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Privacy Policy

PRIVACY & COOKIE POLICY

“WWW.TLPHARMACONSULTING.IT”

Version 1.0 (June 27, 2022)

This information (or “Privacy Policy”) is provided in compliance with current legislation on the protection of personal data and, in particular, pursuant to EU Regulation 2016/679 relating to the protection of individuals with regard to the processing of personal data , as well as the free circulation of such data (so-called “GDPR”) and Legislative Decree 196/2003 (Code regarding the protection of personal data, so-called “Privacy Code”) with reference to the processing of personal data of users who access the website www.lievemente-tlpharma.com (hereinafter also the “Site”)
This Privacy Policy aims to describe in a simple and transparent way to users which personal data are processed, for what purpose, by whom and with what methods, and to inform them about the measures that are applied to protect their rights and freedoms. This Privacy Policy, therefore, concerns only this site and is not provided for other third-party websites that may be consulted by the user via links.

1. Data Controllers

The data controller is TL PHARMA CONSULTING SRL, with registered office in via Lago di Martignano, 18 – 65129 – Pescara, VAT number 02288460682, e-mail address: info@tlpharmaconsulting.it.

2. Purpose Of Processing

By accessing and consulting this Site, as well as using the services that are offered to users through the Site, information relating to users as identified or identifiable natural persons can be collected and processed. If personal data is acquired in this way, the same, in compliance with current legislation on the protection of personal data, will be processed solely to pursue the following purposes:
a) related and/or instrumental purposes to allow access to and use of the Site and its functions;
b) to execute a service or one or more contractually agreed operations;
c) to fulfill any obligations established by law and by European legislation;
d) for operational, administrative and management needs within the Data Controller and related to the services offered through the Site;
e) for statistical purposes, in a completely anonymous and aggregated form; the data collected for this purpose is collected as part of the normal navigation of the Site, for more information please refer to the art. 4.3;
2. In case of explicit and optional manifestation of consent, the data will be processed for marketing and/or commercial promotion purposes, including paper and/or digital advertising material, relating to the services and/or products offered by TL PHARMA CONSULTING SRL . Further details are available in art. 4.1.

3. Submission of Personal Data

The provision of personal data for the purposes referred to in art. 2, paragraph 1, letters a), b), c) and d), e) is mandatory only for the purposes indicated therein, as the legal basis of the processing is the execution of the services requested by the user, the execution of any contractual obligations, or a legitimate interest of the owner. Any refusal opposed to the relative processing may therefore prevent, for example, the stipulation or execution of contractual relationships, the fulfillment of legal obligations, consultation of the Site with all its functions, execution of the requested services; it will still be possible to consult the Site without providing any personal data, even if some functions may not be available and some services may not be provided.
2. The provision of personal data for processing activities for the purposes referred to in art. 2, paragraph 2, is optional, as the legal basis of the processing in this case is the user’s consent, which is always free and optional. In the absence of explicit consent, these services will not be provided (e.g. the user will not receive the newsletter) without further consequences. If the user does not intend to provide his consent for these purposes, he will still be able to use the Site and the services for the purposes referred to in art. 2, paragraph 1, without prejudice to the provisions in the previous paragraph.
3. The consequences of any refusal in the response or in the provision of consent will always be explained and connected to each service rendered: for example, any refusal to process data may prevent the stipulation or execution of contractual relationships, prevent consultation of the Site and its functions (in the case of cookies) or the receipt of the newsletter (in the case of the offer of the newsletter service). Therefore, the user will be adequately informed in the manner provided for each concrete case, but in any case he will be able to consult the Website also by denying consent to the processing of personal data, where required; in this case, certain functions or characteristics of the Site could be disabled.

4. What Data Are Processed?

Depending on the service rendered, different types of personal data may be processed, as specified in this article.

4.1 Navigation Data

The computer systems and software procedures used to operate this site acquire, during their normal operation, some personal data whose transmission is implicit in the navigation of the websites.
This information is not collected to be associated with identified interested parties; however, by their very nature they could, through processing and association with data held by third parties, allow users to be identified. These include the IP addresses or domain names of the computers used by users who connect to the Site, the URL addresses 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 given by the server and other parameters relating to the operating system and the platform used by the user.
The above data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning; are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site: except for this eventuality, the data on web contacts do not currently persist for more than thirty days. As regards cookies, please refer to the art. 4.3 et seq. following.

4.1.1 Data Provided Voluntarily By the User (Communications)

The optional, explicit and voluntary sending of communications by means of the contact forms on the Site (“form”) or by e-mail to the addresses indicated on this Site, involves the subsequent acquisition of the data communicated by the user, including his e-mail address, and consent to receive any response messages to your requests.
The personal data thus provided are used for the sole purpose of satisfying or responding to the requests transmitted and are communicated to third parties only if this is necessary for that purpose.

4.1.2 User Voluntarily Provided Data (To Receive Communications For Marketing And/Or Commercial Promotion Purposes)

Only in the event that personal data (in particular, e-mail address and telephone number) are provided by the interested party in the context of a service requested by the same, the data thus provided may be used to send communications via e-mail and/or telephone relating to services similar to those requested by the user, pursuant to art. 130, paragraph 4, Legislative Decree 196/2003, without the need for express and prior consent (so-called soft spam). In any communication, however, the user is reminded that he can revoke the consent at any time and without formalities. The data are deleted at the request of the interested party.

4.2 Newsletters

The TL PHARMA CONSULTING SRL newsletter is sent by e-mail to those who explicitly request it, by filling in the appropriate form on the Site and authorizing TL PHARMA CONSULTING SRL to process their personal data for the aforementioned purpose.
Consent: The provision of data is mandatory only for the purpose of receiving the newsletter and any refusal will make it impossible to use the service, without further consequences.
Purpose: The personal data provided by users will be used only to send the newsletter and will not be disclosed to third parties.
Method: The data collected will be processed with IT tools; in order to prevent their loss, illicit or incorrect use or in order to prevent any unauthorized access to the Site, specific security measures are adopted.
Cancellation from the service: to no longer receive the newsletter, simply select the unsubscribe link at the end of each email, or send a specific request to the email address info@tlpharmaconsulting.it.
The cancellation is managed automatically, so further newsletters could be received for a period following this request, in any case no later than 72 hours from the cancellation request, and whose sending was planned before the cancellation request was received.

4.3 Cookies

What are? Cookies are information stored by the browser when a website is visited with any suitable device (such as a PC, tablet or smartphone). Each cookie contains various data (e.g. the name of the server it comes from, a numeric identifier, etc.), can remain in the system for the duration of a session (until the browser is closed) or for long periods and can contain a unique identification code.
What are they for? Cookies are used for various purposes depending on their type: some are strictly necessary for the correct functionality of a website (technical cookies), while others optimize its performance to offer a better user experience or allow acquiring statistics on the use of the Site, such as analytics cookies, or allow you to view personalized advertising, such as profiling cookies.
Consent: the user is informed both through the brief information (banner displayed until consent is given or denied, as explained in paragraph 4.3.3 “How to disable cookies?”) and through this extended information; moreover, paragraph 4.3.3 indicates the links to the privacy policies of third parties, also for the purpose of disabling them (where directly available through them).
How to disable them? It is possible to disable cookies both through the browser settings (art. 4.3.4 “How to disable cookies?”) and through the mechanisms made available by some third parties (art. 4.3.2 “Cookies used on the Site”).

4.3.1 General Types Of Cookies Used On The Site

Technical cookies: they are essential for the correct functioning of the Site (e.g. to allow authentication to the site and facilitate the purchase of products).
Analytical cookies (first part): they are used for aggregate analysis of site visits.
Analytical cookies (third party): they are used for the purpose of aggregate analysis of visits to the site, through the use of a third-party service.
Profiling or advertising cookies (third parties): they are used to publish advertisements, also based on interests. These cookies are installed by third parties. The names of the third parties and the links to the related information are available in the following paragraph. In any case, these cookies, and the information acquired through them, are not associated with the user account of TL PHARMA CONSULTING SRL.

4.3.2 Specific Types Of Cookies Used On The Site

Name Origin Duration Purpose Location
frontend TL PHARMA CONSULTING SRL Session CMS service cookie (site content management system) All pages
_ga Third part
(Google Analytics)
26 months from first installation or update. Raccogliere statistiche sulla visita All pages
_dc_gtm Third part
Google Tag Manager)
Session Activate other Javascript TAGs All pages
Facebook Pixel Third part (Facebook Pixel) Cfr. privacy policy Facebook. Collect data deriving from navigation for advertising purposes. All pages
Google ADS Third part (Google ADS) Cfr. privacy policy Google Collect data deriving from navigation for advertising purposes. All pages
         

4.3.3 How to Disable Cookies?

Control via browser: Commonly used browsers (e.g. Internet Explorer, Firefox, Chrome, Safari) accept cookies by default, but this setting can be changed by the user at any time. This applies to both PCs and mobile devices such as tablets and smartphones: it is a generally and widely supported function.
Therefore, cookies can easily be deactivated or disabled by accessing the options or preferences of the browser used and generally only third-party cookies can be blocked; in general, these options will have effect only for that browser and on that device, unless options are active to unify preferences on different devices. Specific instructions can be found on your browser’s options or help page. However, disabling technical cookies can affect the full and/or correct functioning of various sites, including this site.
As a rule, the browsers in use today:
–   offer the “Do not track” option, which is supported by some websites (but not all). In this way, some websites may no longer collect certain navigation data;
–   offer the option of anonymous or incognito browsing: in this way no data will be collected in the browser and the browsing history will not be saved, but the browsing data will still be acquired by the manager of the website visited;
–   they allow you to delete stored cookies in whole or in part, but on a new visit to a website they are usually installed if this possibility is not blocked.
The links to the support pages of the most popular browsers are indicated (with instructions on disabling cookies on these browsers):
–    Firefox (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie);
–    Internet Explorer (http://windows.microsoft.com/it-it/internet-explorer/delete-manage-cookies#ie=ie-11);
–    Safari (iOS)( https://support.apple.com/it-it/HT201265);
–    Chrome (desktop: https://support.google.com/chrome/answer/95647?hl=it; Android and iOS https://support.google.com/chrome/answer/2392971?hl=it).
Third-party cookies: third-party cookies can be disabled both in the manner described above and by referring to each third party (following the links indicated in the previous paragraph).
Online tools: it should be noted that from the Website http://www.youronlinechoices.com/it/ it is possible not only to acquire further information on cookies, but also to verify the installation of numerous cookies on your browser/device and, where supported, even disable them.

5. Mode Of Data Processing

1. Personal data is processed lawfully and fairly and used only for the purposes indicated in art. 2. The processing will take place using tools suitable for guaranteeing the security and confidentiality of personal data and with automated tools suitable for storing, managing and transmitting the data. Specific security measures are adopted to prevent data loss and limit the risks of illicit or incorrect use and unauthorized access.
2. Personal data will be kept for the times prescribed by law and, in any case, for the time strictly necessary to follow up on the activities for which they were collected and/or until the consent given for the purposes of referred to in art. 2, paragraph 2.

6. To Whom Can Data Collected be Disclosed?

1. The treatments connected to the web services of this Site take place at the headquarters of TL PHARMA CONSULTING SRL and are only handled by technical personnel expressly in charge of the treatment, internal and/or external to them. In particular, where necessary only with prior consent, the data may be communicated to third parties whose collaboration TL PHARMA CONSULTING SRL can and/or must use for the performance of the services offered. The data acquired via the web, or in any case deriving from web services, may be communicated to the technological and instrumental partners used by the Data Controller for the provision of the services requested by users, always in compliance with the purposes indicated in the art. 2. To this end, 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 and 29 of the GDPR.
2. The data collected for the purposes set out above may also be communicated to associated companies or companies belonging to the same corporate group as the Data Controller and to subjects authorized for this purpose by provisions of law and European legislation.
3. A list of subjects to whom the Data Controller communicates the personal data collected for the aforementioned purposes is available and can be consulted at the Data Controller’s headquarters and can be requested at the addresses indicated.

7. Changes to the Privacy Policy

This Privacy policy could be modified, also as a result of legislative or regulatory modifications, technological evolutions and the provision of new services or modifications of those already provided. The user/visitor/customer is therefore invited to periodically consult the Privacy policy of TL PHARMA CONSULTING SRL.

8. What Are the Rights of the Interested Parties?

1. The interested party is the natural person, identified or identifiable, to whom the personal data being processed refer and, therefore, the user who accesses the Site and registers.
2. Each interested party is granted the right to access data concerning him or her processed by the Joint Controllers at any time (right of access) in order to verify its correctness and to verify the lawfulness of the processing carried out. The interested party can also exercise all the rights recognized by the current national and European legislation on the protection of personal data (from Legislative Decree 196/2003 and from EU Reg. No. 2016/679 and subsequent amendments and additions): in in particular, may request at any time the correction and updating of incorrect or inaccurate data, the limitation of the processing carried out and the cancellation of the same (right to be forgotten), as well as lodge a complaint with the Guarantor Authority for the protection of personal data .
3. With reference to personal data processed by automated means, the interested party can also receive the data concerning him in a structured and commonly used format and possibly transmit them to another data controller (right to data portability).

9. Right Of Revocation And Opposition

1. Each interested party is also recognized the right to revoke the consent given at any time, without prejudice to the lawfulness of the processing carried out by the Data Controller before such revocation.
2. The interested party is also always given the possibility of objecting to the processing of data concerning him if it is carried out for direct marketing purposes by the Data Controller; in this case your data will no longer be processed for these purposes, depending on the specific consent previously issued, by the Data Controller or by any third parties (right of opposition).

10. Points Of Contact

Any request regarding the processing of personal data and any communication relating to the exercise of one’s rights may be addressed to the Data Controller by sending a communication via e-mail to the address info@tlpharmaconsulting.it or by post to TL PHARMA CONSULTING SRL, via Lago di Martignano, 18 – 65129 – Pescara – ITALY.