PRIVACY POLICY
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Privacy Policy

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C.L.N. S.p.A. (the “Company”) hereby provides you, through this Policy, some information concerning the functionality of its website in relation to the processing of your personal data as users (Section I) and to the use of cookies (Section II).

The Policy has the value of information notice pursuant to article 13 of Regulation UE 2016/679 (“GDPR”), for the data subjects accessing the website www.gruppocln.com (the “Website”), solely in relation to that Website and excluding any other websites possibly accessed by the user via links contained thereby.

The Policy may be revised pursuant to the entry into force of new law provisions; we therefore invite the user to periodically check this webpage.

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SECTION I – PERSONAL DATA PROCESSING


1. DATA PROCESSING

1.1 Data Controller

(a) In relation to this Website the data controller is C.L.N. S.p.A. (the “Data Controller”).
(b) In order to obtain any clarification or to exercise the rights of the user, the Data Controller may be reached via the following email address: This e-mail address is being protected from spambots. You need JavaScript enabled to view it

1.2 Data Processing location
(a) The data processing deriving from the use of this Website is carried out at the Data Controller’s premises.

2. PROCESSED DATA

2.1 Data categories, purposes and modalities of the processing
(a) Similarly to every website, even this Website uses log files which store the information automatically collected during the users’ visits. The electronic systems and the software procedures which allow the functioning of this Website collect, upon their regular use, some data whose transmission is implicit in the use of communication protocols on the Internet. Such information is not collected in order to be associated with identified data subjects, but, considering its nature, it may, through processing and association with data retained by third parties, allow identification of users. The information collected may include the following:
(i) internet protocol address (IP);
(ii) browser category and parameters of the device used to connect to the Website;
(iii) name of the internet service provider (ISP);
(iv) date and time of the visit;
(v) referral and output webpage of the user;
(vi) possibly the number of clicks.
(b) The above-mentioned information is automatically processed and collected in aggregated form only, in order to verify the proper functioning of the Website, and for safety reasons. Such information will be processed pursuant to legitimate interests of the Data Controller.
(c) For safety purposes (anti-spam filters, firewalls, virus detection), the data automatically registered may possibly include also personal data such as the IP address, which may be used, in compliance with the relevant legislation in force, in order to halt attempts to damage the Website itself or to damage other users or, in any case, harmful or criminal activities. These data are never used to identify or profile the user, but only in order to protect the Website and its users.

2.2 Data Retention
(a) The data collected by the Website during its operation are used solely for the above mentioned purposes and are retained for the time strictly necessary to carry out the specified activities and, in any case, for no longer than 14 months.
(b) The data used for safety purposes (to halt attempts to damage the Website) are retained for the time strictly necessary to achieve the abovementioned purpose.

2.3 Data supplied by the user
(a) The user cannot provide any data through the Website.

2.4 Plugin Social Network
(a) This Website do not incorporates plugins and/or buttons for social networks.

2.5 “Whistleblowing” webpage

(a) This Website, at https://leaks.gruppocln.com/#/, has a dedicated webpage for the management of reports of illicit conduct ("whistleblowing"). This platform uses the GlobaLeaks software, specifically designed to protect the identity of the whistleblower and of the receiver in the exchange of information. In addition, the Website suggests using the Tor browser to protect anonymity to use this service.

3. DATA SUBJECT’S RIGHTS

3.1 The Data Subject may exercise all rights provided in articles 15-22 of the GDPR by contacting the Data Controller as per the addresses provided in paragraph 1.

3.2 More specifically the Data Subject is entitled to:
(a) obtain confirmation as to whether or not processing of personal data concerning the data subject exists, even if these have not been recorded yet, and to obtain communication of such data in intelligible form;
(b) obtain, inter alia, indication of:
(i) the source of the data;
(ii) the purposes and modalities of the processing;
(iii) the identification data of the Data Controller;
(iv) the recipients or categories of recipients to whom the data may be disclosed or which may become aware of them, also in their capacity as processors;
(v) the categories of personal data under review;
(vi) when possible, the period of retention provided or the criteria followed to determine it;
(vii) the existence of the right to request the correction, the erasure or the limitation of the processing of the data;
(viii) the existence of the right to object to the processing;
(ix) the right to lodge a complaint before the supervisory authority;
(x) the existence of an automated decision-making processing, including profiling;
(c) obtain:
(i) the correction or integration of data;
(ii) the limitation of the processing, if possible;
(iii) the portability of data, if applicable;
(iv) the certification that the operations as per points (i) and (ii) sub c) and (i) sub d) have been communicated, also with regard to their contents, to the entities to whom the data were communicated or sent, unless this fulfilment is proved to be impossible or to involve manifestly disproportionate means compared to the protected right;
(d) obtain;
(i) the erasure of data when provided by law;
(e) withdraw the consent to the processing of personal data;
(f) object, in whole or in part:
(i) on legitimate grounds to the processing of the data, even though they are relevant to the purpose of the collection;
and (ii) to the processing of personal data for the purposes of sending communications;
(g) lodge a complaint before the Supervisory Authority for the Protection of Personal Data.

4. DATA TRANSFER TO NON-EU COUNTRIES

4.1 This Website may share some of the data collected with services located outside the European Union, in particular with the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

4.2 Data will never be transferred to third countries that do not comply with the conditions set out in Article 45 and following of the EU Regulation.

5. SECURITY OF THE PROVIDED DATA

5.1 This Website shall process the users’ data in a lawful and proper manner, implementing the appropriate security measures aimed at preventing unauthorized accesses, disclosure, modification or destruction of the data. The processing shall be carried out through electronic and/or IT means, with organization modalities and rationales strictly connected with the above-mentioned purposes.

5.2 In addition to the Data Controller, in some cases, categories of persons involved in the organization of the Company (administrative staff, system administrators) or persons outside the Company (such as third-party technical services suppliers, hosting providers, information technology companies) may have access to the data. In this case, they are appointed as data processors pursuant to art. 28 of the GDPR.

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SECTION II - COOKIES

1. CATEGORIES OF COOKIES

(a) The Website www.gruppocln.com uses cookies to allow the user to have an easier and more intuitive browsing experience: cookies are small text strings used to record some information which may concern the user, his or her preferences or the device accessing the Internet (computer, tablet or mobile) and are mainly used to adjust the operation of the Website to the expectations of the user, offering a more customized browsing experience and recording the choices previously made.
(b) A cookie is a small mix of data transferred to the user’s browser from a web server and may be read only by the server which carried out the transfer. It is not an executable code and it does not deliver viruses.
(c) The cookies do not register any personal information and the possible identifiable data will not be recorded. If you wish, you may prevent the saving of some or all cookies. However, in such case the use of the Website and of the services provided may be compromised.

The categories of cookies are the following:

1.2 Technical cookies
(a) Among the technologies used to store information on the user’s computer, the most known and used one is the HTML cookies. They are used to browse and to facilitate access to and use of the Website by the user. They are necessary to send communications via electronic net or for the provider to supply the service required by the client.
(b) The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user may manage or request the general disabling or deletion of cookies, by changing the settings of its own browser. Such disabling may slow down or prevent access to some parts of the Website.
(c) The use of technical cookies allows the safe and efficient use of the Website.
(d) The cookies that are inserted in the browser and retransmitted, either through Google Analytics or through the statistics service, are technical only if used for the purposes of website optimization directly by the owner of the Website, which can collect information in aggregate form on the number of users and how they visit the Website. Under these conditions, for analytics cookies the same rules apply, in terms of information and consent, provided for technical cookies.
(e) With respect to duration, we may distinguish between: temporary session cookies, which are automatically deleted at the end of each session and are used to identify the user and thus to avoid login to every single webpage visited, and permanent cookies, which remain in use on the computer until expiry or deletion by the user. These latter are not recorded permanently but only for the duration of the browsing, until the browser is closed and they vanish upon closing of the browser. Their use is strictly limited to the sending of session identifiers which are made up of random numbers generated by the server necessary to allow safe and efficient exploration of the Website.

1.3 Third-party cookies

The Website does not use any third-party cookies.

1.4 Profiling Cookies
The Website does not use profiling cookies or automatic processing mechanisms.

2. SUPPORT IN THE CONFIGURATION OF THE BROWSER

(a) The user may manage the cookies also through the settings of his or her browser. However, by deleting cookies from the browser, he or she may remove the preferences he or she had set for the Website.
(b) For further information and support, it is also possible to visit the specific help webpage of the web browser in use:
(i) Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
(ii) Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
(iii) Safari: http://www.apple.com/legal/privacy/
(iv) Chrome: https://support.google.com/accounts/answer/61416?
(v) Opera: http://www.opera.com/help/tutorials/security/cookies/

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REVISIONS TO THIS DOCUMENT

This document, published on the page: http://www.gruppocln.com/privacy-policy.html is the Privacy Policy of this Website, which includes the cookies information policy.

The last update of the document was made on 11/07/2018.

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