Information on the processing of personal data of users of the www.sogei.it website

This page provides information on the processing of personal data of the users who consult the website www.sogei.it (hereinafter, the 'Site'), pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter, the 'GDPR').

Please note that this notice refers to the processing of data carried out exclusively on the Site and not also on other websites that may be consulted by the user via links (for which please refer to the respective privacy notices).

The data controller is SOGEI - Società Generale di Informatica S.p.A. (hereinafter, "SOGEI"), with registered office in Via Mario Carucci 99 - 00143 Rome, which can be contacted at the addresses indicated below. 

The Data Protection Officer (DPO) can be reached via the following communication channels:

• Ordinary e-mail: dpo@sogei.it;
• Certified e-mail: dpo@pec.sogei.it

The computer systems and software procedures used to operate the Site acquire, in the course of their normal operation, certain personal data relating to web browsing, the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected in order to be associated with identified data subjects, but by its very nature could, through its processing and association with data held by third parties, allow its users to be identified.

This category of data includes:

• the IP addresses of the computers used by the users connecting to the Site;
• the addresses of the requested resources in URI (Uniform Resource Identifier) notation;
• the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response returned by the server (successful, error, etc.);
• other parameters related to the user's browser, operating system and IT environment.

The processing of user data is therefore necessary for the pursuit of legitimate interests by the Controller pursuant to Article 6, paragraph 1, letter f) of the GDPR, related to the purposes of monitoring the proper functioning of the Site, the anonymous processing of statistical information on the use of the Site, as well as the establishment, exercise and judicial defence of rights.

The data in question could also be used for the fulfilment of regulatory obligations, pursuant to Article 6, paragraph 1, letter c) of the GDPR, connected with the management of the Site and in order to comply with requests made by the competent judicial authorities and the judicial police, to ascertain liability in the event of any computer offences committed to the detriment of the Site.

The optional, explicit and voluntary sending of messages to the contact addresses of the Data Controller indicated on the Site entails the acquisition of the sender's contact data necessary to respond to the requests forwarded, as well as all personal data included in the communications, the processing of which is carried out to enable the Data Controller to provide a service to the user, pursuant to Article 6, paragraph 1b of the GDPR. SOGEI invites users, when making such requests, not to send any personal data that are not strictly necessary.

Cookies are small text strings that the websites visited by the user send to his or her browser where they are stored and then resent to the same websites during subsequent visits. While browsing, the user may also receive cookies on his or her browser sent by parties other than the owner of the site visited (so-called 'third parties').

Through this Site, the user's browser may receive technical cookies and, using certain functionalities, third-party profiling cookies.

This Site uses the following technical cookies:

• browsing or session cookies, which ensure the normal navigation and use of the Site by storing the user's browsing preferences;
• functionality cookies, which allow the user to browse according to a set of selected criteria (e.g. language, pop-ups) in order to improve the service rendered.

These cookies are installed directly by the Owner and are used, pursuant to Article 6, paragraph 1f of the GDPR, to facilitate navigation and, pursuant to Article 6, paragraph 1b of the GDPR, to provide the services requested by the user. Once stored on the user's browser, they are automatically deleted at the end of the session, without prejudice to the possibility for the user to delete them directly, if he/she so wishes, in the manner indicated in the section "How to disable and delete cookies".

The Site also uses its own analytical cookies that collect, in anonymous form (by masking portions of the user's IP address), statistical and aggregate information on how users navigate (e.g. number of pages visited and accessed, time spent on the site). These cookies, used directly by the operator of the Site pursuant to Article 6, paragraph 1f of the GDPR, are assimilated to technical cookies and do not require the user's consent. Furthermore, the aforementioned analytical cookies, once stored on the user's browser, may remain there for up to 12 months, without prejudice to the possibility for the user to decide to disable their use on his or her browser, at any time, in the manner indicated in the section "How to disable and delete cookies".

Profiling cookies are used to monitor and analyse the user's online behaviour in order to personalise the service provided, as well as to send targeted advertising messages in line with the preferences expressed by the user while surfing the web; therefore, the user's consent must be obtained, pursuant to Article 6, paragraph 1a of the GDPR.

By accessing the Site, the user may also receive third-party profiling cookies in his or her browser (in particular, Twitter and YouTube), if he or she consents to the use of specific functions set up by the Site manager, in order to make certain content available on SOGEI's Twitter and YouTube social channels accessible within the Site.

In order to allow the user to freely choose the cookies, a banner flashes open when accessing the Site to inform the user and to allow him/her to give his/her consent to receive cookies other than technical cookies by clicking on the "Accept all cookies" button, or to refuse the installation of such cookies by selecting "Reject all cookies".

To better manage their preferences, users can always click on the "Open Cookie Preferences" button and obtain more information on individual cookies, in order to provide their consent in a selective manner for the display, directly within the Site, of certain personalised contents from SOGEI's social channels published on the Twitter and YouTube platforms.

The choices expressed with regard to the aforementioned cookies are in turn stored in the user's browser using special technical cookies and remain there for a maximum of 6 months, in order to avoid the repetition of the same request during that period, as well as to allow for faster browsing, without prejudice to the possibility for the user to directly delete them, in the manner indicated in the section "How to disable and delete cookies".

In addition, in some pages of the Site, users can find spaces dedicated to allowing the use of functions of other websites by means of so-called social buttons, i.e. icons depicting some social network platforms (in particular, Twitter, Instagram, Linkedin, YouTube), and which allow users who are surfing to interact directly with these websites by way of a 'click'.

In this regard, the Site does not share any of the user's browsing information or data with sites that are accessible in this way, but the use of these functionalities implies the possibility for the user to also receive non-technical cookies in his or her browser from the owners of these so-called, 'third party’ sites.

The Data Controller does not have access to the information collected by these cookies, which are used independently by the 'third parties'. For more information, users are invited to consult the respective notes provided by the third parties, in particular by consulting the following links:

• X: a new windows opens
• Linkedin: a new windows opens
• Instagram: a new windows opens
• YouTube: a new windows opens
• META: a new windows opens

In some browsers it is possible to set rules to manage cookies on a site-by-site basis, an option that offers more precise control over privacy. You can check your preferences on the following pages, depending on your browser.

• Windows Internet Explorer: a new window opens
• Apple Safari: a new window opens
• Google Chrome: a new window opens
• Mozilla Firefox: a new window opens
• Opera: a new window opens

For browsers other than those listed above, please consult the relevant guide on how to manage cookies.

Exclusively for the purposes specified above, the personal data thus collected and processed may be communicated to and processed, in compliance with the legislation in force, by external companies engaged by SOGEI in order to perform services of various kinds, such as, by way of example, the maintenance and support of the Site and related services. These companies will be duly designated as data processors by means of a specific contract.

In addition, where necessary, the data may be disclosed to the competent authorities and other public entities that request them on the basis of the laws in force and in connection with investigations and proceedings relating to the prevention, detection and prosecution of criminal offences, as well as for the legal defence of rights.

The personal data provided are not disseminated in any way.

The personal data provided by the user and/or collected by the Controller through the use of the Site will be kept for the time strictly necessary to provide the services requested and to carry out the related technical and security operations, as well as, once the latter has ended, for the time period established by the regulations in force for administrative and, if necessary, defence purposes.

With specific regard to cookies, the retention periods are indicated in the preceding paragraphs.

The processing operations connected to the web services offered by the Site take place at the Data Controller's premises and are only carried out by technical staff authorised to process data, taking appropriate measures to ensure that they are processed appropriately and in accordance with the purposes for which they are managed.

The personal data are processed by automated means and will not be transferred to non-EU countries.

With the exception of the conditions specified for browsing data and cookies, the user is free to provide his or her personal data for the purposes set out in this notice, but failure to do so may make it impossible to obtain the requested service.

The data subject has the right, at any time, to obtain confirmation of the existence or non-existence of data concerning him/her. He or she also has the right to request, in the forms provided for by law, the rectification of inaccurate personal data and the integration of incomplete data, and to exercise all and any other rights under Articles 18-22 of the GDPR, where applicable.

To this end, the user may send a specific request addressed to SOGEI - Società Generale di Informatica S.p.A., with registered office at Via Mario Carucci 99 - 00143 Rome, which can be contacted at the following addresses: ordinary e-mail: dpo@sogei.it; certified e-mail: dpo@pec.sogei.it

If the user considers that the processing has been carried out in a manner that fails to comply with the GDPR, he or she may also refer the matter to the Supervisory Authority, lodging a complaint pursuant to Article 77 of the GDPR.

Further information can be found on the website of the Italian Data protection Authority at www.garanteprivacy.it.

Last updated: May 2022.