PRIVACY POLICY

Code for purposes of data processing in compliance with art. 13 of the Italian Decree-Law n°196/2003, for those interacting with web sevices of the BRS INVESTIMENTI SRL electronically through the website: https://www.starter-up.com

The privacy policy is valid only for the above mentioned website and does not apply to other sites that may be visited by users via hyperlinks.

DATA CONTROLLER

Upon consultation of this website, data relating to specific or identifiable persons may be processed. The data controller for processing of user data is BRS INVESTIMENTI SRL, Via G. Oberdan, 11 – 40126 – Bologna (BO) ‐ Italy, represented by its legal representative p. t.

LOCATION OF DATA PROCESSING

Data relating to the website’s services will be processed only in the above mentioned headquarters and will only be processed by Associazione Funamboli personnel or external personnel in charge of website maintence and updating. No data deriving from the web service will be communicated or disclosed to third parties. In case personal data is provided by users requesting services or information, such data may be communicated – for the sole purpose of making possible the provision of such services or information – by  Associazione Funamboli personnel to third parties including cooperators, correspondents, subsidiaries, consultants in administrative, financial, and tax accounting, web and telecommunication consultants, bank and financial institutions, subjects in charge of safeguarding the Organization for administrative, judicial, and extrajudicial purposes, as well as those in charge of shipping Organization documents and of surveillance.

TYPE OF DATA PROCESSED

Navigation data

The web servers and software automatically record – as part of their normal activity – certain personal data compulsorily transmitted for the use of Internet communication protocols.

The data are not collected to identify specific persons, but may by their nature allow identification of the users through elaborations and connections with data owned by third parties.

Navigation data include IP addresses or domain names of the computers used by the users through which they connect to the website, the URI (Uniform Resource Identifier) addresses of the resources requested, time of requests, method used for requests to the server, dimension of the answer file, numeric code which indicates the response of the server (positive result, error, etc.) and other parameters relating to the user operating system and user settings.

These data are collected with the sole purpose of obtaining anonymous statistical information on the use of the site and to control its correct functioning, and are deleted immediately after processing. They could also be used to ascertain the responsibility of the user in case of alleged criminal actions against the site. With the exception of such eventuality, at present the data will not be saved for more than seven days.

Data voluntarily provided by the user

The discretional, explicit and voluntary sending of information to the email addresses indicated on this website imply the automatic acquisition of the sender’s e-mail address – necessary to answer requests for services and/or information – and other personal data eventually present in the communication.

COOKIES

No personal data are collected purposely by the website. Cookies are not used for transmission of personal information, nor are any persistent cookies used for user location. The use of session cookies (cookies not memorized persistently and that are deleted upon closure of the browser) is strictly limited to the transmission of session codes (made of randomly server-generated numbers) necessary for safe and efficient website navigation. Session cookies used by this website avoid the use of other IT methods potentially compromising for the privacy of user navigation, and do not allow access to personal user ID data.

OPTIONAL DATA TRANSMISSION

With the exclusion of what previously specified for navigation data, the user is free to provide personal data through service/information request forms. Omission of such data may deny the possibility to obtain the services/information requested.

MODE OF DATA PROCESSING

Personal data are processed through automated and printed means, strictly for the time necessary to be used for their specific purposes in compliance with legal conditions. Personal data are processed in accordance with rules of fairness, legitimateness, and transparency.

PURPOSES OF DATA PROCESSING

Personal data are processed for the following purposes:

a) compliance requirements of the Organization for civil, accounting, tax, and public safety regulations, as well as administration of the requirements related to economic activity of the Organization

b) to send informative and promotional material regarding the Organization, as well as its subsidiaries and affiliates.

RIGHTS OF THE INTERESTED PARTY

The interested party has the right at any moment to request confirmation of the existence or otherwise of his or her personal details, their contents and origin, as well as being allowed to verify their accuracy or requesting any integration, update, or correction (art. 7, Italian Decree-Law n°196/2003)

In compliance with art. 7, Italian Decree-Law n°196/2003, the interested party has the right to ask for erasure, transformation into anonymous form or blocking of any illegally processed data, as well as opposing in any case, for legitimate reasons, any data processing.

All requests must be presented to BRS INVESTIMENTI SRL, by standard post to the address Via G. Oberdan, 11 – 40126 – Bologna (BO) ‐ Italy, or directly through the e-mail  bilotti@starter-up.com

The present document published on the website https://starter-up.com/ represents the Privacy Policy for this website and may be subject to updates.