Privacy Policy (v1.0)
Your privacy is very important to Funnel Company and to better protect you, we provide you with these notes in which you will find info on the type of information collected online and on the various possibilities you have to intervene in the collection and use of such information on the site.
Here are the sections listed here:

1. Website user privacy policy
2. Cookie policy
3. Data privacy information communicated by the interested parties.
1.
INFORMATION FOR THE PROCESSING OF THE PERSONAL DATA OF THE WEBSITE VISITORS
EX ARTT. 13 - 14 REG. EU 679/2016 and ARTT. 13 - 14 L. 171/2018
1. Data Controller
The Data Controller of the data collected through this site is Funnel Company Srl, with registered office in Strada Degli Angariari, 3, Falciano (RSM), C.o.E. SM27916 (hereinafter also the "Owner").
2. Purpose and legal basis of the processing
CUSTOM JAVASCRIPT / HTML
SERVICE DELIVERY / COMMERCIAL COMMUNICATIONS
CUSTOM JAVASCRIPT / HTML
3. Consent and consequences of refusal
The granting of consent takes place through a special banner, or, in the event that this banner is ignored, through the use or consultation of the site, as an unequivocal conclusive behavior. By using or consulting the site, visitors and users approve this privacy statement and consent to the processing of their personal data in relation to the methods and purposes described below, including any communication to third parties if necessary for the provision of a service. The provision of data and therefore the consent to the collection and processing of data is optional, the User can deny consent and can revoke a consent already provided at any time (via the banner at the bottom of the page or the browser settings for cookies). However, denying consent may make it impossible to provide some services and the browsing experience on the site would be compromised.
4. Methods of processing personal data
The processing of your data takes place through the use of tools and procedures suitable to guarantee its security and confidentiality, and can be carried out both through our website and through other electronic tools, and sometimes even with the aid of paper supports. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial staff, system administrators, etc.) or external parties (such as third party technical service providers, hosting providers, etc.) may have access to the Data. IT companies, communication agencies) appointed, in the cases provided for by the law, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.
5. Data retention period
The data collected by the site during its operation are kept for the time strictly necessary to carry out the specified activities. Upon expiry, the data will be deleted or made anonymous, unless there are other purposes for their conservation. The Owner has no control over cookies entirely managed by third parties and does not have access to the information collected through these cookies. For more details on the retention of data collected through cookies, please refer to the cookie policy.
6. Transfer of data to foreign or non-EU countries
We try to avoid the transfer of your data to countries outside the EU or foreign countries. Where necessary, the Data Controller ensures from now on that the transfer of data to foreign countries will take place in compliance with the provisions of art. 46 L. 171/2018 and by art. 44 and following EU Reg. No. 679/2016. We inform you that we do not transfer data outside the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to transfer data to non-EU countries. In this case, the Data Controller ensures from now on that the transfer of data outside the EU will take place in compliance with the applicable legal provisions by stipulating, if necessary, agreements that guarantee an adequate level of protection and / or adopting the standard contractual clauses provided for by the Commission. European Union and / or binding corporate rules.
7. Access and communication of data
Your data may be made accessible to the employees and collaborators of the Data Controller in their capacity as data processors and / or system administrators; to third-party companies or other subjects (by way of example: professional firms, consultants, software houses that provide management, credit institutions, insurance companies, etc.) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external data processors. The Data Controller may communicate your data to the Public Administration, Supervisory Bodies and / or Judicial Authorities as well as to all other subjects to whom the communication is mandatory or necessary by law. Your information will not be disseminated.
8. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) EU Reg. 679/2016 and art. 2 lett. b) L. 171/2018, and more precisely: collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, comparison or interconnection, limitation, cancellation and destruction of data. Your personal data are subjected to both paper and electronic processing. The processing is carried out by appointees and collaborators within their respective functions and in accordance with the instructions received, always and only for the achievement of the specific purposes, scrupulously respecting the principles of confidentiality and security required by the applicable regulations.
9. Rights of the interested party
Pursuant to articles 15 to 22 of Law 171/2018 and from 15 to 22 of EU Reg. No. 679/2016, the interested party is given the opportunity to exercise specific rights. In particular, the interested party has the right to: a) obtain confirmation of the existence of personal data processing concerning him and, in this case, access to such data; b) obtain the correction of inaccurate personal data and the integration of incomplete personal data; c) obtain the cancellation of personal data concerning him, in cases where this is permitted by the Regulation; d) the limitation of processing, in the cases provided for by the Regulation; e) obtain the communication, to the recipients to whom the personal data have been transmitted, of the requests for rectification / cancellation of personal data and for the limitation of processing received from the interested party, unless this proves impossible or involves a disproportionate effort; f) to receive, in a structured format, commonly used and readable by an automatic device, of the personal data provided to the Data Controller, as well as the transmission of the same to another data controller, and this at any time, even upon termination of any relationships maintained with the Owner; g) object at any time, for reasons related to his particular situation, to the processing of personal data concerning him pursuant to Article 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions. If personal data are processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data concerning him for these purposes, including profiling to the extent that it is connected to such direct marketing; h) not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way; i) lodge a complaint with a supervisory authority pursuant to art. 77 of EU Reg. No. 679/2016 and art. 66 of Law 171/2018.
The requests referred to in the previous points must be sent by e-mail to the address of the data controller:support@funnelcompany.com
10. Representative in the European Union
Pursuant to art. 3 and 27 of the EU Reg. No. 679/2016, we inform you that the Data Controller has appointed the company CONSULTANTS PRIVACY SRL, with registered office in Via Valentini n. 11, C.F. and P. IVA 04391970409, Phone 0541 1798723‬, E-mail info@iconsulentiprivacy.it, Legal Email consulentiprivacy@postaleg.it 
11. Updates
This privacy policy is updated as of 01/08/2019.
2.
COOKIE POLICY
1. What are cookies?
As clarified by the Privacy Guarantor in the FAQ of December 2012, cookies are "small text files" - made up of letters and numbers - "that the sites visited by the user send to his terminal (usually the browser), where they are stored to be then retransmitted to the same sites at the next visit by the same user ". Cookies are used to streamline the analysis of web traffic or to signal when a specific site or part of it is visited, to distinguish visitors from each other in order to provide personalized content, and help administrators to improve the site and the browsing experience of the users themselves. Through cookies we cannot access other information stored on your device, even if this is where the cookies are downloaded. Cookies cannot load codes of any kind, carry viruses or malware and are not harmful to the user's terminal.
Below you can find all the information on the cookies installed through this site, and the necessary information on how to manage your preferences in this regard.
2. User consent to the use of cookies
When connecting for the first time to any page of the Site, the user will see an information banner on the use of cookies appear. By closing this information using the appropriate button or clicking outside the banner that contains it and continuing to browse, the user consents to our use of cookies, in the manner described in this Cookie Policy.
The site remembers the choice made by the user, therefore the brief information will not be repeated in subsequent connections from the same device. However, the user always has the option of revoking all or part of the consent already expressed.
If you encounter technical problems related to the provision of consent, please contact us through the appropriate channels provided by this site to allow us to assist you.
3. Duration of cookies
Cookies can be:
  • session, cookies that are stored permanently on the user's computer and are deleted when the browser is closed, are strictly limited to the transmission of session identifiers necessary to allow safe and efficient exploration of the site avoiding the use of other techniques information technology potentially prejudicial to the confidentiality of users' browsing;
  • persistent, cookies that remain stored on your computer's hard drive until they expire or are deleted by users / visitors. Through persistent cookies, visitors who access the site (or any other users who use the same computer) are automatically recognized at each visit. Visitors can set the computer browser to accept / reject all cookies or display a warning whenever a cookie is proposed, in order to evaluate whether to accept it or not. The user can, however, change the default configuration and disable cookies (i.e. block them permanently), by setting the highest level of protection.
4. Types of cookies
Cookies can be:
  • first party, or cookies that report this website as a domain;
  • ​third-party cookies, or cookies that are related to external domains.
Third party cookies are necessarily installed by an external party, always defined as "third party", not managed by the site. Another type of cookies are the so-called "Flash Cookies" (Local Shared Objects), used within Adobe Flash Player to deliver some content, such as video clips or animations, in order to remember settings and preferences. Flash cookies are stored on the device, but are managed through a different interface than that provided by the browser used.
5. Nature of cookies
Regarding the nature of cookies, there are different types:
  • technical cookies: are those used for the sole purpose of "carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service "(see art. 122, paragraph 1, of the Code).
They are not used for other purposes and are normally installed directly by the website owner or manager. They can be divided into:
  • navigation or session cookies, which guarantee normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas); they are in fact necessary for the proper functioning of the site;
  • analytics cookies, similar to technical cookies when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site, in order to improve site performance;
  • ​functionality cookies, which allow the user to browse according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided. For the installation of these cookies, the prior consent of the users is not required (more information in the paragraph on managing cookies below).
  • Profiling cookies: they are aimed at creating profiles relating to the user and are used in order to send advertising messages in line with the preferences expressed by the user while surfing the net. The consent of the interested party is required for the use of profiling cookies. In the case of third-party cookies, the site does not have direct control of the individual cookies and cannot control them (it cannot install them directly or delete them). You can still manage these cookies through your browser settings (follow the instructions below), or the sites listed in the "Cookie management" section.
6. Cookies on this site
This website uses cookies. We use cookies to personalize content and ads, to provide social media features and to analyze our traffic. We also share information about how you use our site with our web analytics, advertising and social media partners who may combine it with other information you have provided to them or that they have collected from your use of their services.
Some cookies are placed by third party services that appear on our pages. This site has no control over cookies entirely managed by third parties and does not have access to the information collected through these cookies. Information on the use of third-party cookies and their purposes, as well as on how to disable them, are provided directly by third parties on the sites of the third parties themselves.
It is recalled that generally the tracking of users does not involve identification of the same, unless the User is already registered for the service and is not already logged in, in which case it is understood that the User has already expressed his consent directly to the third party when registering for the relevant service (eg Facebook).
Below is the list of cookies on the site:
CUSTOM JAVASCRIPT / HTML
Finally, we inform you that the site may also include the so-called "Social buttons", or those particular "buttons" on the site that depict the icons of social networks (for example, Facebook, Twitter, Youtube, etc.) and allow users who are browsing to interact with a "click" directly with the social platforms. The social buttons on the site are links that refer to the owner's accounts on the social networks depicted. By using these buttons, third-party cookies are therefore not installed on the site.
7. Disabling cookies
The user can refuse the use of cookies and at any time can revoke a consent already provided. Since cookies are connected to the browser used, they can be disabled directly from the browser, thus refusing / revoking consent to the use of cookies.
3.
INFORMATION FOR THE PROCESSING OF PERSONAL DATA COMMUNICATED BY THE INTERESTED PARTIES
(registration form for courses, events, requests for free training material, etc.)
EX ARTT. 13 - 14 REG. EU 679/2016 and ARTT. 13 - 14 L. 171/2018
Funnel Company Srl, with registered office in Strada Degli Angariari, 3, Falciano (RSM), C.o.E. SM27916 (hereinafter the "Owner"), in the person of the legal representative pro tempore, as the DATA CONTROLLER, It informs you pursuant to art. 13 and 14 of EU Regulation no. 2016/679 (hereinafter "GDPR") and of the articles 13 and 14 of the L. sammarinese n. 171/2018 that the data you provide will be processed in the manner and for the following purposes:
1. Object of the treatment
The Data Controller, for the establishment and management of relations with you in progress, deals with:
 - your non-specific identification and tax personal data (for example: name, surname, company name, address, bank and payment details, etc.);
 - Your non-specific contact details (telephone, e-mail, etc.);
2. Purpose of the processing and legal basis
The Data Controller, for the establishment and management of relations with you in progress, deals with:

 a. Your personal data are processed without your express consent (Article 6 of EU Reg. 679/2016 and Article 5 of Law 171/2018) for the following purposes: conclude contracts for the Controller's services or fulfill the pre-contractual, contractual and tax obligations deriving from existing relationships with you (for example: completing registration for events, sending the requested material); fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (for example: issuing invoices); exercise the rights of the owner (for example: treasury management, right of defense in court, etc.).

 b. Your personal data may be processed without your express consent (Article 6 of EU Reg. 679/2016 and Article 5 of Law 171/2018), but with the right to object to the so-called processing. (opt out), to exercise a legitimate interest of the Data Controller. In this regard, we inform you that by registering for one of our events, or by requesting the sending of free training material, using one of the data collection forms on our websites or other opt-in methods (e.g. Messenger chat-bot ), the Data Controller may send you subsequent communications by e-mail, including of a promotional nature, containing information on future events and / or training materials similar to those in which you have expressed interest at the time of registration (soft spam or direct marketing). We remind you of your right not to receive such communications (opt-out), by sending an e-mail to support@funnelcompany.com or by clicking on the unsubscribe link in the communications you will receive.
3. Nature of the provision of data and consequences of refusing to respond
The provision of data for the purposes referred to in point 2.a) is mandatory and does not require consent. In the absence of such data we will not be able to provide our services. The use of your contact details for the purposes referred to in point 2.b) falls within the legitimate interest of the Data Controller and does not require consent. However, you can decide at any time to deny the possibility of processing the data already provided for these purposes by sending an e-mail: support@funnelcompany.com. In this case, you will not be able to receive further communications on the services offered by the Data Controller. However, you will continue to be entitled to the services referred to in point 2.a).
4. Processing methods
The processing of your personal data is carried out by means of the operations indicated in art. 4 n. 2) EU Reg. 679/2016 and art. 2 lett. b) L. 171/2018, and more precisely: collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, comparison or interconnection, limitation, cancellation and destruction of data. Your personal data are subjected to both paper and electronic processing. The processing is carried out by appointees and collaborators within their respective functions and in accordance with the instructions received, always and only for the achievement of the specific purposes, scrupulously respecting the principles of confidentiality and security required by the applicable regulations.
5. Profiling
Your non-specific personal data may be subjected to an automated decision aimed at identifying the products and / or services of your future interest, taking into account what has already been purchased or requested. This operation does not involve a decision-making process based solely on automated processing, as human intervention is always necessary and prevalent. Therefore, there is no need to obtain your consent to perform the aforementioned activity, which is also justified in the legitimate interest of the owner to carry out treatments aimed at soft spam or direct marketing. The interested party may request explanations on the methods used by the Data Controller to perform this treatment.
6. Access to data
Your data may be made accessible for the purposes referred to in point 2:
 - To the employees and collaborators of the Data Controller in their capacity as persons in charge of processing and / or system administrators;
 - To third-party companies or other subjects (by way of example: professional firms, consultants, software houses that provide management, credit institutions, insurance companies, etc.) who carry out outsourced activities on behalf of the Data Controller, in their capacity as external managers of the treatment.
7. Communication of data
The Data Controller may communicate your data to the Public Administration, Supervisory Bodies and / or Judicial Authorities as well as to all other subjects to whom the communication is mandatory or necessary by law. Your information will not be disseminated.
8. Transfer of data
Your data are not transferred to foreign countries. Where necessary, the Data Controller ensures from now on that the transfer of data to foreign countries will take place in compliance with the provisions of art. 46 L. 171/2018.
9. Data retention
All personal data provided will be processed in compliance with the principles of lawfulness, correctness, relevance and proportionality, only with the methods, including computer and telematic methods, strictly necessary to pursue the purposes described above.
Personal data may be stored based on present and future business needs, or until a request for cancellation by the interested party. The Data Controller ensures that periodic checks are carried out to identify and delete data deemed obsolete, taking care to avoid storage indefinitely and to facilitate the exercise of the rights of the interested party.
It should be noted that the information systems used to manage the information collected are configured, from the outset, in order to minimize the use of personal data.
10. Rights of the interested party
Pursuant to articles 15 to 22 of Law 171/2018 and from 15 to 22 of EU Reg. No. 679/2016, the interested party is given the opportunity to exercise specific rights. In particular, the interested party has the right to: a) obtain confirmation of the existence of personal data processing concerning him and, in this case, access to such data; b) obtain the correction of inaccurate personal data and the integration of incomplete personal data; c) obtain the cancellation of personal data concerning him, in cases where this is permitted by the Regulation; d) the limitation of processing, in the cases provided for by the Regulation; e) obtain the communication, to the recipients to whom the personal data have been transmitted, of the requests for rectification / cancellation of personal data and for the limitation of processing received from the interested party, unless this proves impossible or involves a disproportionate effort; f) to receive, in a structured format, commonly used and readable by an automatic device, of the personal data provided to the Data Controller, as well as the transmission of the same to another data controller, and this at any time, even upon termination of any relationships maintained with the Owner; g) object at any time, for reasons related to his particular situation, to the processing of personal data concerning him pursuant to Article 6, paragraph 1, letters e) or f), including profiling on the basis of these provisions. If personal data are processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data concerning him for these purposes, including profiling to the extent that it is connected to such direct marketing; h) not be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects his person in a similar way; i) lodge a complaint with a supervisory authority pursuant to art. 77 of EU Reg. No. 679/2016 and art. 66 of Law 171/2018.
11. Procedures for exercising rights
You can exercise your rights at any time by contacting the Data Controller at the following e-mail address:support@funnelcompany.com
12. External managers and agents
The updated list of external managers and data processors is kept at the registered office of the Data Controller.
13. Representative in the European Union
Pursuant to art. 3 and 27 of the EU Reg. No. 679/2016, we inform you that the Data Controller has appointed the company CONSULTANTS PRIVACY SRL, with registered office in Via Valentini n. 11, C.F. and P. IVA 04391970409, Phone 0541 1798723‬, E-mail info@iconsulentiprivacy.it, Legal Email consulentiprivacy@postaleg.it
This information is updated as of 01/08/2019
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