Habacus s.r.l. may modify this privacy statement in accordance with future improvements or modifications of the Website or the provided services. In case of substantial changes, Habacus s.r.l. will publish a notice on the Website to draw the Users’ attention to the changes and collect, if necessary, any request to exercise the rights recognized by the applicable laws on the protection of personal data.
1. DATA CONTROLLER
The data controller is Habacus s.r.l., with registered seat in Milan, Via Filippo Sassetti, 32, Copernico Isola Fintech, 20124, tax code and VAT code no. 04906910262
(“HABACUS” or “Data Controller”).
2. COLLECTED DATA
2.1 Personal data provided by Users
Personal data collected through the Website are provided by the Users by filling-in the form made available on the Website, in particular: Section “Contact Us Now”.
In the section “Contact us now” or by sending HABACUS a request to the addressed indicated on the Website, and within the context of lead generation activities realized by HABACUS on social networks and/or other media, the User will provide his personal identification and contact data (e.g. name and surname, e-mail address), data included in the communications and requests sent to HABACUS, as well as all further data necessary to reply and follow up on Users’ requests.Account registration form
By submitting your account registration request to the Website and filling in the data collection form in the “Registration” section, you will provide your personal, identification and contact data, such as your name and surname, e-mail address and, if required, the name of your organisation and your role.Users are invited to provide HABACUS with up to date and relevant data, limited to what is necessary in relation to the purposes for which they are processed. Any unnecessary data will be immediately deleted or anonymized.
2.2 Web browsing information data
Each time the Users access the Website, the systems automatically register and analyze the access data (like the provider’s IP address, information on the used browser, pages visited, date, time and duration of each visit). The information is automatically collected by the Website and does not require any action by Users.The Website collects only anonymous and aggregated data, which cannot lead to the identification of Users. The information collected merely allows to detect and resolve any technical problems.
3. PURPOSE OF THE PROCESSING
Users’ personal data (the “Data”) shall be processed for the following purposes.
3.1 Follow up Users’ requests
The Data shall be processed:- To respond and follow up on the requests that Users may send to HABACUS through the form in the “Contact Us Now” section of the Website or to the contact details available on the Website;- To allow the registration of the User’s account to the Website and to verify, through a validation flow, the validity of the registered e-mails.The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract.§The provision of Data for the above-mentioned purposes is necessary
for the correct management and execution of the User’s requests. Any partial or total refusal to provide Data for such purposes will make it impossible for the Data Controller to fulfil such requests.
3.2 Sending commercial, informative and survey material
The Data will be processed in order to keep Users constantly updated on the activities, services, products and promotions of HABACUS by sending communications and information materials, as well as to obtain feedback and opinions by Users on it’s activities, services, products and promotions by sending questionnaires and surveys.The sending of communications,
information material and questionnaires and surveys will be carried out through automatic messages, e-mail and/or telephone, depending on the contact data provided by the Users from time to time. The legal basis for the processing is the legitimate interest of HABACUS: (i) to provide information to the Users interested in the activity carried out by the Data Controller, which have provided – in accordance with the collection methods adopted from time to time by HABACUS (lead campaigns, forms, etc.) – their Data in order to receive updates; and (ii) to improve HABACUS’ offer to the Users, through the analysis of the “customer satisfaction” that emerges from the interactions of the Users.Such legitimate interest, in light of the spontaneous release of the Data by the User in the context of the collection activities organized by HABACUS and aimed at promoting the activities of the latter, does not prejudice the rights and freedoms of the Users.
4. MODALITIES OF PROCESSING AND RECIPIENTS OF DATA
The Data shall be processed by means of manual and digital tools by HABACUS’ employees and collaborators and/or by companies specifically appointed as data processors, to which HABACUS has given detailed instructions, with specific regard to the implementation of appropriate technical and organizational security measures.The complete list of the recipients of Data is stored at the data controller’s office and is available upon request, to be sent to the addresses set out in following point 6.
5. PERIOD OF STORAGE
The Data collected and processed by HABACUS, for the purpose set out in point 3.1 above, may be stored and processed in a form that allows the identification of the User for the period necessary to achieve the purposes of processing and, in particular:- in the case of
filling in the “Contact Us Now” form for a period of 12 (twelve) months from the last contact made- in the case of filling in the ” Registration ” form until the User deletes his/her
personal account from the Website and, in any case, for the entire duration of the contractual relationship with the Data Controller, as well as for the time necessary to
(i) fulfil statutory and/or legal obligations and
(ii) ensure the judicial protection of the Data Controller’s rights,
in accordance with the relevant limitation periods.The Data collected and processed by HABACUS, for the purpose set out in point 3.2 above, may be stored and processed in a form that allows the identification of the User for the period necessary to achieve the purposes of processing and, in particular, up to 18 months from the collection, after which HABACUS will ascertain the continued interest of the User in receiving the above mentioned communications referred to in the point 3.2.
6. USER’S RIGHTS AND CONTACT DETAILS
At any time and to the extent applicable the User can:
(I) obtain access to his / her personal data;
(II) obtain the rectification or cancellation or, where applicable,
the limitation on their processing;
(III) lodge a complaint with a supervisory authority or with the relevant judicial authority.
The requests concerning the exercise of the above rights shall be sent to the following addresses:– by e-mail, to: email@example.com;– by registered letter, to:
Habacus s.r.l., Via Filippo Sassetti, 32, Copernico Isola Fintech, 20124, Milan.or to the Data Protection Officer’s contact details, set out in point 8 below.To the same addresses above, the
Users shall send also the requests concerning the recipients of Data, as well as the clarifications’ requests regarding this privacy statement.
7. LINKS TO OTHER WEBSITES
This privacy statement is provided exclusively in relation to the Data collected through the Website and with reference to the purposes identified in point 3., and not for any
other websites accessed and / or accessible through links and / or widgets (e.g. social networks): these other websites will process the Data as independent data controllers and in accordance with their respective privacy statements. The Users are recommended to read them.
8. DATA PROTECTION OFFICER
The Data Protection Officer (DPO) appointed by HABACUS is LCA SERVIZI S.R.L., which can be reached at the following address: via della Moscova, 18, 20121, Milan; email: firstname.lastname@example.org; certified mail: email@example.com.
Data Controller and Data Protection Officer (DPO)
This information is made by habacus.com (hereinafter simply “Habacus“, the “Company” or the “Data Controller“).
If you have any questions about how the Data Controller processes your personal data, you can always contact it:
- To the e-mail address firstname.lastname@example.org
- at the address via Filippo Sassetti, 32, 20124, Milano.
The Data Controller has appointed as DPO LCA Servizi S.r.l., with registered office in Milano, via Della Moscova, 18, 20121, which can be emailed at: email@example.com
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- explain the types of cookies on the Website habacus.com (the “Website“) and how they are used; and
- provide guidance to users of the Website (the “Users“) on actions to refuse or delete, if desired, such cookies.
Cookies are small text strings that the Websites visited by Users send to the respective the terminal, where they are stored, to be subsequently re-transmitted to the same Websites the next time Users visit it. This is required to make the internet browsing experience more fluid and personal.
During the navigation on a Website, Users may receive “first party” cookies on their terminal, i.e. those managed directly by the Data Controller and/or manager of the Website, but also cookies that are sent from different Websites or web-servers (so-called “third party” cookies). This happens because on the Website visited there may be elements that reside on servers other than the one on which the Website itself is located and set by a Website other than the one you are currently visiting.
With reference to the purposes concretely pursued by the Data Controller, cookies can be (a) technical, (b) analytical, and (c) profiling.
What is it about?
Technical cookies are used for the sole purpose of carrying out the transmission of a communication over an electronic communication network, or to the extent strictly necessary for the provider of an information society service to provide a service explicitly requested by the user. Technical cookies are differentiated into (i) session cookies, which are not permanently stored on the user’s computer and are deleted when the browser is closed; and (ii) functionality cookies, which are used to store the customizations chosen by the User on the Website, such as language. The use of these types of cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe, effective and easy exploration of the Website.
Users’ prior consent is not required for the installation of such cookies.
What technical cookies are on the Website?
The Website makes use of the following technical cookies
|Cookie||Supplier||Domain||Treated Data and Purpose||Cookie retention period|
|_zcsrc||Zoho||Zoho sets this cookie for the login function on the website||Session|
|cookielawinfo-checkbox-advertisement||GDPR Cookie Consent plugin||.habacus.com||Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the “Advertisement” category.||1 year|
|cookielawinfo-checkbox-analytics||GDPR Cookie Consent plugin||.habacus.com||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Analytics”.||11 months|
|cookielawinfo-checkbox-functional||GDPR Cookie Consent plugin||.habacus.com||The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category “Functional”.||11 months|
|cookielawinfo-checkbox-necessary||GDPR Cookie Consent plugin||.habacus.com||This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category “Necessary”.||1 year|
|cookielawinfo-checkbox-others||GDPR Cookie Consent plugin||.habacus.com||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.||11 months|
|cookielawinfo-checkbox-performance||GDPR Cookie Consent plugin||.habacus.com||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Performance”.||11 months|
|CookieLawInfoConsent||GDPR Cookie Consent plugin||Records the default button state of the corresponding category & the status of CCPA. It works only in coordination with the primary cookie.||1 year|
|LS_CSRF_TOKEN||Cloudflare||salesiq.zoho.eu||Cloudflare sets this cookie to track users’ activities across multiple websites. It expires once the browser is closed.||Session|
|pll_language||Polylang||.habacus.com||The pll_language cookie is used by Polylang to remember the language selected by the user when returning to the website, and also to get the language information when not available in another way.||1 year|
|yt-remote-connected-devices||YouTube||YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.||Never|
What is it about?
Analytical cookies are those cookies used to collect information, analyze and measure – in aggregate form – the number of Users and how they visit the Website.
What analytical cookies are on the Website?
|Cookie||Supplier||Domain||Treated Data and Purpose||Cookie retention period||Adoption of tools that reduce the identifying power of the Cookie|
|_ga||Google Analytics||.habacus.com||The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.||2 years||Yes|
|_ga_UA-144893821-1||Google Analytics||.habacus.com||A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.||1 minute||Yes|
|_gcl_au||Google Tag Manager||.habacus.com||Provided by Google Tag Manager to experiment advertisement efficiency of websites using their services.||3 months||No|
|_gid||Google Analytics||.habacus.com||Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.||1 day||Yes|
|_hjAbsoluteSessionInProgress||Hotjar||.habacus.com||Hotjar sets this cookie to detect the first pageview session of a user. This is a True/False flag set by the cookie.||30 minutes||No|
|_hjFirstSeen||Hotjar||.habacus.com||Hotjar sets this cookie to identify a new user’s first session. It stores a true/false value, indicating whether it was the first time Hotjar saw this user.||30 minutes||No|
|_hjIncludeInPageviewSample||Hotjar||Hotjar sets this cookie to know whether a user is included in the data sampling defined by the site’s pageview limit.||2 minutes||No|
|_hjIncludeInSessionSample||Hotjar||Hotjar sets this cookie to know whether a user is included in the data sampling defined by the site’s daily session limit.||2 minutes||No|
|_hjSession_2944476||Hotjar||No description||30 minutes||No|
|_hjSessionUser_2944476||Hotjar||.habacus.com||No description||1 year||No|
|_hjTLDTest||Hotjar||To determine the most generic cookie path that has to be used instead of the page hostname, Hotjar sets the _hjTLDTest cookie to store different URL substring alternatives until it fails.||Session||No|
|CONSENT||YouTube||.google.it/.google.com||YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.||2 years||No|
|yt.innertube::nextId||YouTube||This cookie, set by YouTube, registers a unique ID to store data on what videos from YouTube the user has seen.||Never||No|
What is it about?
Profiling cookies make it possible to create a profile of Users based on their experience and browsing habits on the Website. In this way, you can provide targeted advertising based on your interests instead of generic advertising. They can be both first party and third-party cookies.
What profiling cookies are there on the Website?
|Cookie||Domain||Source||Treated Data and Purpose||Cookie retention period|
|_fbp||.habacus.com||This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website.||3 months|
|_uetsid||Bing Ads||.habacus.com||Bing Ads sets this cookie to engage with a user that has previously visited the website.||1 day|
|_uetvid||Bing Ads||.habacus.com||Bing Ads sets this cookie to engage with a user that has previously visited the website.||1 year 24 days|
|b3e783bb62||Zoho||This cookie is set by the provider Zoho. This cookie is used for collecting information on user interaction with the web-campaign content. This cookie helps the website owners to promote products and events on the CRM-campaign-platform.||Session|
|fr||Facebook sets this cookie to show relevant advertisements to users by tracking user behaviour across the web, on sites that have Facebook pixel or Facebook social plugin.||3 months|
|IDE||Google DoubleClick||.doubleclick.net||This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category “Other.||1 year 24 days|
|MUID||Bing||.bing.com||Bing sets this cookie to recognize unique web browsers visiting Microsoft sites. This cookie is used for advertising, site analytics, and other operations.||1 year 24 days|
|test_cookie||doubleclick.net||The test_cookie is set by doubleclick.net and is used to determine if the user’s browser supports cookies.||15 minutes|
|VISITOR_INFO1_LIVE||YouTube||A cookie set by YouTube to measure bandwidth that determines whether the user gets the new or old player interface.||5 months 27 days|
|YSC||YouTube||YSC cookie is set by Youtube and is used to track the views of embedded videos on Youtube pages.||Session|
|yt-remote-device-id||YouTube||YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.||Never|
|yt-remote-connected-devices||YouTube||This cookie, set by YouTube, registers a unique ID to store data on what videos from YouTube the user has seen.||Never|
Finally, it should be noted that the so-called social buttons in the home page of the Website are only simple links to external pages of the relevant social networks, which do not install cookies.
Nature of data provision by users
The provision of data is optional and can be managed through the banner on the homepage of the Website.
You can change your cookie preferences at any time through specific browser configurations, according to the specific procedures described below. Through the browser preferences, it is also possible to delete the cookies installed in the past, including the cookie in which the consent to the installation of cookies by one of the Website may be saved.
If you decide to disable cookies (including technical cookies), you will not have access to many features that make the Website more efficient and some of the Company’s services accessible through the Website will not function properly.
You can control cookies through your browser settings. As each browser has different features, you should check the “help” menu of your browser to understand how to properly modify your cookie settings.
You can then change your browser settings so that cookies are deleted or not stored on your computer or mobile device without your explicit consent. At the following links the User can better understand how to set his browser:
- Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: https://support.mozilla.com/en-US/kb/cookies-information-webWebsites-store-on-your-computer#w_cookie-settings
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: http://support.apple.com/kb/PH504
For further information on the world of cookies, the User can always consult the Website www.allaboutcookies.org.
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For all other information on the processing of personal data collected on the Website, (for example, users’ rights, recipients of data, transfers abroad) please read the information on the processing of personal data on the Website, by clicking here