Privacy Policy

Information on the processing of personal data
With this document ("Information ") the data controller provides you with the terms of data collected and processing to the company services performed on the webhttps ://smellwalksitaly.com/ in relation to Regulation (EU) 2016/679 (GDPR) in strict compliance with the general principles set out in Articles. 5 and 6 of the GDPR, that is to say, according to correctness, accuracy, completeness and consistency with the stated purposes.

Data Controller
The data controller is the company Romina Marovelli, in accordance with current laws, is the administrator of the site (hereinafter referred to as the company) with registered office in via Farini 3 Castelnuovo di Garfagnana 55032 Lucca, can be contacted through the CONTACT section or at: rominamarovelli@pec.it

1.2 Legal basis of processing
This site processes data mainly based on the consent of users. The consent is given through the banner placed at the bottom of the page, or through the use or consultation of the site, as a conclusive behavior. By using or consulting the site, visitors and users agree to this informative document and consent to the processing of their personal data in relation to the methods and purposes described below, including any dissemination to third parties if necessary for the provision of a service. Through the communication or service request forms, additional consents are collected related to the specific purpose of the service.
The conferment of data and therefore the consent to the collection and processing of data is optional, the User can deny the consent, and can revoke at any time a consent already provided (via the banner at the bottom of the page or the browser settings for icookies, or the Contacts link ). However, refusing consent may result in the impossibility of providing certain services and the experience of browsing the site would be compromised.
The data for the security of the site and for the prevention of abuse and SPAM, as well as the data for the analysis of the traffic of the site (statistics) in aggregate form, are processed on the basis of the legitimate interest of the Controller to protect the site and users. In such cases, you always have the right to object to the processing of your data (User’s rights).
Data provided for professional consultancy or assignments are processed on the basis of the performance of a contract and the fulfilment of a legal obligation. In such cases, information is provided.

2. What personal data we process

2.1 Data from navigation
The computer systems and software procedures used to operate this website acquire, in the course of their normal operation, some personal data whose transmission is implied by the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but that by its very nature could, through processing and associations with data held by third parties, allow users to be identified. This data category includes the IP addresses or domain names of computers used by users connecting to the site, the addresses in URI (Uniform Resource Identifier) notation of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the reply given by the server (good end, error, etc.) and other parameters related to the user’s operating system and computer environment.
These data are used only for the purpose of obtaining anonymous statistical information on the use of the site and to check its proper functioning and are deleted after processing. The data could be used to determine liability in case of hypothetical computer crimes against the site, except this eventuality, the data collected through the Site are kept for 12 months.
Regarding IP addresses, it is specified that the Owner uses third-party analysis services (Google Analytics) that use the IP addresses of website users to provide data in reports and install cookies, through the site, also profiling for which you refer to the appropriate information on the site in the Cookie Policy page on this link.

2.2 Data provided by the user
The optional, explicit and voluntary sending of e-mail to the addresses indicated on this Site and the compilation of "formats" (masks) entails the subsequent acquisition of the e-mail address, necessary to respond to requests, and any other personal data communicated voluntarily to the Controller.
Unless you provide additional personal data for the management of your request, for the purposes indicated in this Notice, the Controller processes the following personal data:
● Personal details: name, address, telephone number, e-mail and other contact details;
● data relating to the contract concluded with the Controller.
For the management of your request, including the management of your application, the Data Controller may also process special categories of personal data, such as data suitable to reveal membership in trade unions (office taking, application for deductions for union dues), membership of political parties, religious beliefs (if you would apply to join some religious holidays), as well as the state of health if you voluntarily inform the Data Controller. For the processing of these categories of personal data, the Controller requires your explicit consent to the processing.
Specific summary information will be progressively reported or displayed on the site pages prepared for particular services on request.

2.3 Cookies
Through the Site, the Controller will also process your personal data by using cookies.
For such processing, the Data Controller invites you to consult the Cookie Policy at presenteLINK.
3. What are the purposes of processing
The purposes for which data subjects' data may be processed are attributable to the commercial information activity expressly requested by users interested in the services offered by the Company through the contact form published on this site.
No marketing and/or profiling activities are carried out through this site.
In general, the processing of data takes place for the purposes indicated by time, after your consent. Your personal data is processed:
● without your express consent (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes: conclude contracts for the services of the Data Controller;
● to fulfil the pre-contractual, contractual and tax obligations arising from our relationship with you; Comply with obligations under the law, a regulation, EU legislation or an order of the Authority (such as anti-money laundering); exercise the rights of the Owner, for example the right to defend in court;
● only with your specific and distinct consent (art. 23 and 130 Privacy Code and art. 7 GDPR), for the following marketing purposes: send you by e-mail, post and/ or sms and/ or telephone contacts, newsletters, commercial communications and/ or advertising material on products or services offered by the Owner and detection of the degree of satisfaction with the quality of services;
● send you via e-mail, mail and/or sms and/or telephone contacts commercial and/or promotional communications from third parties (for example partners, other Group companies).
The processing of data collected by the site, in addition to the purposes related, instrumental and necessary for the provision of the service, is aimed at the following purposes:

-Statistics (analysis)
Collection of data and information in an exclusively aggregated and anonymous form in order to verify the correct functioning of the site. None of this information is related to the individual-User of the site, and do not allow in any way identification. Consent is not required.

-Secure
collection of data and information in order to protect the security of the site (spam filters, firewalls, virus detection) and users and to prevent or expose fraud or abuse to the detriment of the website. The data is automatically recorded and may also include personal data (IP address) that could be used
in accordance with applicable laws, in order to block attempts to damage the site itself or to cause harm to other users, or otherwise harmful activities or constitute a crime. These data are never used for identification or profiling of the user and are deleted periodically. Consent is not required.

-Ancillary activitiesCommitting
data to third parties that perform functions necessary or instrumental to the operation of the service (e.g. comment box), and to allow third parties to carry out technical, logistical and other activities on our behalf. The suppliers have access only to personal data that is necessary for carrying out their tasks, and they undertake not to use the data for other purposes, and are required to process personal data in accordance with applicable regulations.

-Professional consultances 
In case of spontaneous sending of data in order to ask for professional advice or for a professional assignment, the data will be used only for the purpose of evaluating the assignment and for the eventual fulfillment of the same. In such cases, information will be provided.

-Sending the Curriculum Vitae
Through the "Work with us" section of the Site or by email you can provide your personal data and CV to the Owner to apply for open positions or for any future positions. Your personal data is processed only for the management of your application and related activities. The legal condition for processing your personal data to manage your application is the need to complete your request, in compliance with article 6, paragraph 1, letter b), GDPR. Therefore, it is not necessary to obtain your prior consent for the processing.
For the evaluation of your application, the Data Controller may also process particular categories of personal data you enter in your CV (for example, your health status, your philosophical or religious beliefs). For the processing of these particular categories of personal data, the Controller needs your explicit consent.

-Requests made through the Site
Your personal data may be processed by the Controller to satisfy your requests made by writing to one of the e-mail addresses available on the Site or by filling in the forms on the Site. Failure to provide the required data will result in the inability of the Owner to complete your request. The condition of lawfulness of the processing
is the necessity of execution of your request, in compliance with article 6, paragraph 1, letter b), GDPR. Therefore, it is not necessary to obtain your prior consent for processing.
For the management of your request, the Data Controller may also process particular categories of personal data transmitted by you to the Data Controller. For the processing of these particular categories of personal data, the Controller requires your explicit consent on the "Contact" page.

-Commercial communications and newsletters
If you want to be updated on the latest news of products and services offered by the Owner you can join our marketing initiatives allowing the Owner to send you the newsletter and other commercial communications related to products and services. The condition of liceity for sending commercial communications and the newsletter is your express consent, which the Data Controller requests you on all pages of the website where it is possible to subscribe to this service, in compliance with article 6 paragraph 1 letter a (GDPR)
Your personal data will be processed until you decide to withdraw your consent or object to the processing.
Right to object to direct marketing activities We inform you that, at any time, you have the right to object to direct marketing activities, by contacting the Data Controller at one of the contacts indicated in point 1 of this Policy or by clicking on the appropriate link present in each communication sent by the Data Controller.

4. Management of the Site
Your personal data described in points 2.1 - 2.3 above will also be processed by the Controller to manage the Site, Complete anonymous statistical analyses on the use of the site to check its proper functioning and/or for the determination of responsibility in case of hypothetical computer crimes against the Site. In any case, these data are processed anonymously and are deleted immediately after processing.
The condition of lawfulness of processing is the legitimate interest of the Data Controller to ensure the correct use of the Site and prevent any possible computer crime, in compliance with article 6, paragraph 1, letter f), GDPR. Therefore, it will not be necessary to obtain your consent. Your personal data will be anonymized immediately and in any case deleted at the end of your browsing session. However, if the information crimes are established, your personal data will be kept for as long as necessary to handle the dispute.

5. Recipients of data
The data provided by the data subject through the contact form will not be transferred to third party companies for commercial purposes or for other purposes. They will be transmitted to those responsible in the commercial and administrative area of the Company to fulfill the actions indicated in paragraph 3 (purpose).
Transfer of collected data to third parties
The data collected by the site are generally not provided to third parties, except in specific cases: legitimate request by the judicial authority and only in the cases provided for by law; if it is necessary for the provision of a specific service requested by the User; for the execution of security checks or site optimization.
Transfer of data to non-EU countries
This site may share some of the data collected with services located outside the European Union. In particular with Google, Facebook and Microsoft (LinkedIn) via social plugins and the Google Analytics service. The transfer is authorised on the basis of specific decisions of the European Union and the Garante for the protection of personal data, in particular decision 1250/2016 (Privacy Shield- informative page of the Italian Garante), for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

6. Processing methods
Your data may be processed in a telematic way. The data of which Romina Marovelli is the holder, are only those necessary for the processing of data related to the services of the website, the Controller uses servers located within the European territory. We inform you that the data will be collected, processed and stored in full compliance with what is provided for in terms of security measures, as well as in accordance with the measures deemed appropriate under the new EU Regulation 2016/679. The data will also be processed in full compliance with the self-regulatory rules on the processing of personal data contained in the codes of ethics applicable to the sector.
Safety measures
We process the data of visitors/users in a lawful and correct manner, taking appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of the data. We are committed to protecting the security of your personal data when you send it, using Secure Sockets Layer (SSL) software that encrypts information in transit. The processing is carried out using computer and/ or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, categories of data subjects involved in the organization of the site or external entities (such as third-party technical service providers, hosting providers) may have access to the data

7. Duration of treatment
The data will be processed for the time strictly necessary to achieve the purposes for which they were collected. They will also remain available to the owner, the responsible and the persons in charge for any retention due to legal obligation (art. 22, paragraph 5, of the Code), only for the necessary duration or until the different date of cancellation request by the user. The maximum duration is however that provided for by law for contractual liability, that is 10 years.

8. User’s rights
In relation to the processing described in this Notice, you may exercise the rights provided for by the articles of the GDPR (from 15 to 21) in particular:
● right of access - the right to obtain confirmation that personal data concerning you is being processed or not and, in such case, to obtain access to your personal data - including a copy thereof;
● right of rectification - where applicable, the right to obtain without undue delay the rectification of inaccurate personal data concerning you and/or the integration of incomplete personal data;
● right to erasure (right to be forgotten) - where applicable, the right to obtain, without undue delay, the erasure of personal data concerning you;
● right to restriction of processing - where applicable, the right to obtain the limitation of processing, when the legal conditions are met;
● the right to data portability - where applicable, the right to receive, in a structured format, commonly used and readable by an automatic device, the personal data concerning you provided to the Controller and the right to transmit them to another;
● right of opposition - the right to object, at any time, to the processing of personal data concerning you based on the condition of the legitimacy of the legitimate interest;
● Revoke your consent - at any time, as easily as you provided it, without prejudice to the lawfulness of the processing based on the consent given before the revocation.
The data subject also has the right to lodge a complaint with the Garante per la protezione dei
dati personali (www.garanteprivacy.it).
The exercise of rights is not subject to any formal restrictions and is free of charge pursuant to Article 12 GDPR. However, in the case of requests manifestly unfounded or excessive, even due to their repetition, the Data Controller may charge you a reasonable fee, in light of the administrative costs incurred in managing your request, or refuse to grant your request. To exercise your rights you must fill in the form of exercise of rights of the interested party on the website of the Guarantor or downloadable by clicking the following link, click here to download the form, and send it to Romina Marovelli, using one of the following methods:
Recommended A.R. addressed to the Office: via Farini 3 Castelnuovo di Garfagnana 55032 Lucca
PEC: (certified e-mail): rominamarovelli@pec.it
Any corrections or deletions or limitations of processing made at your request, unless this proves impossible or involves a disproportionate effort, will be communicated by the Company to each of the recipients to whom the personal data has been transmitted.