1. PRIVACY POLICY
Privacy and cookie policy pursuant to Article 13 of the General Data Protection Regulation (U) 2016/679 (“GDPR” or “Regulation”)
Neos SpA, with registered office in Somma Lombardo, Via della Chiesa, 68 (hereinafter as “Neos SpA”) is constantly striving to protect the online privacy of its users.
A) Source of personal data and Data Controller
This document has been written in accordance with Article 13 of the GDPR in order to allow you to know our privacy policy. It describes the generic methods for processing users' personal data and cookies and how your personal information is processed when you use our site www.neosair. it (hereinafter as the "Site") The information and data you provide or otherwise collect during the use of Neos SpA's services, - such as: access to the personal area of the Site, newsletters, customer care section, sending of booking resumes for the purchase of services, hereinafter referred to as “Services” - will be processed in compliance with the provisions of the Regulation and the confidentiality obligations that govern the activities of Neos SpA. In accordance with the provisions of the Regulation, the processing implemented by Neos SpA will be based on the principles of lawfulness, fairness, transparency, limitation of purposes and storage, data minimization, accuracy, integrity and confidentiality.
The data controller of the processing carried out through the Site is Neos SpA with registered office as defined above, to whom you can write for any information concerning the processing of personal data. The Data Protection Officer (hereinafter referred to as the “DPO”) can be reached at the following address: DPO@neosair.it.
This information notice is provided only for this Site and not for other websites that may be consulted by the user through different links. Please refer to any specific sections of the Site where you can find specific information and any requests for consent for individual processing.
B) Types of data
As a result of your navigation of the Site, we inform you that Neos SpA will process personal data (art. 4(1) of the Regulations), hereinafter only “Personal Data”.
In particular, the Personal Data processed through the Site are as follows:
- Browsing data
The computer systems and software procedures used to implement the Site acquires, during their normal operation, some Personal Data whose transmission is involved in the use of Internet communication protocols. This information is not collected to be matched to identified Data Subjects, but it should be, due to its nature, able to identify users through the processing and association with data processed by others.This category of data includes: IP addresses or domain names of computers used by users who connect to the Site, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the number code indicating the status of the response from the server (successful, error, etc..) and other parameters related to the operating system and computer environment. These data are processed for the unique purpose of obtaining anonymous statistical information on the use of the Site and to check its correct performance, as described in the following paragraph, in order to identify anomalies and/or abuses, and are deleted promptly after the processing. The data could be used by the competent authorities to investigate responsibility in case of potential computer crimes against the Site.
- Data provided on voluntary basis by Data Subject
With the exception of those specified for browsing data, the user is free to provide personal data contained in any request forms on the website (e.g. to activate newsletters, free registration, purchase, etc.). Failure to provide this information could determine the impossibility of providing the service. In these cases will be required only the necessary information for the requested service (please see in detail specific information).
During the use of several Site Services, it is possible that some Personal Data of third parties sent by you to Neos SpA may be processed. Regarding such scenarios, you assume the role of autonomous data controller and you are responsible for all legal obligations and responsibilities. In this sense, you ensure Neos SpA the fullest indemnity with regard to any dispute, claim, request for compensation, for damages caused by processing, etc., that Neos SpA may receive from third parties whose Personal Data has been processed in violation of the applicable data protection regulations as a result of your use of the functions of the Site. However, if you provide or, in any way, you process third parties’ Personal Data during your use of the Site, you guarantee from now - undertaking all related responsibilities - that this particular processing hypothesis is based on an appropriate legal basis pursuant to Article 6 of the Regulation that legitimates the processing of the information involved.
C) Purposes of the processing and legal bases
Our intended processing of personal data, with your specific consent if necessary, has the following purposes:
- To enable the performance of Services of the Site;
The legal basis of the processing is the execution of pre-contractual measures adopted at the request of the data subject (art. 6(1)(b) of the Regulation) as the processing is necessary for the performance of the Service. The transmission of Personal Data for these purposes is optional, but the eventual refusal to transmit them causes the impossibility to activate the Services provided by the Site.
D) Personal data recipients
Your Personal Data may be shared, for the above purposes, with:
-
Persons authorized by Neos SpA to process Personal Data necessary to carry out activities strictly related to the providing of Services, who are under confidentiality obligations or have an appropriate confidentiality legal obligation (e.g., employees and system administrators).
- Third parties who may be involved in the management of the Site and who are typically acting on behalf of Data Processors (a complete and updated list of Data Processors is available at www.neosair.it.
- Subjects, organisations, or authorities to whom it is mandatory to communicate your Personal Data under legal provisions or orders from the authorities.
E) Transfers of personal data
Some of your Personal Data are shared with recipients who may be located outside the European Economic Area. Neos SpA will ensure that your Personal Data are processed by these recipients in compliance with the Regulation. Indeed, these transfers may be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or on another suitable legal basis.
F) Your privacy rights under Articles 15 to 22 of the Regulation
Pursuant to articles 15 et seq. of the Regulation, you have the right to ask Neos SpA, at any time, for access to your Personal Data, to correct or delete the same or to oppose their processing, you have the right to request the limitation of processing in the cases described in article 18 of the Regulation, as well as to obtain the your personal data in a structured, commonly used and machine-readable format, in the cases described in article 20 of the Regulation.
Requests should be addressed in writing to the Data Controller at the following address privacy@neosair.it or to the DPO (Data Protection O cer) at the following address DPO@neosair.it
In any case, you are always entitled to file a complaint to the competent Control Authority (Personal Data Protection Authority), in accordance with Article 77 of the Regulation, if you have considered that the processing of your Personal Data is in contrast with the regulations in force.
G) Modifications
Neos SpA reserves the right to modify or simply update the contents, partially or completely, also as a result of variations of the applicable legislation. Neos SpA will inform you of any such variations as soon as they are introduced, and they will be binding when published on the Site. Therefore, Neos SpA invites you to visit these sections regularly to check the most recent and updated version of the privacy policy, so that you can be constantly updated on the data collected and on use of such data by Neos SpA.
2. COOKIE POLICY
Definitions, features and legal enforcement
Cookies are small text files that websites visited by the user send and store on the user's computer or mobile device, to be then re-transmitted to the same websites at the next visit. Thanks to Cookies, a website remembers the user's actions and preferences (e.g. login details, language, font size, other display settings, etc.) without having to repeat these actions and preferences when the user visits the website again or navigates from one page to another. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding users' activities that access a site and may also contain a unique identification code that allows tracking of the user's navigation through the site for statistical or advertising purposes. During the navigation on a site, the user may also receive on his/her computer also cookies from other sites or web servers than the one he/she is visiting (so-called “third party” cookies). Some operations could not be carried out without the use of cookies, which, in certain cases, are technically necessary for the operation of the site.
There are various types of cookies, depending on their characteristics and functions, and they may remain on the user's computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user's device until a pre-established expiry date.
According to current Italian legislation, the use of cookies does not always require the express consent of the user. In particular, "technical Cookies", i.e. those used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, are not required to obtain this consent. This means, in other words, that the cookies are indispensable for the website to run or are necessary to perform activities requested by the user.
Under technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (see “Decision Simplified Arrangements to Provide Information and Obtain Consent Regarding Cookies - 8 may 2014”, hereinafter only "Decision") also includes:
- “Analytics Cookies” where they are used directly by the owner of the Site to collect information, in aggregate form, on the number of users and how they visit the site navigation or session cookies (for authentication purposes).
- Browsing or session cookies (for authentication purposes), functionality cookies, which allow the user to browsing according to a number of selected criteria (e.g., language, products selected for purchase) in order to improve the service provided to the user.
- For “profiling cookies”, 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 by the user while browsing the web, the user's prior consent is required.
Per i "cookie di profilazione", viceversa, cioè quelli volti a creare profili relativi all'utente e utilizzati al fine di inviare messaggi pubblicitari in linea con le preferenze manifestate dallo stesso nell'ambito
della navigazione in rete, è richiesto un preventivo consenso dell'utente.
Social Plug-in
These 'social buttons' are visible on our website to allow you to share content via social networks, including Facebook, Twitter, LinkedIn and YouTube. Cookies are managed by these platforms on our site to allow them to collect information about your browsing.
For more information on cookie management and the privacy policy of Facebook
click here
, Twitter
click here
, Youtube
click here
.
Web beacons
Web beacons are tiny invisible images that Neos uses in its newsletters. These images identify statistical information about the use of the newsletters and allow Neos to improve this service. If you wish to prevent this statistical information from being collected, you must set your e-mail system to HTML off so that the Neos newsletter is read as text only. All newsletters sent by Neos also contain a link that allows you to unsubscribe.
Your decisions regarding cookies
You can select a feature whereby your computer will notify you whenever a cookie is set, or you can choose to disable all cookies. You can select these features through your browser settings. Each browser is slightly different, so please identify in the "Help" menu of your browser the most appropriate way to change the cookie functionality. If you choose to disable cookies, you will not have access to many features that make your experience on our site more efficient and some of our services will not function properly.
Cookie management instructions
If you have a different type or version of browser, please refer to the "Help" menu of your browser.
Internet Explorer 7 e 8
- Click on the Tools menu and select Internet Options
- Click on the Privacy tab
- Move the cursor to choose your preferred settings
- For more specialized cookie settings, click on Sites or Advanced
- For instructions on deleting cookies in Internet Explorer
, click here
Google Chrome
- Click on the Chrome menu, and then select Settings
- Click on Show advanced settings
- Click on Content Settings to choose your preferred settings
- For instructions on deleting cookies on Chrome
,
click here
Mozilla Firefox 14, 15, e 16
- Click on the Firefox button (or Tools menu), then select Options. For Mac OS X users, click on the Firefox menu, then select Preferences
- Click on the Privacy panel to choose your preferred settings
- For more specialized cookie settings, set Firefox: Use personalized settings for storing browsing data
- For instructions on deleting cookies in Firefox
, click here
Safari 5.1 and later version (Mac OS X)
- Click on the Safari menu, and then select Preferences
- Click on the Privacy tab to display your cookie settings
- Choose your preferred settings
- For more specialized cookie settings, click on Details
- For instructions on deleting cookies in Safari
, click here
Opera
- Open the Tools menu, and then select Preferences
- Click the Advanced tab
- In the Cookies section: click Manage cookies
- Select the options you want
- For instructions on deleting cookies in Opera
, click here
