Extended information on Cookies
Browsing this website involves the sending of cookies and similar tools to the user’s terminal.
Therefore, as required by European Regulation 679/2016, SP CAPITAL in the person of its legal representative pro tempore, data controller, (indicated as “Data Controller”), provides users with information relating to the cookies or similar systems used or which installation is permitted.

What are cookies.

The Service Group Italy website (the “Site”) uses cookies to make its services simple and efficient for users who view its pages. Users who access the Site will see minimal amounts of information inserted into the devices in use, whether computers or mobile devices, in small text files called “cookies” saved in the directories used by the user’s web browser. There are various types of cookies, some to make use of the Site more effective, others to enable certain features.

The Site uses exclusively “technical” cookies, such as navigation or session cookies, functionality cookies and analytical cookies.

• – Browsing or session cookies
  Specifically, navigation or session cookies are used , directed to ensure normal navigation and use of the website, and therefore aimed at making functional and optimizing the same navigation within the site.– Functionality cookies
  In addition, functionality cookies are installed, which are strictly necessary to provide services explicitly requested by the user.

  – Analytical cookies
  Finally, there are analytics cookies, used exclusively by the Site operator, to collect information, in aggregate and anonymous form, on the number of users and how users visit the site.

  – Profiling cookies
  The Site uses its own profiling cookies , i.e. cookies aimed at creating user profiles, in order to send advertising messages based on the preferences expressed by individual users when browsing the web within the Site.

  Third-party cookies
  – Analytics cookies from third-party services.
  These cookies are used in order to collect information about users’ use of the Site anonymously such as: pages visited, time spent, source traffic origins, geographic origin, age, gender and interests for the purpose of marketing campaigns. These cookies are sent from third-party domains external to the Site.

• – Cookies to integrate third-party software products and functions
  This type of cookie integrates functionality developed by third parties within the pages of the Site such as icons and preferences expressed in social networks for the purpose of sharing site content or for the use of third-party software services (such as software to generate maps and additional software offering additional services). These cookies are sent from third-party domains and partner sites that offer their functionality between the pages of the Site.– Profiling cookies
  These are the cookies sent by third parties, through the Site, necessary to create user profiles in order to send advertising messages, by the same third parties, in line with the preferences expressed by the user.

  For third-party cookies: ……………. [it is necessary to indicate the specific third parties – see point 4.2 of the general measure], the user can check the information and request for consent at the following links

• Installing/uninstalling cookies. Browser options
  You may object to the recording of cookies on your device by configuring the browser used for browsing: if you use the Site without changing your browser settings, it is assumed that you intend to receive all the cookies used by the Site and enjoy all the features.Please note that the user can prevent the use of some or all of the cookies described above by configuring the browser used for browsing, namely ……………………………

  [for the main browsers, report the links to the page dedicated to cookies and to the instructions for their disabling or enabling prepared by the browsers themselves, with an indication of this type]: “To disable or enable cookies of the browser …., click here” [example of link for internet explorer: Internet Explorer: http://windows.microsoft.com/it-IT/windows7/Block-enable-or-allow-cookies; Mozilla Firefox:http://support.mozilla.org/it/kb/Bloccare%20i%20cookie?redirectlocale= enUS&redirectslug=Blocking+cookies]

  • • • Extended information on the protection of personal data
        Disclosure pursuant to Article 13 of Legislative Decree 196/2003 and the EU General Data Protection Regulation EU 2016/679 (GDPR) The privacy of our users is very important, which is why we are committed to protecting and safeguarding the personal data each user provides to us.
        This Policy therefore serves to explain in detail how this site uses and handles personal data.Data Controller
        The Data Controller is SP CAPITAL in the person of its legal representative pro tempore, Esseppi Capital CO. L.L.C. – License no. 1351790 Membership no. 533193 – Registration no. 2295446, based in Via Chiana, 38 – 00198 – Rome (RM) – IT. Holder’s email address: info@esseppicapital.com

        Data processed, Purposes and Legal Bases of the Treatment

    • Data generated by accessing the site:
      In order to enable the proper computer operation of this site, certain Personal Data are acquired independently or through third parties, including: Cookies, Usage Data, IP addresses, operating system, time, type of device and browser used to connect to the web, email, first name, last name, username, unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example), geographic location and language.
      Then, it should be pointed out that the collection of the aforementioned data does not allow in a direct way to trace the identity of our users as they are used to obtain anonymous statistical information on the use of the site itself, to control its correct functioning and to ascertain responsibility in case of hypothetical computer crimes.
      The legal basis legitimizing these processing of such data is the need to make the site’s functionalities usable following user access.
      The full details of each type of data collected can be consulted in the dedicated sections of this privacy policy or by means of specific informative texts displayed prior to the collection of such data.
      Please also note that Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this website.
      Unless otherwise specified, all Data requested by this site are mandatory, so if the User refuses to provide them, it may be impossible for this website to provide the Service.
      If this site indicates certain Data as optional, Users have the option not to communicate such Data, without this having any consequence on the availability of the Service or its operation.
      Users who are in doubt as to which Data are mandatory are invited to contact the Data Controller.
      Any use of Cookies – or other tracking tools – by this Site or the owners of third party services used by this Site where not otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy.
      The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to communicate or disseminate it, releasing the Owner from any liability towards third parties.

    • Legal basis of processing:
      The Controller processes Personal Data related to the User if one of the following conditions exists:
      – the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
      – the processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
      – the processing is necessary for the performance of a legal obligation to which the Controller is subject;
      – processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
      – the processing is necessary for the pursuit of the legitimate interest of the Controller or third parties.
      However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

      Mode and place of processing of collected Data

    • Method of processing:
      The data collected will be processed by means of electronic or otherwise automated, computerized and telematic instruments, or by means of manual processing with logic strictly related to the purposes for which the personal data were collected and, in any case, in such a way as to ensure the security of the same. The data are kept for the time strictly necessary to manage the purposes for which the data are collected in compliance with current regulations and legal obligations. In any case, the Owner practices rules that prevent the retention of data indefinitely and thus limits the retention time in compliance with the principle of minimization of data processing
      The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
      The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes.

      In addition to the Data Controller, in some cases, other subjects involved in the organization of this Site (administrative, sales, marketing, legal, system administrators personnel) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

      Location
      The Data are processed at the Data Controller’s operational offices and at any other location where the parties involved in the processing are the Data Controller.
      The User’s Personal Data may be transferred to a country other than the country where the User is located. To obtain more information about the location of the processing the User refer to the section on details about the processing of Personal Data.
      The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

      Should any of the transfers just described take place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting it at the contact details given at the beginning.

      Period of Data Retention
      The Data are processed and stored for the time required by the purposes for which they were collected.
      Therefore:
      – Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
      – Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
      When the processing is based on the User’s consent, the Controller may keep the Personal Data longer until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
      At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

      Purposes of the Data collected
      User Data is collected to enable the Data Controller to provide its Services, as well as for the following purposes: Interaction with social networks and external platforms, Statistics, Address Management, Social Features, Advertising, Commercial Affiliation, Remarketing and behavioral targeting, Displaying content from external platforms, Accessing accounts on third party services and Traffic optimization and distribution.
      To obtain further detailed information on the purposes of processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.

      Cookies
      The site makes use of cookies as better specified in the appropriate policy, to which please refer to the following page: Cookie Policy.

      Data voluntarily provided by the User
      In the presence of specific consent, personal data provided by the user through forms are collected and processed for the following purposes:
      1 In the case of sending job applications, for personnel selection purposes.
      2 Interaction with social networks;
      3 Statistics;
      4 Advertising;
      5 Displaying content from external platforms;
      6 Access to accounts on third-party services;
      7 Traffic optimization and distribution.

    • To obtain further detailed information on the purposes of processing and the Personal Data concretely relevant for each purpose, the User may refer to the relevant sections of this document.Contacting the User
      Contact Form
      The User, by filling out the contact form with his/her Data, consents to their use to respond to requests for information, or of any other nature indicated by the header of the form.
      Personal Data collected: first name, last name, and email.

    • User Rights
      Users may exercise certain rights with respect to the Data processed by the Data Controller.
      In particular, the User has the right to:
      – Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his/her Personal Data.
      – object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
      – access to one’s own Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
      – verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
      – obtain restriction of processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
      – Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
      – Receive their Data or have their Data transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
      – Propose Complaint. The User may propose a complaint to the competent data protection supervisory authority or take legal action.
      Details on the right to object
      When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.
      Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users may refer to the respective sections of this document.

      How to Exercise Rights

      To exercise the User’s rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Holder as soon as possible, in any case within one month.

    • Specific Disclosures
      Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.System Logs and Maintenance
      For operation and maintenance purposes, this Site and any third-party services used by it may collect System Logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

      Information not contained in this policy
      Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

      Responding to “Do Not Track” Requests
      This site does not support “Do Not Track” requests.
      To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.

    • Changes to this privacy policy
      The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller . Therefore, please consult this page regularly, referring to the date of last modification indicated at the bottom.
      If the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.Definitions and legal references.

      Personal Data (or Data).
      Personal Data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

      Usage Data:
      This is the information automatically collected through this Application (including by third party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User’s computer environment.

      User:
      The individual who uses this Application which, except where otherwise specified, coincides with the Data Subject.
      Data Subject
      The natural person to whom the Personal Data refers.

    • Data Controller (or Controller):
      The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this site. The Data Controller, unless otherwise specified, is the owner of this site. Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.Cookies:
      Small portion of data stored within the User’s device.

      Legal references:
      This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.
      Unless otherwise specified, this privacy policy covers this Application only.