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Privacy Policy (art. 13 Reg. EU 2016/679):

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Pursuant art. 13 of the EU Regulation n. 679 of 27 April 2016 (GDPR) regarding processing and free movement of personal data and its subsequent modifications and integration, we hereto publish the information regarding the processing of personal data by our Company regarding the access to the Internet sites www.ctb-consulting.com and www.geodati.com (henceforth "the Site") and the use of the service "Geodati" (henceforth "the Services").

ART. 1 - Definitions
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a.	User: the natural person who accesses the Site over the Internet;
b.	Registered User: the User who - in his/her own name or as an employee, partner or shareholder or owner, director of a legal person from which he/she has received the necessary powers - has entered a contract with CTB for the access to and the use of the Services.
c.	Personal Data: any information which identifies or makes directly or indirectly identifiable the User and which may provide information regarding his/her characteristics, habits, lifestyle, personal relations, health conditions, financial situation, etc.

ART. 2 - Types of Personal Data and their source
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The User's personal data collected by CTB are:

a.	Data on browsing of the Site in its publicly accessible section (IP address, served page, date and time) - data collected automatically by the web server;
b.	Commercial contact data (first and last name, company, organizational position, email address, telephone, reason for contact) - data supplied by the User when requesting a commercial contact through the Site.

The Registered User's personal data collected by CTB are:

c.	Personal identification (first and last name) - supplied by the User;
d.	Personal identification code ("User ID") which may coincide with his/her email address - datum supplied by the User;
e.	User's email address - datum supplied by and updatable by the User;
f.	Billing information (company name, company address, tax code, VAT code, electronic invoicing code or certified email address) - data supplied by the User
g.	Functional Settings for the Services - possibly entered by the User to customize the Services themselves;
h.	Data on browsing and usage of the Services by the User (IP address, type of operation executed, input data entered, output data extracted, copy of reports generated);
i.	Data on commercial transactions performed by the User (date and time, nature and quantity of the services, price, payment method, transaction outcome) - data automatically collected when each transaction is initiated by the User.

Therefore they are not the "sensitive" data pursuant articles 9 and 10 of the GDPR.

CTB does not collect any personal data regarding the User other than those listed above.

ART. 3 - Nature of provision, consent and refusal
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The provision of the data listed under art. 2 and its processing for the purposes listed under art. 5 and with the terms listed under art. 6 are needed for the operation and maintenance of the Site (a), to perform and manage commercial contacts (b) and to execute the contract between the User and CTB (c), (d), (e), (f), (g), (h), (i).

Specifically, at the time of registration to the Services or of the request of a commercial contact - after reading the information herein - the User must freely grant or deny his/her consent to the provision of the data under letters (b), (c), (d) , (e), (f), (g) of art. 2 and to the collection of data under letters (h) and (i), authorizing CTB to the processing thereof.

The User's consent is free and informed. However, should it be denied, CTB will not be able to perform the commercial contact or to accept the registration and execute the contract to provide the Services

ART. 4 - Controller
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Pursuant art. 4 and 24 of the GDPR the Controller is CTB Srl with registered and operating office in Via Domodossola 17 - 20145 Milano - Italy
Tel. +39 02 892 930 00
Dedicated email: info.privacy@ctb-consulting.com

ART. 5 - Purpose of Processing
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The User's personal data is processed for the purpose of the Controller's legitimate interests (art. 6, sub 1, letter f of the GDPR) and specifically in order to:

a.	Perform and manage the commercial contact requested by the User;
b.	Authenticate the User to access to the Services;
c.	Execute the contract between the Controller and the User, including electronic invoicing;
d.	Identify and solve possible technical problems in the Services' operation;
e.	Customize the usage of the Services by applying the settings chosen by the User;
f.	Send to the User messages and updates regarding the Services he/she has access to (e.g. data update, new features, etc.);
g.	Develop statistics on the usage of the Services with the purpose of their monitoring, maintenance and improvement;
h.	Fulfilments required by current fiscal regulations, by national and/or local administrations or by orders of the competent Authorities;
i.	Pursue other purposes of legitimate interest of the Controller under art. 6, sub 1, letter f of the GDPR.

ART. 6 - Terms of Processing
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The processing of the User's personal data is carried out with IT and telematic tools following a logic strictly related to the purposes stated in art. 5 and in any case such to ensure the security and confidentiality of the personal data and a processing which is limited, in general, only to the activities needed to provide the Services.

Specifically, the User's personal data is stored exclusively in encrypted form and normally it is processed in such form ("privacy by default") unless it's strictly necessary to decrypt a specific datum to perform a specific task (e.g. send an email to the User, identify the details of a malfunction reported by the User, perform a transaction, etc.).

The processing takes place exclusively in Italy by select Controller's employees whose activities are individually registered in uneditable logfiles.

ART. 7 - Data storage timespan
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The personal data under art. 2 letter (a) is stored for a period of 60 (sixty) days, after which they are destroyed.

The personal data under art. 2 letter (b) is stored for a period of time strictly necessary for the commercial contact, after which they are destroyed.

The personal data under art. 2 letters (c), (d), (e), (f), (g), (i) is stored until the end of the contract between the Controller and the User.

The personal data under art. 2 letter (h) is stored for a period not exceeding 18 months. After that they are permanently anonymized by irreversible cryptography of personal identification data (User ID and IP Address).

ART. 8 - Categories of subjects to whom data can be disclosed
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The User's personal data can be disclosed to:

a.	Natural or legal persons residing in Italy who provide the Controller with accounting and/or electronic invoicing services, limited to data under letters (f) and (i) of art. 2;
b.	Competent Authorities, if mandated by Law and/or in case of a lawful order by such Authorities.

The User's personal data is not subject to any other disclosure by the Controller.

ART. 9 - Rights of the User regarding personal data
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In accordance with the principles of privacy protection, the User can exercise, within the limits set by reasonableness and common sense and technical possibilities, the rights listed hereafter:

a.	ask to confirm the existence of personal data concerning the User or any other data provided by the User;
b.	ask information about the purpose and the terms of processing as well as the logic applied to processing performed by automated electronic tools;
c.	ask information about the subjects or categories of subjects to whom data can be disclosed or who can access the data;
d.	ask that the possibly unlawfully processed personal data be deleted or blocked;
e.	ask, with an explicit written request to the Controller, the deletion of all or some of the personal data regarding the User (this request may result in the Controller being unable to provide the User with the Services);
f.	ask that the personal data be updated, rectified or, when interested, integrated whenever he/she cannot do it autonomously;
g.	oppose, for legitimate and significant reasons, the processing of his/her personal data beyond the processing needed by the Controller to execute the contract with the User;
h.	file, in case of repeated unlawful processing of personal data, a complaint with the Control Authorities pursuant art. 13, sub 2, letter d) of the GDPR;
i.	ask, in the event of termination of the contract with the Controller, to obtain the personal data regarding him/her in at least one of the structured formats in common use readable by automatic devices;
j.	be promptly alerted by the Controller in case the latter, in the event of a security breach, realizes that the User's personal data were involved in such breach;
k.	receive replies to the aforementioned requests in a clear and transparent fashion.

The aforementioned requests can be made in writing via a motivated email to the dedicated account set in art. 4 addressed to the Controller who may ask the User, before complying with the request, further information and/or supporting documentation.

ART. 10 - "Cookies" Policy
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The term "cookies" generally refers to those text strings or files which can be memorized by the device (computer, tablet or phone) which is surfing the Internet by using a specific function provided by the browser. They can be "first-party" (i.e. they are installed by the same website one is visiting) or "third-party" (i.e. they are installed by a different site).

In operating the Site (in its publicly accessible section) and in providing the Services CTB installs on the User's device exclusively "first-party" cookies. Specifically:

a.	Session cookies
They are cookies which disappear when the browser is closed or after the User has logged out from the Services.
Session cookies are needed to operate the Site (in its publicly accessible section) and the Services provided by CTB to the User.

b.	Persistent cookies
They are cookies which are installed and stored on the User's device for a variable period of time.
In operating the Site (in its publicly accessible section) and in providing the Services CTB uses only cookies which can be defines as "technical" or "functional". Specifically:
In operating the Site (in its publicly accessible section) CTB uses only one persistent cookie which records the visualization by the User of the notification that the Site uses only "first-party" technical and functional cookies. This cookie is valid for 180 days and prevents the repeated notification as mandated by the "Guidelines for cookies and other tracing tools" issued on 10 June 2021 by the Italian Personal Data Protection Authority;

In operating the Services CTB uses cookies which are needed to provide some of the features which are part of the Services to which the User has access. The information in such cookies is protected by 256 bit or stronger cryptography. By way of example and not exhaustive:
-	Online support ID;
-	"Remember me" feature.

CTB does not use any cookie (e.g. profiling, social, analytic, etc.) other than the aforementioned.

(rev. 05/08/2021)

* I hereby declare that:

I freely and consciously submit my personal data to CTB Srl
I have read and understood the above Privacy Policy
I authorize the processing of my personal data by CTB Srl within the limitations, for the purposes and with the rights set forth in the aforementioned Privacy Policy.