Privacy Policy

Dear User,
set out below are the methods for processing personal data supplied directly or collected automatically when browsing the website https://www.prontocyber.com/ ("Website")

1 Data Controller

The Data Controller is Cy4Gate S.p.A. with registered office in Via Coponia n. 8 - Rome (RM) ("Cy4Gate", "Company" or "Data Controller").

2 Type of data processed

I) Data communicated by the user

In order to allow the use of the Website and, in particular, to access the personal area, to purchase the ProntoCyber product or to contact the Company ("Services"), the Owner must process certain personal data and, in particular

to create an account, first name, last name and email address will be required, in addition to a series of information relating to the company for which you work, such as, for example, your company name or turnover;

to purchase ProntoCyber, you will be asked to indicate the type of subscription you want, your first and last name, your email address, a possible telephone number and your company name. If the purchase request is accompanied by a message, all personal data included therein may also be processed;

similarly, when contacting Cy4Gate you will be asked to indicate the desired subscription type, first and last name, email address, a possible telephone number, and company name. In case the purchase request is accompanied by a message, all personal data included therein may also be processed.

II) Browsing data

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

This category of data includes, for example, the IP addresses of the devices 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 to submit 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 relating to the user's operating system, language and IT environment.

These data, which are necessary for the use of the Website, are processed for the sole purpose of obtaining statistical information on the use of the Services (most visited pages, number of visitors per hour or day, geographical areas of origin, etc.) and to check the correct functioning of the Services offered.

Cookie Policy

The Website uses the following types of cookies:

I) Technical cookies

Technical and session cookies are used, i.e. small text files containing a certain amount of information exchanged between the terminal or browser and the Website, which allow it to function and be used correctly. Therefore, the installation of these cookies is necessary to access the Website and the Services.

II) First and third party analytical cookies

This Website uses first and third party analytical cookies that allow us to collect aggregate information about the use of the Website. For example, these cookies allow us to analyse the number of visitors and how they use the Website, provide anonymous statistical analysis that we may use to improve the Website and make its content more usable and interesting. These cookies are not necessary, but they may allow us, for example, to improve our performance. To find out who the third parties are that install cookies, have easy access to their privacy policies and choose which ones to accept, you can click on the button at the bottom left.

III) Profiling cookies

This Website uses first and third-party profiling cookies that allow you to personalise and improve your browsing experience of the Website. For example, these cookies make it possible to know and remember the preferences expressed and show relevant, personalised and non-repetitive advertisements. These cookies are not required, but they may allow you to use the Website in a more personalised way or to have personalised content. To find out who the third parties are that install cookies, have easy access to their privacy policies and choose which ones to accept, you can click on the button at the bottom left.

3 Purposes, legal basis of processing and nature of conferment

	Purpose	Legal basis	Nature
A.	To allow the use of the Website and its Services^(i,ii) and ensure network and information security⁽ⁱⁱⁱ⁾. This purpose includes the possibility of accessing the personal area and contacting the Company. Furthermore, this purpose includes the processing of personal traffic data to the extent strictly necessary and proportionate to ensure network and information security.	(i) Performance of a contract to which the data subject is party (ii) Compliance with legal obligations (iii) Legitimate interest	The provision of personal data is mandatory. In fact, if they are not communicated, it will not be possible to use the Website and its Services and to ensure network and information security.
B.	Receipt of direct marketing communications, including invitations to events and information of a commercial nature. This purpose includes the possibility of receiving communications and information of a commercial nature containing offers, discounts, invitations to events and details of our promotional initiatives. Contact may be made through both traditional and automated contact systems, such as, but not limited to, e-mail.	(i) Express consent	The provision of your data is optional. However, although failure to consent to their processing does not affect your use of the Web Stores, it may not allow you to take full advantage of the benefits we offer through advertising, commercial and direct marketing information.
C.	Receipt of offers, discounts and other benefits based on the preferences expressed (profiling). This includes the possibility of receiving offers, discounts and any other benefits and promotional initiatives modelled on the specific needs expressed and propensity to purchase. This involves the recording, identification and profiling of data relating to your purchase volumes, habits and consumption choices.	(i) Express consent	The provision of your data is optional. . However, although failure to authorise their processing does not affect your use of the Web Stores, it may not allow us to send you personalised communications based on your purchasing habits and choices.

4 Storage period

Personal data processed for direct marketing purposes will be deleted or transformed into anonymous form within 24 months of the data being recorded. Conversely, data processed for profiling purposes will be deleted or anonymised within 12 months after registration. Since it is not possible to predetermine the retention period of other personal data, the Controller undertakes to base its processing on the principles of adequacy, relevance, data minimisation and retention limitation. In addition, personal data may be further retained to comply with regulatory obligations, or to establish, exercise or defend a right in court.

5 Categories of recipients of Personal Data

The personal data processed will not be disclosed, but in pursuance of the purposes indicated, may be communicated to:

I) those who can access the data by virtue of legal provisions provided for by the law of the European Union or by the law of the Member State to which the Controller is subject;

II) data controllers that are part of our business group exclusively for internal administrative purposes;

III) companies that offer advertising, marketing and communication services, companies that offer IT infrastructures and IT assistance and consultancy services as well as the design and creation of software and websites, companies that offer services useful for customising and optimising our services, companies that offer data analysis and development services (including those relating to users' interactions with our services), companies that manage payments, companies or consultants appointed to provide further services to the Controller.

In addition, personal data may also be processed by our employees, designated as individuals acting under the authority of the Controller pursuant to Article 29 of the GDPR or as System Administrators.

6 Transfer of Personal Data to Third Countries

The Controller may transfer your Personal Data to third countries outside the European Union, including the United States of America, for the purpose of carrying out statistical analysis on the use of the Website. Such transfer is subject to appropriate safeguards through the use of EU Standard Contractual Clauses. For more information on this instrument you can click here. To request a copy of those signed by Cy4Gate you can send an email to [info.prontocyber@cy4gate.com].

7 Any Automated Decision Making Processes

Should you consent to the processing of your personal data for profiling purposes, the Data Controller will use automated decision-making processes, including profiling, to allow you to use the Website in a manner consistent with your interests and preferences, as well as to propose offers, discounts and any other benefits and promotional initiatives modeled on the preferences you have expressed. To this end, information relating to your browsing habits and shopping preferences will be analysed and recorded. The logics applied to the profiling process are based on (i) segmentation activities, which allow us to segment users according to their purchasing habits, and (ii) clustering activities through aggregative methodologies, which, through the analysis of the personal data collected, allow us to identify types of users with similar behaviour. Therefore, as a result of profiling activities, you may benefit from viewing content that is exclusively targeted to your interests, as well as from receiving communications that may respond to your interests or habits.

8 Rights of the data subject

As a data subject, you have the right to withdraw your consent at any time and to obtain access to your personal data from the Company. You also have the right to ask the Company to correct or delete your personal data. In addition, you have the right to obtain the restriction of the processing of personal data concerning you, as well as the right to the portability of such data. In addition to the above, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out pursuant to Article 6(1)(e) or (f), including profiling on the basis of these provisions, as provided for in Article 21 of the GDPR. Furthermore, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you carried out for such purposes, including profiling insofar as it is related to such direct marketing. Finally, You have the right to lodge a complaint with a supervisory authority or take appropriate legal action if You consider that the processing concerning You is in breach of the GDPR. To exercise any of your rights, you may contact the Data Controller by sending a communication to its registered office at Via Coponia n. 8 - Rome (RM), or by sending an email to the address [info.prontocyber@cy4gate.com]. "