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Privacy Policy

GIULIO VANZAN as hereafter identified in detail, is in charge of the processing of personal data collected through the website www.segretidellamente.com and considers the privacy of its Users of fundamental importance and guarantees that the processing of personal data is carried out in compliance with the privacy legislation in force, European Regulation nr. 2016/679, the relevant national adaptation legislation D. Lgs. 101/2018 on the protection of personal data and Legislative Decree. 196/2003 to the extent still in force, as amended.
The User is kindly requested to read this Privacy Policy carefully. It should be noted, however, that the same may be subject to revisions, additions, and/or modifications based on legal requirements or as may otherwise become necessary.

Personal data controller and contact information

Dr. GIULIO VANZAN, with registered office in Capoliveri (LI) Località Alberi 2, 57031, C.F. VNZGLI83H02E682K, P. IVA 02062280496 (hereinafter “Data Controller”)
e-mail address: giulio.vanzan[@]gmail.com

Third party data processors

Clickevia S.R.L.: for the implementation and management of the website as well as payments to courses. Personal data collected will also be processed outside the European Economic Area. To obtain information on how Clickevia processes personal data, please click on the hyperlinks provided here: privacy policy. CLICKEVIA S.R.L. Via Pietro Dossena, 11 – 25068 Sarezzo (BS). info@clickevia.it.

Brevo SAS – Politique de confidentialité
55, rue d’Amsterdam 75008 Paris, France
Email: dpo@brevo.com
Personal data collected will also be processed outside the European Economic Area. To obtain information on how brevo processes personal data, the User is asked to click on the hyperlinks provided here: privacy policy.

Aruba Business: for web hosting service.
Company contact details:
Aruba Business S.r.l., in the person of its legal representative p.t., with registered office in Ferrara (FE), Via Gulinelli no. 21/A privacy@staff.aruba.it
D.P.O. contact details: dpo@staff.aruba.it
Personal data collected may also be processed outside the European Economic Area.
For information on how Aruba processes personal data, the User is asked to click on the hyperlinks provided here: privacy policy e cookie policy.
A list of (external) data controllers can always be obtained from the Data Controller.

Types of data collected

Among the Personal Data collected by www.segretidellamente.com independently or through third parties, to whose privacy policy, however, we refer, are: contact data and/or Cookies and/or Usage Data.
More details on the type of data collected are provided in the dedicated sections of this Privacy Policy, or through specific informational texts displayed prior to the collection of such data.Personal Data may be freely provided by the User or, in the case of Usage Data, may be automatically collected during the use of the Site. Unless otherwise specified, all Data requested by www.segretidellamente.com is mandatory. If the User refuses to provide them, it may be impossible for www.segretidellamente.com to provide the service. In cases where www.segretidellamente.com indicates certain Data as optional, Users are free to refrain from communicating this Data, without this having any consequence on the availability of the service or its operation.
Users who may have doubts about which Data are mandatory may contact the Data Controller for clarification.Any use of Cookies by the site or the owners of third party services used by www.segretidellamente.com unless otherwise specified, has the purpose of providing the service requested by the User, in addition to the additional 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 website and warrants that he/she has the right to communicate and/or disseminate it, releasing the Owner from any liability to third parties.

FEATURES, SERVICES, WIDGETS / LINKING LINKS:

Through the forms:

  • For optional, free subscription to the newsletter service
  • To request information / schedule an interview and to sign up for the newsletter (free and optional)

Personal data processed/collected from the contact form (for information request) and to subscribe to the newsletter: first and last name, email address, phone number, usage data.

Through the purchasing process:

  • for purchase of products or services

Personal data processed/collected from the purchase form: first and last name, email address, phone number, address, SDI, PEC email address, usage data.

Services/Third Parties:

  • WordPress
    CMS (content management system) platform for website implementation. To learn about how WordPress processes personal data, please read the relevant privacy policy e cookie policy.
  • Google Recaptcha
    is a Google service/security measure to protect websites from spam and/or abuse by allowing a distinction to be made between human users and automated bots and, in this specific case, to prevent automated form completion and submission by bots.
    For more information on how Google processes personal data, the User is invited to consult the relevant privacy policy e cookie policy and the terms of service of Google by clicking on the hyperlinks given here.
  • Widget / Link to Facebook / Sharing stick.
    Facebook is a product of Meta Platforms Ireland Limited and is a social network. On the website of www.irenesgarbi.it there is a widget/redirect button to the relevant Facebook page and share button. To find out how Facebook processes personal data, please read the relevant cookie policy e privacy policy, by clicking on the links provided here for your convenience.
  • Widget / Link to Instagram
    Instagram is a product of Meta Platforms Ireland Limited and is a social network. On the website www.irenesgarbi.it there is a widget/redirect button to the relevant Instagram page. For information on how personal data is processed and transferred, the User is encouraged to carefully consult the privacy policy, the cookie policy and the terms of use of Instagram.
  • Widget / Link to Whatsapp Messenger (Whatsapp LLC) / Sharing stick
    It is an instant messaging application owned by Whatsapp Ireland Limited. On the website www.irenesgarbi.it there is a widget/redirect button to the Whastapp platform and share button. For information on how personal data are processed and transferred, the User is invited to carefully consult the privacy policy e cookie policy And related terms of service.
  • Widget / Link to Youtube
    It is a web platform for sharing and displaying Google-owned multimedia content on the web. There is a widget/redirect button to Youtube on the website www.irenesgarbi.it. For information on how personal data are processed and transferred, the User is invited to carefully consult the privacy policy, the cookie policy and the related terms of service.
  • Widget / Link to LinkedIn (LinkedIn Corporation)/ Sharing stick
    LinkedIn (LinkedIn Corporation) is a social network for developing professional contacts and for disseminating and sharing specific content related to the job market. On the website www.irenesgarbi.it there is a widget/redirect/share button to the relevant LinkedIn page.
    For information on how personal data are processed and transferred, the User is invited to carefully consult the privacy policy, the cookie policy of LinkedIn.
  • Cookiebot
    The cookiebot plugin (Company Usercentrics A7S Havnegade 39 1058 Copenhagen – Denmark, company registration no. DK34624607) is used for the coookie banner and for managing the User’s consent to the installation of cookies. Cookiebot installs cookies. For information on how Cookiebot processes personal data, the User is kindly requested to view the relevant privacy policy and terms and conditions of service as well as the document “Data Processing Agreement”, i.e. the agreement on data processing.

  • Facebook Pixel
    The Facebook pixel is a portion of code that is applied on the website that allows the effectiveness of advertisements to be measured, giving insight into what actions people perform on the website. The pixel can be used to: show targeted advertisements based on who has visited a particular web page or performed an action on the site in order to increase sales and measure the impact of advertisements in light of Users’ interactions. Facebook pixel performs profiling activities.
    For information on how your personal data is processed, you are encouraged to consult Facebook’s privacy policy and cookie policy by clicking on the links provided here for your convenience.

  • Google Ads
    Google Ads is software that allows you to place advertising space within Google search pages. The User is encouraged to carefully consult the links related to Google’s privacy and cookie policy and terms of service to learn how personal data are processed. Links to Google’s privacy policy and cookie policy and terms of service are provided for your convenience.

  • Google Analytics
    Google Analytics is a free web analytics service provided by Google that allows you to analyze detailed statistics about visitors to the website www.segretidellamente.com
    The User is encouraged to carefully consult the links related to Google’s privacy and cookie policy and terms of service to learn how personal data are processed. Links to Google’s privacy policy and cookie policy and terms of service are provided for your convenience.

  • Whatsapp Click to chat (Whatsapp service to chat with GIULIO VANZAN)
    With this Whatsapp feature, the User can also contact the Owner via Whatsapp by clicking on the relevant logo on the site. This feature allows the User to initiate a direct conversation with the Holder via relevant chat. Personal data processed: user’s first and last name, phone number, Cookies and usage data. For information on the processing of personal data by Whatsapp, the User is invited to consult the relevant privacy policy and cookie policy. Whatsapp is part of the Meta group. Whatsapp could also transfer data outside the European Economic Area.

  • Sendinblue (Brevo)
    Platform to manage sending marketing communications via email, sms, marketing automation, etc. (SENDINBLUE – 7 Rue de Madrid, 75008 Paris, France, French Simplified Joint Stock Company with a registered capital of 387 722 euros, RCS of Paris: 498 019 298, Intra-community VAT number: FR80498019298). For information on the processing of personal data by Brevo (Sendinblue) the User is invited to consult the relevant privacy policy.

Purpose of processing and legal basis

The Data Controller will process Users’ Personal Data, as listed above, in order to carry out its economic and business activities, for the specific purposes set out below.

1. Purposes Pertaining to Purchase, Free Download, Contract and Legal Obligations.

a. Site Navigation;

b. Purchasing services or products on the site;

c. Assistance and customer care activities as well as to respond to requests, complaints, reports and objections from Users via email to the Controller’s addresses or through other communication channels;

d. Download the free resource in e-book format made available through the Site;

e. Handling of User requests via remote communication tools, such as e-mail, chat, banners, notification systems, and other remote communication tools on the Site;

f. Fulfillment of obligations arising from applicable laws, regulations or EU legislation (e.g., tax and accounting obligations) or management of and response to requests from relevant administrative, tax and judicial authorities;

g. Activities of an administrative, accounting and tax nature such as activities related to the contract concluded through the Site, such as, but not limited to, issuing receipts and/or invoices, keeping accounting records;

h. Responding to requests to exercise the rights granted to Users by the contract entered into with the Controller, by the law in relation to that contract, or by the GDPR, and consequent activities.

For these purposes, the Legal Basis is the consent to the processing of one’s personal data (Art. 6.1a), the need to execute pre-contractual and contractual obligations to which the User is a party (Art. 6.1.b) of the GDPR) or the fulfillment of legal obligations to which the Controller is subject (Art. 6.1.c) of the GDPR).

Therefore, their processing is necessary to enable the performance of activities related to consent and pre-contractual obligations through the Site or to respond to requests made by the User in connection with the Site. Failure to provide the data, therefore, will result in the impossibility for the User to carry out the activities indicated above through the Site and/or to receive a response to the requests made.

2. Non-consent-based purposes

i. Ensuring compliance with the Data Controller’s contractual rights, i.e., demonstrating that it has fulfilled its obligations arising from its contract with the data subject or imposed by law, to prevent and/or suppress fraudulent or harmful actions;

The legal basis for this processing is legitimate interest (Art. 6.1(f) of the Regulations). Sometimes the Legal Basis consists of legitimate interest (Art. 6(1)(f) in conjunction with Recital 47 of the Regulations), for sending transactional email communications (e.g., abandoned shopping cart).

3. Direct Marketing Purposes

l. With the User’s consent, we will send commercial emails to show him/her updates, news, offers and promotions, market research, including through automated processing tools such as emails and newsletters.

For this purpose, the processing, including the final decision about the promotional communication to be sent or displayed to the user based on the cluster(s) they belong to, is done in an automated way, without human intervention, based on algorithms whose parameters have been previously set.

The legal basis is the User’s express consent to the processing of personal data for these purposes (Art. 6.1.a) of the Regulations. Providing data for these purposes is optional. In case of non-consent, revocation of the same or exercise of the right to object, the User’s ability to make purchases on the Site will not be affected in any way.

Modification of choices and withdrawal of consent

In case of granting consent, the User may at any time revoke the consent given and/or object to the processing of personal data for generic marketing and profiling purposes through the modalities indicated in the section ‘Rights of Data Subjects’ later in this policy.

If consent is withdrawn, processing carried out on the basis of consent given before its withdrawal will still be considered legitimate. If you withdraw your consent and/or object to the processing of your data for the purpose of generic marketing, your data will no longer be processed for that purpose and will only be retained by the Data Controller in the circumstance that there is another legal basis that legitimizes its processing (e.g., contractual performance; legal obligation; legitimate interest).

Retention period

The Controller will process Users’ personal data for as long as necessary to achieve the purposes for which such data were collected, as defined in this policy. However, for each of the stated purposes, the personal data collected will be kept for the time specified below:

  1. For the purposes inherent to pre-contractual obligations or downloading executable through the Site, the Data Controller will process the User’s data for the time strictly necessary to carry out the individual processing activities, it being understood that, once this period has expired, the Data Controller may retain the data for the purposes and for the maximum retention periods referred to in the other sections of this notice, if relevant and/or, in any case, in the cases established by the GDPR and/or the law.
  2. For tax, administrative, accounting, and legal purposes, until the expiration of the statutory time limits prescribed for the performance of each fulfillment and/or the retention periods prescribed by law.
  3. For purposes based on the legitimate interest of the Controller, the Controller will process the User’s data for as long as is strictly necessary for the satisfaction of that interest, unless, in the face of disputes and/or complaints, the Controller needs to retain personal data in order to carry out defense activities (subsection h) for the next 10 years (of limitation) or, in the case of litigation, further retention is determined by the duration of the litigation or by specific requests from the authority. The User can obtain more information about the legitimate interest pursued by contacting the Owner.
  4. For the purpose of direct marketing, as long as consent is not withdrawn and in any case for a period equal to 24 months from when consent was given or renewed by the User, on the occasion of a new purchase or from the date of the last contact with the User, by which is meant, for example, the opening of the newsletter.

After these retention times, the Personal Data will be deleted and the User will no longer be able to exercise the rights of access, deletion, rectification and portability of the Data.

Communication and dissemination of data

In addition to the Owner, in some cases, they may have access to the Data:

  1. Individuals involved in the organization of the Website (for example: administrative, sales, marketing personnel);
  2. Third parties who perform ancillary and instrumental tasks with respect to the Holder’s activity and who process personal data on behalf of the Holder (for example: lawyers, accountants, system administrators, logistics companies, newsletter services);
  3. Public or private entities that can access the Data in accordance with the law, regulations and measures issued by the competent authorities;
  4. potential purchasers of the Holder company and entities resulting from the merger or any other form of transformation.

These recipients, as the case may be, process Users’ personal data in their capacity as data processors, data controllers or autonomous data controllers. The User may request an updated list of the Processors referred to in Art. 28 GDPR.

Place of processing and transfer of data abroad

Data processing takes place mainly in Italy and in the countries of the European Union. Some third-party tools may process the data of users of this website in countries outside the European Economic Area (the “Third Countries”).

The transfer of data to Third Countries may also occur through the use of external tools that enable certain services (e.g., newsletters, remarketing, advertising, use of social buttons, viewing videos).

Sometimes the use of such tools may involve the transfer of personal data of users visiting this website to a third country for which there is no European Commission adequacy decision.

Should there be a need to transfer data to Third Countries, the Data Controller undertakes to ensure that the country to which the data will be sent guarantees an adequate level of protection, as provided for in Article 45 GDPR; such transfer will be governed on the basis of the standard data protection contractual clauses approved by the European Commission for the transfer of personal information outside the EEA under Article 46.2 GDPR.

Cookie

This Website uses cookies. Cookies are small text files that can be installed by websites on users’ devices to make the browsing experience more efficient and to personalize content and ads, provide social network features, and analyze traffic. To learn more, read the Cookie Policy.

Rights of data subjects

Data subjects have the right to exercise the faculties provided for in Articles 7, 15-22 of the Regulations.

In particular, Users have the right to obtain: the access, updating, rectification or, when they are interested, the integration of data; the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept in relation to the purposes for which the data were collected or subsequently processed; certification that the above operations have been notified, also as regards their content, to those to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate to the protected right.

In addition, Users have the right to revoke their consent at any time, if the processing is based on their consent, to request data portability, i.e., to receive all personal data concerning them in a structured, commonly used and machine-readable format), to request the restriction of the processing of personal data and/or their deletion (“right to be forgotten”), as well as the right to object to the processing of personal data concerning them and to the processing for the purpose of sending advertising material, direct sales and for carrying out market research.

Pursuant to the Applicable Regulations, the Holders inform that Users have the right to obtain the indication (i) Of the origin of personal data; (ii) Of the purposes and methods of processing; (iii) of the logic applied in case of processing carried out with the aid of electronic tools; (iv) of the identification details of the Holders and responsible persons; (v) of the individuals or categories of individuals to whom the personal data may be communicated or who may become aware of them in their capacity as managers or appointees.

Data subjects may exercise their rights, either by sending the Holder an appropriate notice or by using the Data Subject Rights Exercise Form, which can be found at this link, to be sent, duly completed and with signature and attachments, to the Holder by email to: giulio.vanzan[@]gmail.com

Data subjects, should they believe that the processing concerning them violates the Regulations, also have the right to lodge a complaint with the Garante della Privacy as the data protection supervisory authority (Garante per la protezione dei dati personali, headquartered at Piazza Venezia no. 11 – 00187 – Rome(https://www.garanteprivacy.it/).

More information about the treatment

Litigation defense
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of www.segretidellamente.com or for related services. The User declares that he/she is aware that the Data Controller may be obliged to disclose/communicate the Data by order of public authorities.

Specific disclosures
Upon the User’s request, in addition to the information contained in this Privacy Policy, www.segretidellamente.com may provide the User with additional and contextual disclosures regarding specific services, or the collection and processing of Personal Data.

System logs and maintenance
For operation and maintenance purposes, www.segretidellamente.com and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this Privacy Policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided in this Privacy Policy.

Changes to this Privacy Policy
The Data Controller reserves the right to change this Privacy Policy at any time by informing Users on this page. Please, therefore, consult this page regularly, referring to the date of last modification indicated at the bottom of this Policy. If the changes affect processing whose legal basis is consent, the Owner will re-collect the User’s consent, if necessary.

Definitions and normative references

Personal Data (or Data)
Personal data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
This is the information that may be collected automatically through a website (including by third party applications integrated into the site) including, for example: the IP address used by the User who connects, the addresses in URI (Uniform Resource Identifier) notation, 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 operating system used by the visitor, the various temporal connotations of the visit (e.g., the length of time spent on each page), and details about the itinerary followed within the website.

User
The individual using www.segretidellamente.com which, except where otherwise specified, coincides with the Data Subject.

Interested
The natural person to whom the Personal Data refers.

Data Controller (or Owner)
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the means adopted, including the security measures relating to the operation and use of www.segretidellamente.com.

Data Processor (or Manager)
The natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller, as set forth in this Privacy Policy.

www.segretidellamente.com
The Website through which Users’ Personal Data are collected and processed.

Profiling
Any form of automated processing of Personal Data consisting of the use of such Personal Data to evaluate certain personal aspects relating to a natural person, in particular for example, to analyze or predict aspects relating to the professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.

European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document is understood to extend to all current member states of the European Union and the European Economic Area.

Cookie
Small portion of data stored within the User’s device.

Treatment or Processing of Data
Any operation or set of operations, performed with or without the aid of automated processes and applied to Personal Data or sets of Personal Data, such as collecting, recording, organizing, structuring, storing, adapting or modifying, extracting, consulting, using, communicating by transmission, disseminating or otherwise making available, comparing or interconnecting, limiting, erasing or destroying.

Normative references
This privacy policy is prepared on the basis of multiple normative references, including among others also art.13 et seq. of Regulation (EU) 2016/679, Legislative Decree. 196/2003 insofar as it is still in force and the relevant adapting legislation D. Lgs. 101/2018.
Unless otherwise specified, this privacy policy covers only the website www.segretidellamente.com.

Date last updated: 11/02/2025
Please be informed that this is an automatic translation of the italian cookie policy you can find at https://www.segretidellamente.com/privacy-policy/. Please consider only the Italian version to be accurate.