Via Varesina, 173 - 20156 Milan
+39 02 89.07.9400 - info@realstep.it

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Privacy Policy

Information on the processing of personal data of website surfers

Pursuant to Article 13 of Regulation (EU) 2016/679

RealStep SICAF S.p.A., headquartered at Via Varesina No. 173, 20156, Milan (MI), as the Data Controller (hereinafter "Controller" or "RealStep"), provides you with some information about the processing of your personal data in accordance with Regulation (EU) 2016/679 (the "Regulation" or "GDPR").

1. Identity and contact details of the Holder

Data controller: RealStep SICAF S.p.A.
Registered office: via Savona n. 97, 20144 Milan (MI)
Phone: +39 02 89.07.94.00
Fax: +39 02 42.29.61.12
Email: privacy@realstep.it

2. Purpose of processing, legal basis of processing and categories of personal data

The Controller processes your personal data for the following purposes:

  • Respond to user requests via e-mail;
  • Adapt content and resources to user preferences in order to improve the browsing experience;
  • Ensure that the content provided through the website is presented in the most effective way for the user based on their device;
  • Allow you to participate in interactive features of the site, if desired;
  • Allow display of content from external platforms;
  • Fulfilling legal obligations and responding to requests from authorities.

In particular, your free, explicit and voluntary entry of personal data in the digital forms on RealStep's website entails the subsequent acquisition of the data provided, which are necessary for communication between you and RealStep (e.g. personal identification data, e-mail address, telephone number and any other common data). The legal basis for such processing is consent, which is deemed to be given with your input of personal data and the flag to the acknowledgement of the privacy policy. The data will be retained until the consent is revoked by the data subject.

Computer systems and software procedures related to the operation of the RealStep website acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes IP addresses or domain names of the computers used by users connecting to the site, the URI(Uniform Resource Identifier) notation addresses of the requested resources, 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 related to the user's operating system and computer environment.

This data is used for the sole purpose of:

  • To obtain anonymous statistical information about the use of the site;
  • Monitor the proper functioning of the site;
  • Carry out monitoring activities to support service security.

The legal basis for such processing is the legitimate interest of RealStep, and the data would be retained for as long as necessary for that purpose.

3. Modalities of personal data processing and storage period

Personal data will be processed by the Data Controller using computer systems in accordance with the principles of fairness, loyalty and transparency provided for in the applicable legislation on the protection of personal data and protecting your confidentiality and rights by adopting appropriate technical and organizational measures adequate to the risk. The processing does not involve any automated decision-making or profiling.

Your personal data will be kept for a period of time no longer than necessary for the purposes for which they were collected and subsequently processed, in accordance with legal obligations.

4. Recipients of personal data

For the pursuit of the above purposes, RealStep, without the need for consent, may disclose personal data to public or private entities in fulfillment of an obligation required by law, regulation or EU legislation.

RealStep makes use in carrying out its activities of third parties to whom control and/or business functions have been outsourced or who provide consulting services on its behalf.

RealStep may also need to disclose personal data to external parties, including those in the following categories:

  • Subjects that provide services for the management of the information system, including the RealStep website, web applications and telecommunications networks (including e-mail);
  • Individuals who carry out archiving and storage activities, including computer storage, of documentation related to the relationships held;
  • Subjects to whom the right to access the data is recognized by provisions of the law and secondary regulations or provisions issued by authorities empowered to do so by law.

The list of external parties to whom personal data are transmitted by RealStep is constantly updated and is available at the offices of RealStep. Each data subject may exercise his or her rights under the Regulations vis-à-vis the Data Controller.

For the performance of its activities and the pursuit of the above-mentioned purposes, the personal data of the data subject may come to the attention of company representatives, employees, interns, temporary workers and other collaborators appointed as data processors or authorized to process the data.

5. Conferral of personal data

With the exception of personal data related to navigation on this website, the provision of personal data by you is optional. However, any refusal to communicate your personal data on the contact page makes it impossible for the Controller to process them and for you to communicate with the Controller.

6. Transfer of personal data

Your personal data are processed at the registered office of the Data Controller and in any other place where the parties involved in the processing are located. We inform you that your personal data may be transferred outside the European Economic Area only if there is an adequacy decision from the European Commission or other appropriate guarantees provided by the Regulation.

7. Rights of the data subject

We inform you that each data subject is entitled to exercise the following rights under and in the manner provided by the Regulations:

  • Right to ask the Data Controller for access to personal data pursuant to Article 15 of the Regulations;
  • Right to rectification of personal data under Article 16 of the Regulations;
  • Right to erasure of personal data under Article 17 of the Regulations, or "right to be forgotten."
  • Right to limitation of processing under Article 18 of the Regulations;
  • Right to data portability under Article 20 of the Regulations;
  • Right to object to processing under Article 21 of the Regulations.

For processing based on consent, the data subject may, in addition, at any time revoke the consent given, without prejudice to the lawfulness of the processing based on the consent given before such revocation

The above rights may be exercised by a request addressed without formalities to RealStep, at the following e-mail address: .

The data subject also has the right to lodge a complaint with the Garante per la protezione dei dati personali, following the procedure available on the Authority's website, www.garanteprivacy.it.

RealStep, in compliance with Article 19 of the Regulations, proceeds to inform recipients to whom personal data have been disclosed of any rectification, deletion, or restriction of processing requested, where possible.

8. Ways of exercising rights

At any time you may exercise your rights, ask questions and make comments regarding this privacy policy by sending an e-mail to privacy@realstep.it.

9. Cookie Policy

Cookies are small text files that are transmitted from websites to the devices of users who visit them, and are retransmitted to the same websites on subsequent visits. They can have different characteristics and be used for different purposes, either by the owner of the website visited or by third parties.

To learn more and to view the detailed information, the data subject can consult the Cookie Policy.

10. Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by informing interested parties on this page and, if possible, on this website.

Therefore, please consult this page regularly, referring to the date of last modification shown at the bottom.

If the changes affect processing whose legal basis is consent, the Controller will re-collect consent from the Data Subject, if necessary. 

Last updated: 12.11.2024