Privacy Notice

Updated: 18/11/2021

We understand the importance of protecting personal data and consider its protection to be one of the main objectives of our business. Please read this privacy notice carefully before providing us with any personal data.

This privacy policy is intended for:
• The website www.active121.com
• The website www.privacyos.com
• Facebook page www.facebook.com/Active121
• LinkedIn page www.linkedin.com/company/active121

but not for other external websites that the user may consult via links.
This information is provided pursuant to Article 13 EU Regulation No. 2016/679 (hereinafter, “GDPR”) to users interacting with the websites and social network pages mentioned above.
Additional information may be provided within the different access channels, subdivided on the basis of the topics covered. Other information may be provided within the website in relation to specific services.

Data controller

The data controller of data relating to identified or identifiable persons who have consulted the sites www.active121.com and www.privacyos.com, is Active121 srl with headquarters in Via Cal Lusent, 23/8 – 31040 Pederobba (TV). It can be contacted at privacy@active121.com.
With regard to the Facebook page https://www.facebook.com/active121, Active121 is joint controller of the statistical data processing together with Facebook Ireland Limited (“Facebook Ireland”).

Data Protection Officer (DPO)

The Data Protection Officer (DPO) designated by the Data Controller pursuant to Article 37 of the GDPR is PROATTIVA di Valentino Pavan, in the person of Valentino Pavan, VAT no. 04773210267, who can be contacted by e-mail at dpo@proattiva.eu.

Lawfulness of Processing

The processing of personal data is carried out on the legal basis of the consent expressed by the data subject for one or more specific purposes. (ref. Art. 6 paragraph a) of the GDPR).

Purpose of processing

The personal data voluntarily provided will be processed for the following purposes:
• Responding to a commercial enquiry, following up on your requests
• Sending newsletters
• Browsing the websites and social pages mentioned on this page
• Interaction with social networks
• Registering for online formative webinars
• Send event information, to provide you with information and materials related to the event you have registered for.

Type of data processed and methods of collection
Navigation data – log files

It is possible to access the website without the user being asked to provide any personal data. During normal operation, the computer systems and applications dedicated to the operation of this website collect certain data (the transmission of which is implicit in the use of Internet communication protocols) that are not associated with directly identifiable users. The data collected include the IP addresses of the users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request and the numerical code indicating the status of the response given by the server (successful, error, etc.).
These data are processed for the time strictly necessary in accordance with the law in force and could be used to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the site.

Data provided voluntarily by the user

The voluntary and explicit sending of electronic mail to the addresses indicated in the various access channels of this site entails the subsequent acquisition of the sender’s/user’s address and data, which are necessary in order to respond to the requests made and/or provide the service requested. We assure, however, that such processing will be based on the principles of fairness, lawfulness and transparency and protection of confidentiality as indicated in the GDPR. In particular, the newsletter service involves the acquisition of your name and e-mail address.

Specific functions and services

GetResponse is an email marketing platform and online webinar management service provided by Implix Sp. z o.o.
Purposes: managing contacts and sending messages, managing online formative webinars
Personal data collected: name, email
Place of processing: Poland
Privacy Policy

Google Analytics with anonymized IP
Google Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on where this website is used (“Google”).
Google uses the personal data collected for the purpose of evaluating your use of this website, compiling reports and sharing them with other services provided by Google.
Google may use Personal Data to contextualise and personalise ads in its advertising network.
This Google Analytics integration makes your IP address anonymous.
The anonymisation works by shortening the IP address of the users within the borders of the member states of the European Union or other countries which are parties to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google’s servers and shortened within the United States.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

PrivacyOS
This site is interfaced with PrivacyOS, Consent Management software. The personal data you submit to this site when filling out the Contact and Demo Request forms is stored securely in PrivacyOS, together with information relating to the consents you have given for the processing of your data.
In particular, when you fill in these forms on the site, the PrivacyOS software stores the following data (in addition to the data you enter in the form):
• IP address
• Date and time of form completion
• Size of data packet sent
• The website and/or web page from which the request is made
• User-agent of the browser (e.g. browser version, operating system, and other technical information about your browser)
PrivacyOS is a solution by Active121 Srl.
Hosting: Italy

Facebook Remarketing
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that links the activity of this Website with the Facebook advertising network in order to be able to provide you with relevant advertisements on the Facebook network based on the content you have shown interest on this website.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy – Opt Out.

Linkedin Website Retargeting
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that links the activity of this Application with the LinkedIn advertising network.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy – Opt Out.

Linkedin Events
In order to confirm your attendance at our Linkedin Events, you will be asked to fill in a standard Linkedin registration form which is pre-filled with your Linkedin profile data.
The form requires the following information:
– Name
– Surname
– E-mail address
– Professional title
– Company
– Country

The information in this form is all mandatory, and is required in order to confirm your presence in the Linkedin event tab.
We will use this information to send you information related to the event you have registered for (for example: reminder of the event, reminder to complete your event registration, …)

Linkedin Conversion Monitoring
LinkedIn’s conversion tracking is a statistical service provided by LinkedIn Corporation which links data from the LinkedIn ad network with actions taken within this Application.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy.

Remarketing Google Ads
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Inc. which links the activity of this website with the Google Ads advertising network and the DoubleClick cookie.
Users may opt out of the use of Google cookies for ad customisation by visiting Google’s Ads Settings.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy – Opt Out.

Monitoring of Google Ads conversions
Google Ads conversion tracking is a statistical service provided by Google Inc. which links the data from the Google Ads network with the actions performed within this website.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy

Google Tag Manager
Google Tag Manager is a tag management system for the collection of statistical data provided by Google. Inc. collects information on the use of the website by the users.
Personal data collected: Cookie; Usage data.
Place of processing: United States – Privacy Policy

Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects generic ‘Do Not Track’ headers. This means that the browser can instruct the script not to collect any user data. This is a setting that is available in all major browsers.
More Information on opting out of Hotjar is available here.
Personal Data processed: Usage Data; Tracking Tool; various types of Data as specified by the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.

Liidio Oy/Leadfeeder
Leadfeeder is a tool that shows the owner of this website the companies that visit the website, the source of acquisition and the pages they visit. The tool does not uniquely identify the people who visit the website, but the name of the company from which the visit comes. The purpose of the processing is Statistics & Remarketing & Behavioral Targeting.
Personal data collected: Web analytics data, Names of client companies and potential clients, IP addresses.
Place of processing: EU and non-EU, including but not limited to USA – Privacy Policy

Optional provision of data

Apart from that specified for navigation data, the provision of personal data by the interested party for the purposes described in the preceding paragraph is optional. Failure to provide such data may make it impossible to use certain services provided by the website.

Modalities of Data Processing

Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they are collected in accordance with the principles of lawfulness, purpose limitation and data minimization, pursuant to Article 5 of the GDPR and in compliance with the mandatory time limits prescribed by law. Specific security measures are observed to prevent data loss, unlawful or incorrect use and unauthorised access.

Communication and/or Dissemination of Data

Your personal data, the object of the processing, will not be disseminated but may be communicated to companies contractually linked to Active121, in accordance with and within the limits of the GDPR.
Personal data may be communicated to third parties belonging to the following categories:
• subjects who provide services for the management of the information system used by Active121 and the telecommunications networks (including electronic mail);
• firms or companies in the context of assistance and consultancy relationships;
• competent authorities to fulfil legal obligations and/or provisions of public bodies, upon request.
The subjects belonging to the above mentioned categories perform the function of Data Processors, or they operate in total autonomy as separate Data Controllers. The Data Processors list is constantly updated and available at the head office of Active121 srl. Any further communication or diffusion will take place only after your explicit consent.

Data Retention Period

The retention period for data collected with the contact request form and the webinar registration form is strictly limited to the time necessary to follow up on the need that the user is expressing with his request, on how the business relationship will evolve as a result of the contacts and in any case not longer than 6 months from the last expression of interest by the user.
If you register for a webinar by filling in the webinar form, you will then be notified of your webinar participation details by email.
The service offered with the newsletter is continuous and therefore the user with his consent subscribes to a recurring service whose frequency may vary. For this reason, the personal data sent with the newsletter subscription form will be processed until the user revokes his consent.

Possible existence of an automated decision-making process

The Data Controller informs the Data Subject that there is no automated decision-making process on this website, so in particular there is no profiling system.

Minors

This Site and the Data Controller’s Services are not intended for children under the age of 16, and the Data Controller does not knowingly collect personal information from children. In the event that information about minors is unintentionally recorded, the Data Controller will delete it in a timely manner upon the request of users.

Rights of data subjects

The ” Data Subjects “, i.e. natural persons, legal persons, bodies or associations, to whom the data refer have the right, at any time, to obtain confirmation of the existence or otherwise of such data and to know its content and origin, verify its accuracy or request its integration or updating, or rectification pursuant to EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Rights of the Data Subject. Pursuant to the same articles, data subjects also have the right to request the deletion, transformation into anonymous form or blocking of data concerning them, processed in violation of the law, and to oppose in any case, for legitimate reasons, their processing.
Communications can be sent to the following e-mail address: privacy@active121.com

• Right of rectification: contact us directly to have your data modified or rectified.
• Right to erasure: Send us a request to erase all data concerning you and we will process your request within 30 days.
• Right to data portability: if you request it, we will export your data so that it can be transferred to third parties.
• Right to object: you can unsubscribe at any time from all the specific uses we make of your data (newsletters, automated emails, etc.).
• Right of access: We are transparent about the data we collect and how we use it. You can contact us at any time to access the information we hold and request changes to it.
• Right to restriction: you can ask us to suspend the processing of your data if there are legitimate reasons.

ADDENDUM
1. Statistical data processing joint controller with Facebook

For Pages, Facebook offers Page Insights, a function that provides aggregated data to help understand how people interact with Facebook Pages.
With regard to the Facebook page https://www.facebook.com/active121, Active121 is joint controller of the statistical data processing together with Facebook Ireland Limited (“Facebook Ireland”).
In this link, it is possible to consult the appendix on the data controller for Facebook Page Insights, which indicates the division of responsibilities of Facebook Ireland and Active121 as administrator of the page www.facebook.com/Active121.
On this page you can consult Facebook’s data policy and find, among other things, the following information:
• What types of information Facebook collects
• How Facebook uses this information
• How this information is shared
• Legal bases for data processing
• How to exercise your rights under the GDPR
• Contact details of Facebook Ireland for data protection issues
• Contact details of the Data Protection Officer for Facebook Ireland
• Facebook visitor’s rights under the GDPR
• Data retention period
On this page you can find the Facebook cookie policy.

MORE INFORMATION ON THE SOCIAL CHANNELS OF ACTIVE121

LinkedIn
Active121 manages the LinkedIn page at https://www.linkedin.com/company/active121/.
On this page e also on this one, you can consult LinkedIn’s privacy policy.
On this page you can view LinkedIn’s cookie policy.

YouTube
Active121 operates the YouTube channel which can be found at https://www.youtube.com/user/Active121Web.
On this page you can view the privacy policy of Google, of which YouTube is a part.
On this page you can view the cookie policy of Google, of which YouTube is a part.

Twitter
Active121 manages the Twitter account which can be reached at https://twitter.com/Active121.
On this page you can view Twitter’s privacy policy.
On this page you can view Twitter’s cookie policy.

Pinterest
Active121 manages the Pinterest account at https://www.pinterest.it/Active121/.
On this page you can view Pinterest’s privacy policy.
On this page you can view Pinterest’s cookie policy.

Instagram
Active121 manages the Instagram account which can be found at https://www.instagram.com/active121/.
On this page you can view Instagram’s privacy policy.
On this page you can view Instagram’s cookie policy.