Privacy and cookie policy

Clara Buoncristiani PR Boutique Firm srl recognizes the importance of protecting your personal data, and is committed to respect its users' privacy also by ensuring that personal data is processed with the utmost care and confidentiality, and is not used for any purpose other than those detailed below.

To that effect, this policy describes how personal data are processed in connection with the website and with electronic communications sent through the MailUp platform.
This information is provided pursuant to Article 13 of Regulation (EU) 2016/679 to users who interact with the company’s web services and to recipients of electronic communications sent through the MailUp platform; the company’s web services are available at:

https://www.clarabuoncristiani.it

The company may change and/or update this policy at any time.
This policy applies to this website and to electronic communications sent through the MailUp platform; it does not apply to other websites that users may access through links, except for those indicated above.

1. Data Controller

The data Controller is Clara Buoncristiani PR Boutique Firm srl, with registered office in Brescia (Italy), Via San Giovanni Bosco no. 6.

2. Processing purposes

The company hereby informs website users and recipients of communications sent through MailUp that any data collected shall be used solely for the purposes specified below and to keep customers up to date on the company’s general activities and latest news.

3. Processing purposes

The personal data processed include navigation data, data voluntarily provided by website users, and data relating to interaction with electronic communications sent through the MailUp platform.

4. Navigation data

The IT systems and software programs used to operate this website routinely acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols. This data, although not collected for the purpose of being associated with anyone in particular, by its very nature could be cross-referenced and combined with data processed by third parties, and thereby be used to identify the users.
This data category includes information on the IP address, domain names of computers by which users connect to the website, the requested resources URI (Uniform Resource Identifier) address, time of the request, method used to submit the request to the server, the size of the file obtained in response to the request, numerical code indicating the web server reply status, and other parameters pertaining to the user's operating system and IT environment.
This type of data is only used to collect anonymous statistical information regarding the use of the website, and to verify its functionality, and is deleted immediately after being processed.

5. Data voluntarily provided by the user

The optional, explicit and voluntary provision of personal data, including the e-mail address, sent through the addresses on the website and/ or by filling out contact information forms on the site or through digital cloud computing platforms such as MailUp (https://www.mailup.com/privacy-statement/), results in the acquisition of the sender's personal data. This includes the e-mail address required to respond to the query, as well as other personal data listed in the e-mail or contact forms. Privacy policy notices are summarized or displayed on the website pages for services provided upon request, to remind users that their personal data is subject to processing.

The company will use the collected data:
a) for purposes related to the use of services offered by website (navigation)
b) for activities strictly pertaining and instrumental to the management of and response to requests and communications received through the e-mail addresses published on the website, as well as the related professional relationships;
c) for communication conducted solely and exclusively with the user's specific consent, for the purpose of sending informational/photographic/promotional/advertising materials and newsletters, as well as to establish and maintain communication relationships.
For such data, the legal basis is the performance of pre-contractual measures at the data subject’s request, where applicable, or the Controller’s legitimate interest in managing correspondence and professional relationships.
The provision of personal data for the purposes listed in letter c) is optional, and consent has to be provided according to the methods specified in article 7 of the GDPR, directly through the website.

Starting from the date of receipt/update, your personal data shall be retained for as long as required for the processing purposes listed above. Additional information regarding personal data retention periods can be obtained by sending an e-mail to privacy@clarabuoncristiani.it

Data relating to interaction with communications sent through MailUp

Electronic communications sent through the MailUp platform may contain tracking pixels and tracked links. These tools allow information relating to interaction with the communication to be collected, including whether the message has been opened, the date and time of opening, identifiers for the communication/campaign and recipient, any technical data associated with loading the pixel, and clicks on links contained in the communication, including links to downloadable files.
Interaction data are technically associated with the individual recipient within the MailUp platform. However, the Controller uses them solely for statistical purposes and to measure the effectiveness of communications, in particular to keep track of the number of opens and clicks on links, including links to downloadable files, and not to profile individual recipients.
Individual tracking is carried out with the data subject’s prior consent. Recipients may at any time change or specifically withdraw that consent using the appropriate links at the bottom of the communications, while continuing to receive the communications without individual tracking.
Data relating to interaction with communications are retained in a form associated with the individual recipient for the period necessary to pursue the statistical purposes described above and are subsequently anonymised.

6. Cookies

Cookies are small files sent by websites to store short strings of text on the user's computer. Cookies are secure and cannot damage the user's computer, steal information or violate the user's privacy. Cookies are only used to store data regarding the user's visit for statistical purposes (e.g. pages visited) and to improve navigation of the website. Cookies allow the company to track and analyze usage of its website, and to store user settings. Users can refuse to accept cookies, but in that case the website might not function properly.

Cookies and other tracking systems

Cookies are short strings of data sent by the company website to the user's internet browser, where they are stored and retransmitted to the website upon the user's next visit. They can be used to track navigation, verify the user's credentials for access to the website or sections of the website, so that the user name and password and/or preferences do not have to be input and stored every time. There are many cookie categories, differentiated by their technical, duration, origin and functional characteristics.

Technical cookies

Different technologies allow websites to store information on the user's computer and retrieve it. Of these, HTML is the most widely used and recognized.
Cookies are used to enhance navigation and facilitate the user's access and use of the website. They are required to transmit data over electronic communication networks, meaning to the web service provider, to supply the service requested by the user.
Settings for the management and deactivation of cookies may differ depending on the user's browser.
In any case, users can manage, disable or delete cookies by changing their browser settings. Some webpages may take longer to load or be inaccessible if cookies are disabled.
Technical cookies ensure the safe and efficient use of the website.
Cookies added to the browser and retransmitted by way of Google Analytics, Blogger Stats, or similar services are classified as technical only when used directly by the website owner for optimization purposes, to collect aggregate data regarding the website overall number of users, and how they visit the website. Analytics and technical cookies are subject to the same legal notification and consent requirements.

Duration of cookies

From a duration standpoint, there are temporary session cookies and persistent cookies. The first are automatically deleted upon closing the browser, and are used to identify the user and avoid the need of logging into each webpage, while persistent cookies remain active on the pc or any other device, until they expire or are deleted by the user.
Session cookies may be installed to grant access to company webpages accessible only by registered users.
These cookies are not saved after the current navigation session, and are deleted upon closing the browser. They solely serve to transmit session identification data, consisting of random numbers generated by the server, which ensure safe and efficient navigation of the company website.

Use of cookies by our company

On the website, cookies or other tools are not used for user profiling. The tracking tools described in this policy relate exclusively to electronic communications sent through the MailUp platform.
We do use session (non-persistent) cookies, but only to the extent required to ensure safe and efficient navigation of the websites. Users can control whether or not session cookies are saved on computer terminals or browsers. This is not the case for servers, where at the end of HTTP sessions cookie-related information is routinely saved in service logs, which are in any case retained for no longer than 365 days, like other navigation data.

7. Processing methods

Data shall be processed according to GDPR art. 4, by way of the following actions: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, usage, interconnection, blocking, communication, cancellation and deletion of data. These may be performed by paper-based or by IT and electronic processing means, using methods and instruments apt to ensure the security and confidentiality of said data. More specifically, we will implement all technical and organizational data protection measures necessary to ensure an adequate level of security.
Processing is performed by automated systems, for as long as strictly necessary to achieve the purpose by which the data was collected, and in compliance with the prevailing laws.

8. Communication and sharing of data

Personal data shall be processed by employees and/or associates of the Controller, and will not be shared or communicated to third parties except when so required by the Regulation and in any case according to the procedures set forth therein.
For the sending and management of electronic communications and the related interaction data, the Controller uses the MailUp platform, which processes such data on behalf of the Controller as a Processor, within the scope of the services provided.

9. Rights of the Data Subject

In relation to the aforementioned data, users may exercise, at any given time, their right to access, rectification and cancellation of personal data, the right to restrict or object to its processing, and the right to data portability, meaning to receive their personal data in a structured, commonly used, machine-legible format and transmit it to another Controller, without impediment. More specifically, all of these are referenced in the provisions of GDPR articles 15,16,17,18,20 and 21. In case of violations, the data subject has the right to lodge a complaint with the appropriate Personal Data Protection Authority.

10. Revocation of consent

The consent to process personal data may be revoked at any time without prejudice to the legitimacy of processing completed prior to the revocation, or processing based on legal grounds other than consent.
With regard to individual tracking of communications sent through MailUp, the data subject may specifically change or withdraw that consent using the appropriate links at the bottom of the communications, without having to unsubscribe from the communications themselves.

11. Controller and Processor

The Controller is Clara Buoncristiani PR Boutique Firm srl. The list of personal data Processors can be obtained through the Company registered office.