Privacy & Cookie Policy

However, internet-based data transmissions may, in principle, be subject to security vulnerabilities, and therefore absolute protection cannot be guaranteed.
For this reason, data subjects are free to transfer their personal data via alternative means, e.g. by telephone.
1. Definitions
This privacy policy of Marco Ortelli SRL is based on the terms used by the European legislator in the adoption of the General Data Protection Regulation (GDPR). As our data protection statement should be readable and understandable to the general public, as well as to our customers and business partners, the following is a glossary of the terms used:
a) Personal data: any information relating to an identified or
identifiable natural person (‘data subject’).
An identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more factors
specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.
b) Data subject: the data subject is an identified or identifiable natural person whose
personal data are processed by the controller for the purposes of processing.

c) Processing: any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling: any form of automated processing of personal data consisting
of the use of personal data to evaluate certain personal aspects relating to a natural
person, in particular to analyse or predict aspects concerning the natural person’s
performance at work, economic situation, health, personal preferences, interests,
reliability, behaviour, location or movements.
f) Pseudonymisation: the processing of personal data in such a way that the personal data
can no longer be attributed to a specific data subject without the use of additional information,
provided that such additional information is kept separately and is
subject to technical and organisational measures to ensure that the personal data is not
attributed to an identified or identifiable natural person.
g) Controller: means the natural or legal person, public authority,
agency or other body which, alone or jointly with others, determines the purposes
and means of the processing of personal data; if the purposes and means of such processing are
determined by Union or Member State law, the controller or
the specific criteria for its appointment may be laid down by Union or
Member State law.
h) Processor or External Data Processor: means a natural or legal person,
public authority, agency or other body which processes personal data on behalf of the
controller.
i) Recipient: means a natural or legal person, public authority, agency or other
body to whom personal data are disclosed, whether a third party or not.
However, public authorities which may receive personal data in the context of
a specific investigation in accordance with Union or Member State law are not
considered recipients; the processing of such data by such public authorities must
comply with the applicable data protection rules in accordance with the purposes of
the processing.

j) Third party: a natural or legal person, public authority, agency or body other
than the data subject, the controller, the processor and persons who,
under the direct authority of the controller or the processor,
are authorised to process personal data.
k) Consent: a freely given, specific, informed and unambiguous indication of the wishes
of the data subject by which he or she, by a statement or a clear
affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the Controller:

for the purposes of the General Data Protection Regulation (GDPR), other data protection laws
applicable in the Member States of the European Union and other provisions
relating to data protection, this is:
Marco Ortelli SRL – Via Nazario Sauro, 9 – 20813 Bovisio Masciago (Mb)
Telephone: 0362 1858803
Email: privacy@marcoortelli.it
PEC: marco_ortelli@pec.it
Website: www.marcoortelli.it
3. Name and address of the Data Protection Officer (DPO)
Marco Ortelli SRL is not subject to the obligation to appoint a DPO.
4. Cookies
The websites of Marco Ortelli SRL use cookies. Cookies are text files that
are stored on a computer system via a web browser.
Many websites and web servers use cookies. Many cookies contain a so-called cookie ID.
A cookie ID is a unique identifier for the cookie. It consists of a string of
characters through which web pages and servers can be assigned to the specific web browser
in which the cookie has been stored. This enables the websites and servers visited to
distinguish the individual browser of the user from other web browsers that contain
other cookies. A specific web browser can be recognised and identified using
the unique cookie ID.
Through the use of cookies, Marco Ortelli SRL can provide users of this website
with more user-friendly services that would not be possible without the setting of cookies.

Cookies enable us to optimise the information and content on our website
to suit individual users. As mentioned above, cookies allow us
to recognise users of our website. The purpose of this recognition is
to make it easier for users to navigate our website. For website users
who use cookies, for example, it is not necessary to enter login details every time they
access the website, as this is handled by the website and the cookie is
therefore stored on the user’s computer system. Another example is the cookie for a
shopping basket in an online shop. The online shop stores the items that a
customer has placed in the virtual shopping basket via a cookie.
The data subject may, at any time, prevent the setting of cookies via
our website by adjusting the settings of the internet browser used, and
may thus permanently refuse the setting of cookies. Furthermore, cookies that have already
been set can be deleted at any time via an internet browser or other
software programmes. This is possible in all commonly used internet browsers. If the data
subject disables the setting of cookies in the internet browser used, not all
functions of our website may be fully usable.

5. Collection of general data and information
The Marco Ortelli SRL website collects a range of general data and information when
a data subject or an automated system accesses the website. This general data and
information is stored in the server log files.
The following may be collected:
(1) the types and versions of browsers used,
(2) the operating system used by the accessing system,
(3) the website from which an accessing system reaches our website (so-called
referrers),
(4) the directories or subdirectories visited
(5) the date and time of access to the website,
(6) an Internet Protocol address (IP address),
(7) the Internet service provider of the accessing system and
(8) any other similar data and information that may be used in the event of attacks
on our IT systems.
When we use this general data and information, we do not process it; in other words, we do not
profile our visitors.
Rather, this information is necessary to
(1) correctly display the content of our website
(2) optimise the content of our website and, where applicable, its advertising
(3) ensure the performance of our IT systems and website technology

(4) to provide law enforcement authorities with the information necessary
for criminal proceedings in the event of a cyber attack.
Marco Ortelli SRL therefore statistically analyses data and information collected anonymously,
with the aim of enhancing the protection and security of our company’s data
and ensuring an optimal level of protection for the personal data processed.
Anonymous data from server log files is stored separately from all
personal data provided by a data subject.
6. Contact options via the website
The Marco Ortelli SRL website contains information that enables rapid electronic
contact with our company, as well as direct communication with us, which
also includes a general email address. If a data subject contacts the data controller via email or via
a contact form, the personal data transmitted by the data subject is stored
automatically.

Such personal data transmitted on a voluntary basis by a data subject to the data controller

are stored for the purposes of processing or contacting the data subject.
There is no transfer of this personal data to third parties.
7. Routine erasure and blocking of personal data
The data controller processes and stores the data subject’s personal data only for
the period necessary to fulfil the purpose of storage, or to the extent that this is
permitted by the European legislator or other legislators in laws or regulations to which
the data controller is subject.
If the storage purpose no longer applies or if a retention period prescribed
by the European legislator or another competent legislator expires, the personal data
shall be routinely blocked or deleted in accordance with legal requirements.
8. Rights of the data subject
a) Right to confirmation
Every data subject has the right, conferred by the European legislator, to obtain from the
controller confirmation as to whether or not personal data concerning them exist. If
a data subject wishes to exercise this right to confirmation, they may, at any time,
contact any employee of the controller.
b) Right of access
Every data subject has the right, conferred by European legislation, to obtain from the
data controller, free of charge, information regarding their personal data stored at
any time, and a copy of such information. Furthermore, European directives and regulations
grant the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed,
in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored or, if
this is not possible, the criteria used to determine that period;
• the existence of the right to request from the controller the rectification or erasure of
personal data, or the restriction of processing of personal data concerning the data subject, or to
object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information
regarding their origin;
• the existence of automated decision-making, including profiling, as referred to
in Article 22(1) and (4) of the GDPR and, at least in such cases, meaningful information
regarding the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject.
Furthermore, the data subject has the right to obtain information regarding the transfer of personal data
to a third country or an international organisation.

In such cases, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, they may, at any time,
contact any member of staff of the data controller.
c) Right to rectification
Every data subject has the right, conferred by European legislation, to obtain from the controller,
without undue delay, the rectification of inaccurate personal data concerning them.
Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data
completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, they may, at any time,
contact any employee of the data controller.
d) Right to erasure and to be forgotten (right to be forgotten)
Every data subject has the right, conferred by European legislation, to obtain from the data controller
the erasure of personal data concerning them without undue delay,
and the data controller is obliged to erase personal data without undue
delay where one of the following grounds applies, provided that the processing is not necessary:
i. The personal data are no longer necessary in relation to the purposes for which they were collected or
otherwise processed.
ii. The data subject withdraws the consent on which the processing is based in accordance with Article 6(1)(a)
of the GDPR, or Article 9(2)(a) of the GDPR, and
where there is no other legal basis for the processing.
iii. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there
are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant
to Article 21(2) of the GDPR.
iv. The personal data has been processed unlawfully.
v. The personal data must be erased to comply with a legal obligation under
Union law or the law of the Member State to which the controller is subject.
vi. The personal data has been collected in relation to the provision of information society services
referred to in Article 8(1) of the GDPR.
If any of the above grounds apply and the data subject wishes to request the erasure of
personal data stored on the website www.marcoortelli.it, they may, at any time,
contact any employee of the data controller.

An employee of Marco Ortelli SRL will process the request for erasure within a reasonable period of time and
in any event as soon as possible, provided the request is legitimate.
Where the data controller has made personal data public and is required, pursuant to
Article 17(1), to erase the personal data, the data controller shall, taking into account
the available technology and the costs of implementation, take
reasonable measures, including technical measures, to inform other controllers
of the personal data that the data subject has requested the erasure by
such controllers of any links, copies or replicas of such personal data, insofar as
processing is not required.

e) Right to restriction of processing
Every data subject has the right, granted by the European legislator, to obtain from the
controller the restriction of processing where one of the following
conditions applies:
i. The accuracy of the personal data is contested by the data subject, for a period
enabling the controller to verify the accuracy of the personal data.
ii. The processing is unlawful and the data subject opposes the erasure of the personal data
and requests instead the restriction of their use.
iii. The controller no longer needs the personal data for the purposes of the processing, but they are
required by the data subject for the establishment, exercise or defence of legal claims.
iv. The data subject has objected to the processing pursuant to Article 21(1) of the
GDPR pending verification of whether the legitimate grounds of the controller
override those of the data subject.
If any of the above conditions are met, and the data subject wishes to request the
restriction of the processing of personal data stored by Marco Ortelli SRL, he or she
may contact the Data Controller at any time, and the Data Controller will arrange for the restriction
of processing.
f) Right to data portability
Every data subject has the right, conferred by European legislation, to receive the
personal data concerning them, which has been provided to a controller, in a structured,
commonly used and machine-readable format. They have the right to transmit such data to
another data controller without hindrance from the data controller
to whom the personal data were provided, provided that the processing is based on consent
referred to in Article 6(1)(a) of the GDPR or point (a) of Article 9(2) of the GDPR,
or a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is
carried out by automated means, provided that the processing is not necessary for
the performance of a task carried out in the public interest or in the exercise of official authority
vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Article 20(1)
of the GDPR, the data subject has the right to have personal data transmitted directly
from one controller to another, where technically feasible and provided that this does not
adversely affect the rights and freedoms of others.
To exercise the right to data portability, a request may be made to Marco Ortelli SRL.
g) Right to object
Every data subject has the right, recognised by European legislation, to object, on grounds
relating to their particular situation, at any time, to the processing of personal data
concerning them, which is based on point (e) or (f) of Article 6(1) of the GDPR.
This also applies to profiling based on these provisions.
Marco Ortelli SRL will no longer process personal data in the event of an objection, unless
we can demonstrate compelling legitimate grounds for the processing which override the
interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of
legal claims.

If the website www.marcoortelli.it processes personal data for direct marketing purposes,

The data subject has the right to object at any time to the processing of personal data
relating to them for such marketing activities. This applies to profiling in
so far as it is related to such direct marketing. If the data subject objects to the website
www.marcoortelli.it processing their data for direct marketing purposes, the website will no longer process
personal data for such purposes.
Furthermore, the data subject has the right, on grounds relating to their particular situation,
to object to the processing of personal data concerning them by Marco Ortelli
SRL for scientific or historical research purposes, or for statistical purposes pursuant to Article 89,
paragraph 1, of the GDPR, unless the processing is necessary for the performance of a
task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact any employee of Marco
Ortelli SRL.
Furthermore, the data subject is free, in the context of the use of information society services and,
notwithstanding Directive 2002/58/EC, to exercise their right to object by means of
automated tools using specific technical means.
(h) automated individual decision-making, including profiling
Every data subject has the right, granted by the European legislator, not to be
subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning him or her, or similarly
significantly affects him or her, provided that the decision (1) is not necessary for entering into or performing a
contract between the data subject and a data controller, or (2) is not
authorised by Union or Member State law to which the
data controller is subject and which also lays down suitable measures to safeguard the
rights and freedoms of the data subject and legitimate interests, or (3) is not based on the
explicit consent of the data subject.
If the decision (1) is necessary for the conclusion or performance of a contract between
the data subject and a data controller, or (2) is based on the explicit consent
of the data subject, the data subject has the right to obtain human intervention from the data
controller, to express their point of view and to challenge the decision.
If the data subject wishes to exercise their rights regarding automated individual decision-making,
they may, at any time, contact any employee of Marco Ortelli
SRL.

i) Right to withdraw consent to data processing
Every data subject has the right, granted by European legislation, to withdraw their
consent to the processing of their personal data at any time.
If the data subject wishes to exercise their right to withdraw consent, they may, at
any time, contact any member of staff at Marco Ortelli SRL.

9. Data protection provisions regarding the implementation and use of Google Analytics
On this website, the controller has integrated the Google Analytics component (with the
anonymisation function). Google Analytics is a web analytics service. Web analytics is
the collection, compilation and analysis of data on the behaviour of website visitors. A
web analytics service collects, amongst other things, data on the website from which a person arrived
(the so-called referrer), which subpages were visited, or how frequently
and for how long a subpage was viewed. Web analytics is

primarily used to optimise a website and to carry out a cost-benefit
analysis of internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy,
Mountain View, CA 94043-1351, USA.
For web analytics, the controller uses the ‘_gat. _anonymizeIp’ application. Through this
application, the IP address of the data subject’s internet connection is truncated by
Google and anonymised when accessing our websites from a Member State
of the European Union or from another State party to the Agreement on the European
Economic Area.
The purpose of the Google Analytics component is to analyse traffic on our
website. Google uses the data and information collected, amongst other things, to evaluate the use of our
website and to provide online reports showing activity on our websites, as well as to provide
other services relating to the use of our website on our behalf.
Google Analytics places a cookie on the data subject’s IT system. The
definition of a cookie is explained above. By setting the cookie, Google is enabled
to analyse the use of our website. Each time a page on
this website, operated by the controller and on which a
Google Analytics component has been integrated, the internet browser on the data subject’s
information technology system will automatically transmit data via the Google
Analytics component to Google for the purposes of online advertising and commission settlement. 

During
this technical process, Google obtains personal information, such as the data subject’s IP address, which provides Google, amongst other things,
with an understanding of the origin of visitors and clicks.
The cookie is used to store personal information, such as the time of access,
the location from which access was made, and the frequency of visits to our website
by the data subject. With every visit to our website, this personal data, including
the IP address of the internet connection used by the data subject, will be transmitted to Google
in the United States of America. This personal data is stored by Google in the United States
of America. Google may transfer this personal data collected through the
technical process to third parties.
The data subject may, as indicated above, prevent the setting of cookies via
our website at any time by making a corresponding change to the web browser
used and thereby permanently prevent the setting of cookies. Such
adjustment to the web browser used would prevent Google Analytics from setting
a cookie on the data subject’s computer system. Furthermore, cookies already in use by Google

Analytics can be deleted at any time via a web browser or other

software programmes.
Furthermore, the data subject has the option to object to the collection of data generated by
Google Analytics in connection with the use of this website, as well as to the processing of this
data by Google, and to prevent such processing. To do so, the data subject must
download a browser add-on from the link
https://tools.google.com/dlpage/gaoptout and install it. This browser add-on
informs Google Analytics via JavaScript that data and information regarding
website visits may not be transmitted to Google Analytics.
The installation of the browser add-ons is regarded by
Google as an objection. If the data subject’s computer system is subsequently deleted,
formatted or newly installed, the data subject must reinstall the browser add-ons
to disable Google Analytics. If the browser add-on has been
uninstalled by the data subject or by any other person within their sphere
of control, or if it has been disabled, the browser add-ons may be
reinstalled or reactivated.
Further information and the applicable data protection provisions of Google can
be found at https://www.google.com/intl/it/policies/privacy/ and at
http://www.google.com/analytics/terms/us.html.
Google Analytics is explained in more detail at the following link:
https://www.google.com/analytics/.
11. Data protection provisions regarding the implementation and
use of Google AdWords
The controller has integrated Google AdWords into this website. Google AdWords is an
online advertising service that enables advertisers to place adverts in the results
of Google search engines and within the Google advertising network. Google AdWords
enables an advertiser to define specific keywords, with the help of which an
advert on Google’s search results is displayed only when the user uses the
search engine to retrieve a search result relevant to the keyword. In
Google’s advertising network, advertisements are distributed across relevant web pages
using an automated algorithm, taking into account the keywords
previously defined.
The operating company for Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain
View, CA 94043-1351, USA.
The purpose of Google AdWords is to promote our website by placing relevant
advertisements on third-party websites and in the search results of the Google search engine,
as well as placing third-party advertisements on our website.

If a data subject reaches our website via a Google advert, a conversion cookie
is stored on the data subject’s computer system via
Google. The definition of a cookie is explained above. A conversion cookie expires
after 30 days and is not used to identify the data subject. Provided the cookie has not
expired, the conversion cookie is used to check whether certain sub-pages,
such as the shopping basket in an online shop system, have been

accessed on our website. Through the conversion cookie, both Google and the

controller can determine whether a person who clicked on an AdWords advertisement on our
website has generated sales, i.e. has completed or cancelled a purchase of goods.
The data and information collected through the use of the conversion cookie are used by
Google to create visitor statistics for our website. These visitor statistics
are used to determine the total number of users who have been served via
AdWords adverts, to ascertain the success or failure of each AdWords advert, and
to optimise our AdWords adverts in the future. Neither our company nor other
receive information from Google that could identify
the data subject.
The conversion cookie stores personal information, e.g. the web pages
visited by the data subject. Each time we visit our web pages, personal data,
including the IP address of the internet connection used by the data subject, is transmitted to
Google in the United States of America. This personal data is stored by Google in the
United States of America. Google may transfer this personal data collected via the technical
process to third parties.
The data subject may, at any time, prevent the setting of cookies by our website
as described above by making a corresponding setting in the internet browser
used and thereby permanently prevent the setting of cookies. Such a setting
in the internet browser used would also prevent Google from placing a conversion cookie
on the data subject’s computer system. Furthermore, a cookie set by Google
AdWords can be deleted at any time via the internet browser or other
software programmes.
The data subject has the option to object to interest-based advertising by Google.
To do so, the data subject must access the link
www.google.de/settings/ads from each of the browsers they use and configure the desired settings.
Further information and the applicable data protection provisions of Google can
be found at https://www.google.com/intl/en/policies/privacy/.

12. Legal basis for processing
Our company is subject to a legal obligation requiring the processing of
personal data, for example to comply with tax obligations. In rare cases, the processing of personal data
may be necessary to protect the vital interests of the data subject or another
natural person. This would be the case, for example, if a visitor were injured on our
premises and their name, age, health insurance details or other vital information
had to be passed on to a doctor, hospital or other third parties.
13. Legitimate interests pursued by the data controller or by
a third party
Our legitimate interest is to conduct our business in the interests of the well-being of all our
employees and shareholders.

14. Retention period for personal data

The criteria used to determine the retention period for personal data are the respective
retention periods prescribed by law. Once this period has expired, the relevant data
is routinely deleted, provided it is no longer required
for the performance of a contract or the initiation of a contract.
15. Provision of personal data as a legal or contractual requirement;
Requirement necessary to enter into a contract; the data subject’s obligation to provide
personal data; possible consequences of failure to provide such data.
We would like to clarify that the provision of personal data is in some cases required by law (e.g.
tax regulations) or may also arise from contractual provisions (e.g.
information about the contractual partner).
It may sometimes be necessary for the data subject to provide personal data in order to conclude a contract,
which must subsequently be processed by us. The data subject is, for example,
obliged to provide us with personal data when our company enters into a contract with him or
her.
Failure to provide personal data would mean that the contract with
the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact the Data Controller,
who must clarify to the data subject whether the provision of personal data is required by law or
by contract, or is necessary for the conclusion of the contract; whether there is an obligation to provide the
personal data; and the consequences of failing to provide the personal data.
16. Existence of automated decision-making processes
As a responsible company, we do not use automated decision-making or profiling.
17. Our app and geolocation
17. Our app and geolocation
The Marco Ortelli SRL mobile app and our website offer features that may
collect data relating to the user’s geographical location (via the mobile phone’s GPS, the
Wi-Fi connection, and the GSM network).

The collection of this data enables the use of the device’s location service and
facilities near the user’s geographical location.
These services will be activated following authorisation provided by the user, by
selecting the “Allow” option when using the mobile app’s functionality
for the first time.
Data will only be collected when the Application or Website is in use.
At any time, the user may, however, enable or disable the
geolocation services by accessing the relevant section of the location permissions in
their device’s operating system.

The system does not store any geolocation data, thereby preventing both

continuous monitoring of the user’s location and any reconstruction of
their routes.