PRIVACY POLICY

This Privacy Policy is provided pursuant to art. 13 of European Regulation no. 679/2016 and applies exclusively to all Data collected through the Website www.lucamanfredinitax.com. The Policy is subject to updates that will be published on the Website from time to time. This Privacy Policy and the Cookie Policy, set out the basis on which your Personal Data will be processed.

This document contains a section dedicated to Users in Switzerland and their privacy rights.

Data Controller

The Data Controller of the Data collected by this Website is Luca Manfredini legal representative of the Studio MBA Commercialisti associati – P.Iva IT01895620035; email: l.manfredini@mbtax.it

Platform

The website is built with WordPress platform which is meant to host and run key components of the same. These platforms can provide analytical tools, for user registration management, for comment and database management, for e-commerce, for payment processing, etc. The use of these tools involves the collection and processing of Personal Data. Some of these services operate through geographically dispersed servers, making it difficult to determine the exact location where Personal Data is stored.

Personal data

Personal Data means any information relating to an identified or identifiable natural person (Data Subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, one or more factors specific to the physical identity of that natural person.

Category of Personal Data processed

Among the Personal Data processed by this Website, independently or through third parties, there are Common Data such as: Cookies, Usage Data, contact data including name, email, telephone number, billing address; personal data including CF and billing data; your marketing and cookie preferences.

Methods of Processing Personal Data

The Personal Data provided or acquired will be processed in accordance with the principles of correctness, lawfulness, transparency and protection of confidentiality in accordance with current regulations. The Data Controller processes the Users’ Personal Data by adopting the appropriate security measures aimed at preventing access, disclosure, unauthorized modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated.

Purpose of the Processing of Personal Data and Legal Basis

Personal Data may be collected autonomously by the Data Controller or through third parties. In this case, the computer systems and software procedures used to operate this Website acquire some Personal Data of the Users, of a technical-IT nature (e.g. the IP address, the type of browser used, the operating system, the domain name and the addresses of the websites from which it was made access or exit, etc.), the transmission of which is inherent in the normal functioning of the internet. Such Data may be processed for the sole purpose of obtaining anonymous statistical information on the use of the site and/or to check its correct functioning and will be deleted immediately after processing.

The Data that the Data Subject chooses to provide spontaneously will be processed in compliance with the conditions of lawfulness pursuant to Article 6 of the GDPR and will be processed to allow the Website to provide its services, as well as for the Purposes indicated below and will be stored for the time necessary to fulfill the aforementioned Purposes.

The purposes of the processing are:

1) Respond to requests and provide Information

The Data will be processed in order to be contacted or to follow up on specific requests addressed to the Data Controller by the Data Subject for communications of a nature relating to the Services and/or Contents of the Data Controller, through e-mail messages or other communication tools such as telephone or WhatsApp Business instant messaging or through Active Campaign.

Legal basis: this processing is optional and based on the consent of the Data Subject, however the provision of Data is necessary for the pursuit of the indicated purpose.

Data retention period: until the consent is revoked by the Data Subject.

2) Pre-contractual information and fulfilments

The Data will be processed in order to be contacted or to follow up on specific requests addressed to the Data Controller by the Data Subject for communications of an informative nature and/or for information about the purchase of the Data Controller’s Services, through e-mail messages or by filling in the contact form and other communication tools such as telephone or instant messaging WhatsApp Business or through Active Campaign.

Legal basis: this processing is optional and based on the consent of the Data Subject, however the provision of Data is necessary for the pursuit of the indicated purpose.

Data retention period: until the consent is revoked by the Data Subject.

3) Processing necessary in the context of a contract

The Data will be processed in order to fulfil the obligations arising from the contract entered into between the Data Subject and the Data Controller for the sale of the Services on the Website, to contact the Data Subject in relation to the Contract and for the management of the same, for the management of requests for legal guarantees, assistance, withdrawal requests, management and termination of the Contract itself.

Legal basis: this processing is necessary for the performance of the contract to which the Data Subject is a party, for the execution of pre-contractual measures or to comply with a legal obligation to which the Data Controller is subject.

Data retention period: 10 (ten) years or other legal obligation.

4) Fulfilment of any obligations provided for by the laws in force

The Data will be processed to comply with any type of obligation contemplated and provided for by current laws, regulations, related regulations, commercial uses and tax/fiscal matters, including also for the purposes provided for by the anti-money laundering legislation d.lgs. 231/2007 and subsequent amendments.

Legal basis: this processing is necessary to comply with a legal obligation to which the Data Controller is subject.

Data retention period: 10 (ten) years or other legal obligation.

5) Soft spam

The Data may be processed to allow the Data Controller to send commercial and promotional communications by e-mail to the Data Subject concerning Services similar to the Services being sold without the need for the express and prior consent of the Data Subject, as provided for by art. 130, paragraph 4, of the Privacy Code as amended by Legislative Decree no. 101 of 2018, and on condition that the Data Subject does not exercise the right to object.

Legal basis: this processing is based on the legitimate interest of the Data Controller pursuant to art. 6, letter F and Recital no. 47 of the GDPR.

Data retention period: until the Data Subject objects.

6) Newsletter

The Data may be processed for the purpose of sending communications and promotional, commercial and advertising material or relating to initiatives and events of the Data Controller, through newsletters.

Legal basis: this processing is based on the consent freely expressed by the Data Subject pursuant to art. 6, par. 1, lett. A of the GDPR.

Data retention period: until the consent is revoked by the Data Subject through the appropriate tool at the bottom of the newsletter or by request to the Data Controller.

7) Direct Marketing

The Data may be processed for the direct sale of Products/Services, market research, sending communications and promotional, commercial and advertising material or relating to initiatives and events, via e-mail and Whatsapp Business.

Legal basis: this processing is based on the consent freely expressed by the Data Subject pursuant to art. 6, par. 1, lett. A of the GDPR.

Data retention period: until the consent is revoked by the Data Subject.

8) Statistics

The Data may be processed to carry out statistical analyses on aggregated and anonymous data, to analyse the behaviour of the Data Subject, to improve the products and services provided by the Data Controller, as well as to meet the Data Subject’s expectations.

Legal basis: this processing is based on the consent freely expressed by the Data Subject.

Data retention period: until the consent is revoked by the Data Subject.

9) Profiling

The Data may be processed for the analysis and evaluation of interests, habits, consumer choices, including the creation of profiles in order to be able to send personalized information and promotional material on the Services/Products offered by the Data Controller.

Legal basis: this processing is based on the consent freely expressed by the Data Subject pursuant to art. 6, par. 1, lett. A of the GDPR.

Data retention period: until the consent is revoked by the Data Subject.

Communication of Data

In addition to the Data Controller, in some cases, the following may have access to the Data:

a) categories of specially trained persons involved in the organization of the Website (administrative, commercial, marketing, legal, system administrators);

b) external parties (such as third-party technical service providers, hosting providers, IT companies, communication agencies) also appointed as Data Processors by the Data Controller pursuant to Article 28 of the GDPR. The updated list of Data Processors, if appointed, may always be requested from the Data Controller;

c) public or private entities that may access the Data in compliance with legal obligations;

d) subjects who carry out ancillary and instrumental tasks with respect to the Data Controller’s activity;

Timing of Treatment

As expressly provided for by art. 5, paragraph 1, letter e) of the GDPR, the Data are stored for the time necessary for the Processing of the same in relation to the performance of the service requested by the Data Subject, or required by the Purposes described above in this document. At the end of the retention period, the Personal Data will be deleted and therefore, the rights of access, cancellation, rectification and portability of the Data can no longer be exercised

Cookie

This Website uses cookies. Cookies are small text files that can be used by websites to make the experience more efficient for the Data Subject and to personalize content and ads, provide the functions of social networks and analyze traffic. Cookie Policy

Place of Processing and Transfer of Data Abroad

The Data are processed at the Data Controller’s operational headquarters. For further information, please contact the Data Controller. The Data may be processed by natural persons and/or legal entities operating on behalf of the Data Controller and by virtue of specific contractual obligations and based in EU or non-EU member countries. In the event that Data is transferred outside the EEA, the Data Controller will take all appropriate contractual measures to ensure adequate Data protection.

Exercise of the rights of the data subject

The interested party has the right to exercise the faculties provided for in art. 7, 15-22 of European Reg. 679/2016. In particular, you have the right to revoke your consent at any time and, upon simple request to the Data Controller, you may request access to the Personal Data, receive the Personal Data provided to the Data Controller and, where possible, transmit them to another Data Controller without hindrance (so-called portability), obtain the updating, limitation of processing, rectification of Data and the cancellation of those processed in non-compliance with current legislation. You have the right, for legitimate reasons, to object to the Processing of Personal Data concerning you and to the Processing for the purpose of sending advertising material, direct sales and carrying out market research. You also have the right to lodge a complaint with the Data Protection Authority or to take legal action. The interested party may exercise his/her rights by contacting the Data Controller by e-mail at:

Tools used for the Processing of Personal Data

CONTACT FORM

By filling in the Contact Form with his/her Data, the Data Subject consents to their use to respond to requests for information, or for any other purpose indicated by the form’s header. Personal Data collected through the contact form: Email, Name and Surname, telephone

This website uses:

WhatsApp Business

WhatsApp Business is an instant messaging service provided by WhatsApp Ireland Limited. For the purposes of the processing methods, reference is also made to the WhatsApp Business Data Processing Terms, which can be found at the following link: Clicca qui

The Data Subject’s data will transit through WhatsApp Business services according to the terms that WhatsApp sets out in the “WhatsApp Business Terms of Service” document at the following link: Clicca qui

Personal Data collected: phone number, email, Usage Data, Cookies. Place of Processing: Ireland- Privacy Policy

ActiveCampaign (Active Campaign LLC)

ActiveCampaign, LLC (“ActiveCampaign”) provides a newsletter platform that allows Data Controllers to reach their customers, understand how they interact with such communications and other content, and tailor marketing to their interests. The Data Subject can choose at any time to unsubscribe from the newsletter by clicking on a specific button that will be found inside the emails. After clicking on the delete button, your Data will be deleted immediately by the software. Personal Data collected: Email and Name. Place of Processing: USA – Privacy Policy

EMAIL ADDRESS MANAGEMENT

These services make it possible to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the Data Subject. These services may also allow the collection of Data relating to the date and time of viewing the messages by the Data Subject, as well as the Data Subject’s interaction with them, such as information on clicks on links inserted in the messages.

Newsletter

By subscribing to the newsletter, the Data Subject’s email address may be automatically included in a list of contacts to whom email messages may be sent containing information, including commercial and promotional information, relating to this Website. Your email address may also be added to this list as a result of registering on this Site or after making a purchase. The Data Subject can choose to unsubscribe from the newsletter at any time by clicking on a specific button that will be found within the emails. After clicking on the delete button, the Data Subject will be deleted immediately by the “email marketing” software. Personal Data collected: email and name. This Website may use the newsletter service provided by:

ActiveCampaign (Active Campaign LLC)

SPAM PROTECTION AND SECURITY MEASURES

This Website, in order to secure the moment in which Personal Data is entered, has an SSL certificate and uses the HTTPS protocol. With the use of this protocol, the transactions and data that are transmitted on the websites take place with maximum security and the content of the communication is not read or manipulated in any way by third parties.

This website may also use tools that analyze traffic potentially in order to filter it from parts of traffic, messages and content recognized as SPAM.

reCAPTCHA

This Website uses reCAPTCHA which is a service subject to the Privacy Policy privacy

and termini e condizioni of Google’s use.

STATISTICS

Statistical services may only allow the Data Controller to monitor and analyse traffic data and are used to keep track of the behaviour of the Data Subject. This Website may use the following services:

Google Analytics 4

Google Analytics is an analytics service provided by Google LLC. Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its advertising network. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google’s behalf. In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can check out Google’s official documentation. At the following link Google provides a browser add-on for disabling Google Analytics. Person Data collected: Cookies and Usage Data. Place of processing: USA – Ireland Privacy Policy

Facebook Pixel Conversion Tracking (Meta Platforms, Inc.)

Facebook Conversion Tracking (Facebook Pixel) is an analytics service provided by Facebook. The Facebook pixel tracks conversions that can be attributed to Facebook ads. Personal Data collected: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy.

INTERACTION WITH SOCIAL NETWORKS

These services may allow you to interact with social networks directly from the pages of this Website. The interactions and information acquired by this Website are in any case subject to the privacy settings of the Data Subject relating to each social network. In the event that a service for interaction with social networks is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages on which it is installed.

Facebook (Meta Platforms, Inc.)

Facebook buttons are services for interaction with the social network Facebook, provided by Meta Platforms, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

Instagram (Meta Platforms, Inc.)

Instagram buttons are services for interaction with the social network Instagram, provided by Meta Platforms, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

LinkedIn (LinkedIn Ireland Unlimited Company)

LinkedIn buttons are services for interacting with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: Ireland – Privacy Policy

Tik Tok (TikTok Technology Limited)

Tik Tok buttons are social network interaction services provided by TikTok Technology Limited. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy

REMARKETING E RETARGETING

These services may allow this Website to communicate, optimize and serve advertisements based on the past use of this Website by the Data Subject. This activity is carried out through the tracking of Usage Data and the use of Cookies. This Website uses the following services:

Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by Facebook, which links the activity of this Website with the Facebook advertising network. This Website may use the Facebook Pixel tool in order to measure conversions. Thanks to the Facebook Pixel, it is possible to understand the actions that people perform on the Website. The Data we collect may be used to:

– make sure that the ads are shown to the right people;

– create audiences to target ads;

– take advantage of the additional advertising tools of the platform on which you advertise

The information collected is anonymous to the operators of this Site and cannot be used to identify the identity of an individual Data Subject. However, the information is saved and analyzed by Facebook, which could link the action to an individual profile and use this information for Facebook’s internal advertising purposes, as outlined in Facebook’s privacy policy. This will allow Facebook to show ads on both Facebook and third-party sites. The Website Owner has no control over how this data is used. For more information on how users can protect their privacy, please refer to the privacy policy.Please refer to the Privacy of Facebook.

CONTENT ON EXTERNAL PLATFORMS

These services may allow you to view and interact with content hosted on external platforms directly from the pages of this Website.
In the event that a service of this type is installed, it is possible that, even if Users do not use the service, it collects Traffic Data relating to the pages on which it is installed.

This Website uses

Youtube (Google Ireland Limited)

Youtube is a video content display service operated by Google that allows this website to integrate such content into its pages. Personal Data collected: Cookies and Usage Data. Place of Processing: Ireland – Privacy Policy

Calendly (Calendly LCC)

Calendly is an online automated appointment, call, and meeting scheduling software operated by Calendly LCC. Personal Data collected: Cookies and Usage Data. Place of processing: USA – Privacy Policy

Changes to this Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy at any time by giving notice to Users on this page. Please consult this page often, taking as a reference the date of the last modification indicated at the bottom. In the event of non-acceptance of the changes made to this Privacy Policy, the Data Subject is required to cease using this Website and may request the Data Controller to remove his/her Personal Data. Unless otherwise specified, the previous Privacy Policy will continue to apply to Personal Data collected up to that point. The Data Controller is not responsible for updating all the links that can be viewed in this Privacy Policy, therefore whenever a link is not functional and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referred to by such link.

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