Privacy & Policy

Dear User,

We wish to inform you that the personal information you submit to us will be utilized in full compliance with the provisions and principles contained in the regulations currently in force, and specifically with Leg. Decree no. 196/2003 (Protection of personal data). 

This page describes the modalities with which this website processes the personal information of the users who access it.

Pursuant to art. 13 of the above-mentioned Leg. Decree no. 196/2003, this information is provided also to those who interact with the web services offered by Klodea Inc., which can be accessed electronically from the following address:

www.klodea.com

This information note is valid only for the above website and does not apply to any other websites users may access via links.

This information note is also based on Recommendation no. 2/2001, which the European authorities for the protection of personal information, collected in the Group formed as per Art. 29 of Directive no. 95/46/CE, adopted on 17th May 2001 in order to identify some minimum requirements for the collection of personal information online, and specifically, the methods, times and nature of the information that data processing managers must provide to users when the latter access web pages, regardless of the purpose of the access.

Purposes and methods of data processing 

In compliance with the above-mentioned legislation, we summarize below the methodology our company applies in its collection, treatment and storage of the personal data in our possession and the purposes pursued in each case:

• Marketing and Sales Strategies: processing of the data submitted to us by you and of those resulting from your web navigation, for the purpose of developing statistics regarding the interest shown in the various services offered by the Company, to be used for marketing and/or promotional activities in general

• Administrative Management: collection, storage and processing of personal data for administrative/accounting purposes, including any eventual e-mailing of informational notices and/or sales invoices

In particular, regarding the methods of data processing, we guarantee that all the data are kept in a dedicated database and under constant surveillance, and continuously updated by adequately trained personnel. In addition, an in-house operating procedure has been drafted (Program Document on Security - DPSS). In this document, the methods used to ensure that adequate security measures are taken for the protection and confidentiality of the data are described in greater detail. Other than the web navigation data, users are free to provide the personal data contained in the data collection forms, or in any case collected during contacts with the addresses indicated on this website. However, failure to submit said data may result in the impossibility to reply to requests. Submitting personal data is necessary to the extent that they are used by our company to comply with contractual and/or legal obligations. Personal data are processed by automatic means for the time strictly necessary to the attainment of the purposes for which they were collected. Specific security measures are adopted to prevent the loss of data, illicit or improper use and unauthorized access to the same.

Responsible entity and data processing managers

The entity responsible for data processing is the Company.

The data processing administrators responsible for personal data are the personnel charged with managing the databases, depending on their respective area of competence. Their activities, assignments and responsibilities are reported in detail in the Program Document (DPSS).

Place of data processing

The data processing connected to the web services offered by this website takes place at the headquarters of the Company specified above, solely by personnel assigned to data processing. Data collected from the web services are not communicated to third parties or published.

Type of data processed

Web navigation: during the course of their normal functioning, the IT systems and software designed for the operation of this website acquire personal data whose transmission is implicit in the utilization of web communication protocols. These data are not collected for association with the individuals who provide them, but their very nature makes it possible, through processing and association with data in the possession of third parties, to identify the users in question. This category of data includes the IP address, or the domain names that identify the computers users utilize to access the website, addresses in URI (Uniform Resource Identifier) notation, the resources requested, the times of the requests, the method with which the requests are submitted to the server, the dimensions of the file received in reply, the numeric code indicating the status of the server’s reply (good outcome, error, etc.) and other parameters relative to the user’s operating system and IT environment. These data are collected solely for the purpose of obtaining anonymous statistical data about the use of the website and to monitor its proper functioning and are deleted immediately following their processing. The data could be used to attribute responsibility in the case of hypothetical IT violations that damage the website: except in this case, data on web navigation is not otherwise saved for more than seven days.

Data provided voluntarily by the user: the free, explicit and voluntary transmission of e-mails to the addresses indicated in this website involves the subsequent collection of the sender’s address, which is necessary in order to reply, as well as any other personal information that may be included in the message. 

Specific summary notifications will be progressively reported or posted on the website pages dedicated to particular on-demand services.

Cookies

The website does not purposely collect any personal user data. Cookies are not used for the transfer of information of a personal nature, nor are permanent cookies of any kind utilized, or user tracking systems. The use of session cookies (which are not permanently saved on the user’s computer and which are deleted when the browser is closed) is strictly limited to the transmission of session ID data (consisting of random numbers generated by the server), which are necessary to the secure an efficient navigation of the website. The session cookies used by this website make it possible to avoid using other IT protocols that may compromise the confidentiality of user web navigation and do not allow the collection of the user’s personal identification data.

Rights of the party concerned

We also inform you that every interested party can exercise the rights specified under Art. 7 of Leg. Decree no. 196/2003. With respect to personal data processing:

1. The party concerned is entitled to receive confirmation of the existence or absence of his/her personal data, even if not yet registered, and to receive them in an intelligible form.

2. The party concerned is entitled to receive indications regarding: 

a. The source of the personal data

b. The methods and purposes of data processing

c. The logic adopted in the case of data processing carried out by electronic/digital means

d. The ID of the entity responsible for data processing and the data processing managers, as well as the designated representative, as per Art. 5, Para. 2 of the same Decree

e. The persons/entities and categories of persons/entities to whom the personal data may be communicated or who may come into possession of the same as a function of their position as designated agents of the State, its representatives or officials

3. The party concerned is entitled to obtain:

a. The updating, correction or, on request, the integration of his/her personal data

b. The deletion, conversion into anonymous form or blockage of any data processed in violation of the applicable laws, including those for which storage is not necessary to achieve the purposes for which they were collected or subsequently processed

c. A statement confirming that the operations specified under Items a) and b) above have been notified, including the nature of their content, to those to whom the data has been communicated or transmitted, except in the case where this is impossible or would require the application of measures clearly disproportionate to the guarantee of the rights involved. 

4. The party concerned is entitled to deny, entirely or in part:

a. For legitimate reasons, the processing of his/her personal data, even if pertinent to the purpose for which they were collected;

b. The use of his/her personal data for the purpose of sending advertising or promotional material or for direct marketing purposes, or for the carrying out of market research or commercial communications. 

5. To exercise the rights guaranteed by Art. 7 of Leg. Decree no. 196/2003 and summarized above, users must refer to the Data Processing Manager, Ms. Colombo Giorgia, who can be contacted as listed below:

-  by sending an e-mail to: info@klodea.com

-  by regular mail to the following address: 1990 Main Street, Suite 750, Sarasota, FL 34236

-  by fax to the following number: +1 9413095201