Google Sheet or Microsoft Excel software) and will be stored in our cloud software.

Access to our cloud software is protected by double authentication and is reserved only for internal and / or external personnel who follow advertising campaigns, and marketing campaigns.

In some cases, your data may be entered in a CRM (Customer relationship management) software whose access is reserved only to internal and / or external personnel of Leedia Srl.

Access to the CRM is protected by an encrypted password and guarantees a high degree of protection and security.

Commercial contact purposes
Our company, Leedia Srl, collects the personal data of users interested in purchasing a product or service in order to initiate a commercial contact by email or by telephone conversation.

If you fill in one of our contact forms, present in one of our web pages, your data will be processed by internal staff of Leedia Srl, or by third party commercial partners, to initiate a telephone contact with you and to verify which product or service is best suited to your requests and / or needs.

In the event that, during the compilation of the contact form, you have provided your telephone number, the number you have provided us can be used to send you “sms” or commercial messages in line with the advertisement you have viewed.

In some cases we may use your phone number (which you have entered voluntarily in the contact form) through a software called “Message Bird”.

Thanks to the “Message Bird” software, we will be able to send you “sms” or commercial messages in line with the advertisement you have viewed.

Purpose of transferring data with third party partners
Our company, Leedia Srl, collects the personal data of users interested in purchasing a product or service in order to sell it and share it with third party partners.

If you fill out one of our contact forms, present on one of our web pages, your data may be transferred to third-party companies that deal with services or products in line with the topics covered on our web pages.

If you authorize the processing of data for this purpose, your data may be transferred to third parties who are located in the European Community area (EU) or to third parties who are located in a European non-EU area (Extra EU).

How we process your data
In carrying out our business, we enter your data in proprietary management software, access to which is protected by two-factor authentication.
In data processing we could use:
– “cloud” tools, applications or storage services;
– e-mail tools, applications or services;
– data transfer tools, applications or services such as Wetransfer.
These activities may involve the transfer of data to servers located outside the European Union, regardless of our will.
To carry out our services we use these software: Gmail, Google Drive, Google Calendar, Evernote, Dropbox, Slack, Zapier, Integromat, Basecamp, Adversus, Plecto, CRMBO, SEC, SPA.
We invite you to consult the privacy policy of these programs by clicking on these pages:
Gmail
Google Drive
Google Calendar
Google Privacy Policy
Dropbox
Basecamp
Cloud invoices


The data collected are consulted only by us and by external professionals who support us in marketing activities.
You can choose at any time to delete your data on our software by sending a request to the following email address: rdp@leedia.com