Privacy Policy

Information on the processing of personal data, pursuant to Regulation (EU) 2016/679 and Legislative Decree no. 196/2003.

This Website (nero9milano.com) collects some of its Users’s Personal Data.

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Data Controller

Spirito Classico srl,
P.IVA 10034360965,
Via Anfiteatro 9, Milano, MI 20121

Data Controller’s email: info@nero9milano.com

Types of data collected

Among the Personal Data collected by this Website, either independently or through third parties, there are: Tracking Tool; Usage Data; Email.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website. Unless otherwise specified, all data requested by this website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation. Users who have doubts about which data are mandatory are encouraged to contact the Data Controller. Any use of Cookies – or other tracking tools – by this Website or by the owners of third-party services used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.

The User takes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or release them, freeing the Data Controller from any liability to third parties.

Method and place of processing of the collected data

Processing methods

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using software and/or telematic tools, with organizational methods and with an approach strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data. These subjects are also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

  • the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • the processing is necessary for the performance of a task of public interest or for the exercise of public authority vested in the Data Controller;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is however always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided by a contract or necessary to conclude a contract.

Place

The Data are processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can verify if one of the transfers described above takes place by examining the section of this document relating to the details of the processing of Personal Data or by asking the Data Controller for information. The User can contact the Data Controller at the contact details shown above.

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

  • Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of this contract is completed.
  • Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of processing the collected data

The User’s Data are collected to allow the Data Controller to provide its Services, comply with legal obligations, respond to requests or enforceable actions, protect their rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, and for the following purposes: Statistics, Viewing content from external platforms and Remarketing and behavioral targeting.

To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the related sections of this document.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Contact Form (This Website): By filling in the contact form with their data, the User consents to their use to respond to requests for information, estimates, or of any other kind indicated by the form header. Personal Data collected: surname, name, email, home/mobile phone and ip address.
  • Newsletter (This Website): By filling in the contact form with their data, the User consents to their use to respond to requests for information, quotes, or other requests indicated on the form. Personal Data collected: surname, name, email, telephone / mobile phone and ip address. The site contains a bimonthly newsletter dedicated to all readers who spontaneously want to receive exclusive editorial content via email. For the delivery and management of the newsletter, the service offered by MailChimp (The Rocket Science Group, LLC, 512 Means St., Suite 404 – 30318 – Atlanta, Georgia) is used and the data collected is stored on the secure servers of the service. dispensing. Pursuant to MailChimp’s privacy policy, the data will never be used directly by MailChimp or sold by it to third parties. MailChimp uses appropriately authorized operators to maintain the service and in the exercise of this function they may have access to your data. In any case, the guarantees provided by the MailChimp privacy policy apply.
  • Interaction with live chat platforms: This type of service allows you to interact with live chat platforms, managed by third parties, directly from the pages of this Website. This allows both the User to contact the support service of this Website and this Website to contact the User while browsing its pages.In the event that an interaction service with live chat platforms is installed, it is possible that, even if the Users do not use the service, it collects Usage Data relating to the pages in which it is installed. Additionally, live chat conversations may be recorded.
  • Cookies

Information on how to opt out of interest-based advertisements

In addition to any opt-out feature provided by any of the services listed in this document, Users can read more about how to disable interest-based advertisements in the appropriate section of the Cookie Policy.

User rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

  • withdraw consent at any time. The User can revoke the previously expressed consent to the processing of their Personal Data.
  • oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
  • access their data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
  • obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
  • obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Data Controller.
  • receive their data or have them transferred to another Data Controller. The User has the right to receive their data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another Data Controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
  • propose a complaint. The User can lodge a complaint with the responsible personal data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to processing on grounds related to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User’s rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Further information on the treatment

Defense in court

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Website or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Website and any third-party services used by it may collect system logs, which are files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Website does not support “Do Not Track” requests.
To find out if any third-party services used support them, the User is invited to consult their privacy policy.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page. Therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes affect processing operations whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

This document contains information about the technologies that enable this Website to achieve the purposes described below. These technologies allow the Data Controller to collect and save information (for example through the use of Cookies) or to use resources (for example by executing a script) on the User’s device when the latter interacts with this Website.

For simplicity, in this document such technologies are synthetically defined “Tracking Tools”, unless there is reason to differentiate. For example, although Cookies can be used in both web and mobile browsers, it would be inappropriate to talk about Cookies in the context of mobile applications, since they are Tracking Tools that require the presence of a browser. For this reason, within this document the term Cookie is used only to indicate specifically that particular type of Tracking Tool.

Some of the purposes for which Tracking Tools are used may also require your consent. If consent is given, it can be freely revoked at any time by following the instructions in this document.

This Website uses Tracking Tools managed directly by the Data Controller (commonly called “first party” Tracking Tools) and Tracking Tools that enable services provided by third parties (commonly called “third party” Tracking Tools). Unless otherwise specified in this document, these third parties have access to their respective Tracking Tools. Duration and expiration of Cookies and other similar Tracking Tools may vary depending on what is set by the Owner or each third-party provider. Some of them expire at the end of the User’s browsing session. In addition to what is specified in the description of each of the categories below, Users can get more detailed and updated information on the duration, as well as any other relevant information – such as the presence of other Tracking Tools – in the privacy policies of the respective third-party providers (through the links made available) or by contacting the Data Controller.

Used Cookies

Technical and session cookies

Their use is limited to the transmission of session identification data, to allow normal website browsing. They are automatically deleted when the browser is closed (not persistent). These Cookies do not require the User’s prior consent to be installed and used.

Tag Management

This type of service is used to centrally manage the tags or scripts used on this Website.
The use of these services involves the flow of the User’s Data through them and, if applicable, their retention.

  • Google Tag Manager (Google Ireland Limited):
    Google Tag Manager is a tag management service provided by Google Ireland Limited.
    Personal Data processed: Tracking Tool.
    Place of processing: Ireland – Privacy Policy.
    Duration of storage:
    • _dc_gtm_*: 1 minute
    • _gcl_au: 3 months

Traffic Optimization

These types of services allow this App to distribute its contents through servers located in the territory and to optimize its performance. The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter communications between this App and the User’s browser. Due to the distributed nature of this system, it is difficult to determine where the content is transferred, which may also contain Your Personal Data.

  • Cloudflare (Cloudflare Inc.)
    Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
    Cloudflare’s integration modalities provide that it filters all the traffic of this App, ie the communications between this App and the User’s browser, also allowing the collection of statistical data on it.
    Personal Data processed: Tracking Tools; various types of Data as specified by the privacy policy of the service.
    Place of processing: United States – Privacy Policy.

Viewing content on external third-party platforms

This type of service allows you to view content that is hosted on external platforms directly from this web site’s pages and interact with them. This type of service may still collect data on web traffic related to the pages where the service is installed, even when Users do not use it.

  • Font Awesome (Fonticons, Inc. ):
    Font Awesome is a font-style display service operated by Fonticons, Inc. that allows this Website to integrate such content within its pages.
    Personal Data processed: Usage Data and Tracking Tool.
    Place of processing: United States – Privacy Policy.
  • Google Fonts (Google Ireland Limited):
    Google Fonts is a font style display service operated by Google Ireland Limited that allows this Website to integrate such content within its pages.
    Personal Data processed: Usage Data; Tracking Tool.
    Place of processing: Ireland – Privacy Policy.
  • Widget Google Maps (Google Ireland Limited):
    Google Maps is a map display service operated by Google Ireland Limited that allows this Website to integrate such content within its pages.
    Personal Data processed: Usage data.
    Place of processing: Ireland – Privacy Policy.
  • Widget Video YouTube (Google Ireland Limited):
    YouTube is a video content display service operated by Google Ireland Limited that allows this Website to integrate such content within its pages.
    Personal Data processed: Usage Data and Tracking Tool.
    Place of processing: Ireland – Privacy Policy.
  • YouTube Video Widget – privacy mode (Google Ireland Limited):
    YouTube is a video content visualization service provided by Google Ireland Limited, allowing this Application to integrate this type of content on its pages. This widget is configured in such a way that YouTube does not store any information or cookies about Users of this Application, unless they start playing the video.
    Personal data processed: Usage data; Universally Unique Identifier (UUID); Trackers.
    Place of processing: Ireland – Privacy Policy.
  • Widget Instagram (Meta Platforms Ireland Limited):
    Instagram is an image viewing service operated by Meta Platforms Ireland Limited that allows this Website to integrate such content within its pages.
    Personal Data processed: Usage Data and Tracking Tool.
    Place of processing: Ireland – Privacy Policy.
  • TripAdvisor widget (TripAdvisor LLC):
    Widget TripAdvisor is a content viewing service managed by TripAdvisor LLC that allows this Website to integrate content from this external platform into its own pages.
    Personal Data processed: Usage Data and Tracking Tool.
    Place of processing: Ireland – Privacy Policy.

Spam protection

These types of services analyze the traffic of this Application, potentially containing the User’s Personal Data, for the purpose of filtering messages and content that are recognized as SPAM.

  • Google reCAPTCHA (Google Ireland Limited):
    Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
    The use of the reCAPTCHA system is subject to privacy policy and ai Google’s terms of use.
    Personal Data processed: Click; Usage Data; Keypress events; Motion sensor events; Touch events; Mouse movements; Scroll position; Answer questions; Tracking Tool.
    Place of processing: Ireland – Privacy Policy.

Analytical Cookies

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.

  • Google Analytics with anonymized IP (Google Ireland Limited):
    Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the collected Personal Data for the purpose of tracking and reviewing 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 ads on its advertising network.
    This integration of Google Analytics makes your IP address anonymous. Anonymization works by shortening the IP address of Users within the borders of the Member States of the European Union or in other countries that are parties to the Agreement on the European Economic Area. Only in exceptional cases, the IP address will be sent to Google’s servers and shortened within the United States.
    Personal Data processed: Usage Data; Tracking Tool.
    Place of processing: Ireland – Privacy Policy – Opt Out.
  • Google Analytics (Google Ireland Limited):
    Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
    Google may use Personal Data to contextualize and personalize ads on its advertising network.
    Personal Data processed: Usage Data; Tracking Tools.
    Place of processing: Ireland – Privacy Policy – Opt Out.
  • Facebook Ads Conversion Tracking (Facebook pixels) (Meta Platforms Ireland Limited):
    Facebook Ads Conversion Tracking (Facebook pixel) is a statistics service provided by Meta Platforms Ireland Limited that connects data from the Meta ad network with actions taken within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram, and Audience Network ads.
    Personal Data processed: Usage Data; Tracking Tool.
    Place of processing: Ireland – Privacy Policy.

Cookie interaction with social networks with external platforms

This type of service allows you to interact with social networks, or with other external platforms, directly from the pages of this Website. The interactions and information acquired by this Website are in any case subject to the User’s privacy settings related to each social network. This type of service may still collect traffic data for pages where the service is installed, even when Users do not use it. We recommend that you disconnect from the respective services to ensure that the data processed on this Website is not linked back to your profile.

  • Like button and Facebook social widgets (Meta Platforms Ireland Limited):
    “Like” button and Facebook social widgets are social networking services provided by Meta Platforms Ireland Limited
    Personal Data processed: Usage Data; Tracking Tool.
    Place of processing: Ireland – Privacy Policy.

Advertising

This type of service allows you to use your User Data for commercial communication purposes. These communications are displayed on this Website in the form of banners and other forms of advertising, also about the interests of the User. This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below. Some of the services listed below may use Tracking Tools to identify you or use the behavioral retargeting technique, which is to display advertisements tailored to your interests and behavior, also detected outside this Website. For more information, we suggest that you check the privacy policies of the respective services. Services of this type generally offer the possibility to disable such tracking. In addition to any opt-out feature provided by any of the services listed in this document, you may read more about how to opt out of interest-based advertisements in the “How to opt-out of interest-based advertising” section in this document.

  • Similar audience of Facebook (Meta Platforms Ireland Limited):
    Facebook’s Similar Audience is a behavioral advertising and targeting service provided by Meta Platforms Ireland Limited that uses the Data collected through Facebook’s Personalized Public Service in order to display advertisements to Users with behaviors similar to Users who are already on a personalized Audience list based on their previous use of this Website or their interaction with relevant content through Facebook’s applications and services.
    Based on this Data, personalized ads will be displayed to Users suggested by a similar Facebook audience. Users may choose not to use Facebook Tracking Tools for ad customization by visiting this opt-out page.
    Personal Data processed: Usage Data and Tracking Tool.
    Place of processing: Ireland – Privacy Policy – Opt Out.
  • Google Ad Manager (Google Ireland Limited):
    Google Ad Manager is an advertising service provided by Google Ireland Limited with which the Data Controller may conduct advertising campaigns in conjunction with external advertising networks with which the Data Controller unless otherwise specified in this document, has no direct relationship.
    For an understanding of Google’s use of Data, please refer to the Google partner standards.
    This service uses the “Doubleclick” Cookie, which tracks the use of this Website and the User’s behavior in relation to the advertisements, products, and services offered.
    The User can decide at any time to disable all doubleclick cookies by going to: Settings Ads.
    Personal Data processed: Usage Data and Tracking Tools.
    Luogo del trattamento: Irlanda – Privacy Policy – Opt Out.
    Storage life: 2 years.

Profiling and Remarketing cookies

This type of service allows this Website and its partners to communicate, optimize and serve advertisements based on the User’s past use of this Website.
This activity is facilitated by the tracking of Usage Data and the use of Tracking Tools to collect information that is then transferred to partners who manage remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email address lists.
Services of this type generally offer the possibility to disable such tracking. In addition to any opt-out feature provided by any of the services listed in this document, you may read more about how to opt-out of interest-based advertisements in the “How to opt out of interest-based advertising” section in this document.

  • Facebook Remarketing (Meta Platforms Ireland Limited):
    Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Website with the Facebook advertising network.
    Personal Data processed: Usage Data; Tracking Tool.
    Luogo del trattamento: Irlanda – Luogo del trattamento: Irlanda – Privacy Policy – Opt Out.
  • Facebook Custom Audience (Meta Platforms Ireland Limited):
    Facebook Personalized Audience is a remarketing and behavioral targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Website with the Facebook advertising network. Users may choose not to use Facebook Tracking Tools for ad customization by visiting this opt-out page.
    Personal Data processed: email; Tracking Tool.
    Place of processing: Ireland – Privacy Policy – Opt Out.
  • Remarketing Google Ads (Google Ireland Limited):
    Remarketing Google Ads is a remarketing and behavioral targeting service provided by Google Ireland Limited which connects this Website’s activity to the advertising Google Ads network and to the Cookie DoubleClick.
    For an understanding of the use of Data by Google, please consult the rules for Google partners.
    Users may choose not to use Google Tracking Tools to personalize ads by visiting Google Ads Settings.
    Place of processing: Ireland – Privacy Policy – Opt Out.
    Storage life: 2 years.

How to manage preferences and give or withdraw consent

There are several ways to manage your preferences for Tracking Tools and to give or withdraw your consent, if necessary:

Users can manage Tracking Tools preferences directly through their device settings – for example, they can prevent the use or storage of Tracking Tools.

In addition, whenever the use of Tracking Tools depends on consent, the User may give or withdraw consent by setting preferences within the cookie policy or by updating preferences through the tracking settings widget, if present.

Thanks to the browser or the device’s special functions, it is also possible to remove previously saved Tracking Tools.

Other Tracking Tools in the browser’s local memory can be removed by deleting the browsing history.

With regard to Third Party Tracking Tools, Users may manage their preferences and withdraw their consent by visiting their opt-out link (if available) using the tools described in the privacy policy of the third party or by contacting it directly.

Find settings for Tracking Tools

Users can, for example, find information on how to manage cookies in some of the most popular browsers at the following addresses:

Users can also manage some Tracking Tools for mobile applications by disabling them through the appropriate device settings, such as mobile advertising settings or tracking settings in general (Users can consult device settings to locate the relevant one).

How to opt-out of interest-based advertising

Without prejudice to the foregoing, Users are informed of the possibility to use the information on YourOnlineChoices (EU), Network Advertising Initiative (USA) and Digital Advertising Alliance (USA), DAAC (Canada), DDAI (Japan) or other similar services. With these services you can manage the tracking preferences of most advertising tools. The Data Controller, therefore, advises Users to use these resources in addition to the information provided in this document.

The Digital Advertising Alliance also provides an application called AppChoices that helps Users control behavioral advertising on mobile applications.

Last modified: 28 March 2022