This “Privacy Policy” has been drawn up by Intertubi S.p.A., with its registered offices in Brescia, Via Orzinuovi No 57 (hereinafter “Intertubi”), pursuant to EU Regulation 2016/679 on personal data protection (hereinafter the “Privacy Code”), in order to outline the management procedures of the website www.intertubi.com (hereinafter the “Website”) and of the services made available through the Website by Intertubi (hereinafter the “Services”) regarding the processing of users’ personal data who visit the Website and/or use its Services (hereinafter the “Users”).

This Privacy Policy only applies to the Website and not for any other websites that Users may visit via links.

1. Our Policy
Everyone has the right to personal data protection. Intertubi respects the rights of its Users to obtain information on the collection and other processing operations of their personal data. Pursuant to the provisions of the Privacy Code, when processing any data that could directly or indirectly identify the User, Intertubi shall only process data that is strictly necessary.
Consequently, Intertubi has designed the Website to minimise the use of the User’s personal data and to exclude the processing of personal data when we can provide services in individual cases through the use of anonymous data or any other means which identify the User only when it is necessary or requested by the authorities.

2. Personal data collection
Subscription to the Newsletter
It is free to browse the Website and does not require any prior registration.
However, to use certain Services made available for Users, they shall need to register beforehand under a special section of the Website.
Only with express consent from the User will this data be used for a whole series of additional activities.
In particular, registration is required to receive newsletters from Intertubi via e-mail to the address indicated by the User, which will keep Users up-to-date about Intertubi’s exclusive initiatives and its commercial news (hereinafter the “Newsletter”).

Reserved Area/Intertubi Web Portal
Moreover, there is an area of the Website which is not freely accessible to all Users: in fact, by clicking on the area marked in yellow on the Website’s header, known as the “Reserved Area”, the User shall be redirected via a link to the “Intertubi Web Portal”, Intertubi’s commercial web portal which can be accessed by entering your username and password. The Intertubi Web Portal is only for Users who are already Intertubi customers and have been allocated and sent personal usernames and passwords by Intertubi during the commercial relationship. In fact, these log-in details, which identify a given customer, allow Users to access the private area where they can easily view, find and share private data and information on their commercial relationship with Intertubi.  

Data provided voluntarily by the user
If the User sends e-mails optionally, explicitly or voluntarily to the addresses indicated on the Website, the sender’s address and any other personal data included by the User will then be acquired to reply to the requests.
Similarly, if the User provides personal data under the “Contacts” section of the Website, this data voluntarily entered by the User in the appropriate fields will then be acquired by Intertubi and processed to reply to the messages and/or requests sent to Intertubi. This is also done to receive commercial, promotional and/or advertising material via e-mail to the address indicated by the User or by telephone.

Browsing data
During their ordinary course of operation, the IT systems and software procedures required to run this Website will acquire certain personal data, the transmission of which is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects. However, by its very nature, it may identify users through the processing and matching of data held by third parties.
This category of data includes the computer IP or MAC addresses of users who visit the Website, as well as the URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the reply from the server (successful, error, etc) and other parameters relating to the operating system and computer of the user.
This data is only used to extract anonymous statistical information on how the Website is used and to ensure that it is running properly.

Cookies
Cookies are files or bits of information that are stored on the hard disk of the user’s computer (i.e. files sent by the website server to the user’s browser) while browsing websites.
The cookies saved on the User’s computer cannot be used to recover any data from the hard disk, spread computer viruses or identify and use the User’s e-mail address. Each cookie is unique to the browser and device used by the User to access the Website.

* Types of cookies used

Intertubi only uses technical cookies, i.e. cookies that help speed up the browsing and use of its Website.
More specifically, these include:

Necessary Cookies
These cookies are essential for browsing the Website; they enable various tasks such as authentication, validation and management of browsing sessions, as well as fraud prevention.

Functional Cookies
These cookies provide additional features and enable the tracking of Users’ preferences, such as language selection or font size.

Performance Cookies
These cookies track the pages visited most often by Users and their activity on the Website. They also immediately identify and resolve any technical problems which the User might encounter when browsing the Website. These cookies store aggregate, anonymous information which is not used to collect personal data for advertising purposes.

Session Cookies
Session cookies aim to speed up the analysis of Internet traffic and to help the User access the services offered by the Website.  
They do not acquire Users’ personal data for the website. No Cookies are used to send personal information, nor are any type of persistent cookies or user tracking systems.
Session cookies are only used to send session identifiers (consisting of random numbers generated by the server), which are required to allow secure and efficient browsing of the Website.
The session cookies used by this Website mean that we do not need to use any other IT procedures that could potentially jeopardise the confidentiality of user browsing, nor do they acquire any personal data that could identify the user.

First-party and third-party cookies
The aforementioned categories of cookies are used directly by Intertubi; they are therefore “first-party cookies” from the Website.
However, technical cookies are also used from third-party websites, which are sent to the User’s computer via the Website: these are known as “third-party” cookies.
These “third-party” cookies include analytics cookies, i.e. cookies that are used by website operators to collect aggregate information on the number of users and how they use the website, and therefore to compile general statistics on the service and how it is used.
The analytics cookies used by Intertubi are provided by Google Inc. through its Google Analytics service. Google Analytics uses cookies so the Website can analyse how Users use the Website. The information generated by these cookies on the use of the Website (including IP addresses) will be sent to Google Inc. and saved on servers located in all likelihood in the United States. Google will use this information to assess how the Website is used, to compile reports on the Website activity and to provide other services on the Website activity and on Internet use. Google may also send this information to third parties when required by law, or when these third parties process this information on behalf of Google. Google will not match the user’s IP address to any other data held by Google. Nevertheless, Google might technically be able to identify individual users based on the data obtained by processing.
To this end, please see the cookie policy and its relevant consent form at https://tools.google.com/dlpage/gaoptout?hl=en, where you will also be able to disable the Google Analytics service and therefore stop data from being sent to Google Inc.
The cookies sent by Google Inc. as part of its Google Maps service, which are used by Intertubi on the Website, are also “third-party” cookies.
Google sends a certain number of cookies to web pages that contain a map provided by the Google Maps service, most of which are used to obtain information and save the number, behaviour and preferences of users every time they visit web pages containing Google Maps.
These cookies, some of which are semi-persistent cookies that expire 2/10 years after the last visit to a page containing Google Maps, can also be disabled by Users by changing their browser preferences, following the instructions indicated below.
For more details, Users can read Google’s policy on the types of cookies used as part of its services provided to users http://www.google.com/policies/technologies/types/.

* Users’ rights

Cookies will only be used on the Website after data subjects have given their consent.
Users can agree to the use of cookies by clicking on “OK” on the banner shown when they first access the Website on its homepage, or by closing the banner and scrolling down the homepage, or by clicking on any part of the screen (thereby scrolling down).
However, please remember that the consent requested on the aforementioned banner only refers to the use of “third-party” technical cookies and not for first-party technical cookies.
To disable the use of first-party technical cookies, Users must change their browser preferences by following the instructions below.
If the data subject refuses the use of cookies, they will not be used but certain services may be restricted. In this case, some of the Website’s functions might not run properly and certain services might not be available. Cookies cannot and will not be used to collect Users’ e-mail addresses, nor will they be used to obtain information from Users’ hard disks or their personal and/or sensitive data.
All Users can therefore disable cookies through the software they use for browsing the Internet (i.e. their “browsers”). Many browsers are set up to accept cookies, unless instructed otherwise by the User.
Consequently, Intertubi invites Users to check the cookie settings on their browsers and to edit them according to their preferences.
The configuration for managing cookies and User preferences is different for each browser. They can be found under the menu of the browser guide and will show you how to change your cookie preferences.
• For Internet Explorer™: click here
• For Safari™, Safari on iPhone, iPad, or iPod touch: click here
• For Chrome™: click here
• For Firefox™: click here
• For Opera™: click here
To manage their cookie preferences, Users can also consult the website http://www.youronlinechoices.com/uk/ and change, at their discretion, their cookie settings.

3. Optional data provision
Apart from the specifications on browsing data, the User is free to provide personal data when registering under the “Contacts” section or when subscribing to the Newsletter service, or when sending e-mails containing certain personal data, for example, to request information and/or commercial material or any other communications.
Please note that if Users fail to provide this data to Intertubi, it may not be possible to fulfil their request.

4. Data controller
The Data Controller of Users’ personal data is Intertubi S.p.A., with its registered offices in Brescia, Via Orzinuovi No 57, tax code and VAT No 02092360177.
You may also ask Intertubi for the updated list of all the other Data Supervisors, specifically appointed pursuant to Article 29 of the Privacy Code, by sending your request to the following e-mail address: privacy@intertubi.it.
For any other requests, information, clarifications and/or questions on the processing of personal data, please send a written request to Intertubi at the following e-mail address: privacy@intertubi.it.
 
5. Processing methods and purposes
Data storage and access
In its capacity as the Data Controller, Intertubi will, either directly or through specifically appointed Supervisors, save Users’ personal data onto special databases stored on servers provided by the company Glacom Italia S.r.l., with its registered office in Toscolano Maderno (BS), Via Trento No 124. The management, maintenance and updating of the Website is outsourced to this company – with the sole exception of the “Reserved Area” which is run by the Data Controller through programs installed on the servers of the company Virgilio Cena & Figli SpA, with its registered office on Via Oberdan No 39, Brescia – which also provides hosting services for Intertubi, guaranteeing that all necessary security measures are complied with pursuant to Italian and European legislation on proper personal data processing and protection.
The servers made available for this hosting service are located in Italy.
The data is therefore only processed by staff, including technical staff, who are in charge of the processing in accordance with the principles of fairness, lawfulness, transparency and relevance, and will not exceed the purposes of the collection and the subsequent processing.
The databases can only be accessed by authorised individuals using procedures that guarantee the protection and confidentiality of data due to the adopted security measures for the prevention of data loss, unlawful or improper use and unauthorised access. The data will only be stored for the time strictly necessary to process Users’ data, depending on their choices, preferences and instructions.

General processing
Intertubi will use Users’ data in line with the choices they have freely made by giving their consent when the data was collected and/or thereafter. It will also use this data to comply with legal obligations, regulations and European Directives.
Personal data is processed with automated means for the time strictly necessary to achieve the purposes for which it has been collected.
This processing may involve the collection, processing, recording and/or storage of personal data. The personal data of Users who ask for information and/or documents (answers to questions, additional documentation, etc) is only used to perform the requested service and is only disclosed to third parties when it is strictly necessary to handle the User’s request.

Processing operations subject to the consent, communication and circulation of data
Only with express authorisation from the User will Intertubi proceed with the processing of Users’ personal data through the use of automated means for the purposes authorised each time by the User. In order to properly perform the activities requested by Users, Intertubi will disclose the personal data provided by Users to third party companies, co-controllers or external data supervisors appointed to perform certain activities.
This data will not be circulated.

6. Security
Personal data is collected and stored securely through the use of technical and organisational procedures and measures adopted to protect and secure the information and data collected on the Website.

7. Links to external content
The Website might connect or direct you to other websites, services, social networks or external content beyond Intertubi’s control. Once the User has left the Website, Intertubi cannot protect the User’s personal data or be held liable for the protection and privacy of any personal data that the User might provide to other websites.

8. Users’ rights
Pursuant to Article 7 of the Privacy Code, Users have the right to obtain confirmation of the existence or otherwise of their personal data, even if not yet recorded, and to request the communication of this data in an intelligible form.
Data subjects have the right to obtain information on:
a) the source of their personal data;
b) the purposes and methods of the processing;
c) how the processing is done if electronic tools are used
d) the identity of the data controller, the data supervisors and the designated representative pursuant to Article 5, paragraph 2;
e) the subjects or categories of subjects to whom the personal data may be disclosed or who may come across this data in their capacity as the designated representative of the State, the data supervisor or data processor.
Data subjects have the right to:
a) update, correct or, where relevant, supplement their data;
b) cancel, anonymise or block any data being processed illegally, including any data which is being stored unnecessarily in relation to the purposes for which it was collected and subsequently processed;
c) receive confirmation that the parties to which the data has been disclosed or circulated have been notified of the operations specified under points a) and b), including their content, except in cases where this notification proves impossible or requires the use of methods clearly disproportionate to the right being protected.
Users have the right to object, wholly or in part:
a) to the processing of their personal data, on legitimate grounds, even if this data is relevant to the purpose for which it was collected;
b) to the processing of their personal data for the purpose of sending advertising or direct sales material, or for carrying out market research and commercial communications.
You may exercise the aforementioned rights by writing to Intertubi at the following e-mail address: privacy@intertubi.it.

9. Changes to this Privacy Policy
While Intertubi will not perform any processing operations other than those expressly authorised and/or requested by each User, this Privacy Policy may be amended in order to comply with new legislation or if Intertubi changes its data processing policies.
Every updated version of this Privacy Policy will be published on the Website under the appropriate section: Intertubi therefore invites all Users to regularly check the Website to keep up-to-date with the latest uploaded version.