Privacy policy

Dear User,

Target Motivation S.r.l. with registered office in Via Torino 151/E 30172 Mestre, Venice, VAT number 02057670271, in the capacity of Data Controller (hereinafter “Target Motivation” or the “Data Controller”) considers privacy and the protection of Personal Data one of the main objectives of its activities. This document has been drawn up pursuant to art. 13 of Regulation (EU) 2016/679 (hereinafter: “Regulation”) in order to inform you of our privacy policy; we therefore invite you, before communicating any personal data to the Data Controller, to carefully read this Privacy Policy since it contains important information regarding the protection of your personal data.

This Privacy Policy:

• is considered drawn up for the website targetmotivation.it (hereinafter “Website”);

• constitutes an integral part of the Website and the services we offer;

• is drawn up pursuant to art. 13 of the Regulation for those who interact with the web services of the Website.

The processing of your personal data shall be based on principles of fairness, lawfulness, transparency, purpose limitation and storage, data minimisation, accuracy, integrity and confidentiality, as well as the principle of accountability set out in art. 5 of the Regulation. Your personal data will therefore be processed in accordance with the legislative provisions of the Regulation and confidentiality obligations set forth therein.

The processing of personal data implies any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, alignment or combination, limitation, cancellation or destruction

CONTENTS

1. Data Controller and Data Protection Officer (DPO)

2. Personal data being processed

a. Navigation data

b. Data voluntarily provided by the user

c. Third-party data voluntarily provided by the user

d. Cookies

3. Purpose, legal basis and obligatory or optional nature of processing

4. Recipients of Personal Data

5. Transfer of Personal Data

6. Storage of Personal Data

7. Rights of the Data Subject

8. Modifications

1. Data Controller and Data Protection Officer (DPO)

The Data Controller is Target Motivation, as defined above. The Data Controller has a Data Protection Officer (or “DPO). The DPO is available for any information concerning the processing of personal data by Target Motivation, as well as to provide the list of data processors that process personal data, at the following email: amministrazione@targetmotivation.it.

2. Personal data being processed

As a result of browsing the Website, we inform you that Target Motivation will process personal data that may consist of an identifier such as a name, identification number, online identifier or one or more characteristic elements of your physical, physiological, psychological, economic, cultural or social identity capable of identifying or making identifiable the Data Subject (hereinafter only “Personal Data”).

The Personal Data processed through the Website includes:

a. Navigation data

Information systems and software procedures enabling this Website to function, during the normal course of their operation, acquire Personal Data, the transmission of which is implicit in the use of Internet communication. This is information that is not collected for the purpose of being associated with identified data subjects, but which, by its nature, through processes and associations with data held by third parties, may allow the users to be identified. This category includes IP addresses or the domain names of the computers used by the users that connect to the website, the addresses in URI (Uniform Resource Identifier) notation 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 numeric code indicating the status of the response provided by the server (successful, error, etc.) and other parameters concerning the user’s operating system and computer environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation, to allow – given the architecture of the systems used – the correct provision of services, for security reasons and to ascertain responsibility in the event of hypothetical computer crimes to the detriment of the Website or third parties; and it is normally deleted after sixty days.

b. Data voluntarily provided by the user

The Website offers users the opportunity to voluntarily provide personal information through, for example, registration via contact forms, requests for services, information or quotes, the optional, explicit and voluntary sending of emails to the addresses indicated on the Website, etc. This Privacy Policy also applies to the processing of Personal Data voluntarily supplied through the Website.

c. Third-party data voluntarily provided by the user

In using certain services of the Website, third-party Personal Data sent by you to Target Motivation may also be processed. With respect to these hypotheses, you act as an autonomous data controller, assuming all the obligations and responsibilities laid down by the law. To this end, you agree to fully indemnify Target Motivation in respect of any dispute, claim, request for compensation for damage due to processing, etc., that may be received by Target Motivation from any third parties whose Personal Data has been processed through your use of the Website functions in violation of the applicable Personal Data protection regulations.

In any case, should you provide or otherwise process third-party Personal Data in using the Website, you hereby warrant and assume all related liability, that said particular hypothesis of processing is based on a valid legal basis pursuant to art. 6 of the Regulation that legitimises the processing of the data in question.

d. Cookies

Definitions, characteristics and application of legislation

Cookies are small text files that websites send and record in the user’s computer or mobile device each time they are visited, to then be retransmitted to the same websites on the next visit. It is precisely thanks to cookies that a website remembers a user’s actions and preferences (for example, login data, preselected language, font size, other viewing settings, etc.) so that they don't need to be reset when the user returns to the website, or browses from one page to another. Cookies are therefore used for computer authentications, to monitor sessions and store information about the activities of the users who access a given website, and can also contain a unique identification code making it possible to keep track of the user’s browsing habits within the website itself, for statistical or advertising purposes. When navigating a website, the user may also receive on their computer, cookies from websites or web servers other than the one they are visiting (so-called “third-party” cookies). Certain operations would not be possible without the use of cookies, which in certain cases are therefore technically necessary in order for the website itself to function.

There are various types of cookies depending on their characteristics and functions, and these 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-determined expiry date.

Under current Italian law, express user consent is not always required for the use of cookies. In particular, no consent is required for “technical cookies”, that is, those used for the sole purpose of transmitting a communication over an electronic communication network, or to the extent strictly necessary to provide a service specifically requested by the user. In other words, these are indispensable cookies in order for the website to function, or necessary to carry out the activities requested by the user.

According to the Italian Data Protection Authority (cf. Provision for the Identification of simplified procedures for disclosure and the acquisition of consent for the use of cookies, 8th May 2014 and subsequent clarifications), technical cookies, which do not require express consent for their use, also include:

• “analytics cookies”, when used directly by the manager of the website to collect information, in an aggregate form, on the number of users and their behaviour when visiting the website,

• navigation or session cookies (for authentication),

• functional cookies, which allow user browsing based on a series of selected criteria (for example, language, products selected for purchase) in order to improve the service offered to the user.

• for “profiling cookies”, on the other hand, that is, those aimed at creating user profiles and used to send advertising messages in line with the preferences expressed by the user when navigating the web, the user’s prior consent is required.

• Types of cookies used by the Website and possibility for (de-)selection

• The Website uses the following cookies, which can be de-selected, except for third-party cookies for which you should refer directly to the relative selection and de-selection methods for the respective cookies, indicated via links:

• Technical navigation or session cookies strictly necessary for the Website to function or to enable you to make use of the contents and requested services.

• Technical analytics cookies, which make it possible to understand how the website is used by users. These cookies are not used to collect any information regarding the user’s identity, or personal data. The information is processed in aggregate and anonymous form.

• Functional cookies, that is, those used to activate specific functions of the Website and a series of selected criteria (for example, language) in order to improve the service provided.

NOTE: by disabling technical and/or functional cookies, the Website may be unavailable or certain services or certain functions of the Website may no longer be available or may not work properly, and you may be forced to change or manually enter certain information or preferences each time you visit the Website.

Third-party cookies, that is, cookies from websites or web servers other than Target Motivation, used for the third party’s own purposes, including profiling cookies. Note that said third parties, listed below with the relative links to their privacy policies, are typically autonomous data controllers of the data collected through the cookies they serve; therefore, reference must be made to their personal data processing policies, disclosures and consent forms (selection and de-selection of respective cookies) as specified in the aforementioned Provision. For the sake of completeness, we also point out that Target Motivation makes every effort to trace cookies on its own Website. These are updated on a regular basis in the table at the following link, where we transparently indicate the cookies directly sent by Target Motivation and their purposes. In regards to third parties that send cookies through our Website, we provide the following links to the respective privacy policies: we delegate to said third parties, as already specified, all responsibility for providing the disclosure and collecting your consent, as required by the Provision. Said responsibility refers not only to cookies directly sent by third parties, but also any additional cookies sent through our Website by virtue of the services used by the third parties themselves. Target Motivation has no control over said cookies, which are sent by service providers of the aforementioned third parties, and has no knowledge of their characteristics or purposes.

Below are links to information on third-party cookies:

Google

Facebook

YouTube

LinkedIn

Sendinblue

The cookies sent by Target Motivation via the Website are indicated in detail at the following link: https://www.targetmotivation.it/cookie

How to view and modify cookies through the Browser

You can select which cookies to authorise through the specific procedure indicated here: https://www.magnews.it/cookie, as well authorise, block or delete (in whole or in part) cookies through the specific functions of your navigation program (so-called browser): in any case, in the event that all or some of the cookies are disabled, the Website may no longer be available or certain services or certain functions of the Website may no longer be available or may not work properly, and/or the user may be forced to modify or manually enter certain information or preferences each time they visit the Website. For more information on how to set preferences on the use of cookies through the Browser, see the relative instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

3. Purpose, legal basis and obligatory or optional nature of processing

Your Personal Data will be processed, using automated and non-automated means, for the following purposes and relative legal bases, where applicable.

b. To allow subscription to the Target Motivation Newsletters. The legal basis for the processing of Personal Data for the purpose of Service Provision and Newsletters is art. 6(1)(b) of the Regulation, insofar as processing is necessary in order to provide the services, satisfy the requests of the Data Subject and/or for subscription to the newsletters. The provision of Personal Data for these purposes is optional, however failure to do so may make it impossible to activate the requested services, satisfy your requests or send the newsletters. We inform you that you can always request to subscribe or unsubscribe to one or more of the Data Controller’s newsletters by modifying and/or updating your privacy preferences on the “Edit profile” page, which can be accessed via the link at the foot of the page in newsletters, or by writing to amministrazione@targetmotivation.it.

c. To perform marketing activities, such as conducting surveys and market research, and send you informative and promotional material relating to the activities, products and services of Target Motivation. In accordance with the provision of the Italian Data Protection Authority entitled “Marketing and Anti-Spam Guidelines – 4th July 2013 [2542348]", should you decide to provide your consent to receive information on the Data Controller's promotional activities, including market research, we inform you that said activities may be carried out, as provided for by the regulations in force, using “traditional methods” by means of paper mail, phone contact by an operator, and/or using “automated methods” via email, the sending of text messages and use of social media (“Marketing”).

Processing carried out for Marketing purposes is based on the granting of your consent pursuant to art. 6(1)(a) of the Regulation. You are not obliged to give consent to Target Motivation for this purpose and you are free to revoke it at any time, without any consequences. You may revoke your consent at any time, in which case any revocation shall not affect the lawfulness of the processing based on the consent given prior to the revocation. We also inform you of your right to revoke, at any time, your consent previously given by traditional or automated means, communicating your intentions to the Data Controller without any formalities, by simply modifying and/or updating your privacy preferences from the “Edit profile” page which can be accessed via the link at the foot of the page in newsletters, or by writing to amministrazione@targetmotivation.it. If, in any event, you wish to object to the processing of your data for Marketing purposes carried out using the means indicated herein, you can do so at any time by contacting the Data Controller at amministrazione@targetmotivation.it, without prejudice to the lawfulness of the processing based on the consent given prior to the revocation.

d. To create user profiles, analysing their preferences, habits, interests and choices expressed through the use of the Website and the services offered, and, where appropriate, using profiling cookies, for the purpose of sending you personalised sales and marketing materials regarding the services offered by Target Motivation (“Profiling”).

Processing carried out for Profiling purposes is similarly based on your consent pursuant to art. 6(1)(a) of the Regulation, which can be collected through specific check-boxes or cookie banners, or further to the legitimate interest of Target Motivation pursuant to art. 6(1)(f). The provision of your Personal Data for these purposes is therefore entirely optional and does not affect the use of the services. Should you wish to object to the processing of your Personal Data for said purposes, you may do so at any time by writing to amministrazione@targetmotivation.it.

e. To fulfil any obligations under applicable laws, regulations or EU legislation, or satisfy requests by authorities (“Compliance”). The processing of your Personal Data for Compliance purposes represents the lawful processing of Personal Data pursuant to art. 6(1)(c) of the Regulation.

f. Statistical purposes, without it being possible to trace your identity (“Statistics”). Note that data processing for Statistical purposes is not carried out on your Personal Data and therefore can be freely carried out by Target Motivation.

g. To carry out direct marketing activities via email for products and services similar to those you have requested (including: demos, materials or documentation that can be downloaded from the Website), unless you expressly refuse to receive said communications, which you can do when requesting the services or subsequently by writing to amministrazione@targetmotivation.it. The processing of your Personal Data for Soft Spam purposes constitutes lawful processing under current personal data protection legislation, which does not require your consent. You may object to the processing of your Personal Data for said purposes either when requesting the products and services available on the Website or on subsequent occasions when you receive communications from the Data Controller, by writing to amministrazione@targetmotivation.it.

4. Recipients of Personal Data

Your Personal Data can be shared, for the purposes set out in section 3 above, with (the “Recipients”):

• parties that typically act as data processors, i.e.: i) persons, companies or professional firms that provide assistance and consultancy to Target Motivation on administrative and legal matters relating to the provision of services; ii) parties with whom it is necessary to interact for the provision of services (for example, hosting providers); iii) parties delegated to carry out technical maintenance activities (including maintenance of the network equipment and electronic communication networks);

• parties, bodies or authorities to whom it is mandatory to communicate your Personal Data by virtue of legal provisions or orders by authorities, or in the case of reports of abuse in order to investigate the claims and identify the source of the messages received by users;

• persons authorised by Target Motivation for the processing of Personal Data necessary to carry out activities strictly linked to the provision of services, who have committed to confidentiality or who have an appropriate legal obligation of confidentiality (e.g. employees of Target Motivation);

• business partners only in the event you have provided your specific consent in this regard.

5. Transfer of Personal Data

Your Personal Data can be shared with Recipients located outside the European Economic Area, and specifically in the Republic of San Marino. The Data Controller ensures that your Personal Data is processed by said Recipients in compliance with the applicable legislation. Transfers are in fact made by means of appropriate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other. More information can be requested from Target Motivation by writing to amministrazione@targetmotivation.it.

6. Storage of Personal Data 

Personal Data processed for the purposes of Service Provision and Newsletters shall be retained for the time strictly necessary to achieve said purposes. In any case, since the processing is carried out for the provision of services, Target Motivation shall process the Personal Data for as long as permitted by Italian legislation to protect its own interests (Art. 2946 Italian Civil Code et seq.).

Personal Data processed for Marketing and Profiling purposes shall be processed until such time as your consent is revoked.

Personal Data processed for Compliance purposes shall be retained for as long as required by the specific obligation or applicable law.

Personal Data processed for Soft-spam purposes shall be processed until such time as you oppose its processing by writing to amministrazione@targetmotivation.it or via the link at the foot of each soft-spam email.

More information regarding the data retention period and criteria used to determine said period can be requested by writing to the DPO at the following address: amministrazione@targetmotivation.it. In any case, Target Motivation may retain your Personal Data for the period of time provided for and permitted by Italian law in order to protect its interests (art. 2947(1)(3) Italian Civil Code).

7. Rights of the data subject

Pursuant to articles 15 et seq. of the Regulation, you have the right to ask, at any time, Target Motivation to access your Personal Data, to rectify or delete said data or to object to its processing pursuant to art. 21 of the Regulation. You have the right to request the restriction of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain data concerning you in a structured, commonly used and machine-readable format, in the cases provided for by art. 20 of the Regulation.

Requests should be addressed in writing to the following address: amministrazione@targetmotivation.it.

You can stop receiving soft-spam emails at any time via the link at the foot of each email received.

Consent to profiling by means of cookies can be revoked by means of the procedures indicated in section 2.d. above.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Italian Data Protection Authority) pursuant to art. 77 of the Regulation, in the event you believe the processing of your Personal Data to be contrary to the legislation in force.

8. Modifications

The Data Controller may amend or simply update this Website Privacy Policy, in whole or in part, also due to changes in the laws and regulations governing this matter and protecting your rights. Users shall be notified of any such variations and updates to the Privacy Policy via the Home Page of the Website. We therefore invite you to regularly visit this section in order to acquaint yourself with the latest and most up-to-date version of this Privacy Policy in order that you are always up to date on the data we collect and how we use it.