Privacy and Cookie Policy
Legislative Decree 196/2003, as amended by Legislative Decree 101/2018, with reference to EU Regulation 2016/679
This notice describes how the official website of Twproject S.r.l. – Via Don Giulio Facibeni 8/A – 50141 Florence (FI) (hereinafter the “COMPANY”) is managed with regard to the processing of personal data relating to identified or identifiable users who visit it and interact with it and with the web services accessible electronically. This notice
is provided pursuant to Article 13 of EU Regulation 679/2016 (EU Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC).
This notice applies only to the Company’s website (available at https://twproject.com) and not to other external websites that users may access through links on the website pages.
1) Data Controller
Any collection and processing of data within the website is carried out by the Data Controller, pursuant to Article 4(7) of EU Regulation 2016/679, represented by the Legal Representative. The place of data processing is identified as the operating office of Twproject S.r.l. – Via Venezia, 18b – 50121 Florence (FI) – Italy
2) Place of data processing
Processing related to the web services of this website takes place at the aforementioned Company premises and is carried out only by technical personnel appointed to process the data, or by persons occasionally appointed to perform maintenance operations.
No data deriving from the web service is disseminated, except where expressly required by law. Any personal data provided by users is used solely to perform the requested service or activity and is disclosed to third parties only where necessary for that purpose.
3) Types of data processed, processing methods and retention period
a) Browsing data
The IT systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to be associated with identified data subjects; however, by its very nature, through processing and association with data held by third parties, it could allow users to be identified. This category includes IP addresses or domain names of the computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server response (successful, error, etc.), and other parameters relating to the user’s operating system and IT environment.
These data are used solely to obtain anonymous statistical information on use of the website and to check that it is functioning correctly, and are retained only for the time strictly necessary. The data may be used to establish liability in the event of hypothetical computer crimes against the website.
b) Optional provision of data
Except as specified for browsing data, users are free to provide the personal data indicated in request forms submitted to the Company or in the various forms used to interact with different sections of the website. Failure to provide such data may make it impossible to obtain what has been requested or to interact with the website.
If a user registers through “Request a demo” on https://twproject.com, Twproject S.r.l. collects the following personal data:
-personal details (First Name and Last Name);
-email address and telephone number;
Users may voluntarily provide other data relating to themselves in connection with their requests and comments in the relevant registration form field.
If a user registers through “Free trial” on https://twproject.com, Twproject S.r.l. collects the following personal data:
-personal details (First Name and Last Name);
-email address;
Users may voluntarily provide other data relating to themselves in connection with their requests and comments in the relevant registration form field.
In addition, data entered by the user into the software obtained for the trial period will be deleted 2 months after the trial expires.
If a user registers through “Webinar” on https://twproject.com, Twproject S.r.l. collects the following
personal data:
-personal details (First Name and Last Name);
-Company name;
-email address;
If a user registers through “Contacts” on https://twproject.com, Twproject S.r.l. collects the following
personal data:
-personal details (First Name and Last Name);
-Company name;
Users may voluntarily provide other data relating to themselves in connection with their requests and
comments in the relevant registration form field.
If a user registers through “Submit a request” on https://twproject.com, Twproject S.r.l. collects the following
personal data:
-personal details (First Name and Last Name);
-Company name;
Users may voluntarily provide other data relating to themselves in connection with their requests and
comments in the relevant registration form field.
If a user registers through “Blog” on https://twproject.com, Twproject S.r.l. collects the following
personal data:
-Email address
Entering an email address in this menu requires subsequent active confirmation by the user through a link sent by email, which serves as the relevant consent.
If a user registers through “Twproject on premise – download” on https://twproject.com, Twproject
S.r.l. collects the following personal data:
-personal details (First Name and Last Name);
-Company name;
-email address;
Online purchases of licences or cloud services can be made through https://twproject.com. In addition to the data mentioned above, Twproject S.r.l. does not receive or process payment method data for such activities, as payments are managed directly through a third-party financial institution (specifically, through the PayPal platform).
During the purchase, users may also select the location of the servers on which their data will be stored. If a server outside the EU is selected (specifically, in the USA), personal data will be transferred abroad using providers that guarantee appropriate protection standards and legal
transfer mechanisms compliant with EU Regulation 2016/679 (GDPR).”
Twproject S.r.l. does not request or, on its own initiative, process special categories of personal data concerning its users (e.g. data 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 concerning health, sex life or
sexual orientation). However, in order to fulfil specific requests for services and operations relating to the relationship with the user, it may be necessary to process such data. Since Twproject S.r.l. cannot intercept or reject these requests, the contract proposal cannot be accepted unless the Data Subject has declared their
written consent to the aforementioned processing. Such data will be processed exclusively to fulfil the user’s request.
c) Recipients or categories of recipients
The Data Subject’s data may be accessed by natural and legal persons appointed as Data Processors and by natural persons authorised to process the data necessary to perform the duties assigned to them:
employees of Twproject S.r.l., collaborators, interns and external consultants.
Personal data may be disclosed by Twproject S.r.l. to shipping agents and carriers for the delivery of goods to the Data Subject or to third parties indicated by them, and in any case to third parties involved in the performance of agreements for the supply of goods and/or services, where necessary for such performance.
Without requiring the Data Subject’s consent, Twproject S.r.l. may disclose personal data in its possession to parties to whom such disclosure is required in order to comply with an obligation imposed by law, regulation or EU legislation.
d) How we use the personal data collected
In connection with the relationship established with Twproject S.r.l., data will be entered into IT databases owned by Twproject S.r.l. in order to manage registration, accounting, receipts and payments, the issuance of tax documentation, order management, management of the relevant contracts, preparation of internal statistics,
and the sending of information, commercial and promotional communications and advertising material, including to the Data Subject’s email address.
Twproject S.r.l. does not sell, rent or trade personal data.
e) How long we retain personal data
Twproject S.r.l. retains personal data for the entire duration of the contractual relationship and for the time necessary to fulfil the obligations inherent in and arising from it.
After termination of the relationship, personal data will be retained for the periods required by law; in particular, accounting data will be retained for 10 years.
In the event of legal proceedings, the data provided will be retained for the entire duration of the proceedings, until the time limits for available appeals have expired.
4) Cookies
Twproject S.r.l. also collects data through cookies and similar technologies, as described in greater detail in the Cookie Policy, and allows third parties to use cookies.
Cookies are used to recognise the user and/or their devices within, outside and across different Services and devices.
Users can control cookies through their browser settings and other tools. They may also refuse Twproject S.r.l.’s use of cookies and similar technologies that track their behaviour on other websites for third-party advertising.
Cookies are text elements placed on the hard drive of a computer or other device by the online service provider for website visitors. Cookies may collect information about visitors’ habits when using the website, recording activity on their computer or other device in relation to the website,
for example when making purchases.
COOKIES may be:
• First-party cookies (also called proprietary cookies) are cookies saved directly on the
computer or other device. They may include session cookies and persistent cookies (described below).
First-party cookies may be used to track movements made by the visitor’s computer or other device
while browsing the website, for example for analytics purposes.
• Third-party cookies are managed by third parties and may collect and track certain browsing data. This website uses Google Analytics (described under browsing and statistical data collected by third parties).
• Session cookies. The period between opening and closing the Internet browser is called a browsing session. Session cookies are stored on the visitor’s computer or other device during a browsing session, but expire and are normally deleted at the end of the browsing session.
• Persistent cookies are stored on the visitor’s computer or other device during a browsing session but remain there after that session ends (e.g. saved passwords). Persistent cookies allow websites to recognise the visitor’s computer or other device when it is used to access one of our websites again, after one browsing session has ended and a new one begins, essentially helping the visitor reconnect quickly to our website.
For strictly technical reasons, this website uses the following types of cookies:
• technical and session cookies, for example to prevent the user, where applicable, from having to enter a password repeatedly to access restricted sections of the website, to store the preferred browsing language, or to store certain technical characteristics of the browser used for browsing (including acceptance of cookies).
• third-party cookies (Google Analytics) to measure access statistics for this website (in aggregate form), only if express consent to their use is given.
Cookie use can be disabled; however, choosing this option may cause the website to malfunction to a greater or lesser extent depending on the section being visited.
BROWSING AND STATISTICAL DATA COLLECTED BY THIRD PARTIES
As is now common practice on the Internet, this website uses statistical analysis tools provided and managed by third parties that may collect and “track” certain browsing data.
Since these data are collected by tools and companies other than the website operator, they are not physically held by the Company, which can only consult them and cannot independently modify or delete them. For such operations, and to obtain detailed information about the privacy policy applied to these data, users must contact the relevant Data Controller directly, i.e. the company that directly provides the statistical service used.
The third-party tools used on this website are as follows:
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Google Analytics (provided by: Google Inc., 1600 Amphitheatre Parkway – Mountain View, CA 94043, USA)
INFORMATION ABOUT GOOGLE ANALYTICS
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, text files placed on your computer to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored on Google servers in the United States. Google will use this information to track and examine your use of the website, compile reports on website activity for website operators, and provide other services relating to website activity and Internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, although this may prevent you from using all the features of this website. By giving your consent on this website, you consent to the processing of your data by Google in the manner and for the purposes set out above.
Useful addresses for a better understanding of the Google Analytics privacy policy:
http://www.google.com/analytics/terms/it.html
http://www.google.com/privacypolicy.html
If you do not want your data to be collected by Google Analytics, you can also download the official browser “opt-out” plugin by clicking here.
Any requests relating to data involved in this processing should be addressed to the Data Controller (Google Inc.).
5) Rights of Data Subjects
At any time, pursuant to Articles 15 to 22 of EU Regulation No. 2016/679, users may exercise the right to:
a) request confirmation as to whether or not personal data concerning them exists;
b) obtain information on the purposes of the processing, the categories of personal data, the recipients or categories of
recipients to whom the personal data has been or will be disclosed and, where possible, the retention period;
c) obtain rectification and erasure of the data;
d) obtain restriction of processing;
e) obtain data portability, i.e. receive the data from a controller in a structured, commonly used
and machine-readable format and transmit it to another controller without hindrance;
f) object to processing at any time, including processing for direct marketing purposes;
g) object to automated decision-making concerning natural persons, including profiling.
h) request from the Data Controller access to personal data and its rectification or erasure, or restriction of processing concerning them, or object to its processing, in addition to the right to data portability;
i) withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal;
j) lodge a complaint with a supervisory authority. Users may exercise their rights by sending a written request to the Data Controller as indicated in point 1 of this Policy.
6) Updates to the website privacy policy
Twproject S.r.l. reserves the right to amend this website privacy policy at any time. If Twproject S.r.l. makes changes to this website privacy policy, it will update the effective date and such changes will take effect upon publication. Users are encouraged to review this website privacy policy periodically.
7) Links to other websites
The website may contain links to third-party websites whose privacy information and practices differ from those of Twproject S.r.l. Twproject S.r.l. is not responsible for the privacy information or practices applied by such third parties and encourages users to read the privacy statements of those
websites before using them or transmitting any personal data or other information through them.
8) Twproject S.r.l. contact details
For any comments or requests for clarification regarding this website privacy notice, or if you wish to update the information about you that we hold or exercise your rights, you may contact Twproject S.r.l. – Via Don Giulio Facibeni 8/A – 50141 Florence (FI) by email at
support@twproject.com or write to:
Twproject S.r.l. – Via Don Giulio Facibeni 8/A – 50141 Florence (FI) – Italy