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Privacy Policy - Cookie Policy
FD-SOLUTIONS Ltd.
SOFIA (BG) – Bacio Kiro, 24
VAT BG204905042
M: +359 879 453 616
E: clients@fd-solutions.eu
Pursuant to articles 6 and 7 of the EU Regulation 2016/679, as well as pursuant to the provisions of the measure no. 229 of May 8th, 2014 issued by the Guarantor for the protection of personal data, in this page the Personal Data Controller, FD SOLUTIONS Ltd. (hereinafter, “Company”, “Organization” or “Data Controller “), with Registered office in 1000 SOFIA (Bulgaria) – Bacio Kiro, 24, e-mail: clients@fd-solutions.eu, provides to the users of the website https://fd-solutions.eu information related to the cookies used and/or proposed for archiving.
This extensive information on the use of cookies (hereinafter also “cookie policy“) should be read in tandem with the Privacy Policy pursuant to ex art. 13 of the EU Regulation 2016/679, available as a separate document in the appropriate “privacy” section of the website https://fd-solutions.eu, in the footer of the home page.
This cookies policy has also the purpose of describing the elements provided for by the law and describing the characteristics and purposes of the cookies installed from the website https://fd-solutions.eu , including the updated link to the information and consent forms of the third parties with whom the Data Controller has entered into agreements for the installation of cookies through his website and, finally, recalling the possibility for the user to express his/her options on the cookies even through the settings of the browser used.
What are cookies?
The Recital 30 of the European Regulation on the protection of personal data (GDPR), establishes that ” Natural persons can be associated with online identifiers produced by the devices, applications, tools and protocols used, such as IP addresses, temporary markers (cookies) or other identifiers, such as radio frequency identification tags. These identifiers can leave traces which, in particular if combined with unique identifiers and other information received from the servers, can be used to create profiles of natural persons and identify them”.
From the aforementioned rule, it can be easily deduced that cookies are small text files that the sites visited by users send to their devices. In normative texts, they are sometimes referred to as “markers”. These files are stored internally to be retransmitted later to the same sites of origin on the occasion, perhaps, of a subsequent visit (so-called user tracking). The Cookies can be stored within the user’s device directly from the website that the latter is visiting (first-party site) or from a different website, so-called “third party”, since within each website, there may be elements (i.e., images, maps, sounds, specific links to web pages of other domains, etc.) that may reside and/or lead the user to links present on servers other than those provided by the first-party site. Thanks to the storage of cookies, the user can customize the use of some website contents by saving his or her preferred settings. This allows for the association of specific online behaviors to the user and then classify his/her (profiling). For example, it is possible to set up a cookie for the recognition of the user registered on the site without the same having to proceed on the occasion of a new visit with a new authentication (login).
From the GDPR (in particular, Recital 26) it is also deduced that cookies are pseudonymous data, i.e., personal data where the identification elements have been replaced by other elements (such as text strings and numbers).
Pseudonymous data are considered personal data; by crossing them with other information, it is possible to identify the person, or rather achieve the univocal identification of the device used for access and online navigation.
Taxonomy proposed by the Guarantor
(Ref. Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies – May 8, 2014).
The Guarantor for the protection of personal data in the Provision n. 229 of May 8, 2014 proposes a taxonomy that identifies two categories of cookies based on two possible processing purposes:
Technical cookies
They are cookies that are used to navigate and/or provide a service to the user. They are not used for other purposes and are normally installed directly by the website owner. Without the use of these cookies, some operations could not be performed or would be more complex and/or less secure, such as home-banking activities (display of the bank statement, wire transfers, payment of bills, etc.), for which cookies, which allow to make and maintain the user’s identification during the session, are indispensable.
Profiling cookies
They are cookies used to track the user’s browsing on the net and create profiles on tastes, habits, choices, etc. With these cookies, advertising messages can be transmitted to the user’s device in line with the preferences already expressed by the same user when browsing online.
User’s consent for the installation of cookies on the device
The expression of consent to the storage of cookies depends on the purposes for which the cookies themselves are used, and on these it depends whether they fall in the cases of “technical cookies” or “profiling cookies”. For the installation of technical cookies, no consent is required from the users while, in the case of third-party cookies, it is necessary, among other things, to provide appropriate information (pursuant to art. 12 of the EU Regulation 2016/679). However, with regard to profiling cookies only, they can be installed on the user’s device only if the same has expressed his/her free, voluntary, specific and unequivocal consent after having been adequately informed.
Analytical cookies
The Guarantor (with reference to the Provision number 229 of May 8, 2014), has specified that these cookies can be assimilated to technical cookies only if used for the purpose of optimizing the website and directly by the Owner of the website itself (therefore not by any third party ), who can collect information in aggregate form on the number of users and how they visit the website. Under these conditions, the same rules apply to analytical cookies, in terms of information and consent, provided for technical cookies.
Cookies installed on this website
FD SOLUTIONS Ltd. , with Registered Office in 1000 SOFIA (Bulgaria) – Bacio Kiro, as Personal Data Controller, declares not to use profiling cookies or third-party cookies for the provision of the website pages https://fd-solutions.eu .
Provision of data
With the exception of the technical cookies strictly necessary for normal navigation, the provision of the data is left to the will of the data subject who decides to browse the website after having read the brief information contained in the appropriate banner. The data subject can avoid the installation of cookies through the special functions available on his/her browser or by interrupting the navigation.
How to disable the storage of cookies through the browser settings
It is possible to deny the general consent to the installation of any cookie on the user’s device by selecting the appropriate setting of your browser: browsing without tracking your activities will still be available in all its features. Below are links that inform the user on how to disable cookies for the most used browsers:
Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookie;
Google Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&p=cpn_cookie;
MozillaFirefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie;
Apple Safari: https://support.apple.com/kb/ph19214?locale=it_IT.
Last update of the document (Rev. 02) : January 14, 2021
FD SOLUTIONS Ltd.
A- Data controller, data processor managers and persons authorized to process personal data
FD SOLUTIONS Ltd. (hereafter, “Company”, “Organization” or “Data Controller “), with registered office in 1000 SOFIA (Bulgaria) – Bacio Kiro, 24, e-mail: clients@fd-solutions.eu, informs you herewith that the data provided by you in relation to existing and/or future legal relationships (user/data subject) will be processed in compliance with the aforementioned legislation.
The aforementioned processing will take place in a lawful way and according to the principles of art. 5 of the EU Regulation 2016/679. Further communications may be disclosed later either written or verbal.
The updated list of external data processor officers and persons authorized to process the data is kept by the Company in its archives, at the Operational Headquarters of the Company.
B- Data subject to processing
“Personal data processing” means any operation or set of operations performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring , storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or any other form of making available, comparison or interconnection, limitation, deletion or destruction. Specifically, these are data voluntarily provided by you for the execution of the legal relationships in place with the Data Controller.
Article 4, paragraph 1, of EU Regulation 2016/679 defines “personal data” as any information concerning an identified or identifiable natural person (“data subject”); it is considered identifiable the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical , physiological, genetic, psychic, economic, cultural or social identity.
The data subject to processing, summarized below, in a completely exemplary but certainly not exhaustive form, will be voluntarily provided by you for the execution of existing and/or future legal relationships:
Added to this are the navigation data, the IT systems and the software procedures used to operate this website, which could acquire during their normal operation your personal data, and the transmission of which is implicit in the use of the Internet communication protocols. However, this is information that is not collected with the intent of associating it with identified users, but by its very nature, it might lead to the identification of users through processing and association with data held by third parties. This category of data includes the IP addresses or domain names of the computers used by persons who connect to the site, the addresses in notation URI (Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters regarding the user’s operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information about the use of the website and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical cyber crimes to the detriment of the website or requests from the authorities.
C – Purpose of the data processing
The personal data provided by you will be processed for the following purposes:
D – Legal basis of the processing
With reference to the purposes referred to in points 1 to 6 of paragraph C, the processing is necessary for the performance of a legal relationship which you are or may be a part of or the execution of pre-contractual measures adopted at your request. The processing is therefore lawful (art.6, co. 1, letter b), EU Regulation 2016/679). With reference to the purposes referred to in point 7 of the paragraph, the processing is optional and therefore subject to your consent in order to be lawful (art.6 co. 1 lett. A).
E – Duration of the data processing
The personal data collected for the purposes referred to in points 1 to 6 of paragraph C, will be processed for a period of time not exceeding the achievement of the purposes for which they are processed and for the subsequent ten (10) years for legal requirements . The data relating to the purposes referred to in point 7 will be processed for two (2) years, from the date of their acquisition, unless requested by the interested party. Such data, upon expiry of said term, will be destroyed.
The personal data contained in documents relevant for administrative-accounting purposes will in any case be kept in compliance with legal obligations.
F – Nature of the provision of data
The provision of data is mandatory in relation to the purposes from 1 to 6 of paragraph C, i.e., to fulfill the legal obligations regarding an established legal relationship and for any other purpose connected to legal obligations, regulations and community legislation; the refusal to communicate the data will prevent the Data Controller from fulfilling these obligations and consequently the inability to provide you with information and/or services requested by you. The provision of your data and consent to the processing for the purposes referred to in point 7 are completely optional. Failure to provide the conferment or rather the consent to the processing of your personal data for the aforementioned purpose will make it impossible to perform promotional activities within marketing and commercial communication by e-mail or telephone regarding the services provided by the Data Controller including also through any partners.
G – Data processing methods
The data will be processed and stored exclusively for the purposes indicated above through the use of both paper and computer media, inserted in relevant databases and processed with suitable tools to guarantee the integrity, security and confidentiality of the data, in accordance with the provisions of the EU Regulation 2016/679. All the appropriate technical and organizational measures will be taken to ensure a level of data protection compliant with the provisions of the EU Regulation 2016/679. Access will be allowed only to persons authorized in writing to process personal data. The data may also be communicated and/or collected for/by third parties (as in the case of data acquisition from processing centers or from other companies). They will be appropriately designated as Data Processors and will be involved in the fulfilments required by the existing legal relationship as well as by specific legal obligations.
H – Social platforms
The website may offer access doors to so-called services and platforms – Social Network.
FD SOLUTIONS Ltd. recommends excercising caution regarding the dissemination of personal information on telematic channels through “comments” or “public posts” when using the aforementioned platforms. The terms of use and the privacy policies applicable to each of these social media, published on the respective sites, regulate the information provided. FD SOLUTIONS Ltd. does not perform any form of control over the use of personal information communicated in a public forum, a comment area, a message board, making the user solely responsible for any disclosure. For more specific information about the above, please visit the social policy section of the website, at the web address https://fd-solutions.eu/.
I – Cookies
The website https://fd-solutions.eu/ uses only technical cookies, necessary and functional for the provision of the same and third parties, which do not allow to collect information about visitors (profiling). For more specific information about the above, please visit the cookie policy section of the website at the web-address https://fd-solutions.eu/.
L – Communication to third parties and/or dissemination of data
For the purposes referred to in numbers from 1 to 6, FD SOLUTIONS Ltd. informs you that your data could be communicated to external subjects, designated in writing, if this is necessary to fulfill an obligation under the law, for the performance of obligations deriving from a contract of which you are/will be a part, as well as to fulfill, before the conclusion of the contract to your specific requests.
The recipients to whom the personal data of the data subject may be communicated can be identified in the following categories :
The collected data will not be disclosed in any way.
M – Intention to transfer data abroad
The data will be transmitted exclusively in Italy and within the European Union.
N – Rights pursuant to the EU Regulation 2016/679
The interested party can at any time exercise the rights referred to in art. 7, par. 3, and articles 15 and subsequent amendments of the EU Regulation 2016/679:
O – Identifying details of the Data Controller
The Data Controller is FD SOLUTIONS Ltd., with Registered Office in 1000 SOFIA (Bulgaria) – Bacio Kiro, mail: clients@fd-solutions.eu.
The data subject can exercise the rights described above by sending an e-mail to the email address: clients@fd-solutions.eu, or by calling +359 879 453 616.
The list of external data processor managers will be kept up-to-date and will be sent to the interested party upon specific request.
Further information related to the processing of personal data may also be communicated verbally at the time of data collection.
Last update of the document (Rev. 02) : January 14, 2021
FD SOLUTIONS Ltd.
