NEWU S.r.l., (hereinafter also the "Company") in its capacity as Data Controller, wishes to provide the
following specific information relating to the management methods of this site with reference to the
processing of the personal data of users who consult it. It is also an information provided pursuant to art.
13 of EU Regulation 2016/679 "GDPR" (hereinafter the "Privacy Legislation"), in consideration of the
"Guidelines 5/2020 on consent pursuant to Regulation (EU) 2016/679".

DATA CONTROLLER
NEWU S.r.l. is the Data Controller of the data related to the use of the site, with registered office in Via
Aventina 35, 00153, Rome; VAT number 15252181001; email: info@newu.it.

 

TYPE OF DATA PROCESSED
The types of data and information collected and processed by the Company are:
• browsing data (collected automatically);
• data provided by the user voluntarily;
• data collected through the use of cookies.

BROWSING DATA
The computer systems and software procedures used to operate the site acquire, during their normal
operation, some personal data whose transmission is implicit in the use of Internet communication
protocols.
This information is not collected to be associated with identified data subjects, but by its very nature could,
through processing and association with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of the computers used by users who connect
to the website, and other parameters relating to the user's operating system and IT environment. These
data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site
and to check its correct functioning and are kept for the period strictly necessary for statistical analysis. The
data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.

DATA PROVIDED VOLUNTARILY BY THE USER
The optional, explicit and voluntary sending of personal data by the user, necessary for the provision of the
requested service.
If you decide to send a message to the e-mail addresses provided, we inform you that this action
constitutes unequivocal behavior by which you consent to the processing of your data and in particular
your e-mail address as well as any other personal data contained in the text message, for the time
necessary to handle your request.
Regarding your consent to the installation of cookies for which this is required, please read the Cookie
Policy of our website.

PURPOSE OF THE PROCESSING
Personal data will be processed for the following purposes:
1) purposes related to the provision of the requested services (e.g. contacts);
2) defensive purposes in the event of abuse in the use of the site or attempts at fraud;

3) to ensure correct navigation within the site;
4) installation of cookies for which consent is required.

LEGAL BASIS OF THE PROCESSING
The Data Controller processes your data:

- purpose 1): the data subject has given consent to the processing of his/her personal data
for one or more specific purposes, by means of conduct that clearly indicates in this context
that the data subject has accepted the proposed processing (art. 6, par. 1, letter a, GDPR
and Recital 32 GDPR);
- purpose 2): legitimate interest of the Data Controller to defend itself against abuse or fraud
in the use of the site (Article 6, paragraph 1, letter f, GDPR);
- purpose 3): interest of the Data Controller in ensuring that the site functions correctly
(Article 122, paragraph 1, Legislative Decree 196/2003).
- purpose 4): the data subject has given consent to the processing of his or her personal data
for one or more specific purposes (art. 6, par. 1, letter a, GDPR).

In relation to purpose 2), we inform you that the Data Controller, with a view to balancing its own interests
and those of the data subjects – having regard to Recital 49 of the GDPR – considered that the interests or
rights and freedoms of the data subjects did not prevail.

NATURE OF DATA PROVISION
Apart from what is specified for browsing data, the user is free to provide their own personal data.
However, failure to provide them may make it impossible to obtain what has been requested.

METHODS OF PROCESSING
Personal data are processed, including with the aid of automated tools, for the time strictly necessary to
achieve the purposes for which they were collected. Specific security measures are observed to prevent the
loss of data, illicit or incorrect use and unauthorized access. The Company uses hosting providers who
guarantee the highest security standards, taking into account the type of personal data processed.

EXTRA EEA TRANSFERS
The Data are processed at the Data Controller's operational headquarters and in any other place where the
parties involved in the processing are located. The data are not transferred to countries outside the EEA.

PERSONS AUTHORISED TO PROCESS
The data collected may be transferred or communicated to other companies for activities strictly connected
and instrumental to the operation of the service, such as the management of the computer system. The
personal data provided by users who submit requests for information material (brochures, information
material, etc.) are used for the sole purpose of performing the service or performance requested and are
communicated to third parties only if this is necessary for this purpose (companies that provide enveloping,
labelling, shipping services). Outside of these cases, personal data will not be communicated, nor granted
to anyone, unless contractually provided for or authorized by the subjects. In this sense, personal data may
be transmitted to third parties, but only and exclusively in the event that: a) there is explicit consent to
share the data with third parties; b) there is a need to share information with third parties in order to
provide the requested service; c) this is necessary to comply with requests from the Judicial Authority or
Public Security. No data deriving from the web service is disseminated.

USE OF COOKIES

Cookies are small text files, containing a certain amount of information, exchanged between a website and
the user's terminal (usually the browser). They are mainly used for the purpose of making websites work
and operate more efficiently, as well as in order to provide information to the owners of the site itself.
Cookies can be both session and persistent. Session cookies remain stored on the device for a short period
of time and are deleted as soon as the user closes the browser. Their use is strictly limited to the
transmission of session identifiers (consisting of random numbers generated by the server) necessary to
allow safe and efficient exploration of the site. Persistent cookies, on the other hand, remain stored in the
user's terminal until a predetermined expiry date. These, not being deleted directly when the browser is
closed, allow us to remember the choices made by the user on their site as well as to collect information
about the pages of the site visited, the frequency with which the site is visited and to identify the
navigation track of users, in order to improve the experience on the site. Finally, session or persistent
cookies can be first-party or third-party cookies depending on whether the subject who installs the cookies
on the user's terminal is the same manager of the site the user is visiting (we will then speak of first-party
cookies) or of a different subject (we will then speak of third-party cookies).
 
TYPES OF COOKIES
Cookies, depending on the purposes pursued, can be qualified as:
 Technical cookies: these are those cookies that allow you to browse and/or provide a service
requested by the user (for example, cookies that automatically recognize the language the user
uses). These cookies are necessary for the operation of the site and cannot be turned off in our
systems.
 Analytics cookies: these are those cookies used by website managers to collect aggregate
information of a statistical nature (e.g. number of visitors to the website). In turn, analytical cookies
can be first-party analytical cookies, installed directly on the site you are visiting, and third-party
analytical cookies, made available by third parties.
 Profiling cookies: these are those cookies that control the user's browsing, tracking a user's
behavior and the preferences expressed in order to send advertising messages in line with their
profile.  If you do not accept these cookies, you will not be sent targeted advertising.
 
CONSENT
When not required
According to the current legislation, for technical, session and analysis cookies that do not do profiling (as
they are necessary to provide the requested services) the user's consent is not required. These include:
i. Analytics cookies, if used directly by the site manager to collect information, in aggregate form, on
the number of users and how they visit the site;
ii. navigation or session cookies (to authenticate);
iii. functionality cookies that allow the user to browse according to a series of selected criteria (e.g.
language, products selected for purchase) in order to improve the service provided to the user
When it is required
For all other types of cookies, consent can be expressed through:
ii. the banner displayed when you first access this site;
iii. configuring your browser;
iv. from your settings when using third-party services.
*Failure to consent may prevent you from using or viewing the full functionality of the site. The options you
have made can be changed at any time. Consent, in particular, can be revoked, without any burden and
prejudice to the lawfulness of the processing carried out until its revocation.​

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COOKIES USED BY OUR SITE
Necessary cookies help make the website usable by enabling basic functionalities such as page navigation
and access to secure areas of the site. The website is not able to function properly without these cookies.
The site also uses cookies for which the consent of the interested party is required.

TECHNICAL OR ANALYTICAL COOKIES FOR WHICH CONSENT IS NOT REQUIRED.
Google Analytics is a statistical service. IP addresses are used at the time of collection and then deleted
before the data is recorded in any data center or server.
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The information on the use of cookies by Google is available at:
http://www.google.com/intl/it/policies/technologies/cookies/
In rare cases, there may be cookies, used for the purposes indicated in the Privacy Policy of this site and for
which consent is not required, which will be stored for the time strictly necessary for their use. The relevant
information is available at the following links:

- https://support.google.com/analytics/answer/3450482?hl=it&utm_id=ad
- http://www.google.com/intl/it/policies/technologies/cookies/

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OTHER TECHNOLOGIES (e.g. Plugins, Widgets, Local Storage, etc.)
Websites may also involve interaction with social networks and external platforms through the use of
particular technologies, created specifically for these purposes.
Some of the most common ways of interacting are based on the use of:
Plugin: it is a program that interacts with another program, so as to be able to expand or extend the
original functionality of the first. The most used plugins are those of social networks, which allow – through
a click – to follow a page or a social profile, or to underline the liking of a specific web content and/or to
share it on one's social profile, etc.;
Widget: it is a graphic component of the user interface of a program, used to make the interaction between
the user and the program itself more immediate and easier. The most commonly used widgets are those of
social networks, which allow the user to quickly open the chosen social network in a separate browser
window.  
All these services allow you to interact with social networks, or in any case with external platforms, directly
from the pages of a site. Any interaction and the resulting information that may be acquired by the site is
subject to the privacy settings of the third party that created these technologies.

– Google Maps widget – info: https://support.google.com/maps/answer/10400210?hl=it 

– LinkedIn widget – info: https://it.linkedin.com/legal/privacy-policy 

– Youtube Widget – info: https://www.youtube.com/intl/ALL_it/howyoutubeworks/user-settings/privacy/

– Spotify Widget – info: https://www.spotify.com/it/safetyandprivacy/personal-data-collected 

COOKIE MANAGEMENT
Browsers normally allow you to control most cookies through the browser settings. Please note, however,
that the total or partial disabling of so-called cookies. may compromise the use of the site's features.
In any case, if the user does not wish to receive any type of cookie on their computer either from this site
or from others, they can increase the level of privacy protection by changing the security settings of their
browser:

Mozilla Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie 

Google Chrome: https://support.google.com/chrome/answer/95647?hl=it 

Internet Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies 

Safari: https://support.apple.com/kb/PH17191?viewlocale=it_IT&locale=it_IT  

Safari on your iPhone, iPad, or iPod touch: https://support.apple.com/it-it/HT201265 

RIGHTS OF THE DATA SUBJECTS
The user has the right to exercise at any time the rights referred to in articles 12 et seq. of EU Regulation
2016/679, namely:
1. access to personal data;
2. to obtain the rectification or erasure of the same or the limitation of the processing of personal
data concerning him/her;
3. to object to the processing;
4. right to data portability;
5. Right to withdraw consent.
To exercise the aforementioned rights, make a report or receive information on the methods of processing
personal data, requests can be made by writing to the Data Controller at the addresses indicated in this
Privacy Policy.
We remind you that you also have the right to lodge a complaint with the supervisory authority (Privacy
Guarantor).

LINKS TO OTHER WEBSITES
This site may contain links or references for access to other sites. Please note that the Data Controller does
not control the cookies or other tracking technologies of these websites, to which this Policy does not
apply.

MORE INFORMATION ABOUT THE TREATMENT
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the
Data Controller using the contact details.

Changes to this Privacy Policy
The Data Controller periodically checks its privacy and security policy and, if necessary, revises it in relation
to changes in the law, organisation or dictated by technological evolution. In the event of changes to the
policies, the new version will be published on this page of the website.
If the changes concern processing whose legal basis is consent, the Data Controller will collect the User's
consent, if necessary.