Privacy Policy

INFORMATION ABOUT PERSONAL DATA TREATMENT PURSUANT TO ART. 13
OF THE REGUALATION (EU) 2016/679

Dear User,

pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) we report the information relating to the processing of personal data (hereinafter for short “Data”) to those (hereinafter “Interested Parties” or “Users”) who interact with the web services of the Saturnalia website (hereinafter “Website”), accessible electronically from the address: www.saturnalia.tech, corresponding to the home page of the site (hereinafter termed “Homepage”) nonetheless from the platform available from the address: https://platform.saturnalia.tech (hereinafter termed “Platform”).

This information relates only to the Saturnalia website and not to any other third website that may be consulted or accessed by the user through links on the Website.

Introduction

Ticinum Aerospace srl (the owner of the Saturnalia website, hereafter “Owner” and/or “Holder”) operates a business to business exchange. To do its business, it needs to collect and use certain types of information about the Individuals or Service Users who come into contact with Ticinum Aerospace srl. This personal information must be collected and dealt with appropriately whether it is collected on paper, stored in a computer database, or recorded on other material. This Privacy Notice explains, in the framework of the General Data Protection Regulation (GDPR) of the European Union (EU), what personal data and other information Ticinum Aerospace collects as part of our activities, and how we use or process that information. This information is provided only for the Saturnalia website and not for other websites that may be consulted or accessed by the user through links on the Saturnalia Website.

1. Types of data and how we collect them

Navigation data

The computer systems and software procedures used to operate this Website do acquire, during their normal operation, some personal data as an implicit consequence of using information protocols on the Internet (for example domain names and IP addresses).

This category of data includes IP addresses or domain names of computers used by users who connect to the Site, URI (Uniform Resource Identifier) addresses of the 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 response given by the server (successful, error, etc.), other parameters related to the user’s operating system and IT environment, country from which the user connects, type of internet connection and access provider.

These data, as well as those that may be derived from them, are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Website.

Data provided voluntarily by the user

The user is free to provide the personal data contained in the forms proposed by the Site in order to register there, join certain services of the Site or to request the Owner to send information, advertising or other communications.

The optional and voluntary sending of forms filled out with personal data of the user or of e-mails to the addresses indicated on this Site involves the processing of transmission data (e.g.: sender’s email address) as well as those contained in the letter (including the attachments). This is necessary to fulfill the User’s requests.

Specific summaries will be provided or visualised in the Site’s pages prepared for particular services that may be requested and, if necessary, shall be subject to the interested party’s consent.

Third Party Data Provided Voluntarily by the User

In case the user provides personal data of third parties (for example so that third parties are invited to visit or register for the services of the Site), the user must be aware that, to do so, it is necessary that he/she has obtained beforehand the recipient’s prior consent to the communication of his/her email address to Saturnalia, in order to allow Saturnalia to send him/her, at the user’s request, the invitation to visit and/or register for the services of the Site.

Cookies

Cookies are identifiers that are transferred to the User’s machine in order to allow its recognition and to consequently enable the Site to offer the User some features, including the ability to save shopping cart items between visits.

a. session cookies, i.e. cookies that are not permanently stored on the user’s computer and disappear when the browser is closed. Their function is strictly limited to the transmission of session identifiers necessary to allow safe and efficient browsing of the site, as well as the indication of the Javascript support of the user’s browser. The session cookies used on the Site avoid the use of other computer techniques potentially prejudicial to the confidentiality of the navigation of users and do not allow the acquisition of personal data identifying the user.

b. persistent cookies, i.e. cookies that remain stored on the hard drive of the computer until their expiry or explicit erasure by users/visitors. Through persistent cookies, users/visitors who access the site (or any other users who use the same computer) are automatically recognized at each visit.

c. third-party cookies are specified below according to the type of servic

To handle tags, the website takes advantage of the following service

Google Tag Manager –  Google Ireland Limited

Google Tag Manager is a service to handle tags enabling quick and easy updates of monitoring scripts and relative pieces of source code, know as tags on the website. The service is provided by Google Ireland Limited.

Session cookies

Mapbox – Mapbox Inc.

Mapbox is a service by Mapbox Inc. used on the platform to allow navigation in three dimensions.

Place of processing: USA –  Privacy Policy

Registration and authentication cookies (also known as sign on or OAuth)

After sign in or log in, the user allows to be identified, through third parties, to the service. Third parties can, through their authentication service, allow the registration to the site and give access to some Data, preserved by third parties, with the needed purpose for sign in or log in.

The following services could use personal Data also for targeting and profiling scopes; for all details it is suggested to read the privacy and policy indicated for every sign on and authentication service.

Facebook Authentication – Facebook Ireland Ltd

Place of processing: Ireland – Privacy Policy

Linkedin Single Sign on – Linkedin Corporation 

Place of processing: USA – Privacy Policy 

Google LLC – Google Ireland Limited

Place of processing: Ireland – Privacy Policy 

Sign in with Apple – Apple Inc

Place of processing: USA – Caratteristiche del servizio – Privacy Policy 

Twitter Log in – Twitter Inc 

Place of processing: USA –  Caratteristiche del servizio – Privacy Policy

Use of content from external platforms

This type of service allows the user to interact and use content hosted by external platforms directly through the site. This type of service could register web traffic where the service is installed even when the user doesn’t use it.

YouTube video Widget – Google Ireland Limited

Place of processing: Ireland – Privacy Policy 

Analytics and tracking cookies

Third party services reported in this section allow the site Holder/Owner to monitor and analyse web traffic and can be used to track and know how the site is used by users.

Google Analytics –  Google Ireland Limited

Google Analytics is a web analysis service provided by  Google Ireland Limited with the aim to collect and analyse the site usage, make reports on activities and share this information also with other Google services. Google can use collected data with the purpose of contextualizing advertising content on its advertising network.

Place of processing: Ireland – Privacy Policy – Opt Out

Google Ads conversion tracking – Google Ireland Limited

Google Ads conversion tracking service provided by Google Ireland Limited connects Google advertising network with users actions on the site.

Place of processing: Ireland –  Privacy Policy – Opt Out

Ads conversion tracking/Facebook pixel – Facebook, Inc.

Ads conversion tracking/Facebook pixel is a web service provided by Facebook Inc. or Facebook Ireland Ltd. -depending on which country the user connects from- connecting Facebook advertising network data to users’ actions on the site. Facebook pixel tracks conversion of advertisements that may be published on Facebook, Instagram and Audience Network.

To know how Facebook uses data of its own registered users it is recommended to check out the Facebook’s data policy.

Place of processing: USA – Privacy Policy

Yandex.Metrica – Yandex Oy, Finland

The service allows the Owner of the site to monitor and analyze web traffic, to track and know the use of the site by users.

Place of processing: Finland – Privacy Policy

Users database management

This type of service allows the Owner to manage and treat users data from the site and to track for statistical purposes users activities and match them with public information (such as social network profiles) in order to upgrade the service provided by the site. Scheduled messages are also planned for users such as emails based on specific actions carried out on the site.

Active Campaign – Active Campaign Inc

Place of processing: USA – Privacy Policy

Hubspot – HubSpot Inc

Place of processing: USA – Privacy Policy

Heat mapping and session recording

The site uses a heat mapping and sessions registration service by which it is possible to know mouse movements and clicks giving useful information about users’ interested points on visited pages. The service monitors and analyses web traffic and tracks actions on the pages. The service monitors the navigation on pages related to the site www.saturnalia.tech and monitors the users’ sessions on the platform.saturnalia.tech platform. This service allows to take vision of the users’ sessions in playback. 

Place of processing: Italy

Yandex.Metrica – Yandex Oy, Finland

The service allows the Owner of the site to register sessions through which it is possible to know the movements of the mouse and clicks, providing useful information to know the points of interest for users on the pages visited. This service allows the Owner to view the visit sessions in playback.

Place of processing: Finland – Privacy Policy

Targeting & advertising cookies

The following services are used for promotion and advertising. Advertising communication may be through banners or other digital supports defined by third parties. Services may use cookies for user’s tracking and retargeting in order to submit ads in accordance with users interests and behaviour also outside the site.

Facebook Audience Network – Facebook Ireland Ltd.

To learn how Facebook uses its registered users data it is recommended to read Facebook’s data policy.

The site may use identifiers for smartphone devices among which Android Advertising ID or iOS Advertising Identifier and similar technologies for Facebook Audience Network operation.

The service is based on users’ preferences and on content posting based on preferences.  To manage its own preferences the users may check its own Advertising setting section.

Place of processing: Ireland – Privacy Policy – Opt-out

Facebook Lookalike Audience –  Facebook Ireland Ltd.

Facebook Lookalike Audience is a Facebook Ireland Ltd. service that allows to show advertising contents to Facebook users with similar interest and behaviour to the site users that are already in a list as service’s users and to their interest in the same relevant context.

Place of processing: Ireland – Privacy Policy –  Opt-out

Remarketing and retargeting cookies

The following services allow the site to perform promotional activities targeting users that have already browsed the site.

Remarketing with Google Analytics – Google Inc.

Remarketing with Google Analytics is a web service provided by Google Inc. or from Google Ireland Ltd., depending on which country the user connects from. The service relates the site with Google Ads advertising network and the DoubleClick Cookie.

Place of processing: USA – Privacy Policy – Opt-out

Facebook Remarketing –  Facebook Ireland Ltd.

Facebook Remarketing service connects site activities with Facebook Advertising Network based on site visits and users’ behaviour profiles and interests.

Place of processing: Ireland – Privacy Policy –  Opt-out

Payment systems

The Owner of “Saturnalia” service uses for the payment of service/products – as reported in the site specific section – third parties payment systems. Credit card details and sensitive data are not managed by the Owner and are processed with the following service:

Stripe  Stripe Payments Europe Limited 

Place of processing: Irlanda – Privacy Policy

The Owner of the service “Saturnalia” provides  to Stripe – as service provider – only necessary user’s details for the payment (amount) and for fiscal document emission related to service/product purchase defined in the user’s cart.

The User can refuse at any time to use cookies by selecting the appropriate setting on his/her browser, but this may slow down or prevent the User from accessing all the features of the Site; the user can select – by means of the cookie banner – the type of cookies he/she to enable. By clicking on “Accept all”, the user confirms his/her will to enable all services available on the website, including those third-parties cited before.

Usage of cookies can be modified by means of the cookie banner from the website or cookies can be deleted by the user using the appropriate option of the User’s browser.

Link to most-used browsers:

2. Purpose of the processing of data

The collection and processing of data are aimed at the following activities:

a. purposes strictly related to the interaction with the Site and the provision of the Services offered therein, in compliance with the applicable general conditions of use;

b. administrative and accounting purposes, including the electronic transmission of commercial invoices;

c. purposes related to the fulfilment of obligations under law, regulations, Community law and the protection of public order, the detection and prosecution of crimes;

d. management and processing of requests for information;

e. subscription to Saturnalia’s mailing lists and/or newsletters and provision of information and/or commercial communications at a distance by e-mail, post, sms or other means of electronic communication by Saturnalia on the products and services also offered by its commercial partners, in any case without transfer of the User’s personal data to third parties.

  1. Provision of data and consent

The provision of the personal data indicated above for the purposes referred to in points (a) – (b) is optional. However, since such processing is necessary to allow the registration of the Site pre-ordered for the provision of certain services including the sales service and the activities related to it, any refusal to provide the data in question will make it impossible to complete the registration procedure and, therefore, to use the aforementioned services including purchasing services on the Site.

The provision for the purposes referred to in point (c) is mandatory.

The provision of the personal data reported above for the purposes referred to in point (d) is optional. However, since such processing is necessary to allow the fulfilment of the request for information sent to Saturnalia, refusal to provide the data in question will make it impossible to fulfill the request.

The provision of data for the purposes referred to in point (e) is optional and failure to provide consent will not result in any consequence on the relationship, including contractual, with Saturnalia.

The User may, in any case, change their consent for one or more of the purposes indicated above at the time of each new entry in the dedicated section of their “Profile”, clicking on “Privacy Policy” at the bottom of the notices/ and-mail received, or by contacting the Data Controller at the addresses indicated at the end of this statement.

4. Method of treatment

Personal data will be processed in paper and/or electronic format, using automated procedures. The processing is carried out directly by the organization of the Data Controller or by persons external to that organization, as Data Processors and/or Data Processors, as well as by service companies, as Data Processors and/or Data Processors. The data will be processed for the time strictly necessary to achieve the purposes for which they were provided and the related computer media will be protected by the adoption of the security measures as per the GDPR regulations.

  1. Place of processing, communication and dissemination of data

The processing of personal data relating to the Website [“in hosting” at cloud services Microsoft Azure, Microsoft Corporation], will be carried out at the registered office of the owner of the Website and, functionally, at the server farm of the provider the Website is hosted on.

No data deriving from the web service will be communicated or disseminated outside of the hypotheses expressly provided by the Law.

Any communication and/or diffusion of data will be possible only where explicitly indicated and with the consent of the interested party.

The Data Controller may communicate the data of the interested party to certain parties, appointed by the Data Controller for the provision of instrumental services or necessary for the execution of obligations related to the registration to the Website and online purchase, within the limits and in accordance with the instructions given.

In particular, to exemplify, the data of the interested party may be communicated to:

  • companies and internet providers responsible for sending advertising material on behalf of Saturnalia;
  • persons responsible for accounting and invoicing;
  • legal and tax advisors of the Owner;
  • companies and consultants who may be in charge of installing, maintaining, updating and, in general, managing Saturnalia’s hardware or other hardware used by the latter for the provision of its services;
  • the entity or entities that manage online payment transactions;
  • the persons who carry out the after-sales assistance activity on behalf of the Owner;

Within the limits provided by law, personal data may be transferred to countries of the European Union and to third countries with respect to the European Union that guarantee adequate levels of protection as defined in the GDPR.

6. Rights of the data subject

GDPR confers on the interested party the exercise of specific rights, including:

  • to know what personal data is collected about them, why, who is collecting data, how long it will be kept, how they can file a complaint, and with whom will they share the data;
  • submit subject access requests and attain information from the organization about whether their personal information is being processed;
  • ask the organization to update any inaccurate or incomplete data they have on them;
  • ask for their personal data to be deleted;
  • limit the way the organization uses their personal data, in some specific cases;
  • obtain their own personal data that they have previously provided to the organization in a structured, commonly used, and machine-readable format;
  • object to the processing of personal data at any time, in certain situations;
  • ask not to be subjected to automated decision-making if it is producing a legal effect that significantly affects them.

The interested party may assert the aforementioned rights by contacting the Data Controller. The Owner will consequently take reasonable and proportionate steps to comply with the request.

Should you want to exercise any of the rights above, please mail info@ticinumaerospace.com ‘FAO Data Protection Officer’.

7. Data Controller

Ticinum Aerospace srl, Via Ferrini 17/C, 27100 Pavia (e-mail: info@ticinumaerospace.com)  by means of its legal representative is the Data Controller under the General Data Protection Regulation (GDPR), which means that it determines what purposes the held personal information will be used for. 

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