PRIVACY POLICY

Information on the processing of personal data

This policy describes the processing of personal data of visitors and users (collectively, "Users") of the website of Big Rock S.r.l. (http://www.bigrock.it/: the "Site").
BIG ROCK S.r.l. may amend this policy to adapt it to future expansions or future changes to the Site or the services offered. In the event of substantial changes, BIG ROCK S.r.l. will publish a notice on the Site and/or send an e-mail notification to point out the changes and collect a possible request to exercise the rights recognized by the legislation on the protection of personal data.

1. Data controller

The data controller is Big Rock S.r.l. with registered office in Roncade (TV), via Sile 41, P.IVA 03483440230, in the person of its Legal Representative Riccardo Donadon ("BIG ROCK" or "DataController").

2. Data processed

Identifying, Contact, and Data Disclosed by Users

BIG ROCK provides Users with its contact details (such as, for example, address, e-mail, phone no., whatsapp and links to its social networks), as well as special forms to be filled out, in the sections of the Site "Contact Us" - "Contact Us" - "Services > Ask Us a Question", in order to get in touch with BIG ROCK and request information, download course brochures and/or proceed to book and purchase the services offered.
In this case, the personal data collected by the Website are the User's identification and contact data (including, first and last name, e-mail address and possible telephone number), and data voluntarily communicated by the User in the "message" section. BIG ROCK also collects and processes personal data voluntarily communicated by the User (including, for example, first and last name e-mail address and any other personal data contained in the request) when contacting BIG ROCK at the contact details indicated on the Website.
Additional personal data (including, for example, first name, last name, date and place of birth, social security number, residential address, e-mail, no. phone number, any additional information and additional requests) may be collected and processed by BIG ROCK in the case of pre-registration/pre-enrollment in one of the courses, masters or workshops offered by BIG ROCK.

We recommend that Users communicate only data that are up-to-date, relevant and not excessive for the specific purposes of processing.
Any unnecessary data will be immediately deleted or anonymized.

Navigation Data

Each time the Site is accessed, the systems automatically record and analyze access data (e.g. provider IP address, information about the browser used, pages visited, date, time and duration of each visit). The information is collected automatically by the Site and does not require any action on the part of the User.
The data collected is anonymous and aggregated data only, and therefore cannot lead to the identification of Users. The information collected simply allows for the detection and resolution of any technical problems.

3. Purpose of processing.

Personal data of Users of the Site ("Data") may be processed for the following purposes.

3.1. Responding to requests from Users

The Data will be processed in order to respond to requests that Users may send to the contact details and through the forms available on the Site, to contact the Owner and/or to proceed with pre-registration for a BIG ROCK course, master or workshop: for this purpose, it is necessary for Users to communicate their contact details as, without them, it will not be possible for BIG ROCK to respond to them.
The legal basis for this processing is the need to execute pre-contractual and contractual measures taken at the request of the User, and to comply with related legal obligations.

3.2. Download brochure and contact

In the event that the User wishes to download one or more brochures of the courses, masters and workshops offered by BIG ROCK, the Data will be processed, not only to provide the User with the requested brochure, but also to enable H-Farm to contact the User via whatsapp, telegram, email/newsletter, phone calls to the numbers and contact details indicated in the form "Download the brochure".
The legal basis of this processing is the express consent of the User, upon acceptance of the Terms and Conditions of BIG ROCK, by clicking on the "Submit" button.

3.3. Site operation, monitoring and troubleshooting

Browsing data will be used: (i) in order to monitor the proper functioning of the Site, (ii) in an anonymous and aggregate form, for statistical purposes related to understanding how the Site is used by Users, to improve the ease of access and increase its attractiveness, as well as (iii) to detect any technical problems as soon as possible.

The information is automatically collected by the Site and does not require any action on the part of the User.

Said processing finds its legal basis in the legitimate interest of the Data Controller in the improvement of its digital services, especially in relation to the use of the Site, and is compatible with the position of the data subjects since: (a) monitoring the functioning of the Site and statistical data related to its use does not involve direct identification; and (b) the interest of the Data Controller reasonably appears to be also of the Users, who will thus be able to enjoy an increasingly high-performing and optimized Site. For more information on the processing of browsing data through the use of cookies, please read Section 10 "Cookie Policy" below.

4. Methods of processing

The Data will be processed by manual and computerized means by staff and collaborators of BIG ROCK and/or companies expressly appointed as data processors, and to whom BIG ROCK has given detailed operating instructions with particular reference to the adoption of adequate technical and organizational security measures.
The complete list of Data processors is kept at BIG ROCK's head office and is available upon request, which may be forwarded to the contact details indicated in section 7 below, "Rights of the User and contacts of the Data Controller".

5. Recipients of the data

6. Retention period

The personal data collected and processed by BIG ROCK, for the purposes identified in point 3 above, may be kept in a form that allows the identification of the User for the period necessary to achieve the purposes of the processing and, in particular:
- for the processing referred to in point 3.1., i.e. to respond to requests from Users, for the period of 12 (twelve) months from the last contact made;
- for the processing referred to in point 3.2., i.e. to provide Users with the requested brochure and to contact them at the contact details indicated, for the period of 12 (twelve) months from the request to download the brochure or, in the case of previous contact, unless the User has revoked consent, for the period of 12 (twelve) months from the last contact made;
- for the processing referred to in point 3.3., i.e. for the operation, monitoring, assistance and technical improvement of the Site, for the period of [___ days] and are deleted immediately after their aggregation (except for any need to ascertain crimes by the competent Judicial Authority) or for the different period indicated in section 10 "Cookie Policy" below for each cookie used.

The Data may be retained for longer periods where necessary to comply with legal obligations, or for the protection of BIG ROCK's rights, until the expiry of the relevant limitation period.

7. User Rights and Contact Information of the Owner

The User may, at any time and to the extent that the rights are applicable:

(I) obtain confirmation of the existence or non-existence of personal data concerning him/her;
(II) request access to his/her personal data;
(III) request the rectification, erasure or restriction of the processing of personal data;
(IV) object to the processing, or revoke his/her consent to the processing, without prejudice to the lawfulness of the processing on the basis of the consent given before revocation;
(V) receive, in a structured, commonly used and machine-readable format, the personal data concerning him/her provided to BIG ROCK, as well as request that such data be transmitted to another data controller (right to personal data portability);
(VI) lodge a complaint with the Data Protection Authority, or appeal to the competent judicial authority.

Requests to exercise the above rights should be sent to one of the following addresses:

- via e-mail, to info@bigrock.it;
- via registered mail with return receipt, to BIG ROCK S.r.l, Roncade (TV), Via Boschi 12.

Requests relating to the recipients of the Data, as well as requests for clarification of this policy, may also be addressed to the same addresses.

8. Links to other websites

This information on the processing of personal data is provided exclusively in relation to the Data collected through the Site and with reference to the purposes identified in point 3., and not also for any other websites consulted and/or consultable through links and/or widgets (e.g. social networks): these additional websites will process the Data as autonomous controllers and in accordance with their respective information notices, the consultation of which by users is expressly recommended.

9. Responsibility for data protection

The Data Protection Officer (DPO) appointed by BIGROCK is LCA SERVIZI S.R.L., and can be reached at the following address: Via della Moscova, 18, 20121, Milan, email: info@lcalex.it, or at the PEC address: lcaservizi@pec.lcaservizi.it.

10. Cookie policy

Cookies are small text strings that sites visited by the user send to the user's own terminal browser, where they are stored and then transmitted back to the same sites on the next visit by the same user. In the course of browsing a site, the user may receive on his or her terminal "first-party" cookies, when they are managed directly by the owner and/or operator of the site, and also cookies that are sent from different sites or web servers (so-called "third-party" cookies); this happens because on the website visited there may be elements that reside on servers other than the one on which the website is located. In other words, they are those cookies that are set by a website other than the one you are currently visiting.

With reference to the purposes pursued, cookies can be technical, analytical and profiling cookies.
The Site uses the following cookies for the purposes set out below.

Technical cookies are 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 to provide a service explicitly requested by the User.

Technical cookies

Technical cookies on the Website can be divided into: navigation or session cookies, which ensure normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas). These cookies include functionality cookies, which allow to store the choices made by the user on the website (e.g. language), in order to improve the service rendered to the user.
Users' prior consent is not required for the installation of such cookies.

Analytical cookies

Analytical cookies are used to collect information, in aggregate form, about the number of users and how they visit the Site.

Profiling cookies

These cookies allow us to create an anonymous profile of users based on their browsing experience.

Nature of provision of data by Users

The User authorizes the use of cookies by continuing to browse the Site, after reading the banner. The provision of data is optional.

You can change your cookie preferences at any time through specific browser configurations, according to the specific procedures described below. Through the browser preferences, it is also possible to delete cookies installed in the past, including the cookie in which consent to the installation of cookies by the Site is possibly saved.

The User can express his or her consent to the Site's use of cookies. It is possible to accept all cookies, only some, or reject them all. In the event that the User decides to disable cookies (including technical cookies), he/she will not have access to many features that make this Site more efficient and some of our services will not function properly.

With regard to third-party cookies, the User may also exercise his/her right to object to their processing by informing himself/herself via the third party's privacy policy, via the opt-out link if explicitly provided in the aforementioned privacy policy or cookie policy, or by contacting the third party directly.

Options regarding the use of cookies

You can control cookies through the settings of the browser you use. Since each browser has slightly different functions, the User will need to check on the "help" menu of his or her browser to understand how to properly change the cookie settings.

The User can then change the browser settings so that cookies are deleted or not saved on his or her computer or mobile device without his or her explicit consent.

At the following links the User can better understand how to set his or her browser:

- Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: https://support.mozilla.com/en-US/kb/cookies-information-websites-store-on-your-computer#w_cookie-settings
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Safari: http://support.apple.com/kb/PH504