PRIVACY & COOKIE POLICY
INFORMATION PROVIDED IN ACCORDANCE WITH ART. 13 AND 14 OF EU GDPR 2016/679 – Rev. GDPR 1.0 of 25/05/2018
In accordance with and for the purposes of Articles 13 and 14 of EU GDPR 2016/679, we inform you that Liberty processes the personal data you freely provide, ensuring that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the interested party, with particular reference to confidentiality and identity.
This Privacy Policy describes Liberty's procedures in relation to the information we collect through the activities that refer to the Privacy Policy, including websites (our "Websites") and any site for portable devices.
You will have the opportunity to view this Privacy Policy during and after registration on the Sites by selecting the “Privacy / Cookies” link located at the bottom of each page of the Website.
This Privacy Policy does not concern – and we are not responsible for – the privacy, information or other activities of third parties that manage a website accessed by a link contained in the Website.
The inclusion on the Website of a link that refers to another website does not imply any involvement or endorsement by us in relation to the linked website.
I) Source of personal data
The personal data processed by Liberty are collected directly from the interested party or at Liberty's offices.
II) Data controller
The data controller is Liberty, with registered office in Via Giuseppe Mazzini, 6, 23037 Tirano (SO) – Liberty.tirano@gmail.com
III) Purpose of data processing
All personal data communicated, collected via the form filled out by you (personal data, email addresses, telephone numbers, written texts, etc.), in compliance with the current legislative provisions, may be processed for the following purposes:
inclusion in Liberty’s personal data and computer databases [legal basis for processing: execution of contractual measures];
fulfil specific requests from the interested party [legal basis for processing: our legitimate interests in responding to your requests];
subject to your explicit consent, to carry out market research and to send informational, promotional and/or advertising material on the services offered by Liberty via – by way of example and not limited to – text messages or instant messaging tools (such as Skype, WhatsApp, Telegram, Viber, Messenger, Hangouts, Chat, etc.), push notifications, e-mails, newsletters, faxes, reserved and private areas of the website and/or traditional tools (call with a non-pre-recorded telephone operator and paper mail) [legal basis for processing: your consent. You have the right to withdraw your consent at any time, using the information and contact methods indicated in point XII Rights of the interested party];
we may adapt our commercial communications to your needs and applications based on your profile information, the way you interact
with our Website or your interactions with our commercial communications [legal basis for processing: your consent. You have the right to withdraw your consent at any time, using the information and contact methods indicated in point XII Rights of the interested party];
to send you administrative information, for example, information regarding the Sites and changes to the contractual terms and conditions and policies
[legal basis for processing: our legitimate interests to inform you about the evolution of our sites];
functional for the operations of comparison and historicization of customer data through questionnaires that detect the degree of satisfaction in order to improve the service offered [legal basis for processing: your consent. You have the right to withdraw your consent at any time, using the information and contact methods indicated in point XII Rights of the interested party];
functional to the use of common personal data identifying the Data Subject (company name and logos) as company references, for the creation of commercial, informative and advertising material for Liberty [legal basis for processing: your consent. You have the right to withdraw your consent at any time,
using the information and contact methods indicated in point XII Rights of the Data Subject];
IT administration: to diagnose server problems, administer the Sites and check that they function appropriately [legal basis for processing:
our legitimate interests in administering our IT systems and networks].
protection of our interests (to comply with our legal obligations – to respond to requests from public and government authorities, including those outside your country of residence – to enforce our contractual terms and conditions – to protect our business – to protect our rights, our privacy, our safety or our and/or third parties' property – to allow us to take all available remedies or limit the damages we may suffer) [legal basis for processing: compliance with legal obligations and our legitimate interests in protecting Liberty]
The personal data provided by users who access the Site will be used only to perform the requested services and will not be communicated or disclosed to third parties,
unless communication is required by law or is strictly necessary to comply with the fulfillment of the user's requests or with the user's prior written consent.
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the Website, by its very nature, involves the subsequent acquisition of the sender's email address, necessary to respond to requests, as well as any other personal data included in the message.
Liberty processes personal data to the extent that this is strictly necessary to perform the functions for which the service is requested, excluding processing when the purposes pursued can be achieved using anonymous data or methods that allow the interested party to be identified only in case of necessity. We invite our users, in requests for information through a specific email address, not to send names or other personal data of third parties that are not strictly necessary, nor data belonging to special categories of personal data pursuant to Article 9 of GDPR 2016/679.
If the user sends personal and contact data of any third party other than the Interested Party in requests for information, he/she acknowledges that this operation
represents a processing of personal data with respect to which he/she acts as an independent controller, assuming all obligations and responsibilities. In this sense, the user guarantees to the Controller that any data of third parties that will be indicated by the user (and that will consequently be treated as if the third party had provided informed consent to the processing) has been acquired by the user in full compliance with the GDPR. The user grants the widest indemnity on this point with respect to any dispute, claim, request for compensation for damage from processing, which may be received by the Data Controller from any third party interested due to the provision of the data indicated by the user in violation of the rules on the protection of personal data.
No personal information of users that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs,
or trade union membership is collected or disclosed, nor is genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation of the person.
IV) Recipients of personal data - Communication
The personal data of the interested party, if necessary, may be communicated (with this term meaning giving knowledge of them to one or more specific subjects):
to subjects whose right to access the data is recognized by provisions of law, secondary legislation, community legislation, as well as collective bargaining;
to subjects to whom the communication of personal data is necessary or in any case functional to the management of the contractual relationship (consulting firms,
labor consultancy firms for the compilation of pay slips, Judicial Offices, Chambers of Commerce, Labor Chambers and Offices, Public Security, Health, Inspection authorities, Public Administrations, Trade Unions, Airports, Flight Agencies, Customs and insurance companies, hotel booking services, technical suppliers of multimedia telematic IT services, third-party service providers) in the ways and for the purposes illustrated above. A list of these subjects can be consulted at the Liberty headquarters;
to Liberty collaborators and employees, within the scope of their duties and/or any contractual obligations, including the Data Processors and the Persons in Charge;
Valtnet Srl for the development and maintenance of the website
our third-party service providers who provide support in communications, auditing and consultancy.
Specific and express consent will be requested if there is a need to communicate data to third parties not expressly indicated.
V) Dissemination of personal data
Personal data are not subject to dissemination.
VI) Types and Categories of data processed
The data processed by Liberty are personal (personal, communication and availability).
We may collect and process the following information about you:
Last name
First name
Phone numbers (including home and mobile numbers)
Email address
Public social media profile
Browser and device information
Server log file information
Information collected through cookies, pixel tags and other technologies
WE ASK YOU NOT TO SEND OR DISCLOSE TO US ANY “SENSITIVE INFORMATION” ON – OR THROUGH – THE WEBSITE OR ANY OTHER MEANS.
“Sensitive Information” is personal data relating to aspects such as:
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Trade union membership
Health or medical conditions
Criminal history
Sex life or sexual orientation
We may collect your personal data:
online, or through the Sites, for example when you create or use an account connected to our database
offline, for example when you contact us by telephone.
In compliance with current legislation, the personal data you provide to us through the Sites may be interconnected with other personal data and information that you provide to us (through online or offline means), or that Liberty may in other ways obtain online or offline.
VII) Transfer of data to a third country
The data processed for the purposes indicated above may be transferred to other countries belonging to the European Union.
VIII) Data retention period
We intend to keep your personal data accurate and up to date. The data processed will be retained for the minimum period necessary to achieve the purposes indicated above and will be processed for the entire time in which you are a registered user of our Sites, without prejudice to the retention obligations and applicable limitation periods. At the end of this period, the data will be made anonymous or deleted where technically possible.
IX) Lawfulness, nature of the provision and consequences of any refusal
The provision of data is a contractual obligation and indispensable to pursue the purposes of the processing indicated above in points III 1) 2) 5) 8) 9). Failure to provide the data of the interested party would in fact make it impossible to fulfill the obligations arising from the contract, as well as from legislative provisions. The processing, pursuant to art. 6 of the GDPR, is aimed at the execution of a contract to which the interested party is a party or the execution of pre-contractual measures adopted at the request of the interested party is a party or the execution of pre-contractual measures adopted at the request of the same; to fulfill a legal obligation to which the data controller is subject.
The provision of personal data is optional for the purposes referred to in points III 3) 4) 6) and 7) and the denial of consent does not entail any consequences.
Apart from what is specified for navigation data and technical cookies, the user is always free to provide personal data for the purposes for which he/she connects to the Site.
X) Method of data processing
In relation to the indicated purposes, the processing of personal data, in compliance with the law and confidentiality obligations, occurs through manual processing, computer and telematic tools, with logic strictly related to the purposes themselves and, in any case, in a way that guarantees the security and confidentiality of the data (even in the case of use of remote communication techniques).
XI) Rights of the interested party
The interested party has the right to ask the data controller for access to their personal data (art. 15 GDPR), their rectification (art. 16 GDPR), their erasure (art. 17 GDPR), the limitation of their processing (art. 18 GDPR), notification (art. 19 GDPR) also has the right to request their portability (art. 20 GDPR) and to oppose their processing (art. 21 GDPR) by contacting the Data Controller Liberty, Via Giuseppe Mazzini, 6, 23037 Tirano (SO), Liberty.tirano@gmail.com.
The interested party has the right to lodge a complaint with the Guarantor for the protection of personal data.
The use of automated decision-making processes is not envisaged, including profiling as per Art. 22 of the GDPR, based on the explicit consent of the interested party.
XII) Use of the Sites by minors and warnings for parents
The Sites are intended for Data Subjects aged 14 or over, subject to parental consent until the age of 16. Liberty requests that Data Subjects under the age of 14 NOT PROVIDE any personal data through the Sites. We reserve the right to request proof of parental consent at any time in order to allow the processing of personal data relating to minors. For some Sites or Apps there may be age restrictions, based on what is appropriate to see at a certain age or what is legally permitted by law. Where age restrictions are applied, we will take care to expressly indicate this on the relevant Site and we may ask questions in order to verify the age of the data subject before proceeding.
XIII) Updates to this Privacy Policy
You can find out when this Privacy Policy has been modified by checking the date and revision index at the beginning of the policy.
XIV) Cookies
General information about cookies
Liberty would like to use cookies and similar technologies for various purposes, but for this purpose it requires your consent. Select the “Accept” button to accept,
or the “Close” button to refuse use by Liberty. We will not use any cookies or similar technologies other than those strictly necessary for the operation of the site without your consent.
Cookies are small text strings that the websites visited by the user send to the browser, within which they are stored before being re-transmitted to the same sites at the next visit by the same user.
During navigation on a website, some elements (such as, for example, images, maps, sounds, specific links to pages of other domains) of other websites (so-called “third parties”) may reside. In these cases, the user may also receive cookies on his terminal that are sent by the latter.
Cookies are classified based on duration and the website that set them.
We believe it is essential to provide users with information about the cookies our website uses and the purposes for which they are used. The aim is threefold: to guarantee your privacy, to ensure ease of use and to optimise the development of our website. The main types of cookies and the purposes for which they are used are explained below.
Technical cookies
Technical cookies are those used for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide such service).
They are not used for other purposes and are normally installed directly by the owner or manager of the website. They can be divided into navigation or session cookies, which guarantee normal navigation and use of the website.
Session cookies are temporarily stored in the device's memory while browsing a site, for example, to keep track of the chosen language or authenticate to access restricted areas. Session cookies remain stored on the device for a short period of time. In fact, they are deleted as soon as the user closes the browser.
Permanent cookies save a file on the device for a long period of time. This type of cookie has an expiration date. Permanent cookies allow websites to remember information and settings for subsequent visits by users, thus making browsing more practical and quick, since, for example, it is no longer necessary to log in.
Upon expiration, the cookie is automatically deleted when you first access the website that created it.
Analytics cookies are assimilated to technical cookies when used directly by the website manager to collect information, in aggregate and anonymous form, on the number of users and how they visit the site.
This website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses “cookies” to analyze how users use the site.
The information generated by cookies on the use of the website (including your anonymous IP address) will be transmitted to and stored on Google servers in the United States. Google will use this information for the purpose of examining your use of the website, compiling reports on website activity for its operators and providing other services relating to website activity and Internet use in aggregate and anonymous form. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
Functionality cookies allow the user to navigate according to a series of selected criteria (for example, language, products selected for purchase) in order to improve the service provided.
The prior consent of users is not required for the installation of all types of technical cookies.
Below is a list of the technical cookies used by our site.
Google Analytics (statistics)
Facebook (widget)
Instagram (widget)
Technical Cookies for Statistical Analysis (detect the visitor's origin and IP)
Technical Cookies for the use of the site (to allow viewing of the site and navigation)
YouTube (we use the widget to include videos)
Google Maps widget (for the map)
| Cookie |
Duration |
| _ga |
2 years |
| _gat |
24 hours |
| _gid |
48 hours |
| displayCookieConsent |
1 month |
Profiling cookies
Profiling cookies are designed to create profiles relating to the user and are used to send advertising messages in line with the preferences expressed by the user while browsing the internet. Due to the particular invasiveness that such devices may have in the private sphere of users, European and Italian legislation requires that the user must be adequately informed about their use and thus express their valid consent.
This website does not use profiling cookies.
Third-party cookies
These cookies are set by domains other than the one indicated in the address bar of the browser, or by organizations that do not correspond to the owners of the website.
Cookies used, for example, to collect information for advertising purposes and to personalize content, as well as to process web statistics, may be "third-party cookies".
Third-party cookies allow for more complete surveys of users' browsing habits (profiling cookies).
This website does not use third-party cookies in order to profile users.
How to notify the user and manage consent for the use of cookies
When you visit our website for the first time, a banner is displayed to inform you that the Liberty company uses the cookies described in this document. The banner asks the user if they want more information and contains a link that allows them to open the corresponding page. If you decide to ignore the notice and continue to use the website, we will store a cookie on the device used by the user to record this choice and, the subsequent navigation of our website will be considered a consent to the use of cookies. The banner will not be displayed on the screen on subsequent visits to the website.
Disabling, enabling or deleting cookies
At any time, the user can limit or block cookies through the settings of the browser (Internet Explorer, Google Chrome, Mozilla Firefox, Opera, Safari, etc.).
If you prefer that the website does not store any cookies on your device, set the browser to receive a notification before storing each cookie. Alternatively, you can set your browser to reject all cookies or only third-party cookies. You can also delete all cookies already present in the system. It is important to note that the settings must be changed separately in each browser and device used (PC, notebook, smartphone, tablet, etc.).
If you set the blocking of cookie storage, we can no longer guarantee the correct functioning of the website.
Some functions of the site may not be available. The settings are changed in each browser following a different procedure. If necessary, to define correct settings use the browser's Help function.
More detailed information on the procedures for managing cookies (deactivation, activation, deletion and control) is available by consulting the address www.aboutcookies.org
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