Privacy Policy of

    This Application collects some Personal Data from its Users.

    Users may be subject to different levels of protection. Some Users therefore enjoy higher levels of protection. Further information on the protection criteria can be found in the applicability section.

    Data Controller

    Studio Villa Roveda e Associati, with registered office in Milan, at Via Fontana, 18.

    email address of Data Controller:

    Types of data collected

    The Personal Data collected by this Application, either independently or through third parties, include: Cookies and usage data.

    Full details of each type of data collected are provided in the related sections of this privacy policy or in specific informative texts viewed before the data are collected.
    The Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
    Unless otherwise specified, all the Data required by this Application are mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain types of Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
    Users who have doubts about which data are mandatory are encouraged to contact the Data Controller.
    Any use of Cookies – or other tracking tools – by this Application or third party service providers used by this Application, 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, if available.

    The User assumes responsibility for any Personal Data of third parties obtained, published or shared through this Application and guarantees he/she is entitled to communicate or disseminate them, freeing the Data Controller from any liability towards third parties.

    Method and place of processing of Data collected

    Data processing methods

    The Data Controller uses appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
    Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal staff, or system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, media agencies) also appointed, if necessary, as Data Supervisors by the Controller, may have access to the Data. The updated list of Data Supervisors may always be requested from the Data Controller.

    Legal basis for data processing

    The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

    • the User has given consent for one or more specific purposes (Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without needing the User’s consent or another legal justification as specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data);
    • the processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
    • processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
    • the processing is necessary for the performance of a task of public interest or for the exercise of public powers vested in the Data Controller;
    • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

    It is in any case always possible to ask the Controller to clarify the concrete legal basis of each act of processing and in particular to specify whether this is based on law, provided for under a contract or necessary to conclude a contract.


    The Data are processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For additional information please contact the Data controller.
    The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section providing details on the processing of Personal Data.
    In the event of greater protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization of international law which is public or constituted by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
    If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting him according to the contact details specified above.
    Data retention period
    The Data is processed and stored for the time required for the purposes for which it was collected.


    • The Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of this contract is completed.
    • The Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information on the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Controller.

    When processing is based on User consent, the Data Controller may retain the Personal Data for longer, until such consent is revoked. Furthermore, the Data Controller may be obliged to retain the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

    At the end of the retention period the Personal Data will be deleted. Therefore, upon expiration of this term the right to access, cancel, rectify and transfer the Data may no longer be exercised.

    Purposes for Processing Data collected

    The User Data is collected to allow the Controller to provide its Services, as well as for the following purposes: Statistics and Interaction with external social networks and platforms.

    To obtain further detailed information on the purposes of the processing and on the Personal Data that are effectively relevant for each purpose, the User may refer to the relevant sections of this document.

    Details on the processing of Personal Data

    Personal Data is collected for the following purposes and using the following services:

    ·         Interaction with external social networks and platforms

    ·         Statistics

    Rights of the User

    Users can exercise certain rights with reference to the Data processed by the Controller.

    In the event of higher levels of protection, the User can exercise all the rights listed below. In any other case, the User can contact the Data Controller to find out what rights are applicable in his case and how to exercise them.

    In particular, the User has the right to:

    • withdraw consent at any time. The User may revoke consent to the processing of Personal Data previously given.
    • object to the processing of his Data. The User may object to the processing of his data when it takes place on a legal basis other than consent. Further details on the right to object to use of data are specified in the section below.
    • access his Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
    • verify and ask for rectification. The User can verify the correctness of his Data and request that it be updated or corrected.
    • obtain processing restrictions.When certain conditions are met, the User can request restrictions on the processing of his Data. In this case, the Data Controller will not process the Data for any other purpose than to retain them.
    • obtain the cancellation or removal of his Personal Data. When certain conditions are met, the User can request the deletion of his Data by the Controller.
    • receive his data or have it transferred to another data controller. The User has the right to receive his data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to have them transferred to another controller without obstacles. This provision is applicable when the Data is processed by automated tools and the processing is based on User consent, on a contract to which the User is a party or on contractual measures connected to it.
    • submit a complaint. The User can file a complaint with the competent personal data protection supervisory authority or take court action.

    Details on the right to object

    When Personal Data is processed in the public interest, in the exercise of public authority with which the Data Controller is invested, or to pursue a legitimate interest of the Data Controller, Users have the right to object to processing for reasons connected to their particular situation.

    Users are reminded that if their Data is processed for direct marketing purposes, they may oppose processing without needing to provide any reason. To find out if the Data Controller is processing data for direct marketing purposes, Users can refer to the respective sections of this document.

    How users can exercise their rights

    To exercise their rights, Users can send a request to the contact address of the Data Controller as specified in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, and in any case within one month.

    Applicability of higher levels of protection

    While most of the provisions herein apply to all Users, some are expressly subject to the applicability of a higher level of protection in the processing of Personal Data.

    This higher level of protection is always guaranteed when the processing:

    • is carried out by a Data Controller based in the EU; or
    • concerns Personal Data of Users located in the EU and is functional to the supply of goods or services for consideration or free of charge to such Users; or
    • concerns Personal Data of Users located in the EU and allows the Data Controller to monitor the behaviour of such Users to the extent that such behaviour takes place within the Union.

    Additional information about data processing

    Defence in court

    The User’s Personal Data may be used by the Controller in court or to prepare legal action against ill-conduct by the User in the use of this Application or of the connected Services.
    The User states that he is aware that the Controller may be required to disclose the Data by order of the public authorities.

    Specific information notices

    At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

    System log and maintenance

    For needs related to operation and maintenance, this Application and any third party services it uses may collect system logs, that is files that log interactions and may also contain Personal Data, such as the User’s IP address.

    Information not contained in this 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.

    Response to “Do Not Track” requests

    This application does not support “Do Not Track” requests.
    To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

    Changes to this privacy policy

    The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending notification to Users using one of the contact details of which the Data Controller is in possession. Please therefore consult this page regularly, and take note of the “last changed” date specified at the foot of the page.

    If the changes involve processing whose legal basis is consent, the Data Controller will request the User’s consent again, if necessary.

    Legal references

    This privacy statement is drafted on the basis of various legislative orders, including articles 13 and 14 of Regulation (EU) 2016/679.

    Unless otherwise specified, this privacy statement applies exclusively to this Application.


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    Essential cookies

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    If you wish to allow cookies from the site, you can follow the steps below:

    Google Chrome

    • Click on “Tools” at the top of the browser window and select Settings
    • Now locate the “Privacy” section, and select the “Content settings” button
    • Now select ‘Allow local data to be set’

    Microsoft Internet Explorer 6.0, 7.0, 8.0, 9.0

    • Click on “Tools” at the top of the browser window and select “Internet Options”, then click on the “Privacy” tab
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    • Setting the privacy level above Medium will disable the use of cookies

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    • Click on Cookies, then select “Allow sites to use cookies”


    • Click on the Cog icon at the top of the browser window and select the “Preferences” option
    • Click on ‘Protection’, select the option that says ‘Block third-parties and advertising cookies’
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    How to manage cookies on Mac

    If you use a Mac operating system you can follow the steps below:

    Microsoft Internet Explorer 5.0 su OSX

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    • Scroll down until you see “Cookies” in the File Reception section
    • Select the option ‘Don’t ask’

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    Mozilla e Netscape su OSX

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    • Scroll down until you see cookies under “Privacy and security”
    • Select ‘Enable cookies only for the origin site’


    • Click ‘Menu’ at the top of the browser window and select “Settings”
    • Then select “Preferences”, then select the ‘Advanced’ tab
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