Privacy Notice

Last updated: November, 15^th 2024

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.a121.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 website www.a121.com is Active121 srl with headquarters in Via Cal Lusent, 23/8 – 31040 Pederobba (TV) - Italy.  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.

Purposes of processing, Legal basis and Retention Period 

Personal data voluntarily provided through forms on the website will be processed for the following purposes:

1. Responding to a commercial enquiry, following up on your requests
   Legal basis: Contractual obligations (pre-contractual)
   Retention period: 6 months
2. Newsletter subscription
   The newsletter service is ongoing, and users subscribe to a recurring service whose sending frequency may vary. Currently, the newsletter service is provided in Italian language.
   Legal basis: Consent
   Retention period: Until withdrawal
3. Website navigation: website technical management
   Legal basis: Contractual obligations for the provision of services requested by you through the website.
   Retention period: as strictly required under applicable law.

Type of data processed and methods of collection

Navigation data – log file (automatically collected)

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 GetResponse S.A. 

Purposes: managing contacts and sending messages, managing online formative webinars
Personal data collected: name, email
Place of processing: Poland, or other countries of the European Economic Area
Privacy Policy

Google Tag Manager

These services facilitate the centralized management of tags or scripts used on this website. Using these services results in user data flowing through them and, if applicable, being retained. Google Tag Manager is a tag management service provided by Google LLC or Google Ireland Limited, depending on how the Controller manages the processing of data.
Personal Data Processed: Tracking Tools
Place of processing: USA – Privacy Policy; Ireland – Privacy Policy.
Legitimacy for transfer: EU-US Data Privacy Framework adequacy decision

Google Analytics 4
Google Analytics is a statistical analysis service provided by Google LLC or Google Ireland Limited, depending on the user's location. Google uses personal data collected to track and examine the use of this site, compile reports, and share them with other Google services. Google may use personal data to contextualize and personalize ads in its advertising network. This integration anonymizes the user's IP address by shortening it within member states of the European Union or other countries adhering to the European Economic Area Agreement. In exceptional cases, the IP address will be sent to Google's servers in the United States and shortened there.
Personal Data Collected: Cookies, Usage Data
Processing location: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Legitimacy for transfer: EU-US Data Privacy Framework adequacy decision

Trust Guardian
This website interfaces with Trust Guardian, the consent management platform developedby A121 (Active121 srl). When you fill out a contact form on this website, information regarding the consents or authorizations of processing you granted, and acknowledgements of privacy notices, is sent to Trust Guardian.
Specifically, when completing any form on this website,e Trust Guardian collects and stores following personal data of yours:
• Email
• IP address
• Date and time of form submission
• The website and webpage from which you filled the form.
Hosting: Italy

Optional provision of data

Apart from what is specified for navigation data, the provision of personal data by the data subject 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.

Data processing methods

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, illicit 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 dissemination will take place only after your explicit 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 minors. If information about minors is unintentionally recorded, the Data Controller will delete it promptly, upon user request.

Special categories of data

This website does not process special categories of data. 

Data subject rights

"Data subjects," meaning natural persons, legal persons, entities, or associations, to whom the data refer, have the right, at any time, to obtain confirmation of the existence of such data and to know its content and origin, verify its accuracy, or request its integration, updating, or correction pursuant to EU Regulation 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Data Subject Rights.
Pursuant to the same articles, data subjects also have the right to request erasure, anonymization, or blocking of data that have been processed unlawfully, as well as to object to their processing for legitimate reasons. Any communications can be sent to the following email address: privacy@active121.com 

• Right to rectification: Contact us directly to modify or correct your data.
• Right to erasure: Send us a request to delete all data concerning you, and we will process your request within 30 days. • Right to data portability: If requested, 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 specific uses we make of your data (newsletters, automatic emails, etc.).
• Right of access: We are transparent regarding the data we collect and how we use it. You can contact us at any time to access the information we hold and request modifications.
• Right to withdraw consent: You can withdraw your consent at any time. To withdraw consent for the newsletter, you can click the unsubscribe link in the footer of each newsletter you receive, or you can write to us at privacy@active121.com to request consent withdrawal.
• Right not to be subject to automated decision-making
• Right to lodge a complaint with the data protection authority: In cases provided by the Privacy Regulation, you can lodge a complaint directly with the Data Protection Authority: Website www.garanteprivacy.it – Email: protocollo@gpdp.it

ADDENDUM

1. Statistical data processing joint controller with Meta
For Facebook Pages, Meta 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 Meta Platforms Ireland Limited (“Meta 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 Meta’s data policy and find, among other things, the following information:
• What types of information Meta collects
• How Meta uses this information
• How this information is shared
• Legal bases for data processing
• How to exercise your rights under the GDPR
• Contact details of Meta Ireland for data protection issues
• Contact details of the Data Protection Officer for Meta 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.

X
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.

Company information

Active121 s.r.l. – Company managed by Sole Director – Via Cal Lusent, 23/8 – 31040 Pederobba (TV) – F.C. / VAT Registration Number/ Reg. Impr. TV n. 03755420266 – R.E.A. TV 295897 – Fully paid up Share Capital Euro 12.000. – Certified E-mail: amministrazione@pec.active121.com