Privacy & Cookie Policy

This page describes how the website is managed with regard to the processing of personal data of users consulting it. This information is provided pursuant to article 13 of EU Regulation 2016/679 applicable from 25 May 2018 – General Data Protection Regulation (hereinafter referred to as GDPR) to those who interact with the web services of Cyber Guru S.r.l., accessible electronically from the address cyberguru.it or cyberguru.it

This information is provided only for the cyberguru.co.uk website and not for any other websites that may be consulted by the user via links, and is in accordance with Recommendation 2/2001 on minimum requirements for on-line data collection in the European Union, adopted on 17 May 2001 by the Article 29 Working Group.

The information is also based on Directive 2009/136/EC of 25 November 2009 and the General Provisions of the Italian Data Protection Authority “Identification of simplified procedures for the provision of information and the acquisition of consent for the use of cookies” of 8 May 2014.

DATA CONTROLLER

In accordance with article 4 point 7 of GDPR 2016/679, the Data Controller is the company Cyber Guru S.r.l., with registered office in Rome (Italy), Viale della Grande Muraglia 284, 00144 Rome, in the person of its Legal Representative, Tel. (+39) 065159281, Fax (+39) 0651963515.

THE DATA PROTECTION OFFICER (DPO – Data Protection Officer)

Cyber Guru has taken steps in accordance with Article 37 of GDPR 2016/679 to appoint a Data Protection Officer (DPO). The DPO is the company’s primary point of reference for all relevant privacy issues, including the protection of clients’ personal data – users and the exercise of their rights.

For any problem related to your privacy you can contact our DPO at the following references: privacy@3.126.211.109.

LOCATION OF DATA PROCESSING

The processing operations connected to the web services of this site take place at the headquarters of The Data Controller and at the company Aruba S.p.a., which manages the hosted site, and are carried out only by technical personnel of the service assigned to such processing. No data from the web service is communicated or distributed externally.

TYPES OF DATA PROCESSED

Browser data

During their normal operation, computer systems and software procedures used to operate this website acquire certain personal data the transmission of which is implicit in the use of internet communication protocols. This information is not collected with the intent of associating it with identified users but, by its own very nature, could lead to the identification of users through processing and association with data held by third parties. This category includes IP addresses or domain names of the computers used to connect to the website, URI (Uniform Resource Identifier) addresses of the requested resources, time of the request, method used to submit the request to the server, size of the file obtained in response, digital code indicating the server response status (successful, error etc.) and other parameters pertaining to the user’s operating system and IT environment.

This data is used only to obtain anonymous statistics about the usage of the website and to check that it is functioning correctly; it is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site; except for this possibility, web contact data is presently retained for no longer than thirty days.

Data provided voluntarily by the user

The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, which is necessary to reply to requests, as well as any other personal data included in the message. Filling in a form on the pages of the same site also entails the subsequent acquisition of the data voluntarily provided by the person who completed it.

METHODS OF PROCESSING

Personal data are processed by automated tools for the time necessary to achieve the purposes for which they were collected. Specific security measures are adopted to prevent loss of data, possible illegal or improper use of data and unauthorised access.

PURPOSE, LEGAL BASIS AND NATURE OF PROVISION

Personal Data collected through the Website will be processed by Cyber Guru S.r.l. for the following purposes:

purposes of research and statistical analysis on anonymous aggregate data, aimed at measuring the functioning of the Site, measuring traffic and assessing usability and interest in order to make it more functional and efficient; Consent not necessary as there is no processing of personal data;
purposes relating to compliance with laws and regulations; Consent not necessary as the legal basis for processing is to fulfil a legal obligation;
purposes necessary to establish, exercise or defend a right in court or whenever the courts exercise their jurisdictional functions. Consent not necessary as the legal basis of the processing is to pursue a legitimate interest of the data controller;
sending emails via the “Contact” link to request information or technical assistance. Consent not necessary as the processing is aimed at the performance of a contract to which the data subject is a party;
to log in and access the e-learning platform if accredited. Consent not necessary as the processing is aimed at the performance of a contract to which the data subject is a party;

TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANISATIONS

Some of the Data Subject’s Personal Data are transferred to Recipients located outside the European Community. Cyber Guru S.r.l. ensures that the electronic and paper processing of your Personal Data by Recipients takes place in compliance with Applicable Legislation that has a legal scope of applicability outside the EU.

Otherwise, transfers of data are subject to an adequacy decision or compliance with the Standard Contractual Clauses approved by the European Commission or, in cases of transfers to the USA, compliance with the Privacy Shield policy.

SCOPE OF THE TRANSMISSION OF PERSONAL DATA

Personal data acquired through the website in question may be disclosed to:

persons authorised to process Cyber Guru S.r.l.’s data;
the company Aruba S.p.a. where the website is hosted;
companies that provide management and technical support services for the company’s IT infrastructure;
third parties handling analytical cookies (according to the cookie policy);
public offices and organisations as a function of legal and/or contractual obligations.

An up-to-date list of the external data controllers appointed pursuant to article 28 of GDPR 2016/679.

DATA STORAGE

Cyber Guru S.r.l. will process the data collected through it for the time strictly necessary to achieve the purposes set out in this information notice. Notwithstanding the above, Cyber Guru S.r.l. will process Personal Data for as long as permitted by Italian law to protect its interests (article 2947, paragraph 1, 3 Italian Civil Code).

MINORS

The services provided on this website are not intended for minors. We do not knowingly collect data, including personal details, related to minors.

Should we become aware that we have collected the personal data of a minor, we will immediately delete such data, unless we are obliged by law to retain the same.

Users are kindly requested to contact us if they believe that Cyber Guru Srl has mistakenly or unintentionally collected information about a minor.

AUTOMATED PROCESSING

Cyber Guru S.r.l. does not carry out processing based on automated decision-making, nor does it process your personal data acquired through the company’s website for profiling purposes, however, it does use profiling cookies. Details of the profiling cookies used and their interaction with social tools can be found in the Cookie Policy below.

Cookies are small text files that can be used by websites to provide a more efficient browsing experience for the user.

Cookies provide for the storage and transmission of information from your first visit and then transmit updated information again on your subsequent visits in order to optimise your browsing experience by remembering your actions and preferences (e.g. your chosen language, display settings, any login data, etc.) so that you do not have to set them on subsequent visits.

There are different types of cookies that, depending on their features and functions, may remain on your device for a predetermined period of time (which can last up to years) and are called persistent cookies, while there are cookies that are automatically deleted when you close your browser, so-called session cookies.

These technologies therefore involve the processing of personal data and as such are subject to the relevant mandatory legislation.

In line with Applicable Law, we do not have to request your consent for the use of cookies that are strictly necessary for the proper functioning and operation of the website (named technical cookies) and for cookies for statistical purposes (named analytical cookies) in aggregate, i.e. anonymous form.

Types of Cookies used on this site

Technical cookies

These cookies are of a technical nature and enable the site to function properly. This category includes cookies that are indispensable for the website to function properly and functional cookies that allow the user to favour the browsing experience based on the choices he or she has made (e.g. choice of language, etc.).

The use of permanent technical cookies or session cookies (i.e. cookies that are not persistently stored on the user’s computer and are deleted when the browser is closed) is strictly limited to the technical provision of the service requested by the user and to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site and its applications.

Technical cookies are used on this site to avoid using other computer techniques that may potentially compromise the confidentiality of user browsing.

Analytics cookies

These cookies help us understand, through data collected in an anonymous and aggregate form, how users interact with our website by providing us with information on the pages visited, the time spent on the site, the type of platform used, the number of clicks on a given page, any malfunctions, etc.

Statistical cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

We use Google Analytics to anonymously collect and analyse information on website usage behaviour for statistical purposes, without acquiring any personally identifying information about the user.

Profiling cookies

Profiling cookies are designed to create profiles relative to the user and are used in order to send advertising messages in line with the preferences expressed by the user when browsing the web.

We do not use profiling cookies.

List of cookies used and their specifications

Cookie Name	Type / Purpose	Deadline	Possible Link to the third party’s Privacy Policy
First-party Technical Cookies	FIRST-PARTY TECHNICAL COOKIES First-party technical cookies are instrumental and essential to the proper functioning of the website. Aligning with European legislation on cookies, we use a technical cookie to keep track of the user’s consent to accept the use of third-party and profiling cookies.	At the end of the browsing session	–
Google Analytics	THIRD-PARTY ANALYTICAL COOKIES. Google Analytics is an analysis tool from Google that helps website owners understand how visitors interact with the content of their website (pages visited, browsing time, etc.) by providing useful statistics aimed at optimising and improving website navigation without identifying the user This cookie is used for the sole purpose of collecting information in aggregate and anonymous form on the number of users and how they visit the site. We use this cookie anonymously, rendering the user’s IP address anonymous and do not cross-reference this information with third parties.	_utma – 2 year _utmt – 10 minutes _utmb – 30 minutes _utmc – until the end of the session _utmz – 6 months _utmv – 2 years	Google Analytics Privacy Policy http://www.google.com/intl/it_ALL/analytics/learn/privacy.html
Vimeo	Vimeo is a platform owned by Vimeo LLC for sharing videos, and uses cookies to collect information from users and browsing devices.		https://vimeo.com/privacy

How can I disable cookies

For more information on cookies and to manage your preferences on third-party profiling cookies, please visit http://www.youronlinechoices.com

Most browsers accept cookies automatically, but you can also choose not to accept them or limit their use.

Disabling cookies may lead to problems in navigating websites or limitation in the use of all website services (e.g. bookings, etc.). In order to remove cookies, we invite the user to follow the instructions on the dedicated pages of the various browsers:

If you are using Internet Explorer

In Internet Explorer, click on “Tools” then “Internet Options”. In the Privacy tab, move the cursor up to block all cookies or to the bottom to allow all cookies, and then click OK.

If you are using Firefox

Go to the “Tools” menu of your browser and select the “Options” menu. Click the “Privacy” tab, uncheck the “Accept cookies” box and click OK.

If you are using Safari

From the Safari browser, select the “Edit” menu and select “Preferences”. Click on “Privacy”. Place the “Cookies Block” setting to “always” and click OK.

If you are using Google Chrome

Click on the Chrome menu in the browser toolbar. Choose “Settings”. Click on “Show Advanced Settings”. In the “Privacy” section, click on the “Content Settings”. In the “Cookies” section, select “Do not allow sites to store data” and check “Block cookies and third-party site data”, and then click OK.

If you use any other browser, look in the browser settings for how to manage cookies.

RIGHTS OF DATA SUBJECTS

The user can freely exercise the rights referred to in Articles 15 et seq. of the GDPR 2016/679 or:

withdraw their consent at any time. Users may revoke their consent to the processing of their personal data as described above.
the right to object to the processing of their data. Users may object to the processing of their data when it is carried out on any legal basis other than consent.
the right to access their data. Users have the right to obtain information on what data is being processed by the Controller and on particular aspects of the processing methodology, and to obtain a copy of any data processed.
the right to rectification of inaccurate personal data. Users may verify that their data is correct and ask for it to be updated or corrected as necessary.
obtain limitation to processing. In certain circumstances, the User may ask for restrictions to be set on the processing of the Personal Data. In this eventuality, the Data Controller may not process the data for any purpose with the exception of storage.
the right to have their personal data removed or erased. In certain circumstances, users may request the erasure of their data by the Data Controller.
receive the Personal Data concerning them or transfer it to another Data Controller. The User has the right to receive the Personal Data in a structured, commonly used and machine-readable format, where technically feasible, and to have it transferred without hindrance to another Data Controller. This provision is applicable where the data is processed automatically, and the processing is based on the user’s consent, or a contract to which the user is a party or contractual provisions connected to it.
the right to lodge a complaint. The User may lodge a complaint with the competent supervisory authority responsible for Personal Data protection, or take legal action.

Requests should be addressed to the Data Protection Officer (DPO) at Cyber Guru S.r.l by writing to the email address: privacy@cyberguru.eu.

RIGHT TO SUBMIT A COMPLAINT

Data subjects who consider that the processing of their personal data relating to navigation through this website is in breach of the provisions of Regulation 2016/679, have the right to submit a complaint to the Supervisory Authority, as provided for in article 77 of the Regulation, or to take legal action (Article 79 of the Regulation).

UPDATES AND REVISIONS

The privacy & cookie policy was updated to revision 5 on 20-05-2020 and may be subject to future revisions.

Privacy & Cookie Policy

COOKIES