Cookies

COOKIES POLICY—WEBSITE USERS

Who are we and how do we use your personal information?

The European House – Ambrosetti S.p.A., with legal headquarters in Via F. Albani, 21 – 20149 Milan (hereinafter the Data Controller), safeguards the privacy of your personal information and guarantees that it is sufficiently protected against any action or eventuality that could jeopardize its security.

Towards this end, the Data Controller implements policies and practices involving the collection and use of personal information and the exercising of your rights as provided for in the applicable legislation. The Data Controller is responsible for updating the policies and practices adopted regarding the protection of personal information as this becomes necessary, most notably in the event of legislative and organizational changes that could impact on how your personal information is processed.

The Data Controller has appointed a Data Protection Officer (DPO) whom you can contact should you have any questions concerning the policies and practices adopted. The Data Protection Officer can be contacted at: dpo@ambrosetti.eu.

How does The European House – Ambrosetti S.p.A. collect and process your information?

The Data Controller gathers and/or receives information pertaining to you, specifically your IP address and cookies registered while navigating the www.ambrosetti.eu website. These are used by the Data Controller to manage the website and gather information in aggregate form. Your personal information is disseminated primarily to third parties and/or recipients whose activity is required for specific purposes and to meet precise legal or regulatory requirements involving the control and monitoring of work-related activities. For any dissemination which does not conform to these purposes, your consent will be requested.

Your personal information will not be disseminated to or shared indiscriminately in any form with unspecified parties.

What are cookies and what is their primary use?

A “cookie” is a small text file created by certain websites on the user’s computer when the user accesses a site for the purpose of storing and transmitting information. The cookies are sent by a web server (which is the computer on which the website visited is running) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the latter’s computer; they are then re-sent to the website during the user’s subsequent visits to the website.

Some operations could not be performed without the use of cookies, making them technically necessary in certain case. In other instances, the site uses cookies to facilitate and streamline navigation by the user or to allow the user to access specifically requested services.

The cookies can remain in the system for long periods of time and can also contain a unique identification code. This enables the websites that use them to track the navigation of the user inside the website itself for statistical or advertising purposes, in order to create a personalized profile of the user based on the pages visited and show or send him/her targeted advertising messages (known as Behavioral Advertising).

Which cookies are used and for what primary purpose?

This website uses different types of technical, non-profiling cookies.

Below, the Data Controller has provided the specific types of cookies utilized, their purpose and what happens if they are disabled.

Third party cookies

Third party cookies are also run on this website. They are cookies created by a website other than the one the user is currently visiting.

The Data Controller is required to provide the updated link to the information notices and consent forms of third parties with which specific agreements have been made for the installation of cookies via their own websites.

Specifically, we would like to inform users that this website utilizes the following services that generate cookies:

• the “Google Analytics” web analysis service provided by Google Inc. Google Analytics is a World Wide Web analysis service that utilizes “cookies” which are stored on the user computer to allow the website visited to analyze how users make use of it. The information generated by the cookie on the use of the websites visited by the user (including the IP address) is sent to Google, and deposited on the Google servers in the United States. Google will employ this information to track and analyze the use of the website by users, compile reports on website activities for website operators and provide other services concerning website activities and use of the Internet. To consult the Google privacy notice related to the Google Analytics service, and to express your consent for the use of the cookies described above, please refer to the website http://www.google.com/intl/en/analytics/privacyoverview.html or click on the following link: Privacy Policy. To disable these cookies, please click on the following link: Opt Out .
• the “ShareThis” service provided by Share This (https://www.sharethis.com/) enables the sharing of content such as news, articles and events from the website with other systems. To consult the Share This privacy notice and to express your consent for the use of the cookies described above, please refer to the website https://www.sharethis.com/privacy/.

Social buttons

The website www.ambrosetti.eu contains certain “buttons” (known as “social buttons/widgets”) which display social network icons (e.g., LinkedIn). These buttons allow users browsing the website to interact with the social networks indicated with a simple “click”. In this case, the social network acquires the data concerning the user’s visit, but the Data Controller will not share any navigation information or user data acquired through its own website with the social networks that are accessible via the social buttons/widgets.

Disabling and enabling cookies

By accessing the website and viewing the initial banner containing the short informational notices, users provide their express consent to the use of the above-mentioned cookies from third parties.

You may freely enable/disable individual cookies from your own browser (select the settings menu, click on the Internet options, open the privacy page and select the required cookie blocking level). For more information, visit the following links: Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Windows Explorer.

In addition, the Do Not Track option, found in most of the latest-generation browsers, may be activated.

Third party cookies can be disabled by consulting third party privacy policies using the links given above, or by contacting them directly. Disabling “third party” cookies does not jeopardize navigation in any way.

Secondary purposes:

1. Dissemination to third parties and recipients

Your personal information is handled on the basis of the contract and obligations, including legislated and/or regulatory on which they are dependent.

Your personal information will not be communicated to third parties/recipients for their own uses, unless:

1. you authorize it;
2. it is required to fulfill the obligations prescribed contractually or by applicable laws (for example, safeguarding your rights, etc.);

The personal information the Data Controller processes for these purposes includes:

• the IP address and cookies issued during navigation.

2. Cyber Security

Including through its suppliers (third parties/recipients), the Data Controller processes your personal, computer-related or traffic information (e.g., logical access) gathered or obtained in the case of services offered on the website that are strictly necessary and designed to guarantee the security and ability of a network or servers connected with it to resist (at a given security level) unforeseen events or illegal or criminal acts that compromise the availability, authenticity, integrity and confidentiality of the personal information stored or transmitted.

Towards this end, the Data Controller has provided for procedures to manage data breaches.

What happens if you do not provide your information?

We invite you to examine the consequences of disabling individual cookies, provided in the table above.

How

Data is processed using computerized data processing procedures by personnel within the company who have been specifically authorized and trained. They have permission to access your personal information only to the extent required to carry out the processing activity that involves you. Your information is processed separately from that of other people using pseudonymization or aggregation techniques that make identifying you difficult.

The Data Controller will verify on a regular basis the tools utilized to process your information, as well as the safety measures applied to it, which are updated constantly; verification, including through individuals authorized to process information, that no personal data not required for processing be gathered, processed, archived or stored; and verification that the information is stored so that its integrity and authenticity is guaranteed and that it is used for the purposes of the processing actually carried out.

Where

The information is stored in computer and telematic archives located within the European Economic Area.

For how long

Please refer to the personal information storage terms as provided in the table above.

What rights do I have?

In essence, at any time, free of charge and without any special procedures for making the request, you can:

• obtain confirmation about how the Data Controller processes information;
• access your personal information and know the origin (if the information was not supplied by you directly), the goals and objectives of processing, information regarding who the information has been shared with, how long your information is stored or criteria relevant for determining this;
• update or correct your personal information so that it remains accurate and current;
• cancel your personal information from the data banks and/or archives, including the Data Controller’s back-up archives if, for example, it is no longer required for processing purposes or if it becomes unlawful as provided for by law; and, in any case, if the processing is not justified by any other equally-legitimate motive;
• limit processing of your personal information under some circumstances, for example, if you have contested its veracity, for the time required by the Data Controller to verify its accuracy. You must be informed, within a reasonable period of time, even when the period of suspension has lapsed or the reason for limiting processing no longer pertains, and therefore the limitation has been revoked;
• obtain your personal information if received or processed by the Data Controller with your consent and/or if it has processed the information on the basis of a contract and using automatic methods in a computerized form including for sharing it with another processing entity.

In this case, the Data Controller must proceed immediately and, in any case, no longer than one month from receiving your request. If necessary, this deadline may be extended by two months if necessitated by the complexity and number of requests received by the Data Controller. In such situations, within a month of receiving your request, the Data Controller must inform you and provide the reasons for the deadline extension.

For further information or to send your request, please write to the Data Controller at: privacy@ambrosetti.eu.

How and when can you object to the processing of your personal information?

For reasons inherent to your personal situation, you may, at any time, object to the processing of your personal information if it is based on legitimate interests, by sending your request to the Data Controller at:  privacy@ambrosetti.eu.

You have the right to cancel your personal information if there are no overriding legitimate grounds for the processing.

How can I lodge a complaint?

Without prejudice to any other administrative or judicial action, you may lodge a complaint to the relevant authority operating and with jurisdiction in Italy where you regularly reside or work, or if different from the member state in which the violation of Regulation (EU) 2016/679 occurred.

Any amendment to this Privacy Policy will be communicated in a timely and appropriate manner. Similarly, you will be informed if the Data Controller undertakes to process your information for purposes other than those indicated in this policy before the processing occurs and in time for you to give your consent, if required.

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