Armonia S.R.L., with registered office in Viale degli Eucalipti, 38 84134 Salerno, Italy (hereinafter “Armonia” or the “Data Controller”) is constantly committed to protecting the online privacy of its users. This document has been drawn up in accordance with art. 13 of EU Regulation 2016/679 (hereinafter: “Regulation”) in order to allow you to know our privacy policy, to understand how your personal information is managed when you use our site (hereinafter also the “Site”) and, if necessary, to give consent to the processing of your personal data expressed and aware. The information and data provided by you or otherwise acquired in the context of the use of the Site services will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that inspire the activity of Armonia. According to the rules of the Regulation, the processing carried out by the Data Controller will be based on the principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality.
— Data Controller
— Types of Data collected
— Methods and place of processing of the collected Data
— Purposes of the processing
— Legal basis and mandatory or optional nature of the processing
— Recipients of personal data
— Transfers of personal data
— Retention of personal data
— Rights of the data subject
— Changes
The Data Controller of the processing carried out through the Site is Armonia S.R.L., as defined above, reachable at the email address: hi@armonia.io. The Data Protection Officer (hereinafter, “DPO”) can be contacted at the following addresses: hi@armonia.io.
Among the Personal Data collected by this Application, independently or through third parties, there are: Cookies; Usage Data; various types of Data; email; name; surname.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the Data is collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. If not otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation. Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller. Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application is intended to provide the Service requested by the User, in addition to the other 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.
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. These are information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes 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 in submitting 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 computer environment. This data is 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 is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the site or third parties.
In the use of some sections of the Site, there may be a provision of your personal data falling under the special categories of Personal Data referred to in Article 9 of the Regulation, verbatim the '[...] data capable of revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as dealing with genetic data, biometric data intended to uniquely identify a natural person, data concerning the health or sex life or sexual orientation of the person.' We urge you to disclose such data only where necessary. Indeed, we remind you that in the face of the transmission of special categories of Personal Data, but in the absence of specific manifestation of consent to process such data, Armonia cannot be held responsible in any way, nor can it receive any complaints, as in this case the processing will be allowed as it concerns data made manifestly public by the data subject, in accordance with art. 9.1.e) of the Regulation. We specify, however, the importance, as already mentioned above - of expressing explicit consent to the processing of special categories of personal data, if you decide to share such information. We also inform you that, for selection purposes, Armonia may analyze the professional social profiles made freely available on the Internet (by way of example, but not exhaustive, the portal called LinkedIn).
In the use of some Services of the Site, there may be a processing of personal data of third parties sent to Armonia by you. In relation to such hypotheses, you act as an independent data controller, assuming all the obligations and responsibilities of the law. In this sense, you confer the broadest indemnity with respect to any dispute, claim, request for compensation for damage from processing, etc. that may come to Armonia from third parties whose personal data have been processed through your use of the Site functions in violation of the applicable data protection laws. In any case, if you provide or otherwise process personal data of third parties in the use of the Site, you guarantee from now on - assuming all related responsibilities - that this particular processing hypothesis is based on an appropriate legal basis pursuant to art. 6 of the Regulation that legitimizes the processing of the information in question.
Definitions, characteristics and application of the legislation Cookies are small text files that the sites visited by the user send and record on his computer or mobile device, to be then retransmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user's actions and preferences (such as, for example, login data, the chosen language, font sizes, other display settings, etc.) so that they do not have to be indicated again when the user returns to visit that site or browse from one page to another. Cookies are therefore used to perform computer authentications, session monitoring and storage of information regarding the activities of users who access a site and may also contain a unique identification code that allows tracking of the user's navigation within the site itself for statistical or advertising purposes. During navigation on a site, the user may also receive cookies on his computer from sites or web servers other than the one he is visiting (so-called “third-party” cookies). Some operations may not be performed without the use of cookies, which in some cases are therefore technically necessary for the same operation of the site.
There are various types of cookies, depending on their characteristics and functions, and these can remain on the user's computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user's device until a predetermined expiration date. According to current legislation in Italy, the use of cookies does not always require the express consent of the user. In particular, “technical cookies” do not require such consent, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.
Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see Provision on the identification of simplified procedures for the information and the acquisition of consent for the use of cookies of 8 May 2014 and subsequent clarifications, hereinafter also only “Provision”) includes:
— the “analytics cookies” where used directly by the site manager to collect information, in aggregate form, on the number of users and how they visit the site itself,
— navigation or session cookies (to authenticate),
— functionality cookies, which allow the user to navigate based on a series of selected criteria (for example, language, products selected for purchase) in order to improve the service provided to the user.
For “profiling cookies”, on the other hand, i.e. those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the user in the context of online browsing, the prior consent of the user is required.
The Site uses the following cookies that can be deselected, except for third-party cookies for which you will have to refer directly to the respective selection and deselection methods of the respective cookies, indicated by means of links:
— Technical navigation or session cookies and strictly necessary for the operation of the Site or to allow you to use the requested content and services.
— Functionality cookies, i.e. used to activate specific functions of the Site and a series of selected criteria (for example, language) in order to improve the service provided.
WARNING: by disabling technical and/or functionality cookies, the Site may not be viewable or some services or certain functions of the Site may not be available or may not work correctly and you may be forced to manually change or enter some information or preferences every time you visit the Site. Third-party cookies, i.e. cookies from sites or web servers other than the Data Controller's, used for the purposes of those third parties. It should be noted that these third parties, listed below with links to their privacy policies, are typically independent data controllers of the data collected through the cookies they serve; therefore, you will need to refer to their personal data processing policies, information and consent forms (selection and deselection of the respective cookies), as specified in the aforementioned Provision. As for third parties that send cookies through our Site, we provide below the links to their respective privacy policies: to these third parties we entrust, as already specified, the responsibility to provide the information and collect your consent, as required by the Provision. This responsibility refers not only to the cookies that third parties send directly, but also to any additional cookies that are sent through our Site by virtue of the use of services that the third parties themselves enjoy. With respect to these cookies, in fact, sent by service providers of the aforementioned third parties, Armonia has no possibility to exercise any control and does not know either the characteristics or the purposes.
Below are the links to information about third-party cookies:
The user has the possibility to block (in whole or in part) technical and functionality cookies through the specific functions of his Browser. We inform you, however, that not authorizing technical cookies may result in the impossibility of using the Site, viewing its contents and using the related services. Inhibiting functionality cookies may result in some services or certain functions of the Site not being available or not working correctly and you may be forced to manually change or enter some information or preferences every time you visit the Site.
The choices made in reference to the Site's cookies will in turn be recorded in a special cookie. However, this cookie may, in some circumstances, not work properly: in such cases, we recommend that you delete unwanted cookies and inhibit their use also through the browser's functions.
Your preferences regarding cookies will need to be reset if you use different devices or browsers to access the Site.
You can authorize, block or delete (in whole or in part) cookies through the specific functions of your Browser. For more information on how to set preferences on the use of cookies through the Browser, you can consult the relevant instructions:
— Firefox
— Chrome
— Safari
The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators personnel) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, Data Processors by the Data Controller. The updated list of Data Processors can always be requested from the Data Controller.
The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller. The User's Personal Data may be transferred to a country other than the one in which the User is located. For more information on the location of the processing, the User can refer to the section on details on the processing of Personal Data.
Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the consent of Users.
The processing that we intend to carry out, with your specific consent where necessary, has the following purposes:
— Allow the provision of the Services requested by you, namely:
— access to the reserved area of the Site;
— the request for contact by Armonia;
— conclude a contract;
— Privacy.jobApppcationsManagement
— respond to requests for quotes through the appropriate form;
— respond to requests for assistance or information;
— Privacy.legalObpgationsFulfillment
— Privacy.directSalesMarketingProfipng
— The data provided may be processed, subject to explicit and specific consent, for direct sales purposes and/or for sending promotional and marketing communications, including the sending of newsletters and market research, through automated tools (sms, mms, email, push notifications, fax) and non-automated tools (paper mail, telephone with operator), as well as for the analysis of personal data, purchase choices and behavioral preferences on the Site, in order to better structure personalized commercial communications and proposals, to carry out general analyzes and, in general, for profiling activities.
The legal basis for the processing of personal data for the purposes referred to in section 4 (a-b) is art. 6.1.b) of the Regulation as the processing is necessary for the provision of the Services or for the response to the data subject's requests. The provision of personal data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Site, respond to requests or evaluate CVs. The purpose referred to in section 4.c represents a legitimate processing of personal data pursuant to art. 6.1.c) of the Regulation. Once the personal data has been provided, the processing is indeed necessary to comply with a legal obligation to which Armonia is subject. The data provided for the purposes referred to in section 4.d may be processed, subject to explicit and specific consent, for the direct sales and/or for sending promotional and marketing communications, including the sending of newsletters and market research, through automated tools (sms, mms, email, push notifications, fax) and non-automated tools (paper mail, telephone with operator), as well as for the analysis of personal data, purchase choices and behavioral preferences on the Site, in order to better structure personalized commercial communications and proposals, to carry out general analyzes and, in general, for profiling activities. The legal basis for the processing of your data for these purposes is art. 6, paragraph 1, lett. a) of the Regulation. Commercial profiling and direct marketing processing are optional and depend on the free choice of the user; therefore, failure to provide consent for these purposes will not affect the use of the services. For processing carried out for the direct sending of its own advertising material or for its own direct sales or for the completion of its own market research or commercial communications in relation to products or services of the Data Controller similar to those already purchased, Armonia may use, without the consent of the data subject, the email and postal addresses in accordance with and within the limits allowed by art. 130, paragraph 4 of the Code and by the provision of the Guarantor Authority for the protection of personal data of 19 June 2008. The legal basis for the processing of your data for this purpose is art. 6, paragraph 1, lett. f) of the Regulation. The data subject has the possibility to object to this processing at any time, initially or on the occasion of subsequent communications, easily and free of charge also by writing to the email address: hi@armonia.io, as well as to obtain an immediate response confirming the interruption of such processing (art. 15 of the Regulation). If necessary, specific summary information on the processing of personal data and requests for consent will be progressively reported or displayed on the pages of the Site prepared for particular services.
Your personal data may be shared, for the purposes referred to in section 4 above, with:
— Subjects who typically act as data processors pursuant to art. 28 of the Regulation, namely:
— individuals, companies or professional firms that provide assistance and advice to the Data Controller in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services;
— subjects with whom it is necessary to interact for the provision of the Services (for example, hosting providers);
— or subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks);
— Subjects, entities or authorities, independent data controllers, to whom it is mandatory to communicate your personal data by virtue of legal provisions or orders of the authorities;
— Persons authorized by Armonia to process Personal Data pursuant to art. 29 of the Regulation necessary to carry out activities strictly related to the provision of the Services, who have undertaken to keep confidentiality or have an adequate legal obligation of confidentiality (e.g. Armonia employees);
— With your specific consent, third parties with whom the Data Controller has entered into commercial agreements and/or conventions, belonging to the following categories: communication and marketing professionals and companies; professionals and companies operating in the legal, tax/fiscal, financial, accounting/administrative, insurance, training sectors; professionals and companies in the health, medical/pharmaceutical sector and suppliers of leisure services, for their marketing and communication purposes.
With regard to any transfer of Data to Third Countries, the Data Controller informs that the processing will take place according to one of the methods allowed by current legislation, such as, for example, the consent of the data subject, the adoption of Standard Clauses approved by the European Commission, the selection of subjects adhering to international programs for the free circulation of data or operating in countries considered safe by the European Commission. Further information is available, upon request, from the Data Controller at the above contacts.
Personal data processed for the purposes referred to in section 4 (a-b) will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and limitation of storage pursuant to art. 5.1.e) of the Regulation. In any case, Armonia will process personal data for the time necessary for contractual and legal obligations. Further information on the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller, at the email address hi@armonia.io.
Pursuant to articles 15 and following of the Regulation, you have the right to request at any time, access to your Personal Data, rectification or erasure of the same, limitation of processing in cases provided for by art. 18 of the Regulation, obtain in a structured format, of common use and readable by an automatic device the data concerning you, in the cases provided for by art. 20 of the Regulation. At any time, you can revoke the consent given pursuant to art. 7 of the Regulation; propose a complaint to the competent supervisory authority pursuant to article 77 of the GDPR (Guarantor for the Protection of Personal Data) pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the legislation in force. You can make a request for opposition to the processing of your data pursuant to article 21 of the GDPR in which you provide evidence of the reasons justifying the opposition: the Data Controller reserves the right to evaluate the request, which would not be accepted in the presence of compelling legitimate reasons to proceed with the processing that prevail over your interests, rights and freedoms.
Requests must be addressed in writing to the Data Controller at the email address hi@armonia.io.
The Data Controller reserves the right to modify or simply update the content of the privacy policy, in whole or in part, also due to changes in the applicable legislation. You will be informed of such changes as soon as they are introduced and they will be binding as soon as they are published on the Site. Armonia therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data collected and on the use by the Data Controller.
The User's Personal Data may be used by the Data Controller in court or in the preparatory stages for its possible establishment for defense against abuse in the use of this Application or the connected Services by the User. The User declares to be aware that the Data Controller may be required to disclose the Data by order of public authorities.
Upon request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
For needs related to operation and maintenance, this Application and any third-party services it uses may collect system logs, i.e. files that record interactions and that may also contain Personal Data, such as the User's IP address.
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in his possession. Therefore, please consult this page frequently, referring to the last modification date indicated at the bottom.
If the changes affect treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.
Personal data means any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
This is information collected automatically through this Application (including from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI notation (Uniform Resource Identifier), 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 the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the IT environment of the User.
The individual who uses this Application who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
The natural person, legal entity, public administration and any other body that processes personal data on behalf of the Data Controller, as described in this privacy policy.
The natural person or legal entity, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures related to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
The hardware or software tool through which the Personal Data of Users are collected and processed.
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Cookies are Tracking Tools that consist of small portions of data stored inside the User's browser.
By Tracking Tool we mean any technology - e.g. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting - that allows Users to be tracked, for example by collecting or saving information on the User's device.