Updated May 24, 2018
WHY THIS ANNOUNCEMENT?
In this page we describe the modality of managing the website with reference to the processing of personal data of users who visit it.
This circular is also in compliance with the Code on the Protection of Personal Data to those who interact with the digital services of ‘il nuovo manifesto societa’ cooperativa editrice’ (hereinafter ‘il manifesto’).
The circular is provided only for ‘il manifesto’ website, its apps and digital products and not for other websites, digital products and apps that the user may consult via links.
The circular is also based on the Recommendation no. 2/2001 that the European authorities for the protection of personal data, gathered in the Group established by art. Directive 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online. In particular, the manner, timing and nature of the information that data controllers must provide users when they connect to web pages, regardless of the purpose of the link, and EU Regulation No 2016/679 on the protection of personal data (in short, GDPR).
On the digital version of ‘il manifesto’, we do everything possible to protect your privacy, your personal data and your reading and subscribing experience.
Here are some examples:
1- the website is built according to the HTTPS/SSL protocol and therefore only accepts encrypted and secure connections.
2- we do not display advertising banners so that you cannot be tracked or profiled by third parties for commercial or any other purpose.
3- we only use technical, anonymous ‘cookies’ that are necessary for the proper functioning of the website. They do not collect any personal information.
4- we do not collect users’ profiles or sell to third parties the data of those who, by registering, entrust them to us.
5- To delete your data recorded on the site you can write to email@example.com.
6- All of our servers are physically within the European Union.
7- In short, we collect as little data as possible, the minimum necessary to provide you with our editorial, cultural and journalistic services.
You can trust our website not only for the quality of our journalism but also for the way we try to offer it.
1. TYPES OF DATA COLLECTED/PROCESSED
1.1 BROWSING DATA
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the communication protocols of the Internet functioning. This information is not collected to be directly associated with identified subjects, but by their nature they could allow users to be identified through processing and association with data held by third parties.
This category of data includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating and computer system.
These data are used only to obtain anonymous statistical information on the use of the website and to check its correct functioning.
The data could be used to verify responsibilities in the case of hypothetical computer crimes against the website.
No personal data of users are acquired by the site.
The site does not profile either authenticated or non-authenticated users.
Cookies do not collect any information other than that needed to provide the service (see purpose in point 2).
For information only, you can read the privacy policies of some third parties used by il manifesto here (in Italian).
1.3 DATA VOLUNTARILY PROVIDED BY THE USERS
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site involves the subsequent acquisition of the sender’s address, necessary to respond to requests, and any other personal data included in the message.
The provision of personal data is optional and is aimed at providing and improving the service in the interest of the customer.
However, the failure to provide, even partially, the requested data will make it impossible to proceed with the complete provision of services offered.
1.4 USING ‘IL MANFESTO’ APP
2. PURPOSE OF DATA PROCESSING
The personal data collected are processed for goals related to the purposes for which they were collected. Therefore, for the proper functioning of our site, as well as for statistical analysis and to respond to any requests you may make.
3. MODALITIES OF TREATMENT
The data processing will be carried out mainly through the use of automated tools for the time strictly necessary to achieve the purposes for which they were collected.
The data will be kept for a period of time not exceeding that necessary for the purposes for which it was collected or subsequently processed.
Specific security measures are observed to prevent loss of data, illicit or incorrect use and unauthorized access.
In no case will your data be treated through processes that involve automated decisions or profiling processes.
The data are not transferred to entities established in countries outside the European Union.
4. COMPULSORY OR OPTIONAL NATURE OF DATA CONFERMENT
Apart from the specified navigation data, the user is free to provide personal data for the request of information sent by mail.
5. COMMUNICATION AND DATA DIFFUSION
To pursue the purposes indicated and within the limits of what is strictly necessary, the data may be brought to the attention of employees or collaborators of the Publisher in the reason and within the limits of the tasks and duties assigned to them.
The data may also be disclosed to categories of persons who carry out activities connected or instrumental to the Publisher and to whom the latter may turn, after appointment as data processors, to carry out the said activities, within the limits of what is strictly necessary and in compliance with the purposes indicated. These categories include, but are not limited to, PC manager and logistics operators.
In no case will the data be stored on systems not directly controlled by the poster and in no case will it be disseminated.
6. DATA OWNER
The data controller is ‘il nuovo manifesto societa’ cooperativa editrice’, headquarters in Via Bargoni n. 8 – 00153 – Rome.
7. DATA OF THE INTERESTED SUBJECT
At any time you can obtain confirmation of the existence of your data and to know its content and origin, verify its accuracy or request its integration, updating, rectification, deletion or even limitation of processing in the event of processing in violation of the law, as well as transformation into anonymous form or to oppose and revoke consent at any time.
Users registered on the site can do so in their profile at the top right on every page of the site.
In order to exercise their rights, their requests should be sent to the following e-mail address: firstname.lastname@example.org or by sending a registered letter with return receipt to ‘il nuovo manifesto societa’ cooperativa editrice’ responsible for privacy, with registered office in Via Bargoni 8 – 00153 – Rome.
In case of failure or partial response, the person concerned has the right to lodge a complaint with the Authority for the protection of personal data following the procedure indicated on the site: www.garanteprivacy.it.
The security standards used by the controller to make personal information confidential and reserved shall be in line with the security measures set out in the best practices and the GDPR. The navigation and all services on the site, including transactions relating to payment services, are managed by transmission of data through SSL (Secure Socket Layers) with protocol TLS 1.2 or higher.
Version November 17, 2015
Please note that our Sites, Apps and Mobile Content are under constant development. Services can change frequently and this agreement may therefore be modified and updated on an ongoing basis. It is important to check back this page regularly.
At il manifesto global, a publication of il nuovo manifesto cooperativa editrice (“Global”), we want you to enjoy and benefit from our websites and online services secure in the knowledge that we have implemented fair information practices designed to protect your privacy.
WHAT INFORMATION DO WE GATHER ABOUT YOU?
The information gathered when you interact with Global Services falls into two categories: 1) Personal information, which includes personal information you supply when you subscribe, order, complete a survey, register to our Sites, enter a contest or provide your email address and 2) Non-personal information collected through technology, which includes tracking information collected by us as well as third parties.
What We Learn from Personal Information that You Give Us or Ask a Third Party To Share With Us
Registration for Global Services may require that you supply certain personal information, including a unique email address and demographic information (for example ZIP code, name, surname, address, sex, job title, etc.) to register.
Social media registration features may collect your IP address, the page you are visiting on our site, and may set a cookie to enable the features to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our web site. You can disassociate your Global Services registration from third-party accounts any time.
Billing and Credit Card Information
We enable payment and donations via Global Services however we do not collect and store credit card information and other billing information. This information will be stored by third parties who help to complete the purchase transaction (for example Stripe or PayPal). Examples of this include fulfilling orders and processing credit card payments.
User Generated Content and Public Activities (Including Comments)
We offer you opportunities to engage in public activities on global.ilmanifesto.it and other Global Services. “Public activities” are any actions you take on global.ilmanifesto.it that are designed to be visible to other users, including comments, recommendations, reader reviews, ratings or any other items that you submit. Any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public and may be used by il nuovo manifesto società cooperativa editrice for online and offline promotional or commercial uses in any and all media. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these areas. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions.
Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds. Keep in mind that we are not responsible for any personal information you choose to make public via your public activities, and you agree that such sharing will be deemed to have been done by you, not Global Services or il nuovo manifesto società cooperativa editrice.
Reader Surveys and Market Research
Global may collect personal information from you in connection with voluntary surveys conducted via Global Services. Data may be collected through the Global Services, on the phone or through the mail. The information you provide may be shared, but only in the aggregate, with advertisers and partners unless we notify you otherwise at the time of collection.
What We Learn from Non-Personal information
Our Sites may automatically recognize your domain name, IP address, browser version, operating system, region and the website you passed through to reach us. In addition, our Sites automatically gather certain usage information, like the numbers and frequency of visits to the Sites and their areas – very much like television ratings that tell how many people tuned in to a program. The information we obtain in providing Mobile Content varies depending on the practices of your device manufacturer, service provider, and choices available to you as a user.
Some features of our Sites do offer you the option of providing information such as your name, e-mail address, postal address, phone number, organization, location, or any other identifying information. (You may also provide us with such information in the course of registering at global.ilmanifesto.it or other offerings from Global – details of how we use such information are also provided above.)
How We Use What We Learn
The information we collect is used to improve the content of Global and our Sites and to keep you apprised of important developments. For example, we may use personally identifiable information to contact you as part of an online survey about our editorial offerings, inform you of material changes or additions to our services, advise you of account status, or contact you in order to comply with any legal requirements. Also, we compile and use your information so that we may keep you apprised of special offers, as well as additional products that may be of interest to you. We could perform statistical, demographic and marketing analyses of users of Global Services, and their subscribing and purchasing patterns, for product development purposes and to generally inform advertisers about the nature of our subscriber base. We use this information for analysis purposes, including analysis to improve customer relationships. In some cases, we may share personally identifiable information to contact you (sometimes through a service or business partner) for the reasons we have described.
If, at any time, you prefer not to receive email information from us, simply follow the unsubscribe options at the bottom of each email.
What We Tell Others About You
If you have registered to use Global Services, we will not sell, rent, swap or authorize any third party to use your email address without your permission.
In the future, we may sell, buy, merge or partner with other companies or businesses. In such transactions, we may include your information among the transferred assets.
We contract with other companies to provide services on our behalf, including credit-card and billing processing, ad serving, shipping, email distribution, list processing and analytics or promotions management. We provide these companies only with the information they need to perform their services. These service providers are restricted from using personal information in any way other than to provide services for Global Services or il nuovo manifesto società cooperativa editrice, and they may not share, resell or use the data for their own direct marketing purposes.
We may provide statistical usage data in the aggregate–not information about you personally–to our partners about how visitors use the Sites. From time to time we conduct research on our users’ demographics, interests and behavior based on the information you provide to us upon registration, on order forms, as well as from our server log files or from surveys. We do this to better understand and serve our users. This research is compiled and analyzed on an aggregated basis and we may share this aggregated data with advertisers or other businesses.
In some cases, we may disclose information about you to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or with legal process, to protect and defend our rights and property or to prevent misuse of our Sites, or to protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, Global reserves the right to transfer your personally identifiable information to the new party in control or the party acquiring assets.
What Are Cookies And How Do We Use Them?
The Sites place a “cookie” on the browser of a user’s computer to gather and store basic tracking information and to monitor the presentation of advertisements. We may also use the information for editorial purposes and for other purposes such as measuring certain traffic patterns. For example, cookies are used to ensure that you don’t see the same ad too many times in a single session. Cookies are also used to restrict access to certain areas of the Sites to bona fide subscribers or to enable you to set up customized alerts that no other subscribers are permitted to see. Cookies are not related to any personally identifiable information and are not used to retrieve information from your computer that was not originally sent in a cookie.
Advertising service vendors that serve ads on our Sites may also use their own cookies. You may opt-out of the cookies delivered by the Sites by changing the setting on your browser. Some browsers are set to refuse all cookies, or to restrict the conditions under which they are set. Please be aware that this will disable all cookies delivered to your browser, not just the ones delivered by us.
Advertisers and Links
The Sites may contain links to other sites, including those produced by other organizations, for your convenience and information. Additionally, our advertisers, or Web sites that have links on our Sites, may also collect personally identifiable information directly from you. We are not responsible for the privacy policies or the content of those sites. Please visit the sites of these businesses to review their privacy policies.
Kids & Parents
Kids under 14: Do not send us any information about yourself, such as your name, address, or e-mail address.
Parents: These Sites are not directed to children under the age of fourteen (14) and we do not knowingly collect personally identifiable information from children under the age of 14 as part of the Sites. If we become aware that we have inadvertently received personally identifiable information from a user under the age of 14 as part of the Sites without verifiable parental consent, we will delete such information from our records.
We have in place reasonable physical, technical, electronic and administrative procedures to protect the information we collect online and to prevent unauthorized access. However, as effective as these measures are, no security system is impenetrable or 100% secure. We cannot guarantee the security of our database, websites, or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.
What if I am a Non-Italy User?
If you are located outside of Italy, the information you provide to us will be transferred to Italy in the European Union, whose laws may not provide the same level of protection for personal information as your home country.
By using this web site, you consent to this transfer.
You also consent to the adjudication of any disputes arising in connection with this website in the courts of, and in accordance with the laws of, Rome Italy.
How Can I cancel or review my Personally Identifiable Information?
You may review and update your membership or account information and access your transaction history in the My Account area.
If you have any questions, let us know by e-mailing or writing us (see addresses below).
Our Postal Address
il manifesto global
c/o il nuovo manifesto società cooperativa editrice
via Angelo Bargoni 8
00153 Rome (RM)