Last updated 16 October 2015
What information do we collect?
At times you may voluntarily choose to supply us with personal information, such as when emailing us from the “Contact Us” page or applying for employment with us. In such instances, we may gather the following information about you:
- Telephone number
- IP address (a unique identifier for your computer or other device)
- Mobile device ID
- Information provided by you in relation to submitting a job application to us (this may include sensitive personal information e.g. ethnic origin)
How do we use it?
We will use this information in the following ways:
- to provide you with information that you have requested (e.g. a newsletter, bulletins);
- to respond to specific queries you may raise regarding S&H;
- to provide you with better ways of accessing information from this website;
- to process and consider your job application; and
- as otherwise disclosed to you at the time such information is collected.
For how we use your information that is collected using cookies and similar technologies please see the “Cookies” section here.
For such purpose we need to process your Personal Data. Your failure to provide such Personal Data will prevent us from supplying the Service.
You are entitled to exercise certain rights in connection with your Personal Data, including the right to:
- request and obtain from us a copy of your Personal Data;
- ask us to delete your Personal Data; and
- update and correct your Personal Data.
If you have any queries and/or would like to exercise one of your rights under the Italian Data Protection Code you may , please let us know by contacting our Compliance Officer at firstname.lastname@example.org
Where Your Personal Data is Processed and Stored
Your Personal Data is processed in our Milan offices, via Bertieri, 4 and stored in our servers in [United Kingdom ], where the degree of protection, security and compliance is equal to that guaranteed in Italy, pursuant to EC Data Protection Laws.
Duration of Processing and Storage of Your Personal Data
Your personal information will be stored in a way that allows your identification for the time strictly necessary for the purpose for which the data were collected and subsequently processed and, in any case, within the limits of law. After that date they will be deleted.
Do we pass your information to third parties?
We may send your personal information to our affiliated companies if the nature of your request requires us to do so. We may also use third party vendors to help us process your personal information for the purposes set out in this policy, but they are not authorized by us to use your personal information for their own purposes. We may disclose your personal information if we or any of our assets are the subject of a sale or similar corporate transaction. We may disclose personal information to third parties when we reasonably believe we are required by law, and in order to investigate, prevent, or take action regarding suspected or actual unlawful or otherwise prohibited activities, including, but not limited to, fraud.
How do we use your information for marketing?
We will only provide information to you that you have asked for via the website.
What are cookies?
We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which are stored by your computer or device when you visit our website. Therefore, when we refer to “you” in this section we mean your computer. We can recognize these cookies on subsequent visits and they allow us to remember you.
Cookies come in many forms. We have set out below the main types and categories of cookies that are used. This section refers to all types and categories of cookies and not just those we use on our website.
First and third-party cookies – whether a cookie is first-party or third-party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user, the website displayed in the URL window e.g. www.sudler.com . Third-Party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.
Persistent cookies – these cookies remain on a user’s device for the period of time specified at the time the website requested the cookie to be set. They are activated each time that the user visits the website that created that particular cookie.
Session cookie – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
- Strictly necessary cookies – These cookies enable services you have specifically asked for.
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies certain services you have asked for cannot be provided.
- Performance cookies – These cookies collect information on the pages visited.
These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. Such cookies may include third party cookies provided by Google and Yahoo analytics. All information these cookies collect is aggregated and not used by us to identify individual users. They are only used to improve how the website works.
If you want to delete any cookies that may already be on your computer or device, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
- Anonymous analytics cookies
Every time someone visits our website, a third party software automatically generates an “anonymous analytics cookie”.
Such cookies can tell us whether or not you have already visited our website.
Your browser will tell us if you have these cookies installed in your device and, if you don’t, we generate new ones.
This allows us to track how many individual users we have, and how often they visit the website.
Unless you already are a registered user of our website, we cannot use these cookies to identify individuals. We only use them to gather statistic information (e.g., the number of visits to a webpage). If you are logged in, we will also detain all the information you provided by logging in, such as your username and email address.
How do I manage ‘cookies’?
It is usually possible to stop your browser from accepting cookies, or prevent it from accepting cookies from a single website. However, we cannot tell if you are signed in without using cookies, so you would not be able to post comments.
All current browsers allow you to change your cookies settings. You can usually find such settings in the ‘options’ or ‘preferences’ menu of your browser. In order to fully comprehend said options, the following links may be helpful, or you can use the ‘Help’ option in your browser for more information.
Cookie settings in Internet Explorer (http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies#ie=ie-10)
Cookie settings in Chrome (https://support.google.com/chrome/answer/95647?hl=en&ref_topic=14666)
If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to your Online Choices site.
You can also visit the trade body representing these advertising platforms for more information: Network Advertising Initative, where you can visit a website where you can control all third-party online advertising.
Our IP Address Policy
An IP (Internet Protocol) address is composed of a unique number which is automatically assigned to your device by your Internet Platform Provider (ISP) every time you access the Internet. As it is customary for Platforms, we can register Your IP address in order to analyze the Data regarding the number of visits to our Platform. Your IP address, however, is not connected to Your personal information in any way. SUDLER always retains the right to use said Data to identify any threats to its Platform, to our Platform, or Yourself.
Links to Third Party Websites
How We Process Your Personal Data
For all intents and purposes aforementioned, Your Data will be processed through electronic and physical means. All processing operations are carried out so as to guarantee the safety and protection of your Personal Data throughout the whole process.
What Happens if the National Privacy Law Changes
Social Media Sites
Our website may use links or tools from social media services, such as a “Like” or “Share” button. We do not control such services or how they use your information. By using such features you acknowledge that S&H is not responsible for how such social media services track you or use your information and you will be subject to the applicable social media provider’s privacy practices and disclosures.
How do we protect your information?
We take appropriate measures to ensure that your personal information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. Under 13 year oldsThis website is not intended or designed to attract children under the age of 13. We do not knowingly collect personal information from or about any person under the age of 13. If you are under 13 years old and wish to ask a question or use this website in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.
How to obtain a copy of your information
You are entitled to ask for a copy of the personal information we hold about you (for which we may charge a small fee) and to have any inaccuracies in your personal information corrected. Please contact us using the details set out below.
How to contact us if your information or choices change
If your personal information or your preferences change, you don’t want us to send you the information you have requested or if you have any queries about how we use your personal information, please let us know by contacting our Compliance Officer at email@example.com