隐私政策

欧盟条例 2016/679 第 13 条和第 14 条

本声明（以下简称“隐私政策”）系根据有关个人数据保护的现行法律，具体地讲，是根据欧盟关于个人数据处理和数据自由流动方面的个人保护条例 2016/679（“GDPR”）第 13 条提供，涉及网站 https://www.aetnagroup.com（以下简称“站点”或“网站”）访问者个人数据的处理。

This Privacy Policy aims to describe in a simple and transparent manner to the users which personal data are processed, for what purpose, by whom and how the data are processed and to inform the users about the measures undertaken to protect the data subjects’ rights and freedoms. 

This Privacy Policy, therefore, concerns only this Website and does not apply to other websites that may be visited by the user through hyperlinks accessed on the Website.

This information may undergo modifications and variations over time, so we invite you to consult this page regularly to be updated on the processing of personal data carried out by Aetna Group. 

INDEX:
  1. Data Controller 
  2. Contacts
  3. Data collect
  4. Categories of data processed 
  5. In which other cases we may use the data?
  6. To whom may the data be disclosed?
  7. How are the data processed?
  8. Extra Europe processing
  9. How long are the data stored? 
  10. Links to other web sites and social networks 
  11. Data subject’s rights
  12. The right to lodge a complaint

 

Data Controller

The Controller of the processing of personal data is Aetna Group S.P.A., VAT number 01551781204, with registered office in S.P. Marecchia 59 - CAP 47826, Villa Verucchio (RN) - Italia, who determines the means and purposes of the processing of personal data involved in the use of this Website. 

Contacts

You can contact the Data Controller sending a communication to:

Data collect 

Aetna Group S.P.A. will collect information directly from the user: 

  • when the user accesses and browses the Website; 
  • when the user sends questions or requests through the sections or contacts available on the Site;
  • when the user requests assistance on Aetna Group’s products or services; 
  • if the user subscribes to the newsletter.

Categories of data processed 

Different types of personal data may be processed and treated differently, depending on the services rendered and on the purposes pursued:

a) Navigation data 

The information systems and software procedures used to the operation of this web site acquire personal data as part of their standard functioning. Such information is not collected in order to relate it to identifiable data subjects; however, it may allow User identification after being processed and matched with data held by third parties.

This data category includes the: IP addresses or names of computer domains used by visitors who access the website; URI (Uniform Resource Identifier) addresses of the requested resources; time of request; method used to submit the request to the server; size of the file obtained in response; numerical code indicating the status of the response from the server and other details relating to the operating system and the information environment of Users. This data is used only to obtain anonymous statistical information about the website and to check its correct functioning and is deleted immediately after processing. This data may also be used to ascertain responsibility in the case of possible computer crimes against the website. Excepting this, data on web contacts is not stored for more than seven days.

• Purpose of the processing: to guarantee the correct functioning and safety of the Site;

• Legal basis of the processing: Aetna Group’s legitimate interest in the proper functioning of the site and navigation safety, regularly balanced with the rights of the data subject (Article 6, paragraph 1, letter f, GDPR).

 b) Information requests

The user can optionally, explicitly and voluntarily send communications or requests to Aetna Group by using the contact forms on the Site or by writing an e-mail to the addresses indicated on the Site itself: this involves the subsequent acquisition of the data communicated by the user, including his e-mail address, name and surname, and his/her consent to receive any response messages to his/her requests. 

In particular, the spontaneous communication of the data may take place, upon declaration of having read this Privacy Policy, in the following sections: 

a) Contacts and Footer of the site: by clicking on the e-mail which incorporates a mailto link; 

b) Information request form.

• Purpose of the processing: ensure adequate support in relation to your needs and respond to your requests; 

• Legal basis of the processing: the provision of the service you have requested (Article 6, paragraph 1, letter b, GDPR).

c) Newsletter

Aetna Group’s newsletter is sent by e-mail to those who explicitly request it, by filling out the appropriate form on the Website and authorizing the Data Controller to process their personal data for the aforementioned purpose.  The service is provided only following explicit and unequivocal consent (released by the user selecting the appropriate box on the Website) and the provision of data is mandatory only for the purpose of receiving the newsletter. Any failure to provide consent will prevent the user to use the service, without further consequences.

In order to stop receiving the newsletter, you can simply select the link for removal at the end of each e-mail or send a specific request to the e-mail address [email protected].  

The erasure could be managed automatically, therefore the user may receive for a period no longer than 72 hours further newsletters, whose submission had been planned before the reception of the cancellation request.

Please note that by indicating the “Topic” of the request sent to the Data Controller through the form on the Site, communications relating to this area of interest will be sent to the user.

The newsletter service is provided by Contactlab S.p.A., with registered office in Via Natale Battaglia 12 – 20127 Milano (Italy), PEC: [email protected]; https://contactlab.com/it/privacy-policy/; it is also possible to request more information by contacting the e-mail address: [email protected] or its Data Protection Officer: [email protected]

• Purpose of the processing: to send the interested party e-mail communications relating to Aetna Group products and services, news and updates on the topics related to Aetna Group products and services; 

• Legal basis of the processing: the express and specific consent of the data subject (Article 6, paragraph 1, letter a, GDPR).

d) Data that can be used for sending soft-spam communications

Only in the event that the e-mail address is provided by the data subject in the context of the purchase of products or in the event that you have shown interest in our products and have requested information from us, the data thus collected by the Data Controller they can also be used to send e-mail communications relating to products similar to those already purchased or of interest to the user, pursuant to art. 130, paragraph 4, legislative decree 196/2003 and art. 6, lett. f, of the GDPR, without the need for express and prior consent (so-called soft spam). In every communication, the user is reminded that he can revoke the consent at any time and without formalities. 

• Purpose of the processing: to inform you about products and services similar to those of your previous purchase; 

• Legal basis of the processing: the regulatory provision of art. 130, paragraph 4, of Legislative Decree 196/2003 and the legitimate interest of the Data Controller in sending communications regarding products or services similar to those already purchased or subject to requests by the data subject (Article 6, paragraph 1, lett f, GDPR).

e) Cookie

What is a cookie? Cookies are information stored by the browser when you visit a Web Site using a PC, smartphone or tablet. Each cookie contains several pieces of data (e.g., the name of the server from which it originates, a numeric identifier, etc.). Cookies can remain in the system for the duration of a session (until the closing of the browser), or for long periods, and may contain a unique identifier.

When you will visit the website again, cookies will be reforwarded to the website that has generated them (first-party cookies) or to the ones that were provided by third parties and that are able to recognize them (third-party cookies).

In any case, Aetna Group grants that the cookies used in its website are safe: they will not cause any damage to your device and they will allow you to surf faster the website.

What are they used for? Cookies are used for different purposes, depending on their type: some are strictly necessary for the correct function of the Web Site (technical cookies), whereas others optimise performance in order to provide the User with a better experience while they are visiting the Web Site. In addition, cookies allow Web Site usage statistics to be obtained, such as cookies analytics; others are for the purpose of displaying advertisements (in some cases advertisements are targeted based on cookie profiling).

Consent: Consent from the Users is stored by the Controller, for the purpose of fulfilling its responsibilities, through a technical cookie. The User is informed both by the brief privacy notice (displayed in a banner upon the first visit to the Web Site until permission is granted or denied) and by this privacy policy.

Aetna Group’s website uses both cookies that do not require your previous consent (e.g. Technical cookies) and cookies you will have to assent to (e.g. profiling cookies). In detail, on the website might be active: 

Types of cookies used on the Web Site

a) Technical cookies (which do NOT require your consent):

These are cookies necessary for the functioning of the site and allow you to access its functions (so-called navigation cookies) or to authenticate yourself in the session.

Functional cookies are also used to store your preferences and settings, thus improving your browsing experience on the site. 

In order to guarantee their functionality, these cookies are generally not deleted when you close your browser; however, they have a default duration (generally up to a maximum of 2 years) and after this period they are automatically deactivated. These cookies and the data they collect will in no way be used for further purposes. 

The installation of technical cookies takes place automatically when you access the site or to activate certain functions (e.g. by selecting the "remember me" option). You can always decide to disable them at any time by changing your browser settings: in this case, however, you may have some problems viewing the site.

• Purpose of the processing: to guarantee the correct functioning and safety of the site;

• Legal basis of the processing: Aetna Group’s legitimate interest in the proper functioning of the site and navigation safety, regularly balanced with the rights of the data subject (Article 6, paragraph 1, letter f, GDPR).

b) Analytical cookies (which may NOT require your consent)

These cookies keep track of the choices made on the site and data relating to users' online browsing (for example, pages viewed, dwell times on a page, etc.), in order to perform statistical analysis, in an anonymous and aggregate form. 

These tools can only be used after expressing the user's consent, unless their settings meet the following requirements:

- the duly anonymized IP address; 

- the information obtained with analytical cookies refers to a single IT resource (site, app, etc.) and is used only in anonymous and aggregate form; 

- the cookie provider does not combine the information with other processing and does not pass it on to third parties. 

If these requirements are met, the complete anonymization of the collected data is guaranteed and even the cookies falling into this category can be activated without the need for the user's consent, precisely because the data processed cannot be linked to any identifiable user.

• Purpose of the processing: to have statistics relating to user behavior on the Site, based on aggregated and anonymized data:

• Legal basis of the processing: depending on the case: 

- Aetna Group's legitimate interest in optimizing the performance of the Site and improving the services provided through the Site, regularly balanced with the rights of the interested party (Article 6, paragraph 1, letter f, GDPR); 

- the user's consent (Article 6, paragraph 1, letter a, GDPR), freely provided and revocable at any time, through the cookie banner or by following the instructions below and in the Cookie Policy.

c) Tracking and Profiling cookies (requiring your CONSENT): 

This site also uses profiling and third-party cookies. However, your prior consent is required for their installation.

Profiling cookies may include several categories, including advertising profiling, retargeting or social cookies. 

- Advertising profiling cookies: create a user profile that allows you to view advertising content in line with your preferences while browsing the site;

- Retargeting cookies: are designed to create a user profile in order to send you personalized advertising content related to products in which you have expressed interest;

- Social cookies: this site provides for the installation of cookies related to social network plug-ins. These cookies are managed directly by third parties and allow the display of advertising messages in line with your preferences.

• Purpose of the processing: to analyze the user's browsing behavior to present personalized advertising;

• Legal basis of the processing: the user's consent (Article 6, paragraph 1, letter a, GDPR), freely provided and revocable at any time, through the cookie banner or by following the instructions below and in the Cookie Policy.

d) Social media plugin 

On the Site there are some buttons that refer the user to the Controller's profiles on social networks. Only after clicking on these buttons, some cookies could be activated for marketing and profiling purposes by the third parties that manage the social networks. The Controller does not directly manage these tools, but informs you of the possibility that, by making use of the Site's features, they may be activated.

For more information, including on how to disable these cookies, please read the information on the processing of personal data on social networks: 

- YouTube: https://policies.google.com/privacy?hl=it 

- LinkedIn: https://it.linkedin.com/legal/privacy-policy?trk=public_authwall_company-scraping_join-form-privacy-policy 

When you access the site, through a special banner you will be informed of the presence of profiling and retargeting cookies and, through it, you can consent or not to their installation. Of course, you can revoke your consent at any time, without any prejudice to the possibility of visiting the site and enjoying its contents.

The installation of profiling, retargeting, analytical and social cookies and every other related activity is provided by third parties. For further information and to turn on or off these cookies, please visit the specific privacy notices of the third parties. You can find a list with the link to their policies at our Cookie Policy.

The User is informed both by the brief privacy notice (displayed in a banner upon the first visit to the Web Site until permission is granted or denied) and our Cookie Policy, that we invite you to read, in order to get all the information you need about the cookies used in the website and how to disabilitate them.

The setting can be changed by the User at any time. You can always use the “Set your preferences” page, available in the footer of the Site, to change the settings relating to the cookies used on the site and to check the Cookie Policy and more information.

Therefore, cookies can easily be disabled or turned off by accessing the browser’s options or preferences, and in general third-party cookies can also be blocked. As a general rule, these options will only have an impact on that browser and on that device, unless there are active options to synchronize the preferences on different devices. Specific instructions can be found on the Options page or Help page of the browser itself. Disabling technical cookies, however, may affect the full and/ or proper functioning of different sites, including this one.

Normally, browsers used today:

- offer the “Do not track” option, which is supported by some websites (but not all). Thus, these websites are no longer able to collect certain navigation data;

- offer the option of anonymous surfing or incognito mode: in this way, data will not be collected in the browser and browsing history will not be saved, but the navigation data may still be acquired by the operator of the Web Site that was visited;

- allow the deletion of cookies stored in whole or in part, but after visiting a Web Site again they are usually installed, where such possibility is not blocked.

Below are links to the support pages for the most popular browser (with instructions on how to disable cookies on these browsers):

- Firefox: (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);

- Internet Explorer e Microsoft Edge: (https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies );

- Safari: (iOS) (https://support.apple.com/it-it/guide/safari/sfri11471/mac) and (https://support.apple.com/it-it/HT201265#:~:text=Per%20cancellare%20i%20cookie%20senza,o%20disattiva%20la%20navigazione%20privata);

- Chrome: (https://support.google.com/chrome/answer/95647?hl=it).

On-line tools: You may notice that from http://www.youronlinechoices.com/ you can not only learn more about cookies, but also check the installation of numerous cookies on your browser and/or device and, if supported, also disable them. 

In which other cases we may use the data?

Your personal data may also be used in order to: 

a) comply with legal obligations and requests from public or government authorities; 

b) manage any disputes or contentions and therefore defend the rights of Aetna Group both in court and out of court. 

In such cases, the legal bases of the processing will be: 

for point a), the fulfilment of a legal obligation; 

for point b), the legitimate interest of the Data Controller in the protection of their rights, as long as they are adequately balanced, from time to time, with the rights of the data subject.

To whom can the collected data be disclosed?

The processing operations related to the web services of this Site are only handled by internal and/or external technical staff specifically delegated for processing. In particular, where necessary and only with prior consent, the data may be disclosed to third parties whose collaboration is needed for the performance of the services offered. The data collected via the web, or in any case arising from web services, may be disclosed to the technological and instrumental partners who cooperates with the Data Controller to provide the services required by users, always in compliance with the purposes set forth in article 4. To this purpose, the subjects who will have access to personal data will be specifically authorized for processing by the Data Controller and, if due, appointed as Data Processors, pursuant to Articles 28 of the GDPR.

In this regard, we specify that the newsletter service is provided by Contactlab S.p.A.; for more information, please read the information on the processing of personal data at the following link https://contactlab.com/it/privacy-policy/ or send a request to: [email protected]; or: [email protected] .

Further information in this regard can be requested from the Data Controller, using the contact details referred to in Par. 2

User data will in no case be transferred to third parties except in the case in which the nature of the services rendered requires it, or in the case in which, by virtue of a legal obligation or in the presence of a legitimate interest, the Data Controller has the need to communicate them to the competent judicial or supervisory authorities.

How are the data processed?

Data will be managed lawfully and used only for the aforementioned purposes. It will be processed using suitable means to guarantee its security and confidentiality, using the most appropriate, also automated, means (hard copy or electronic) to store, manage and transmit the data. The Controller assess the appropriate level of security in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.

Extra Europe processing

The data Aetna Group processes are held in server located within the European Union, in particular in Italy.

Some of the cookie service providers have registered offices outside European Union, especially in the U.S.A., as specifically explained in our Cookie Policy [anchor point]. In these cases, the personal data are held in server located in the United States, in compliance with art. 45 and thereafter of GDPR. 

Indeed, we will adopt all the necessary precautions in order to ensure a complete data protection. The data transfer will be based on: a) an adequacy decision of the European Commission about a third country designed as receiver; b) appropriate and explicit safeguards of the third subject designed as receiver pursuant to art. 46 GDPR; c) the adoption of Corporate binding rules. These requirements are always ensured by Aetna Group’s suppliers.

Further information in this regard can be requested from the Data Controller, using the contact details referred to in Par. 2.

How long are the data stored?

Aetna Group S.P.A. will process your personal data for the time reasonably necessary to achieve only the purposes listed above, as reported in “Categories of Data processed” and “For which other purposes can you use my data?” sections. 

At the end of the retention period, your personal data will be deleted or made irreversibly anonymous and aggregated. 

Links to other web sites and social networks 

The Website may contain links to and from the websites of our partners, as well as to advertisers and social networks. Please note that the Data Controller assumes no responsibility for the personal data that may be collected through these sites and the use of the related services and that, if the user follows a link to any of these websites, he/she is invited to consult the Privacy policy provided by each external party with respect to the Website. 

Furthermore, the user is invited to consult the specific information on the processing of personal data relating to “Work with us” section.

Data subject’s rights

In relation to your personal data and in compliance with the provisions of the GDPR, Aetna Group S.P.A. informs you that you have the right to request: 

• to access to your data; 

• the modification and correction of any errors in our databases relating to your data; 

• the cancellation of your data if they are held in the absence of the legal conditions; 

• the limitation of the processing of your data; 

• to oppose to data processing; 

• data portability. 

In particular, each data subject has also the right to withdraw his or her consent at any time, without prejudice to the lawfulness of the processing based on consent before its withdrawal.

The data subject is also always entitled to object to the processing of any data concerning him or her if it was carried out for direct marketing purposes by the Data Controller; in this case, his/her data will no longer be processed for these purposes (right of objection).

Models and more information are also available here: 

https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924.

We ensure that we will answer to your requests within 30 days from the receipt.

The right to lodge a complaint

You have the right to lodge a complaint to a supervisory authority, if you think that Aetna Group’s personal data processing is not compliant to GDPR or any other national law. 

In Italy, the competent authority is Garante per la protezione dei dati personali, whose contact are accessible at the following page: http://www.garanteprivacy.it/ . 

Further information and a template to lodge a complaint are available here: https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 .

Finally, in case there are the conditions of artt. 78 e 79 GDPR, you have the right to an effective judicial remedy at the competent court. 

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