INFORMATION ON THE PROCESSING OF PERSONAL DATA of users who visit the website www.languagerome.com pursuant to article 13 of (EU) Regulation 2016/679
Protection of users’ privacy is very important to Language Rome Srls.
We therefore decided to draw up and publish a downloadable detailed document relating to the site’s privacy policy.
This privacy policy (“Privacy Policy”) describes personal data processing activities carried out by Language Rome Srls through the website www.languagerome.com and the related commitments undertaken by the Company.
Language Rome Srls can process the user’s personal data upon visiting the Site and using the services and features thereupon. In the sections of the Site where the user’s personal data is collected, specific information is generally published pursuant to art. 13 of EU Reg. 2016/679 and, before sending, the user’s specific consent is required.
Where required by EU Reg. 2016/679, the user’s consent will be required before proceeding to the processing of personal data.
For further information concerning Italian privacy law, visit the official website of the Guarantor for the protection of personal data.
In particular, please be informed that the “owner” of the treatment pursuant to the Privacy Code is LANGUAGE ROME SRLS whose address is Via Bruno Buozzi 19, 00197 Rome and that can be contacted by using the following email address: info@languagerome.com.
Type of data processed
Visiting and consulting the Site does not generally involve the collection and processing of the user’s personal data except for browsing data as specified hereby.
Browsing data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its proper functioning; data may also be used to ascertain responsibility in case of hypothetical computer crimes against the site (legitimate interests of the owner), for statistical purposes, to improve browsing and site contents.
In addition to the so-called “browsing data”, personal data voluntarily provided by the user may be processed when he/she interacts with the functionality of the Site or requests to use the services offered on the Site.
The personal data that LANGUAGE ROME SRLS processes to provide its online services generally concerns:
• identification data (for example: name, surname, address, telephone, fax, e-mail, etc …);
Your personal data is collected by LANGUAGE ROME SRLS upon use of our services.
Your personal data is collected and processed using electronic and, in any case, automated tools. In some cases, automatic collection tools, such as “cookies”, may be used to allow you to take advantage of some personalized services.
Purpose of the treatment
The personal data that the Data Controller gains is that provided by you when browsing.
In addition, your personal data will be processed in addition to the purposes related to the provision of the service and, therefore, to allow you to use our website, also for the following purposes:
• Allow you to use our website
• Collection of data and information in an exclusively aggregated and anonymous form in order to verify the proper functioning of the site
• Collection of data and information in order to protect site security
• Communicate data to third parties who perform functions necessary or instrumental to the operation of the service
• The fulfillment of specific obligations under the law, regulations and applicable EU legislation.
• In addition, the protection of personal data in cases identified by the Guarantor, pursuing a legitimate interest of LANGUAGE ROME SRLS or a third party, such as, for example, protection from scams or other behavior that is contrary to the Agreement for users, as well as to assert and defend a right in court;
Moreover, with the further and specific optional consent of the user, Language Rome Srls may process personal data for the following purposes:
• Marketing Activities: to send the user promotional material and/ or commercial communications relating to the Company’s services, to the specified addresses
• Profiled Marketing Activities: analysis of your preferences, habits, behaviors, interests inferred in order to send you personalized commercial communications / carry out targeted promotional actions, business intelligence. The processing of your personal data for profiling purposes will take place, in case of consent (located on the banner at the bottom of the page), with data processing tools which, following a crosscheck, will create your commercial and behavioral profile on the web.
Legal basis
This site processes data mainly based on user consent.
The consent is provided by means of the banner located at the bottom of the page, or by using and consulting the site, as conclusive behavior.
By using or consulting the site, visitors and users approve this privacy policy and consent to the processing of their personal data in relation to the methods and purposes described.
The provision of data and therefore consent to the collection and processing of data is optional, the User can deny consent, and can revoke at any time an already provided consent (through the banner at the bottom of the page or browser settings for cookies, or Contact link). However, denying consent may make it impossible to provide certain services and the browsing experience on the site would be compromised.
Concerning the purposes of direct marketing and profiled marketing, they take place with explicit and distinct consent; consent is optional and non-acceptance does not entail any consequence.
However, if you do not give your consent, we will not be able to send you our newsletter containing promotional material and/ or commercial communications relating to the Company’s services and/ or send you personalized commercial communications / carry out targeted promotional actions, business intelligence.
At any time, you will have the opportunity to verify and revoke any consent provided for these purposes.
The data collected for site security purposes, abuse prevention and statistics, are processed based on the legitimate interests of the data controller.
Processing methods
Personal data will be processed in paper, computerized and digital form, pursuant to the provisions of art. 32 of the GDPR 2016/679 concerning security measures, by specifically appointed persons and in compliance with the provisions of art. 29 GDPR 2016/679.
Data Recipients
The data processed will not be disclosed to third parties. However, they may become aware of your data, in relation to the aforementioned processing purposes:
• all subjects to whom the right of access to such data is recognized depending on regulatory provisions;
• employees of the company appointed as “authorized individuals”
• to all those natural and / or legal persons, public and / or private when communication is necessary or functional for the performance of our business and in the ways and for the purposes illustrated above;
• external managers for the maintenance of the website;
• State financial administration and P.A.;
• Judicial authorities and police departments;
• banks and credit institutions, debt collection companies, private risk centers;
• Company consultants and professional firms (legal, accounting, tax consultants, etc.);
• participants in the Property Rights Verification Program (VeRO) (if LANGUAGE ROME SRLS receives a formal request from the judicial authority in relation to investigations regarding the alleged violation of their intellectual property rights);
• Google AdWords (thanks to the updating of your navigation cookie that inserts your computer in a segment of public interested in the service offered by LANGUAGE ROME SRLS’ advertising);
• conversion monitoring (the site uses advanced action monitoring functions, this service is provided by Google and the data is collected anonymously);
• Google Analytics (this monitoring technology records your IP address anonymously and inserts it inside a chart that allows the marketing staff of LANGUAGE ROME SRLS to analyze traffic and visibility flows).
LANGUAGE ROME SRLS guarantees uttermost confidentiality of your personal data by applying the most suitable technologies, in compliance with Italian and European standards regarding minimum security measures to avoid unauthorized access to databases, possible loss and / or accidental destruction of data. For further information, please view the section concerning Privacy Policy.
Data Transfer
The owner also wishes to communicate that he/she does not intend to transfer the data to a non-EU third country or to an international non-EU organization.
Place of treatment
Data is processed at the Owner’s operating offices and in any other place where the parties involved in the processing are located; the data is managed by the owner or by third party suppliers of technical services; for further information, please contact the owner directly.
Data Retention Period
The Data Controller retains and processes personal data for the time necessary for the processing and management of the request received and, subsequently, it will be deleted unless conservation is otherwise justified.
If you consent to the processing of data for marketing or commercial communications purposes, data will be processed for a period not exceeding 5 years from the data collection, while for profiling activities data will be processed for a period not exceeding 12 months.
Rights of the interested parties
In relation to the processing carried out, you have the rights referred to in articles 15-22 of the GDPR and, therefore, you can request access to your personal data and the correction or deletion thereof or the limitation of treatment of data concerning you or a minor or to oppose to treatment, as well as having the right to the portability of the data processed in electronic format.
Instances relating to the exercise of rights must be sent to the Data Controller who will verify within the period referred to in art. 12 of the GDPR.
At any time, you can complain to the Guarantor Authority for the protection of personal data, Piazza Venezia n. 11, 00187 Rome, garante@gpdp.it.
Consent withdrawal
With reference to art. 6, paragraph 1, letter a) of the GDPR 679/16, the owner informs the interested party that he/she has the right to revoke any consent given at any time without prejudice to the lawfulness of the treatment based on the consent given prior to revocation.
Automated decision-making processes
If consent is given to the processing of personal data for the purpose of using personalized services through profiling, it may be subject to an automated decision-making process, through a specific algorithm that will select communications that are most suitable for your profile or which could be of greater interest. The treatment carried out as such includes, in terms of consequences, by way of example, sending highly profiled commercial communications, discounts, invitations to events considered as being of interest, etc.
In any case, the interested party has the right to obtain human intervention in the decision-making process on behalf of the Data Controller, to express his/her opinion, to obtain an explanation of the decision obtained and to oppose to the decision itself.
Special note for minors
Minors <age 18 cannot use our services; therefore they do not have to provide any personal data in the registration process. If you are under 18 you can NOT use our services as they are aimed at adults only.
Cookies and browsing data
The Site uses “cookies”. By using the Site, the user consents to the use of cookies in accordance with this Privacy Policy.
Cookies are small files stored on the hard disk of the user’s computer.
There are two macro-categories of cookies: technical cookies and profiling cookies:
• Technical cookies are necessary for the proper functioning of a website and to allow user navigation; without them, the user may not be able to properly view pages or to use some services.
• Profiling cookies have the task of creating user profiles in order to send advertising messages in line with the preferences expressed while browsing.
According to the legislation in force in Italy, the user’s express consent is not always required for the use of cookies. In particular, so-called ‘technical’ cookies do not require such consent. i.e. those used for the the sole purpose of carrying out the disclosure of a communication over an electronic communication network, or to the strictly necessary extent to provide a service explicitly requested for by the user. These are cookies that are indispensable for the functioning of the site or necessary to perform activities requested by the user.
Among technical cookies, which do not require an express consent for their use, the Italian Guarantor for the protection of personal data (see Gen. Prov. ‘Identification of the simplified procedures for the information and acquisition of consent for the use of cookies – 8 May 2014’) also includes:
• “analytics cookies” when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site;
• Navigation or session cookies (to authenticate, to make a purchase, etc.);
• Functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
For so-called profiling cookies, on the other hand, i.e. those aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed in the context of surfing the net, the user’s prior consent is required.
Cookies can also be classified as:
• “Session” cookies: they are immediately deleted when the navigation browser is closed;
• “Persistent” cookies: they remain within the browser for a certain period of time. They are used, for example, to recognize the device that connects to a site facilitating authentication operations for the user;
• “Personal” cookies: generated and managed directly by the manager of the website which the user is browsing;
• “Third party” cookies: generated and managed by subjects other than the manager of the website which the user is browsing.
This site uses:
The site uses the following types of cookies:
• Personal, session and persistent cookies, necessary to allow for navigation on the Site, for purposes of internal security and system administration;
• Third-party, session and persistent cookies, necessary to allow the user to use multimedia elements on the Site, such as images and videos;
• Persistent third-party cookies used by the Site to send statistical information to the Google Analytics system, through which the Data Controller can perform statistical analyses of accesses / visits to the Site. The cookies used only pursue statistical purposes and collect information in aggregate form. Through a pair of cookies, including a persistent one and a session one (expiring when the browser is closed), Google Analytics also saves a register with the start times of the visit on Site and its exit. Google can prevent data collection through cookies and subsequent data processing by downloading and installing the browser plug-in from the following address: http://tools.google.com/dlpage/gaoptout?hl=it
• Third-party persistent cookies used by the Site to include the buttons of some social networks on its pages (Facebook, Twitter and Google). By selecting one of these buttons, the user can publish the contents of the website page of the site he/she is visiting on a personal page of the related social network.
The Site may contain links to other sites (so-called third party sites).
The owner does not perform any access to or control of cookies, web beacons and other user tracking technologies that could be used by third party sites that the user can access from the Site; he/she does not carry out any checks on contents and materials published by or obtained through third party sites, nor on the related methods for processing of user’s personal data, and expressly disclaims any related liability for such cases.
The user is required to verify the privacy policy of third party sites accessed through the Site and to inquire about the conditions applicable to the processing of personal data. This Privacy Policy applies only to the Site as defined above.
For further information on the personal data processing, please refer to art. 13 of EU REGULATION 2016/679 (GDPR).
The user can select which cookies to authorize also through the specific functions of his/her navigation program (so-called browser); however, in case all or some of the cookies are disabled, it is possible that the site may not be available or that some services or certain functions of the site are not available or do not work properly and/ or the user may be forced to modify or manually enter some information or preferences every time he/she visits the site.
The user can block or delete (entirely or in part) cookies also through the specific functions of his/her navigation browser. For further information on how to set preferences for the use of cookies through your navigation browser, you can follow the hereby instructions:
The settings to manage or disable cookies may vary depending on the internet browser used, therefore, for further information on how to carry out such operations, we suggest the User to consult the device manual or the “Help” function or “Help” of your internet browser.
Please find below links that explain users how to manage or disable cookies for the most popular internet browsers:
• Internet Explorer: http://windows.microsoft.com/it-IT/internet-explorer/delete-manage-cookies
• Google Chrome: https://support.google.com/chrome/answer/95647
• Mozilla Firefox: http://support.mozilla.org/it/kb/Management of cookies
• Opera: http://help.opera.com/Windows/10.00/it/cookies.html
Third party cookies
Profiling cookies, of third parties, are cookies aimed at creating profiles related to the user and, for example, used in order to send advertising messages in line with the preferences expressed by the user upon browsing online.
For the service, LANGUAGE ROME SRLS mainly uses identification cookies which are automatically deleted at the end of each access session.
Such data allows LANGUAGE ROME SRLS’ marketing staff to:
• monitor the conversions of the LANGUAGE ROME SRLS PPC (Pay Per Click) campaigns on Google, Yahoo and Bing.
• enable advertising based on audiences (remarketing)
• monitor conversions to optimize the CPA-based marketing plan (Cost Per Action).
Concerning third-party cookies, these are cookies from sites or web servers other than this, used for the purposes of such third parties. We cannot have specific control over such subjects and their cookies. To gain information on these cookies, their features and operating methods and to provide specific consent, please contact such third parties directly.
The following third-party cookies are installed on the site:
• Google Adwords
• Youtube
• Clickease
The use of third-party cookies can normally be inhibited by the user also through the specific option present within the navigation program (browser); please view the above-mentioned directions for further insights on the matter.