PRIVACY POLICY

Pursuant to Articles 13 and 14 of European Regulation (EU) 679/2016

Dear Data Subject/User,

We would like to inform you that European Regulation 2016/679, hereinafter GDPR 679/2016, provides for the protection of individuals with regard to the processing of personal data as a fundamental right.

Pursuant to GDPR 679/2016, this page describes the methods of processing the personal data of users who consult the website of the Bear & Code consulting services, accessible online at the following addresses:

bearandcode.com

Pursuant to Article 13 (data collected from the data subject) and Article 14 (data not collected from the data subject) of GDPR 679/2016, we inform you that:

DATA CONTROLLER

Following consultation of the website listed above, data relating to identified or identifiable natural persons may be processed.

Gabriele Ferrazzi with registered office in Via R.Forster 88 – 00143 Rome (RM), VAT number 14702311003 and Tax Code FRRGRL82L22H501L – PEC gabriele.ferrazzi@pec.it, Data Controller.

LEGAL BASIS OF THE PROCESSING

This website processes data mainly on the basis of the consent of users. The conferment of consent takes place through the banner placed at the bottom of the page, or through the use or consultation of the website, as a conclusive behavior. By using or consulting the website, visitors and users approve this privacy policy and consent to the processing of their personal data in relation to the methods and purposes described below, including any dissemination to third parties if necessary for the provision of a service.

Further consents relating to the specific purpose of the service are collected through the communication or service request forms.

The provision of data and therefore consent to the collection and processing of the same is optional. The User may deny consent, and may revoke any consent already given at any time (through the banner placed at the bottom of the page or the browser settings for cookies). However, denying consent may make it impossible to provide certain services and the browsing experience on the website would be compromised.

Data for the security of the site and for the prevention of abuse and SPAM, as well as data for the analysis of site traffic (statistics) in aggregate form, are processed on the basis of the legitimate interest of the Data Controller in protecting the site and the users themselves. In such cases, the user always has the right to object to the processing of data, as indicated in the paragraph Rights of the User.

PURPOSES OF THE PROCESSING

The personal data of users of the website will be processed in the manner and forms prescribed by GDPR 679/2016, for the performance of the functions of the website itself, with particular, but not exclusive, reference to the procedures described therein for collecting data, contact forms, any registration/access procedure to the reserved area, subscription to the newsletter and similar.

In particular, the personal data provided to the Data Controller will be processed for the following purposes:

  • To follow up on specific requests made to the Data Controller by the User through the Website and its communication tools (contact forms, information request forms and similar);
  • For the possible subscription to the newsletter and the consequent sending of various commercial and informative communications concerning the sector in which the Data Controller operates, with specific consent given by the user;
  • For informative communications regarding the services of the same Data Controller, following a request for information via e-mail or by filling out the contact form and other communication tools;
  • For other ancillary or related purposes to those indicated above and in any case falling within the scope of the activities of the Website. The data may be communicated to third parties who perform functions necessary or instrumental to the operation of the service and to allow third parties to carry out technical, logistical and other activities on our behalf. The suppliers have access only to the personal data that is necessary to perform their tasks, and undertake not to use the data for other purposes, and are obliged to process personal data in accordance with current regulations;
  • For the processing of the e-mail address provided by the data subject in the context of the sale of a product or service, also aimed at sending, without further consent, communications for subsequent direct sales;
  • For the security of the site and Users and to prevent or unmask fraud or abuse to the detriment of the website. The data is recorded automatically and may also include personal data (IP address) that may be used, in accordance with current laws, to block attempts to damage the site itself or to cause damage to other users, or in any case harmful or criminal activities. Such data is never used to identify or profile the User and is deleted periodically. The processing of data provided in a general manner will be carried out, even following automatic collection during browsing, for the sole purpose of ascertaining and controlling access to the Website. This also applies to technical cookies, to be understood as session cookies, functionality or analytics cookies that meet the requirements specified by the Guarantor. For more information, please refer to the specific Cookie Policy.

OBLIGATION TO PROVIDE DATA

The provision of data relating to browsing by users, for the purposes expressed in this information, depends on the degree of privacy that the User has enabled or disabled through their browser. In some cases, disabling could affect browsing on this Website. For certain modules of this Website, the provision of browsing data and/or the use of technical cookies is mandatory for the correct functioning of the Website itself. The provision of some data is in any case necessary for the structure of the Website itself and its procedures.

SOURCE OF PERSONAL DATA

The site may collect other data in case of voluntary use of services by users, such as comment services, communication (contact forms, comment boxes), and will be used exclusively for the provision of the requested service.

CATEGORIES OF DATA PROCESSED

The Data Controller will process your personal data in compliance with GDPR 679/2016, such as:

  • Data collected automatically. The IT systems and applications dedicated to the operation of this website collect, during their normal operation, some data (whose transmission is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected includes the IP addresses and domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters regarding the operating system, browser and IT environment used by the user. This data is processed, for the time strictly necessary, for the sole purpose of obtaining statistical information on the use of the site and to control its regular functioning. The provision of such data is mandatory as it is directly related to the web browsing experience. Such data is stored in the log files of the server (hosting) of the site.
  • Data provided voluntarily by the user. The voluntary and explicit sending of e-mail to the addresses indicated in the different access channels of this site does not require consent and the possible compilation of forms specifically prepared involves the subsequent acquisition of the address and data of the sender/user, necessary to respond to the requests made and/or provide the requested service. The voluntary sending of emails by the User to our email addresses does not require further information or requests for consent.
  • The site uses third-party technical cookies which may collect browsing data of users, the provision of which is optional and takes place through the expression of free and informed consent. In fact, by clicking OK on the banner present on the first access to the site or by browsing the site, the visitor expressly consents to the use of cookies and similar technologies, and in particular to the recording of such cookies on their terminal for the purposes indicated above, or to access through cookies to information on their terminal. Cookies are used to analyze the effectiveness of the site and make it easier and more intuitive over time. The data collected thanks to cookies is used to make the browsing experience more pleasant and more efficient in the future, trying to evaluate the behavior of users and to modify the offer proposal based on their behavior. The site also uses profiling cookies aimed at creating profiles relating to the user and are used to send advertising messages in line with the preferences expressed by the same in the context of browsing the net. For profiling cookies, the express consent of the data subject is required. In the absence of consent, it will not be possible for the user to continue browsing the website. For more information, please refer to the specific Cookie Policy. DATA COLLECTED THROUGH THE EMAIL PLATFORM For complete information, we specify that in sending communications by e-mail, the Data Controller uses a compliant platform, which, through statistical tracking systems, allows you to detect the opening of a message, the clicks made on the hypertext links contained within the e-mail, from which IP address or with which type of browser the e-mail is opened, and other similar details. The collection of such data is functional to the use of the platform and constitutes an integral part of the functionality of the message sending system.

PLACE OF PROCESSING

The data is processed at the premises of:

  • Data Controller;
  • Web hosting: siteground.com
  • Subject that provides the development and maintenance services of the web platform
  • Any subject that has external servers on which the site data is stored;

RECIPIENTS OF THE DATA

The recipients of the data collected following consultation of the website www.bearandcode.com, are the following subjects designated by the Data Controller, pursuant to Article 28 of GDPR 679/2016, as data processors:

  • Company name of the subject that provides the development and maintenance services of the web platform: Gabriele Ferrazzi
  • Company name of the subject that provides the development, provision and operational management of the technological platforms used: Gabriele Ferrazzi
  • Web hosting: SiteGround Spain S.L. Within the limits relevant to the purposes of processing indicated, your data may also be processed by Data Processors appointed by the Data Controller, who act on the basis of specific instructions provided in order to purposes and methods of processing or external subjects (such as third-party technical service providers, hosting providers).

METHODS OF PROCESSING DATA AND SECURITY MEASURES

The Data Controller processes the data of visitors/users in a lawful and correct manner, taking the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the data and committing to protect the security of your personal data during their transmission, using the Secure Sockets Layer (SSL) software, which encrypts information in transit. Processing is carried out using IT and/or telematic tools, with organizational methods and with logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, data may be accessed by categories of employees involved in the organization of the site or external subjects (such as third-party technical service providers, hosting providers).

DATA RETENTION PERIOD

The data provided by the Data Subject will be stored until revoked expressly by the same, also through action on their browser, cookie cleaning, express request or otherwise manifested. Browsing data will be stored for the technical time necessary to carry out the functions for which they were collected. At the end of the period, the data will be deleted or anonymized, unless there are further purposes for their retention.

  • The data (IP address) used for site security purposes (blocking attempts to damage the site) is stored for 12 months.
  • The data for analytics purposes (statistics) is stored in aggregate form for 26 months.

TRANSFER OF DATA TO NON-EU COUNTRIES

This site may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized on the basis of specific decisions of the European Union and the Guarantor for the protection of personal data, in particular decision 1250/2016 (Privacy Shield), for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.

RIGHTS OF THE DATA SUBJECT

We inform you that as a data subject, in addition to the right to lodge a complaint with a supervisory authority (Guarantor for the Protection of Personal Data), you also have the rights under Articles 15, 16, 17, 18, 20 and 22 of GDPR 2016/679, listed below, which you can exercise by sending a written request to the Data Controller and/or the Data Protection Officer:

Article 15 – Right of access – The data subject has the right to obtain confirmation from the data controller as to whether or not personal data relating to him or her is being processed and, in that case, to obtain access to the personal data and information relating to the processing.

Article 16 – Right to rectification – The data subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, also by providing a supplementary declaration.

Article 17 – Right to erasure (right to be forgotten) – The data subject has the right to obtain from the data controller the erasure of personal data concerning him or her without undue delay, and the data controller is obliged to erase personal data without undue delay.

Article 18 – Right to restriction of processing – The data subject has the right to obtain from the data controller restriction of processing where one of the following applies: (a) the data subject contests the accuracy of the personal data, for the period necessary for the data controller to verify the accuracy of such personal data; (b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests instead that its use be restricted; (c) the data controller no longer needs the personal data for the purposes of the processing, but it is necessary for the data subject for the establishment, exercise or defense of a right in court; (d) the data subject has objected to processing pursuant to Article 21(1), pending verification as to whether the legitimate grounds of the data controller override those of the data subject.

Article 20 – Right to data portability – The data subject has the right to receive the personal data concerning him or her which has been provided to a data controller in a structured, commonly used and machine-readable format, and has the right to transmit those data to another data controller without hindrance from the data controller which provided the personal data. In exercising their right to data portability pursuant to paragraph 1, the data subject has the right to obtain the direct transmission of personal data from one data controller to another, if technically feasible.

Article 22 – Right not to be subject to automated decision-making, including profiling – The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar manner.

We also inform you that the consent already given can be revoked at any time through the browser settings for cookies or by following the procedure indicated in the Cookie Policy.

These rights can be exercised in the forms and terms set out in Article 12 GDPR 679/2016, by sending a written communication to the Data Controller at the following pec e-mail address: gabriele.ferrazzi@pec.it

COMPLAINTS

Each Data Subject has the right to lodge a complaint pursuant to Articles 77 et seq. of the GDPR with a supervisory authority, which for the Italian State is the Guarantor for the Protection of Personal Data, whose contacts are: pec: gabriele.ferrazzi@pec.it . The forms, methods and terms for bringing complaints are provided for and governed by current national legislation. The complaint does not prejudice administrative and judicial actions, which for the Italian State may be brought alternatively to the same Guarantor or to the competent Court (Article 79 GDPR 679/2016).

Updates

This Privacy Policy is updated as of 03 April 2025.