I – INFORMATION REGARDING THE WEBSITE PRIVACY POLICY

1. This section contains information on the management methods of About Sorrento in relation to the processing of user data of www.aboutsorrento.com

2. This policy is also valid for the purposes of Article 13 of Legislative Decree No. 196/2003, Personal Data Protection Code, and for the purposes of Article 13 of EU Regulation No. 2016/679, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, for subjects who interact with About Sorrento and can be reached at the address corresponding to the home page:

www.aboutsorrento.com

3. The policy is provided only for About Sorrento and not also for other websites that may be consulted by the user through links contained therein.

4. The purpose of this document is to provide indications about the methods, times and nature of the information that data controllers must provide to users when connecting to the web pages of About Sorrento, regardless of the purposes of the connection itself, according to Italian and European legislation.

5. This policy may be subject to changes due to the introduction of new regulations on the matter; users are therefore invited to periodically check this page.

6. If the user is under 16 years of age, pursuant to Article 8, paragraph 1 of EU Regulation 2016/679, they must legitimize their consent through authorization from their parents or guardians.

II – DATA PROCESSING

1 – Data Controller

1. The data controller is the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data. It also deals with security profiles.

2. With regard to this website, the data controller is: Giovanni Cioffi, and for any clarification or exercise of the user’s rights, he may be contacted at the following email address: info@aboutsorrento.com.

2 – Data Processor

1. The data processor is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.

2. Pursuant to Article 28 of EU Regulation No. 2016/679, upon appointment by the data controller, the data processor of the About Sorrento website is: Giovanni Cioffi.

3 – Data Processing Location

1. The processing of data generated by the use of About Sorrento takes place at Via Pellegrino Matteucci 41, 00154 Rome.

2. If necessary, data connected to the newsletter service may be processed by the data processor or persons appointed by it for this purpose at its registered office.

III – COOKIES

1 – Type of Cookies

1. The About Sorrento website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small strings of text used to store certain information that may concern the user, their preferences or the device used to access the Internet (computer, tablet or mobile phone) and are mainly used to adapt the operation of the site to the user’s expectations, offering a more personalized browsing experience and memorizing choices made previously.

2. A cookie consists of a small set of data transferred to the user’s browser by a web server and can only be read by the server that made the transfer. It is not executable code and does not transmit viruses.

3. Cookies do not record any personal information and any identifiable data will not be stored. If desired, it is possible to prevent the saving of some or all cookies. However, in this case the use of the site and the services offered may be compromised. To proceed without changing the cookie options, simply continue browsing.

Below are the types of cookies used by the site:

2 – Technical Cookies

1. There are numerous technologies used to store information in the user’s computer, which are then collected by websites. Among these, the best known and most widely used is that of HTML cookies. They are used for navigation and to facilitate access to and use of the site by the user. They are necessary for the transmission of communications on an electronic network or for the provider to deliver the service requested by the customer.

2. The settings to manage or disable cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or deletion of cookies by changing the settings of their internet browser. Such deactivation may slow down or prevent access to certain parts of the site.

3. The use of technical cookies allows the safe and efficient use of the site.

4. The cookies that are inserted in the browser and retransmitted through Google Analytics or through the blogger statistics service or similar are technical only if used for site optimization purposes directly by the site owner, who may collect information in aggregate form on the number of users and how they visit the site. Under these conditions, the same rules regarding information and consent provided for technical cookies apply to analytics cookies.

5. From the point of view of duration, a distinction can be made between temporary session cookies, which are automatically deleted at the end of the browsing session and are used to identify the user and thus avoid logging in on every page visited, and permanent cookies, which remain active on the computer until expiration or deletion by the user.

6. Session cookies may be installed in order to allow access to and permanence in the reserved area of the portal as an authenticated user.

7. They are not stored persistently but only for the duration of the browsing session until the browser is closed and vanish when the browser is closed. Their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the safe and efficient exploration of the site.

3 – Profiling Cookies

1. Profiling cookies are those used to create user profiles and are used to send advertising messages in line with the preferences expressed by the user while browsing the Internet.

2. When these types of cookies are used, the user must give explicit consent.

3. Article 22 of EU Regulation 2016/679 and Article 122 of the Personal Data Protection Code shall apply.

4 – Cookies used on this website

This site uses technical cookies (necessary for it to work) and, upon consent, analytics cookies (Google Analytics 4). We do not use advertising/profiling cookies or third-party ads.

Cookies used:

We use Google Consent Mode v2: before consent no analytics tool is activated. Analytics cookies are processed on consent (Art. 6(1)(a) GDPR), withdrawable at any time. Data is processed by Google Ireland Limited (GA4); any transfer outside the EU is based on the European Commission’s standard contractual clauses.

You can change or withdraw your consent at any time via the Manage cookies link at the bottom of every page, or from your browser settings.

IV – DATA PROCESSED

1 – Data Processing Methods

1. Like all websites, this site also uses log files in which information collected automatically during user visits is stored. The information collected may be as follows:

– internet protocol (IP) address;
– type of browser and parameters of the device used to connect to the site;
– name of the internet service provider (ISP);
– date and time of visit;
– web page of origin of the visitor (referral) and exit;
– possibly the number of clicks.

2. The aforementioned information is processed in automated form and collected exclusively in aggregate form in order to verify the correct operation of the site, and for security reasons. Such information will be processed based on the legitimate interests of the controller.

3. For security purposes (anti-spam filters, firewall, virus detection), automatically recorded data may possibly also include personal data such as the IP address, which may be used, in accordance with applicable laws, in order to block attempts to damage the site itself or to cause damage to other users, or otherwise harmful activities or activities constituting a crime. Such data is never used for user identification or profiling, but only for the protection of the site and its users; such information will be processed based on the legitimate interests of the controller.

4. If the site allows the entry of comments, or in the case of specific services requested by the user, including the possibility of sending a Curriculum Vitae for a possible employment relationship, the site automatically detects and records certain identifying data of the user, including the email address. Such data is understood to be voluntarily provided by the user at the time of requesting the provision of the service. By entering a comment or other information, the user expressly accepts the privacy policy, and in particular consents that the contents entered may be freely disclosed even to third parties. The data received will be used exclusively for the provision of the requested service and only for the time necessary for the provision of the service.

5. The information that users of the site deem to make public through the services and tools made available to them is provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violations of laws. It is up to the user to verify that they have permissions for the entry of personal data of third parties or content protected by national and international laws.

2 – Purposes of Data Processing

1. The data collected by the site during its operation are used exclusively for the purposes indicated above and stored for the time strictly necessary to carry out the specified activities, and in any case no longer than the times provided by law.

2. In any case, the data detected by the site will never be provided to third parties, for any reason, unless it is a legitimate request by the judicial authority and only in the cases provided by law.

3. Data used for security purposes (blocking attempts to damage the site) are stored for the time strictly necessary to achieve the aforementioned purpose.

3 – Data Provided by the User

1. As indicated above, the optional, explicit and voluntary sending of emails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.

2. Specific summary information notices will be progressively reported or displayed on the pages of the site prepared for particular services on request.

4 – Support in Configuring Your Browser

1. The user can also manage cookies through their browser settings. However, deleting cookies from the browser may remove the preferences set for the site.

2. For further information and support, you can also visit the specific help page of the web browser you are using:

– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences

– Safari: http://www.apple.com/legal/privacy/it/

– Chrome: https://support.google.com/accounts/answer/61416?hl=it

– Opera: http://www.opera.com/help/tutorials/security/cookies/

5 – Social Network Plugins

1. This site also incorporates plugins and/or buttons for social networks, in order to allow easy sharing of content on your favorite social networks. These plugins are programmed so as not to set any cookies when accessing the page, to safeguard the privacy of users. If necessary, cookies are set, if so provided by the social networks, only when the user makes effective and voluntary use of the plugin. Please note that if the user browses while logged into the social network, they have already consented to the use of cookies conveyed through this site at the time of registration with the social network.

2. The collection and use of information obtained through the plugin are governed by the respective privacy policies of the social networks, to which please refer:

Facebook: https://www.facebook.com/help/cookies

Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di-twitter

Google+:http://www.google.com/policies/technologies/cookies

Pinterest: https://about.pinterest.com/it/privacy-policy

AddThis: http://www.addthis.com/privacy/privacy-policy

Linkedin: https://www.linkedin.com/legal/cookie-policy

V. USER RIGHTS

1. Article 13, paragraph 2 of EU Regulation 2016/679 lists the rights of the user.

2. The About Sorrento website therefore intends to inform the user about the existence:

– of the right of the data subject to ask the controller for access to personal data (Article 15 EU Regulation), their updating (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003), rectification (Article 16 EU Regulation), integration (Article 7, paragraph 3, letter a) of Legislative Decree 196/2003) or restriction of processing concerning them (Article 18 EU Regulation) or to object, for legitimate reasons, to their processing (Article 21 EU Regulation), as well as the right to data portability (Article 20 EU Regulation);

– of the right to request erasure (Article 17 EU Regulation), transformation into anonymous form or blocking of data processed in violation of law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed (Article 7, paragraph 3, letter b) of Legislative Decree 196/2003);

– of the right to obtain attestation that the operations of updating, rectification, integration of data, erasure, blocking of data, transformation have been brought to the knowledge, also as regards their content, of those to whom the data have been communicated or disseminated, except where such compliance proves impossible or involves a manifestly disproportionate use of means with respect to the protected right (Article 7, paragraph 3, letter c) of Legislative Decree 196/2003);

3. Requests may be addressed to the data controller, without formalities or, alternatively, using the model provided by the Italian Data Protection Authority, or by sending an email to the address: info@aboutsorrento.com

4. If the processing is based on Article 6, paragraph 1, letter a) – express consent to use – or on Article 9, paragraph 2, letter a) – express consent to the use of genetic, biometric, health-related data, which reveal religious or philosophical beliefs or trade union membership, which reveal racial or ethnic origin, political opinions – the user has the right to withdraw consent at any time without prejudicing the lawfulness of the processing based on the consent given before withdrawal.

5. Likewise, in the event of a violation of the regulations, the user has the right to lodge a complaint with the Italian Data Protection Authority, as the authority responsible for supervision of processing in the Italian State.

6. For a more in-depth examination of your rights, see Articles 15 et seq. of EU Regulation 2016/679 and Article 7 of Legislative Decree 196/2003.

VI – TRANSFER OF DATA TO NON-EU COUNTRIES

1. This site may share some of the data collected with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of EU Regulation 2016/679, so no further consent is required. The above-mentioned companies guarantee their adherence to the Privacy Shield.

2. Data will never be transferred to third countries that do not comply with the conditions provided for by Article 45 et seq. of the EU Regulation.

VII. SECURITY OF DATA PROVIDED

1. This site processes user data lawfully and correctly, adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification or unauthorized destruction of data. Processing is carried out using computer and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated.

2. In addition to the controller, in some cases, categories of persons involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the data.

VIII. CHANGES TO THIS DOCUMENT

Last updated: 12 October 2026.

1. This document, published at the address:

https://dev.aboutsorrento.com/privacy-policy

constitutes the privacy policy of this site.

2. It may be subject to changes or updates. If they are significant changes and updates, these will be reported with appropriate notifications to users.

3. Previous versions of the document will in any case be available for consultation on this page.

4. The document was updated on 12/11/2018 to comply with the regulatory provisions on the matter, and in particular in accordance with EU Regulation 2016/679.