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INFORMATION ON THE PROCESSING OF personal data (Article 13 EU Regulation 2016/679)

This Privacy Policy, provided by Performance Technology Solutions (PTS) pursuant to Article 13 of EU Regulation 2016/679 (and Article 13 of Legislative Decree n. 196/2003 as compatible – Italian Personal data Protection Code), also takes into account the Commission Recommendation No. 2/2001 adopted on 4th October 2017 by the Working Party set up according to Article 29 of the Directive 95/46/EC on the protection of personal data in relation to the minimum requirements for on-line collection of data within the Union according to the aforementioned EU Regulation 2016/679.

Purpose of this policy is to provide you with the information on the processing of your personal data that could be collect by the Server managing the e-mail account: Further purpose of this document is to provide information on the processing of other data automatically acquired by the Website (cookies, IP etc.) in the course of standard browsing.


This Privacy Policy only applies in respect to the website and related organizational consultancy services and management training; it does not apply to other online websites and services that can eventually be accessed via links on the above Website, with reference to which we invite you to read the respective Privacy Policies.


Data Controller for data, download of the content of this Website and the contact information obtainable in the contact form, is Performance Technology Solutions (PTS) represented by the Managing Director.


Data volountarily communicated by Data subjects

This Website may collect personal data sent by you during the use of the account  Specifically, such data may be those communicated when filling the request for information, such as name, surname, email, or may be referred to other information required in the Request form made available on the website and provided by using the latter during the browsing. Said data are sent by e-mail directly to the Data Controller at  Communications sent by filling the form on the Website entail the acquisition of the sender’s address as necessary to provide a reply to the requests and manage the commercial/professional relationship; the acquisition may also refer to other data enclosed in the sender’s e-mail.


Generally, information systems and software procedures relied upon to operate this Website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. This information is not collected to be associated to identified

subjects; based on its nature and through elaborations and associations with data collected by third parties, this information may however allow the identification of the users. This data category includes the IP addresses, or the domain names of the computers used by any users vising the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such request, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.) and other parameters related to the user’s operating system and computer environment. The data could be used to ascertain responsibility in case of any computer crimes against the Site and will however be kept for the time strictly necessary, in compliance with the related privacy legislation and regulation.


The use of session cookies (PHPSESSID) – text files that are not permanently stored on the user’s computer and expire when the session on the website is closed – is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) that is necessary to enable secure and efficient browsing. The session cookies used in this website avoid the use of other computer techniques that could be potentially detrimental to the confidentiality of users’ browsing and do not allow the acquisition of personal data identification.

The use by this Site of cookies related to the WordPress CMS technology (W3tc_referrer) – that are not persistently recorded on the user’s computer – is strictly limited to the proper functioning of the said technology, which otherwise would cease to function. These cookies do not record any type of information that can lead to the individual visitor user. These cookies do not record any information that could refer to the single visitor user.

Moreover, this Site uses performance cookies through the analysis service of “Google Analytics” to perform statistic surveys.  Google Analytics is a free web analytics service offered by Google and essentially enabling website owners to understand the interaction between visitors and their websites. It also set cookies on the domain of the website you are visiting. Analytics uses a series of cookies (“__utma” and “__utmz”) to collect information in an anonymous way and track website traffic avoiding the identification of each visitor.

Should you accept to receive cookies by this Website, please consider that you are entitled to modify at any time the choice and disable the operation of all or some cookies in a simple and easy way through the configuration options of the browser you are using (Google Chrome; Mozilla Firefox; Internet Explorer; Safari Browser).

List of cookies used by this website:


How to disable cookies

Cookies can be enabled and disabled with the browser. When cookies are accepted, the information will be kept and restored in the next navigation. They can be disabled completely or just for specific sites in respect of which there is no interest in providing and then keeping certain information. All modern

browsers allow the modification of cookies settings. These can usually be found on one own browser menu under the item ‘option’ or ‘preferences’.

Purposes of the Processing

Pursuant to the principles set for in Article 5 of EU Regulation UE 2016/679, the personal data provided by you in downloading the contents on the website, as well as the communications sent by using the e-mail contact form available on the website, are processed to the the scope of our business activities: management and performance of consultancy services and training.  Services that should be governed by a separate contract and a specific separate privacy policy. Specifically, the data communicated by you will be processed for purposes related to the respect of the following fulfilments, relating to legislative or contractual obligations, provided that the processing of data will be limited only to adequate, relevant and necessary processing in relation to the purposes of collecting information through the form on the website :

– mandatory fulfilments provided by the legislation governing the management of the first contact in the light of a formalization of a subsequent appointment;

– further obligations provided for by the laws in force for the correct keeping of the first contact data acquired from the Site ;

– communications necessary for the starting and subsequent management of the contractual relationship between the parties, as resulting from the request for information.

We specify that the collected data will not be used for purposes other than those listed above.


The processing of those data that are functional for the provision of the service/request for information is necessary for a correct management of the commercial relationship. The supply of your data is optional; however, any non-communication or incorrect communication of your data may cause the impossibility for the Controller to provide the requested service.


Your personal data could be processed as follows:

– by electronic means
– without electronic menas.

Data will be stored for 10 years.


The Controller uses an external hosting supplier named Sinte s.r.l (P.IVA: 13295960150)  acting as an “External Processor” on the basis of a written appointment. Personal data communicated by you according to the aforementioned modalities (OPTIONAL DATA SUBJECTS’ SUPPLY and INTERNET BROWSING DATA) will therefore be stored at the premises of that company which owns the server and detains the hosting of this Website.

Provided the guarantee of all data subjects’ rights, your data will be exclusively disclosed to:

– those subjects that are competent for the performance of the services necessary to properly manage the commercial relationship and that have been adequately appointed as Data Processor;

– the subjects to whom the communication of your data is due by law or regulation.

More specifically, your data may be disclosed to:

– subjects, entities or Authorities to whom the communication of your data is due by law or regulation;

– persons, companies or professional offices carrying out assistance and advice services in favour of the Controller in the sector of labour law as well as accounting, administrative, fiscal, tax sector.

The complete list of Data Processors is available, upon request, by sending an e-mail to the data Controller.
Your personal data will not be disseminated.


Data subjects shall have the right to obtain at any time by the Data Controller confirmation as to whether or not personal data concerning him/her exist are processed and, where that is the case, be aware of their content and from which source the personal data originate, to verify their accuracy, to have incomplete personal data be completed, updated, limited or to obtain rectification or erasure, pursuant to Article 7 of Personal data Code (Legislative Decree No. 196/2003) and Regulation EU No. 2016/679.

The Data subject shall also have the right to obtain confirmation as to whether or not personal data concerning him/her are existing, even if not yet registered, and their disclosure in an intelligible form.

The data subject shall have the right to obtain from the Controller the following information:
a) from which source the personal data originate;
b) the purposes and modalities of processing;
c) the logic involved in case of processing by electronic means;
d) the identification details of Controller and Processors;
e) the recipients or categories of recipient to whom the personal data may be disclosed or that may be informed of such data in their role as representative appointed in the territory of the country or in the Union or also in third countries where data are processed on behalf of Controller.

The data subject shall have the right to obtain:
a) the update, rectifications or, in case of interest, the integration of data as well as the restriction of their processing;
b) the erasure, the transformation in an anonymous form or the block of those data that are processed in breach of legal provisions; these data also include those that do not need to be kept for the purposes for which the data have been collected or subsequently processed;
c) acknowledgment that the operation set out in points a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfilment proves impossible or would involve a disproportionate effort in respect to the protected right.

The data subject shall have the right to object, totally or partially to:
a) on lawful grounds, to the processing of personal data concerning him/her, even when the processing is relevant to the purpose of data collection;
b) the processing of personal data concerning him/her for sending advertising, direct marketing or for carrying out market research or commercial communication purposes

The Data subject shall have the right:
c) to withdraw his/her consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
d) the right to lodge a complaint with a supervisory national authority.

Data Subjects could ask at anytime to the Data Controller information regarding his/her data processing and management to the following addresses:

–  by e-mail to the e-mail address

–  by mail to: Performance Technology Solutions (PTS), via Valparaiso, 10/6, 20144 Milano:

–  by certified mail:

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