Introduction

Italy Will srl is constantly committed to protecting the online privacy of users of its sites and all related subdomains and domains registered in the name of Italy Will srl (hereinafter, unless otherwise indicated, cumulatively the "Site").

This document ("Information") has been drawn up in order to allow you to understand how your Personal Data, as defined below, will be processed when using the Site.

The Information is aimed at providing you with the necessary information so that you can express explicit and informed consent to the processing carried out through the Site, if you deem it appropriate.

In general, any information or Personal Data that you provide to Italy Will srl via the Site, or that is collected in any other way through the Site, as part of the use of the services offered by Italy Will srl (the "Services"), as better defined below, will be processed according to the internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality.

Data controller

Italy Will srl, as identified at the beginning of the Information, is the Data Controller in relation to all Personal Data that is processed through the Site.

You can contact the Data Controller at the email privacy@italywill.com.

The personal data being processed

When you browse the Site you may communicate to us or we may collect some of your Personal Data, which - depending on the case - may consist of an identifier such as your name, an identification number, an online identifier or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity capable of making you identified or identifiable (hereinafter only "Personal Data").

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you sign up for our newsletter or when you access your Reserved Area) or simply by analyzing your behavior on the Site.

The Personal Data processed through the Site are as follows:

In various sections of the Site, you will be asked to enter information such as your name, telephone number, email address, postal address, the company you work for, etc.

Furthermore, when you communicate with Italy Will srl via the email addresses or telephone numbers found on the Site, Italy Will srl may collect additional information that you decide to freely provide.

Some sections of the Site (e.g. the information request form) include free fields in which you can provide Italy Will srl with some information, which may contain Personal Data.

Since these fields are free, you may use them to communicate (voluntarily or otherwise) some sensitive categories of Personal Data, such as data capable of revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to health or a person’s sex life or sexual orientation.

Italy Will srl invites you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data can only be processed with your explicit consent and in compliance with the legislation in force at the time. Italy Will srl therefore underlines the importance of expressing your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

As already mentioned above, in some sections of the Site you are allowed to insert text messages, visible to Italy Will srl, which may contain Personal Data of other people.

With respect to these hypotheses, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant on this point the broadest indemnity with respect to any dispute, claim, request for compensation for damage caused by treatment, etc. that should reach Italy Will srl from third parties whose Personal Data has been processed through your use of the Site’s functions in violation of the applicable personal data protection regulations. In any case, if you provide or otherwise process the Personal Data of third parties when using the Site, you guarantee from now on - assuming all related responsibility - that this particular processing hypothesis is based on the consent of such interested third party or on another suitable legal basis that legitimizes the processing of the information in question.

When we send emails, messages, phone calls or more generally communications, we use tracking systems, subject to the user’s freely given consent, such as pixels or web bacons, to detect the opening of a message, the clicks made on the hyperlinks contained within the messages, from which IP address or with which type of browser the message is viewed and other similar details.

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: except for this eventuality, data on web contacts currently do not persist for more than fifteen (15) days.

All information on the processing of Cookies can be found in the specific section accessible at the address https://italywill.com/cookiepolicy/.

Purpose of the processing

Italy Will srl uses your Personal Data, collected through the Site, for the following purposes:

  • respond to your requests for information sent via the forms or resolve any problems you may have encountered and provide you with any other Service you request (“Assistance”);
  • send you marketing communications, promotions and advertising, market research and surveys, via email, SMS, by telephone, via banner, paper mail, instant messaging, through an operator, as well as for marketing activities in the broad sense, including prize events, games and competitions, of products and/or services referable to Italy Will srl or to third parties ("Marketing");
  • to create your profile through the use of profiling cookies, where accepted, therefore collecting and analyzing information on your general activities on the Site. This profile will be used to provide you with information on other products and/or services that Italy Will srl believes may be of interest to you. All the algorithms involved in this automated or semi-automated process are regularly tested and associated with the preferences freely indicated by you to ensure that you are not offered products that are not of interest to you ("Profiling");
  • fulfill legal obligations that require Italy Will srl to collect and/or further process certain types of Personal Data (“Compliance”);
  • control the methods of use of the Site, prevent or identify any abuse in the use of the Site, or any fraudulent activity and therefore allow Italy Will srl to protect itself in court ("Abuse/Fraud");

Legal basis and nature of the processing

The legal bases used by Italy Will srl to process your Data, according to the purposes indicated above, are the following:

  • Assistance: processing for this purpose is necessary to be able to follow up on the request for assistance that arises from your free specific request by completing the form. It is not mandatory to provide Italy Will srl with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any assistance;
  • Marketing: processing for this purpose is based on your consent. It is not mandatory to give your consent to Italy Will srl for this purpose and you are free to withdraw it at any time without any consequences (except for the fact that you will no longer receive marketing communications from Italy Will srl). You can revoke your consent previously given by following the instructions in the "Rights of the interested party" paragraph;
  • Profiling: the processing for this purpose is based on your consent collected through the cookie banner. It is not mandatory to give your consent to Italy Will srl for this purpose and you are free to withdraw it at any time without any consequences. You can revoke your consent previously given by following the instructions in the "Rights of the interested party" paragraph or, as regards cookies, the instructions in the specific Cookies section (https://italywill.com/cookiepolicy/);
  • Compliance: processing for this purpose is necessary for Italy Will srl in order to fulfill any legal obligations. When you provide Personal Data to Italy Will srl, they must be processed in accordance with applicable legislation, which may involve their conservation and communication to the Authorities for accounting, tax or other obligations;
  • Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activities or abuses in the use of the Site and therefore allows Italy Will srl to protect itself in court;

Recipients of personal data

Your Personal Data may be shared with the subjects indicated below:

  • subjects who typically act as data controllers i.e:
    • people, companies or professional firms that provide assistance and consultancy to Italy Will srl in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services;
    • subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks);
  • subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers);
  • persons authorized by Italy Will srl to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of Italy Will srl);
  • company of the corporate group of which Italy Will srl is part or will be part in the future, for internal administrative and marketing purposes;
  • subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or by order of the authorities;

Transfers of personal data

Some of your Personal Data is shared with Recipients, both internal and external to the corporate group of which Italy Will srl is part or will be part in the future, who may be located outside the European Economic Area. Italy Will srl ensures that the processing of your Personal Data by these Recipients takes place in compliance with the applicable legislation. Indeed, transfers are carried out through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

Storage of Personal Data

Personal Data processed for the purpose of Assistance, Italy Will srl may retain them for a longer period, in particular as may be necessary in order to protect the interests of Italy Will srl from possible complaints relating to the Services.

Personal Data processed for Marketing and Profiling purposes will be retained by Italy Will srl until you revoke your consent; you will however be asked to renew your consent periodically. Once consent has been revoked, Italy Will srl will no longer use your Personal Data for these purposes, but may still retain them, in particular as may be necessary in order to protect the interests of Italy Will srl from possible complaints based on such processing.

Personal Data processed for Compliance purposes will be retained by Italy Will srl for the period required by specific legal obligations or applicable legislation.

The Personal Data processed for the purpose of preventing Abuse/Fraud will be kept by Italy Will srl for the time strictly necessary for the aforementioned purpose and therefore until the moment in which Italy Will srl is required to keep them to protect itself in court and to communicate said data to the competent Authorities.

Your Rights

Below you will find the list of countries in which we operate and related rights.

You have the right to ask Italy Will srl, at any time:

  • access to your Personal Data, (or a copy of such Personal Data), as well as further information on the processing in progress on them;
  • the rectification or updating of your Personal Data processed by Italy Will srl, where they are incomplete or not updated;
  • the deletion of your Personal Data from the Italy Will srl databases;
  • the limitation of the processing of your Personal Data by Italy Will srl;
  • to obtain the Personal Data concerning you in a structured, commonly used and machine-readable format;

as well as you can:

  • object to the processing of your Personal Data by Italy Will srl;
  • revoke your consent for Marketing and Profiling purposes;

You can revoke your consent to Marketing by using the appropriate link found at the bottom of each communication received, or by sending an email to privacy@italywill.com.

In any case you always have the right to lodge a complaint with the competent Supervisory Authority if you believe that the processing of your Personal Data is contrary to the legislation in force. Below are the contact details of the Guarantor for the protection of personal data:

In addition to the above, you can also exercise your rights by writing to Italy Will srl at the following address: privacy@italywill.com.

Version

Rev-25.207 del 07/02/2025