Privacy Policy

Navigation information according to Art. 13 EU Regulation 2016/679

Reference Standards:

- EU Regulation No. 679 dated April 27, 2016 on the protection of individuals with regard to the protection and processing of personal data (hereinafter “EU Regulation”)

- Legislative Decree No. 196 dated June 30, 2003 (hereinafter the “Privacy Policy”), as revised by Legislative Decree No. 101 dated August 10, 2018

- Recommendation No. 2 dated May 17, 2001 concerning the minimum requirements for online data collection in the European Union, adopted by the European Data Protection Authorities, gathered in the task force established under article 29 of the directive No. 95/46/CE (hereinafter “article 29 task force recommendation”)

Cadlog Group S.r.l. (hereinafter “the association”), a company belonging to the Var Group S.p.A., with its head office in Via Derna, 26 - 20132 Milan - VAT number 02989490368, desires to inform users about the terms and conditions applied by the association to the processing operations performed on their personal data.

In particular, the information is provided in relation to the personal data of users who proceed to consult and use the association's website, which corresponds to the following domain:


The association acts as a “data processor”, meaning “the natural or legal person, public authority, service or other body which alone or jointly with others determines the purposes and means of processing personal data”.

Specifically, the processing of personal data may be carried out by individuals specifically authorized to perform processing operations on users' personal data and, to this end, specifically instructed by the association.

In the application of the legislation on the processing of personal data, users who consult and use the association's website acquire the status of “interested subjects”, meaning the natural person to which the personal data processed refer.

Please note that this statement does not extend to other websites that may be consulted by users via links, including Social Buttons, on the association's website.

In particular, Social Buttons are digital buttons in the sense of direct links to Social Network platforms (such as, but not limited to, LinkedIn, Facebook, Twitter, YouTube), configured in each individual “button”.

By clicking on such links, users will be able to access the association's social accounts.
The administrators of the Social Networks, to which the Social Buttons refer, act as autonomous data processors; consequently, all information relating to the modalities by which the said data processors carry out the processing of the users' personal data may be found in the relevant Social Network platforms.


  1. Personal data subject to processing

In view of the interaction with this website, the association may process the following personal data of users:

a) Navigation data: the informatics systems and software procedures used to operate this website, acquire in the course of normal operation certain personal data whose transmission is involved 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 processing and association with personal data held by third parties, allow users to be identified. This category of personal data includes the IP addresses or domain names of the computers used by users connecting to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relative to the user's operating system and informatics environment. This personal data is only used to obtain anonymous statistical information on the use of the website and to monitor its proper functioning.

Navigation data are not stored for longer than (12 months), without prejudice to any need for criminal investigations by judicial authorities.

b) Personal data voluntarily provided: the optional, explicit and voluntary transmission of personal data to the association, by filling in the forms on the website, entails the acquisition of the email address and all further personal data of users requested by the association in order to comply with specific requests.

With reference to the processing of personal data provided by filling in the contact form provided on this website, please refer to the relative “contact form disclosure”.


  1. Purpose and legal ground of personal data processing

With regard to the personal data referred to in point 1), sub-point a) of this notice, users' personal data are processed automatically and “obligatorily”, by the association for the purpose of enabling navigation; in this case, the processing is carried out on the basis of a legal obligation to which the association is subject, as well as on the basis of the association's legitimate interest in ensuring the proper functioning and security of the website; the explicit consent of users is therefore not required.

With regard to the personal data referred to in point 1), sub-point b) of this notice, the processing is performed to provide information or assistance to users; in this case, the processing is based on the execution of specific requests and the fulfillment of pre-contractual measures; the explicit consent of users is therefore not required.


  1. Nature of providing personal data

Without affecting what has been specified for navigation data in relation to which conferment is obligatory as it is essential for browsing the association's website, users are free to provide or withhold their personal data for the purpose of receiving information or assistance from the association.

With reference to the processing of personal data provided by filling in the contact form provided on this website, please refer to the relevant “contact form disclosure”.


  1. Modalities and duration of personal data processing

The processing of personal data is carried out by authorized subjects, specifically identified and instructed for this purpose by the association.

The processing of users' personal data is carried out through the use of automated tools with reference to access data to the website pages.

With reference to the processing of personal data provided by filling in the contact form provided on this website, please refer to the relevant “contact form disclosure”.

In any case, the processing of personal data is carried out in full compliance with the regulations aimed at guaranteeing the security and confidentiality of personal data, as well as the accuracy and relevance of personal data to the purposes stated in this notice.

Notwithstanding the fact that the navigation data referred to in point 1, sub-point a) do not persist for more than 12 months, personal data will be processed for the time strictly necessary to achieve the purposes for which they were collected or, in any case, in accordance with the deadlines provided by law.

It is further specified that the association has adopted specific security measures to prevent loss, illegal or incorrect use of personal data, and unauthorized access to such data.


  1. Recipients of personal data

Limited to the purposes identified in this notice, your personal data may be disclosed in Italy or abroad, for the fulfillment of legal obligations.

For further information with reference to the recipients of users' personal data provided by filling in the contact form provided on this website, please refer to the relevant “contact form disclosure”.

Personal data may be transferred to third countries outside the EU or the European Economic Area on based on the existence of adequacy decisions of the European Commission or based on specially authorized contractual clauses or binding corporate rules.

Personal data will not be disclosed to the public.


  1. Rights under articles 15, 16, 17, 18, 20 and 21 of EU Regulation 2016/679

Users, as data subjects, may exercise their rights of access to personal data under article 15 of the EU Regulation and their rights under articles 16, 17, 18, 20 and 21 of the EU Regulation regarding adjustment, cancellation, restriction of processing of personal data, data portability, where applicable, and the objection to the processing of personal data.

The aforementioned rights may be exercised by writing to the following address:

If the association does not respond within the timeframe provided by law, or if the response to the assertion of rights is inadequate, users may submit a complaint to the Data Protection Authority (Garante per la Protezione dei Dati Personali).

Contact details:

Garante per la Protezione dei Dati Personali

Piazza Venezia n. 11 - 00187 Rome

Fax: (+39) 06.69677.3785

Telephone switchboard: (+39) 06.69677.1



  1. Data Protection Manager

It is hereby specified that SeSa S.p.A., the holding company of the business group to which the association belongs, has appointed a Personal Data Protection Manager. The Data Protection Manager monitors compliance with data protection regulations and provides appropriate consulting. Furthermore, where necessary, the Data Protection Manager cooperates with the Data Protection Authority. Please find the relevant contact details hereafter:



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