Privacy Policy

Privacy Policy (simplified)

The purpose of this privacy policy is to provide maximum transparency regarding the information collected by this website.
In compliance with obligations arising from national legislation (Legislative Decree 30 June 2003 no. 196, Personal Data Protection Code, and subsequent amendments) and European regulations (European Regulation for the Protection of Personal Data no. 679/2016, GDPR), this website respects and protects the confidentiality of visitors and users, making every possible and proportionate effort not to infringe users’ rights.
This website does not display advertising, nor does it use data to send advertising. However, it uses third-party services to improve website usability; these third parties may collect user data and subsequently use it to display personalised advertising on other websites. Nevertheless, this website makes every possible effort to safeguard users’ privacy and minimise the collection of personal data.
For further information, please read the full privacy policy below.

Privacy Policy (full)

Data Controller
The Data Controller under applicable laws is Hermes Consulting, a company located at Via Capo di Mondo 56 int. 2, 50136 Florence, Italy.

Legal Basis for Processing
This website processes data predominantly on the basis of user consent. Consent is granted via the banner at the bottom of the page, or by using or browsing the site, as conclusive conduct. By using or browsing the website, visitors and users approve this privacy policy and consent to the processing of their personal data according to the methods and purposes described below, including any transfer to third parties if necessary to deliver a service. Additional consent relating to specific service purposes is collected through contact or service request forms.
Providing data and consequently granting consent to data collection and processing is optional. The User may refuse consent and may revoke previously granted consent at any time (via the banner at the bottom of the page, the browser cookie settings, or the Contact us link). However, refusing consent may prevent the delivery of certain services and compromise the browsing experience.
Data required for website security, abuse and SPAM prevention, as well as website traffic analysis (statistical data) in aggregated form, are processed based on the Data Controller’s legitimate interest in protecting the website and its users. In such cases, users always retain the right to object to data processing (see section: User Rights).

Purposes of Processing
In addition to purposes related, instrumental, and necessary to provide the service, the processing of data collected by the website pursues the following objectives:

– Statistics (analytics)
Collection of data and information exclusively in aggregated and anonymous form to verify the correct functioning of the website. None of this information relates to the individual User of the website, nor does it permit identification in any way. Consent is not required.
– Security
Collection of data and information to safeguard the security of the website (anti-spam filters, firewalls, virus detection) and Users, and to prevent or detect fraud or abuse harmful to the website. Data are automatically recorded and may include personal data (IP address) which could be used, in compliance with applicable laws, to block attempts to damage the website or harm other users, or any harmful or criminal activities. Such data are never used to identify or profile the User and are deleted periodically. Consent is not required.
– Ancillary activities
Sharing data with third parties that perform functions necessary or instrumental to service operations, and enabling third parties to perform technical, logistical, and other activities on our behalf. Suppliers only have access to personal data required to perform their duties, undertake not to use data for other purposes, and are required to process personal data in compliance with current legislation.

Data Collected
This website collects user data in two ways.

– Automatically collected data
During User browsing, the following information may be collected and stored in the server (hosting) log files of the website:
– internet protocol (IP) address;
– browser type;
– device parameters used to connect to the site;
– name of the internet service provider (ISP);
– date and time of visit;
– referring and exit web page;
– number of clicks, where applicable.

These data are used for statistical and analytical purposes exclusively in aggregated form. The IP address is used solely for security purposes and is not cross-referenced with any other data.

– Voluntarily provided data
The website may collect other data when users voluntarily use services, such as communication channels (contact forms), which will be used exclusively to provide the requested service.

Place of Processing
Data are processed at the Data Controller’s registered office and at the datacentre hosting the website code (OVH sas).

Data Retention Period
Data collected by the website during its operation are kept for the period strictly necessary to perform the specified activities. Upon expiry, data will be deleted or anonymised, unless further retention purposes exist.

Transfer of Collected Data to Third Parties
Data gathered by the site are generally not shared with third parties, except in specific instances: legitimate requests by judicial authorities and solely in cases provided for by law; where necessary to deliver a specific service requested by the User; or to carry out security checks or site optimisation.

Data Transfer to non-EU Countries
This website may share some collected data 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 based on specific decisions of the European Union and the Data Protection Authority, specifically Decision 1250/2016 (Privacy Shield – see the Italian Garante information page), therefore no further consent is required. The aforementioned companies guarantee their adherence to the Privacy Shield.

Security Measures
We process visitor/user data lawfully and correctly, adopting appropriate security measures designed to prevent unauthorised access, disclosure, alteration, or unauthorised destruction of data. We are committed to safeguarding the security of your personal data during transmission, using Secure Sockets Layer (SSL) software, which encrypts information in transit. Processing is carried out using computerised and/or telematic tools, with organisational procedures and logic strictly related to the stated purposes. In addition to the Data Controller, in certain cases, specific categories of personnel involved in the organisation of the website or external entities (such as third-party technical service providers, hosting providers) may have access to the data.

Cookies
This website uses cookies, which are text files stored on the user’s terminal or which allow access to information on the user’s terminal. Cookies allow preferences of visitors to be retained; they are used to ensure the proper functioning of the site and improve its features by customising page content according to browser type, or to simplify navigation by automating procedures (e.g. login, website language, where available), and finally to analyse site usage by visitors.

This website uses the following categories of cookies:

– technical cookies, used solely to carry out the transmission of an electronic communication, to ensure correct website display and navigation. Furthermore, they allow distinguishing between connected users to deliver a requested service to the appropriate user (Login), and for site security reasons. Some of these cookies are deleted upon closing the browser (session cookies), while others have a longer lifespan (such as the cookie required to store user consent regarding cookie usage, which lasts 1 year). Consent is not required for these cookies;

– analytical cookies, used directly by the website operator to collect information, in aggregated form, on the number of users and how they visit the site. These are treated as technical cookies if the service is anonymised.

– profiling and marketing cookies, used exclusively by third parties other than the controller of this website to collect information on user browsing behaviour, interests, and consumption habits, including for the purpose of delivering personalised advertising.

By clicking OK on the banner displayed upon first accessing the site, or by browsing the site, the visitor expressly consents to the use of cookies and similar technologies, specifically to the storage of such cookies on their terminal for the purposes indicated above, or to access information on their terminal via cookies.

Disabling Cookies
The user can refuse the use of cookies and may revoke previously granted consent at any time. Because cookies are linked to the browser used, THEY CAN BE DISABLED DIRECTLY FROM THE BROWSER, thereby refusing/revoking consent to cookie use, or via the banner at the bottom of the page.

DISABLING COOKIES MAY PREVENT THE PROPER FUNCTIONING OF CERTAIN WEBSITE FEATURES; in particular, services provided by third parties may become inaccessible and might not display correctly.

Third-Party Cookies
This website also acts as an intermediary for third-party cookies (such as social media buttons), used to provide additional services and features to visitors, simplify site usage, or deliver personalised advertising. This website has no control over third-party cookies, which are entirely managed by third parties, and has no access to the information collected through them. Information on the use of these cookies and their purposes, as well as instructions on how to disable them, is provided directly by third parties on the pages listed below.

Please note that user tracking generally does not involve personal identification, unless the User is already registered with the service and logged in, in which case the User is understood to have already consented directly to the third party when registering for the service (e.g. Facebook).

This website uses cookies from the following third parties:

– Google Inc.
For information on data use and processing by Google, please refer to Google’s Privacy Policy and Google’s Partner Technologies page.

– Google Analytics: used to analyse website usage by users, compile reports on website activity and user behaviour, check how often users visit the website, how the website is found, and which pages are visited most frequently. The information is combined with information collected from other websites to establish a comparative overview of website usage relative to other sites in the same category.
Data collected: browser identifier, date and time of interaction with the site, referral page, IP address.
Place of data processing: European Union, as the service anonymisation feature is enabled.

The data collected do not allow personal identification of users and are not cross-referenced with other information relating to the same individual. They are processed in aggregated and anonymised form (truncated at the last octet). Under a specific data processing agreement (DPA), Google Inc. (data processor) is prohibited from cross-referencing these data with information obtained from other services.

Further information on Google Analytics cookies can be found on the Google Analytics Cookie Usage on Websites page.

The user can selectively opt out of data collection by Google Analytics by installing the specific opt-out browser add-on provided by Google.

– YouTube: a video-sharing platform owned by Google. Cookies are set upon accessing the page containing the embed and upon starting the video; they do not allow User identification unless already logged into a Google profile.

Social Network Plugins
This website may also incorporate plugins and/or buttons to enable easy sharing of content on your preferred social networks. When you visit a page on our website that contains a plugin, your browser connects directly to the servers of the social network hosting the plugin. That server may track your visit to our website and, where applicable, associate it with your social media account, particularly if you are logged in at the time of your visit or have recently browsed a website containing social plugins. If you do not want the social network to record data relating to your visit to our website, you must log out of your social media account and delete any cookies installed by the social network in your browser.

The collection and use of information by such third parties are governed by their respective privacy policies, to which you should refer.

User Rights
Pursuant to European Regulation 679/2016 (GDPR), the User may, in accordance with the procedures and within the limits laid down by current legislation, exercise the following rights:

– object, in whole or in part, on legitimate grounds, to the processing of their personal data for the purpose of sending advertising materials, direct marketing, market research, or commercial communications;
– request confirmation of the existence of personal data concerning them (right of access);
– know the origin of the data;
– receive an intelligible communication thereof;
– obtain information regarding the logic, methods, and purposes of processing;
– request the updating, rectification, integration, erasure, anonymisation, or blocking of data processed in breach of the law, including data no longer necessary for the purposes for which they were collected;
– in cases of consent-based processing, receive, at the sole cost of any physical medium, their data provided to the controller in a structured, commonly used, and machine-readable format;
– lodge a complaint with the Supervisory Authority (Italian Data Protection Authority – link to the Garante website);
– and, more generally, exercise all rights recognised under applicable legal provisions.

Requests should be addressed to the Data Controller.

Full privacy notice