Privacy Policy

This document describes how the personal data of users interacting with the website www.jelu.it is managed and processed. The notice is provided pursuant to Regulation (EU) 2016/679 and other applicable legislation, and applies exclusively to data collected through this website.

Article 1 - Data controller and legal basis

Pursuant to art. 13 of EU Regulation 2016/679, the General Data Protection Regulation (hereinafter GDPR), please note that JELU Consulting, tax code 97910400585, VAT no. 14145441003, with registered office in Rome, Viale Romania 32, will process, as Data Controller, the personal data of the persons this notice is addressed to, for the purposes and in the ways set out below.

Article 2 - Purposes of processing

Data is processed in order to obtain statistical information on the use of the services, to guarantee the correct functioning of the services offered and improve the browsing experience, and to send communications or reply to those received from the Data Subject through the website.

Article 3 - Data processing

Such data is collected for the purposes described in article 2 on the basis of the consent given by the user. Processing is carried out in automated and/or manual form in compliance with article 32 GDPR.

In any case, personal data is processed in compliance with the principles of lawfulness and fairness set out in article 5 GDPR, always operating so as to guarantee the confidentiality and security of the information.

Article 4 - Data retention period

The Controller reserves the right to retain the data collected for a maximum of 180 (one hundred and eighty) days, in order to fulfil the purposes set out in article 2. After that period the data will no longer be available.

Article 5 - Types of data processed

The processing described here covers the following data:

Browsing data, meaning the technical information collected automatically during the visit to the website and used for statistical and security purposes;
Contact data, meaning the data sent optionally, explicitly and voluntarily to the Controller. By way of example, electronic communications include messages sent by Data Subjects to the pages on the main social media platforms managed by the Controller, and the completion and/or submission of any forms on the website www.jelu.it.

Article 6 - Rights of the Data Subject

The Data Subject has the right:

Pursuant to article 15 GDPR, to obtain confirmation from the Controller as to whether or not processing concerning their personal data is in progress. If so, the Data Subject has the right to request specific information such as, by way of example, the purposes of processing, the categories of data processed, the third parties to whom such data has been or will be disclosed, and the retention period;
Pursuant to article 16 GDPR, to obtain rectification of processed personal data that proves inaccurate and completion of incomplete data;
Pursuant to article 17 GDPR, to obtain, without undue delay, the erasure of personal data held by the Controller, where one of the conditions of article 17 applies, the so-called “right to be forgotten”. This is only possible where a specific reason exists, such as the data no longer being necessary for the purposes it was collected for, unlawful processing, or the need for erasure to comply with a legal obligation.
Pursuant to article 18 GDPR, to request restriction of processing in the cases provided for, namely: where the data processed is inaccurate, where processing is unlawful and the Data Subject wishes it to continue in restricted form, where the Data Subject needs the data for legal claims, or while an objection to processing is pending;
Pursuant to article 19 GDPR, the Controller communicates to each recipient to whom the personal data has been disclosed any rectification, erasure or restriction of processing carried out under article 16, article 17(1) and article 18, unless this proves impossible or involves disproportionate effort.
Pursuant to article 20 GDPR, to obtain a copy of the data concerning them, in a structured, commonly used and machine-readable format as provided for;
Pursuant to article 21 GDPR, to object at any time to the processing of personal data concerning them;
Pursuant to article 34 GDPR, in the event of a personal data breach (following theft of archives, cyber attacks, accidental events and so on) likely to result in a high risk to the rights and freedoms of the Data Subject, such as indiscriminate disclosure of the data to third parties, the Controller will notify the Data Subject without undue delay, as required.

Requests by the Data Subject to the Controller must be made in writing to the email address indicated in article 8 of this notice. The Controller will fulfil the Data Subject’s requests without delay.

Article 7 - Right to lodge a complaint with the supervisory authority

The Data Subject in any case has the right, where they consider that the processing of their data by the Controller infringes the rights set out in the Regulation, to lodge a complaint with the competent supervisory authority, pursuant to Article 77 GDPR, namely the Italian Data Protection Authority (Garante per la protezione dei dati personali).

Article 8 - Communications to the Data Controller

For further information or to exercise the rights set out in this notice, the Data Controller can be contacted at the email address cda@jelu.it. Requests are handled free of charge and dealt with by the Controller as quickly as possible, and in any case within one month of receipt.

Article 9 - Changes to this notice

The Data Controller reserves the right to modify or update, in whole or in part, the content of this notice, including following changes in the applicable European or national legislation. In the event of changes, updated consent will be requested again at the Data Subject’s next visit.

Article 10 - Definitions and legal references

In order to ensure a correct and informed understanding of this privacy notice, it is appropriate to set out the correct interpretation of the terms listed below.

Please also note that for any further definitions not specified here, reference should be made to the relevant legislation, namely the General Data Protection Regulation and Italian Legislative Decrees no. 196 of 30 June 2003 and no. 101 of 10 August 2018.

Personal data, pursuant to art. 4(1) GDPR, means “any information relating to an identified or identifiable natural person (”data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Processing, pursuant to art. 4(2) GDPR, means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.

Profiling, pursuant to art. 4(4) GDPR, may be defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”.

Data controller, pursuant to art. 4(7) GDPR, may be defined as “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law”.

Article 11 - Referral

For anything not set out in this notice, reference is made to the provisions of the General Data Protection Regulation, of Italian Legislative Decrees no. 196 of 30 June 2003 and no. 101 of 10 August 2018, and of any further applicable legislation.

Article 1 - Purpose

The purpose of this document is to give users of the “Jelu.it” website a clear and detailed explanation of how cookies work, and to set out transparently how they are managed and the purposes for which they are used on the platform.

Article 2 - Definition of cookies

Cookies are small text strings that the websites visited by the user send to the computer and to any device used to access the Internet (such as smartphones and tablets), where they are stored and then sent back to those same sites on the user’s next visit.

Cookies may be stored permanently and have a variable duration (so-called persistent cookies), but they may also disappear when the browser is closed or have a limited duration (so-called session cookies). Likewise, cookies may be installed by the site being visited (so-called first-party cookies) or by other websites (so-called third-party cookies), and they may be used for different purposes, such as carrying out computer authentication, monitoring sessions and storing information about the activities of users who access a given site.

Article 3 - Types of cookies used

This site does not install any cookies, whether technical, preference-related or profiling cookies. The site consists of static pages and does not use the user’s browser to store information: it uses neither cookies nor equivalent technologies such as localStorage or sessionStorage.

The data processed during browsing are therefore:

the connection data that any web server records in its technical logs in order to allow and secure browsing (IP address, address of the requested resource, date and time of the request, browser and operating system type). These data are processed by the hosting provider in accordance with its own notice and are not used by the Data Controller to identify users;
the data voluntarily provided by the data subject, that is the contact details of anyone who optionally, explicitly and voluntarily sends electronic communications to the Data Controller, such as filling in the contact form on the site or messages sent to the social media pages run by the Data Controller.

Article 4 - Third-party cookies

This site does not install third-party cookies. There are no statistical analysis, tracking or advertising tools.

For some parts of the site to work correctly, however, the user’s browser connects to two external services. Neither of them installs cookies, but the connection necessarily entails communicating the user’s IP address to the service provider:

Google Fonts (fonts.googleapis.com, fonts.gstatic.com): supplies the typeface used by the site. The connection is made when each page loads;
Web3Forms (api.web3forms.com): receives the contact form data and forwards it to the Data Controller. The connection is made only when the user voluntarily submits the form.

For further information, please consult the respective privacy notices, available on the two providers’ websites.

As no cookies are installed, as stated in Articles 3 and 4, there are no cookies whose duration needs to be indicated.

Since the site installs no cookies, either its own or third-party ones, and carries out no profiling activity, no consent banner is shown: there are no optional cookies for which the data subject would need to give or withhold consent.

Should the Data Controller decide in future to introduce tools that involve installing non-technical cookies, for example for statistical analysis or profiling, this Cookie Policy will be updated and the related banner for collecting prior consent will be introduced.

Article 7 - Managing cookies

Users can decide whether or not to allow the use of cookies through their web browser settings. Most web browsers allow you to: check which cookies are installed on your device and delete them individually, block third-party cookies, block cookies from specific sites, block all cookies and/or delete all cookies when the browser is closed.

To manage cookies, users can refer to the specific documentation for their browser.

The Data Controller reserves the right to amend or simply update the content of this Cookie Policy, in part or in full, including as a result of changes to the applicable legislation at European or national level, or following changes to the tools used by the site. Data subjects are therefore invited to consult this page periodically.

Article 9 - User rights

In accordance with the General Data Protection Regulation (GDPR) and other applicable legislation, users have the right to exercise a number of rights regarding their personal data. These rights include:

Right of access: the user has the right to request confirmation as to whether or not personal data concerning them is being processed and, if so, to obtain a copy of that data and detailed information on how it is processed;
Right to rectification: the user has the right to request the correction of any inaccurate or incomplete personal data;
Right to erasure (right to be forgotten): the user may request the erasure of their personal data where the data are no longer necessary for the purposes for which they were collected, where the user withdraws the consent on which the processing is based, where the user objects to the processing and there are no overriding legitimate grounds to continue, or where the personal data have been unlawfully processed;
Right to restriction of processing: the user may request a restriction of the processing of their personal data in certain circumstances, for example where they contest the accuracy of the data or object to its processing;
Right to data portability: where technically feasible, the user has the right to receive the personal data they have provided in a structured, commonly used and machine-readable format, and to transmit it to another data controller;
Right to object: the user has the right to object at any time to the processing of their personal data, where that processing is based on a legitimate interest of the controller or is for direct marketing purposes;
Right to withdraw consent: where the processing of personal data is based on the user’s consent, the user has the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
Right to lodge a complaint with the supervisory authority: where the user believes that the processing of their personal data infringes applicable law, they have the right to lodge a complaint with the competent data protection supervisory authority.

Article 10 - Contact information

Pursuant to art. 13 of EU Regulation 2016/679, the General Data Protection Regulation (hereinafter GDPR), please be informed that JELU Consulting, tax code 97910400585, VAT no. 14145441003, with registered office in Rome, will process, as Data Controller, the personal data of the persons to whom this Cookie Policy is addressed (hereinafter also referred to as “data subjects”) for the purposes and in the ways set out below.

This data is collected for the purposes set out in the Privacy Notice and in this Cookie Policy.

The Data Controller can be contacted at the email address cda@jelu.it.