Privacy Policy & Cookies

This Privacy Policy describes the management of this Site, with reference to the use of cookies and the processing of personal data of users/visitors who consult it. The provided notice is pursuant to the EU Privacy Regulation - GDPR 2016/79, as well as the articles 13 and 122 of the Code regarding the protection of personal data (Legislative Decree 196/03, the so-called Privacy Code, as long as in force), of the General Provision of the Guarantor of 8 May 2014 concerning cookies, to those who connect to the H2O Pvt. site.

The information provided is for the site mentioned above, solely (hereinafter "Site" or "this Site"), with the exception of other websites that may be consulted by the user through various links available. The indicated Site is owned and managed by H2O Pvt., which guarantees compliance with the regulations regarding the protection of personal data, in line with the provisions of current regulations.

Users/visitors are encouraged to read this Privacy Policy carefully before submitting any type of personal contact and/or reading articles or circular letters present and/or filling in an electronic form on the Site.

Type of data processed and the purpose of the processing

1.Navigation data

The computer systems and software procedures used to operate this Site acquire, during normal operations, some personal data that are implicitly transmitted in the use of Internet communication protocols.

This information is not collected to be associated with identified interested parties, but due to its nature could, through processing with data held by third parties, allow identification of users/visitors (e.g. IP address, domain names of computers used by users connected to the Site, the code indicating the response status given by the server, type of browser, etc.).

These data are used only for statistical information (therefore, anonymous) and to check the proper functioning of the Site. The data on web contacts are not stored over six months, except for any investigation of computer crimes against the Site itself.

No data deriving from the web service will be communicated or disseminated.

2. Cookie

1. General information about cookies

Cookies are small-text-files that the websites visited by users send to their terminals (usually to the browser), where they are stored before being re-transmitted to the same sites at each subsequent visit via the same terminal. In addition, each site may allow the transmission of so-called "third-party" cookies, i.e. those generated by internet sites other than the ones the user is visiting (through objects available such as banners, images, maps, sounds, links to web pages of other domains).

Depending on their duration, they can be divided into session cookies (temporary and automatically deleted from the terminal at the end of the browsing session, by closing the browser), and persistent cookies (those that remain stored on the terminal until their expiration or cancellation by the user).

Cookies have different purposes. They are primarily used for the transmission of communication or to provide the service requested by the user; more precisely, they allow to enable and optimize operations of the website, perform IT authentication and prevent abuse, monitor sessions, improve the browsing experience of users, by, for example, keeping the connection active to restricted areas while browsing through the pages of the Site without the need to re-enter User-Id and password, storing specific information about the users themselves (including preferences, type of browser and computer used).

The aforementioned cookies are called technical (for which the user's consent is not necessary) as without them some of the above operations could not be completed or would be more complex and/or less secure.

Otherwise, if cookies are used for further purposes, typically for behavioural analysis and sending personalized advertising messages (so-called profiling cookies) or to obtain, through third-party services, information in aggregated form on the number of users and how they visit the Site (so-called analytics cookies), for which the user's consent is required. In fact, before sending these cookies on the terminal, in accordance with current legislation (EU Privacy Regulation - GDPR 2016/79 - Privacy Code and general provision of the Guarantor of 8 May 2014), when you access the home page or other pages of the Site, a banner with an initial brief information on the use of cookies and consent appears immediately in a foreground window, which the user can consult continuing browsing by scrolling down the banner, or close the banner.

In any case, cookies can be read or modified only by the website that generated them; they cannot be used to retrieve any data from the user's terminal and cannot transmit computer viruses.

Some of the cookies' roles can also be performed by other technologies; therefore, in the context of this web privacy policy, the term "cookies" refers to cookies and all similar technologies.

2. Use of cookies on this Site

This site may use session cookies and persistent cookies. The type of cookies generated by this Site are technical cookies, used for:

a) the authentication and management of a browsing session (for example, to identify and validate the user for the access to Reserved Area);

b) security purposes (e.g. to register the number of failed log-in, identifying possible abuse in authentication and preventing fraud);

c) a better usability of the Site and its audio-visual contents (e.g. through the execution of flash player programs);

d) the correct functioning of the connection (e.g. by routing the user's requests in more than one server)

3. Third-party cookies

This Site allows transmission to the user's terminal of third-party cookies, which H2O Pvt. is connected with. H2O Pvt. limits itself, as a technical intermediary, to send these cookies, but it does not manage their operations (it does not, therefore, have control and access to the information provided/acquired) as their functioning is the responsibility of the third parties. Thanks to these cookies, you can access to the notes and third-party consent acquisition forms, by clicking on the links below.

The third parties are the availed subjects whose services H2O Pvt. use to collect gathered information/statistics on the users who visit this Site.

3. Management of cookie choices

Cookies can be managed by the user through their browser.

A) Browser settings

The user can manage their cookie preferences through the settings of the common browsers (Internet Explorer, Mozilla Firefox, Google Chrome, Apple Safari), which allow to delete/remove cookies (all or some) or to change the settings of the browser to block the sending of cookies or to limit it to specific sites. It is possible to configure the browser settings (normally accessible from the tool bar) by going to the Support web pages of the aforementioned browsers (also reachable through a common search engine). Disabling cookies does not preclude the usage of the services of the Website itself; however, if all cookies were deleted/blocked, including technical cookies, some operations could not be performed or would be more complex and/or less secure, for example, for the execution of activities within the Site (cookies allow to implement and maintain user's identification during the session).

4. Data provided voluntarily by users/visitors

Whenever users/visitors send their personal data, by connecting to this site, to access and request certain services and information, or to make requests by e-mail, this implies obtaining the sender's address (and/or any other personal data) by H2OPvt. which will be processed exclusively to respond to that request, or for the provision of the service. Personal data provided by users/visitors may be communicated not only to all subjects whose right to access such data is recognized by law or secondary legislation, but also to external subjects who perform functions related to the activity of H2O Pvt., to data processing companies and business consultants, only if the communication is necessary to comply with the requests of the users/visitors. Any dissemination and communication of the data will, however, always be within the limits, for the purposes and with the modalities hereunder reported.

Purposes and methods of treatment

Pursuant to the EU Privacy Regulation - GDPR 2016/79 of Legislative Decree no. 196/2003 on the protection of persons and other subjects regarding processing of personal data, the processing of information is based on principles of correctness, lawfulness, transparency and protection of privacy and rights of the subject in question.

Data processing refers to the collection, registration, storage, communication, dissemination, extraction, comparison, the use i.e. combination of two or more of such operations.

Pursuant to the EU Privacy Regulation - GDPR 2016/79 and the article 13 of Legislative Decree no. 196/2003, we inform you that the data gathered will be processed solely for the reasons linked to the activity of H2O Pvt. and to the legal obligations, accounting purposes and tax obligations; compliance with contractual obligations, or to answer services requested; information on news in the business sector of H2O Pvt.

The personal data provided by the user of the site are treated, as part of the normal activity of the owner, according to the following purposes:

  • purposes strictly connected and instrumental to the management of each phase of acquisition process and any fulfilment deriving from any contract. Failure to provide, even partially, the above prevents the execution of the request, in particular, the establishment and/or continuation of contractual agreements. For these purposes prior consent is not required, since the processing is compulsory to have personal data for the execution of a contract of which the person concerned is a party or for the execution of specific requests, is legitimised;
  • purposes related to the obligations established by laws, regulations, community legislation, as well as by instructions issued by the Authorities to do so after signing a contract with H2O Pvt. For these purposes, prior consent is not required, since the data processing is needed to fulfil legal obligations to which the Data Controller is subjected. The processing of personal data is performed manually, computerized or by electronic devices, strictly related to own purposes, to ensure the security and confidentiality of the data, when using both traditional or innovative tools.

The potential treatment of so-called sensitive personal data will be carried out within the limits and in the forms provided for by the General Authorization of the Guarantor no. 4/2004, in compliance with all applicable provisions of the law.

The methods of processing data of the user/visitor may include the use of manual and automatic tools suitable for its processing, based on qualitative, quantitative and temporal criteria. The data can be entered in electronic devices and can be processed automatically.

Optional provision of data

Apart from navigation data, users/visitors are free to provide their personal data. Failure to provide such data may entail the impossibility of obtaining what has been requested or establishing any negotiation or professional relationship, for which the acquisition of such data is essential.

Owner, Managers and Representatives

The Data Controller is H2O Pvt. with registered office in Italy, Genoa, via Dante 2-142, Palazzo della Borsa, Post Code 16121, Vat No. IT01947740997 (www.h2osrl.org). The Manager is the Sole Director Ms Simona Corsini. Within H2O Pvt. the data of users/visitors/interested parties may be processed by employees and collaborators, who act as Managers under the direct authority of the data controller. Without prejudice remains the right of the Data Controller to appoint a DPO and the subsequent revocation. Specific details can be asked to the Data Controller by each interested party.

Data transfer abroad

For some activities, always in the interest of the interested party, H2O Pvt. could use trusted subjects - operating sometimes outside the European Union - that perform on behalf of H2O Pvt. technical, organizational, management or assistance tasks and advice. In this case, the transfer of data will take place on the basis of current legislation (Chapter V - Transfer of personal data to third countries or international organizations of GDPR), including the application of standard contractual clauses defined by the European Commission for transfers to third-party companies or verification of the adequacy judgement of the personal data protection system of the importing country.

Data retention time

The collected data are kept for the time strictly necessary for the fulfilment of the purposes for which they were collected, in compliance with limitation period or the different periods established by law for their conservation or for a longer time, in case it is necessary to keep them for the protection of the rights of the owner. Specific details can be enquired from the Data Controller by each interested party.

Rights of the interested parties

Users/visitors can access the data concerning them at any moment and exercise their rights (requesting the origin of data, their correction, updating or integration of inaccurate or incomplete data, as well as their cancellation, portability or blocking in violation of the law, or oppose their use for legitimate reasons) provided by the EU Privacy Regulation - GDPR 2016/79 together with the Article 7 of the Privacy Code, by writing to: info@h2osrl.org.

in particular the right to:

  • access, or confirmation/denial of the existence of personal data collected by H2O Pvt., to know the origin, as well as the approach and purposes on which the treatment is based, the recipients or categories of recipients to whom the data can be communicated and, if possible, the definition of retention period;
  • correct inaccurate data;
  • cancel ('right to be forgotten'), when data are no longer necessary regarding the purpose of their collection and their subsequent processing, or in the case of withdrawal of consent to their processing (where such consent is provided as optional or there is no other legal basis for treatment);
  • portability, the right to receive personal data of the interested party in a structured, commonly used and readable form by an automatic device with the possibility of transmitting them to another Data Controller. This right does not apply to non-automated treatments (for example archives and paper records); furthermore, only data processed with the data subject's consent are subjected to portability and only if the data are supplied by the data subject;
  • objection, the right to oppose the processing for reasons connected to a particular situation of the interested party, including the right to object to the processing of personal data for the purpose of sending advertising material or newsletters, direct sales or for carrying out market research or receiving commercial communication;
  • complaint, to be sent to the Guarantor for the Protection of Personal Data, piazza di Monte Citorio no. 121 - 00186 Rome (garante@gpdp.it); + 39 06696771; fax + 39 06696773785).
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