GhiniAssociati Privacy Policy

Last review: 31 Maggio 2018

GhiniAssociati (“GhiniAssociati”, “we”, “us” and “our”) is committed to respecting and protecting your privacy. We have prepared this Privacy Policy to describe how we collect, use and share personal information (as defined below) that we collect from users of our websites, located on and all subdomains thereof (including but not limited to, our mobile applications (“Applications”), our widgets (“Site”) and online services (“Services”).

  1. Requests; How to contact GhiniAssociati. If you have any questions or concerns about our privacy policy or our data collection and processing practices, or if you wish to report any security breaches, please contact us at the following address or number:

    Via Zago 2/2, 40128
    Bologna, Italy
    +39 051362100
  2. For the purposes of data protection legislation, the data controller of your personal data is GhiniAssociati, Via Zago 2/2, 40128, Bologna, Italy. Our data protection officer is Massimiliano Ghini, GhiniAssociati, Via Zago 2/2, 40128, Bologna, Italy.
  3. Complaints. We are committed to resolving any complaints about our collection or the use of your personal data. If you want to make a complaint about this Privacy Policy or our practices in relation to your personal data, please contact us at: Via Zago 2/2, 40128, Bologna, Italy or via We will respond to your complaint as soon as possible and, in any case, within 60 days. We hope to resolve any complaints brought to our attention; however, if it is perceived that the complaint has not been adequately resolved, it reserves the right to contact the local data protection supervisory authority.
  4. Note about children. This policy applies to users of the site and services who are 16 years or older, as indicated in our terms of use. We do not knowingly collect personal information from visitors who are under the age of 16. If a child submits personal information to us without specific parental consent and we learn that the personal information is a child’s information, we will try to delete the information as soon as possible. If you believe that we may have some personal information of a child under 16, please contact us at
  5. Note to users outside the United States about data transfer. Your data, including any personal information we collect from you, may be transferred, stored to and processed by us and our affiliates and other third parties outside the country where you reside, including places where the data, regulations and protection and privacy laws may not offer the same level of protection. We will take all steps reasonably necessary to ensure that data, including personal information, is treated securely and in accordance with this policy.
  6. Types of data we collect. We collect information of various kinds, including personal information. “Personal information” (or “personal data”, as defined in the European Data Protection Directive 95/46 / EC / General Data Protection Regulation) is data that allows someone to identify or contact you, for example, name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with any of the above data. “Anonymous”, data that does not refer to an identified or identifiable natural person, or personal information made anonymous in such a way that the person concerned is no longer or is no longer identifiable. Anonymous data, by itself, does not allow the identification of individuals. We collect personal data and anonymous data as described below.
  7. Why do we need your personal data? We will process personal data in accordance with data protection and privacy laws. We need some personal information in order to provide access to the Site and Services. If you have created a profile / registration with us, you have been asked to indicate your agreement to provide such data in order to access our services, purchase our products or view our content. This consent provides us with the legal basis required by law to carry out the data processing. You retain the right to withdraw this consent at any time. If you do not agree to our use of your personal information in line with this policy, please do not use the Site or the Services.

(a) Information you provide to us.
• We collect your first and last name, e-mail address and password when you create an account to access our network (“Account”). You are also asked to tell us where they are based. You can also provide additional contact information, such as the postal address, job title and organization name.
• We collect information, including personal data, from any behavioral assessments we provide.
• If you use our services on your mobile device, including through our applications, we may collect your phone number and device identification number (ID).
• Our mobile homepage allows you to store preferences such as your location, security search settings, and favorite widgets. We can associate these choices with your ID or mobile device, and you can change these preferences at any time on the mobile home page.
• When you connect to our Services through a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and / or functionality.
• Some services may require our phone number collection. We may associate that phone number for mobile device identification information.
• When you order products or services on our online store, we will collect all the information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.
• We store information about you, such as files and messages that you store using your account.
• If you provide us with feedback or contact us by email, we will collect your name and email address, as well as any other content included in the email, in order to send a response. This information may be shared with third parties who allow them to process and fulfill your purchases. When sending credit card numbers, industry standard data encryption technology is used.
• When you post content (text, image, photo, message, comment or any other type of content other than your e-mail address) on our site, the information contained will be stored on our servers and other users will be able to see it, along with your profile photo and any other information you choose to make public on your public profile (“Profile”). The information provided in your profile will be visible to others, including anonymous visitors to the site.
• When you post messages on the message boards of our site, the information contained in your submission will be stored on our servers and other users will be able to see it.
• When you participate in one of our surveys, we may collect additional profile information.
• We also collect other types of personal information that are voluntarily provided to us, such as the operating system and version, product registration number, and other information required if you contact us by email regarding support for services.
• If you enter a sweepstakes or giveaway on our site, we may ask for your email address and / or home number (for notification of whether you win or not). We can also ask for your name and surname, and, sometimes, the post office address to verify your identity. In some situations you may require additional information as part of the entry process, such as a choice of award selection. These sweepstakes and contests are voluntary. We recommend that you read the rules of each prize draw and contest in which you participate.

(b) Information provided through Social Networking Sites (“SNS”).
The Services allow users to access Facebook to interact with friends and to share news on Facebook through the wall and friends. If you are already connected to the Services and to Facebook, or another SNS, when you click on “Connect with Facebook”, or a similar connection on another SNS, you will be prompted to merge the profiles. If you are already logged into the Services, but have not logged into Facebook or another SNS that we support, when you click “Connect with Facebook”, or a similar connection on another SNS, you will be prompted to enter the SNS or “Sign Up” credentials on the SNS. By continuing, you allow the Services to access your information and agree that Facebook, or other SNS terms, make use of your Services. Conversely, if you are not currently registered as a user of the Services, and click “Sign in” using Facebook or another SNS we support, you are first asked to enter your Facebook or SNS
credentials and then have the possibility to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an account on the site and show our relevant content from your Facebook or SNS friends. Once registered on the Site and connected with Facebook or another SNS, you will be able to automatically send the recent activity back to Facebook or the other SNS. Any information we collect from your Facebook or other SNS account may depend on the privacy settings you have with that SNS. For more information please contact the data privacy practices of the SNS. There is the possibility to deactivate Facebook Connect at any time.

(c) Google ID.
It is allowed to use Google ID to set up an account. If you wish to use the Google ID, data is taken from the Google website to access your account and this information is then shared with us for the sole purpose of creating the account.

(d) Information Collected Through Technology.
• Information collected by our servers. To make our site and services more useful to you, our servers (which may be hosted by a third party service provider) may collect information about you, including your browser type, operating system, Internet Protocol (“IP ”) (A number that is automatically assigned to your computer when using the Internet, which may vary from session to session), domain name, date / time of your visit.
• Log files. As with most websites, we collect some information automatically and store it in log files. This information includes IP addresses, browser type, Internet Service Provider (“ISP”), referring / exit pages, operating system, date / time, and clickstream data. This information is used to analyze trends, administer the site, track users and movements on the site, collect demographic data about our user base as a whole, and tailor our services to the needs of our users. For example, some of the information may be collected so that when you visit the Site or Services again, they will recognize you and the information may then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically collected data to personal information.
• Pixel Tag. We also use “Pixel Tags” (also referred to as Gifs, Web beacons or Web bugs). Pixel tags are small graphic images with a unique identifier, similar in function to cookies, which are used to track the movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, pixel tags are embedded in web pages invisibly. Pixel Tag also allows you to send emails in a format users can read, and tell us if emails have been opened to ensure we are only sending messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information collected by pixel tags to the personal information of our users.
• Do Not Track. At the moment we are not responsible for “do not track” signals from browsers.
• Mobile services. We may also collect non-personal information from your mobile device if you have downloaded our applications. This data is generally used for the purpose of offering the most relevant information to you. Examples of information that can be collected and used include your geographic location and the type of device used. In addition, if our applications crash on your mobile device, we will receive information about your device, software version and supporting device, which will allow us to identify and fix bugs and otherwise improve the performance of our applications. This information is sent to us as aggregate information, it is not attributable to the individual and cannot be used to identify him.
• Cookies. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. Our site and our services may use some types of cookies.

(e) Information collected by third party companies.
We may receive personal information and / or anonymous data about you from companies that provide our services through a website or from companies that offer their products and / or services on our site, co-branded or privately-labeled. These third-party companies may provide personal information. For example, we use Eventbrite for all of our events. Eventbrite shares the personal information they collect with us, which is in addition to the personal information in our database.

  1. Use of personal information
    (a) In general.
    Generally, personal information sent to us is used both to respond to requests and to help us serve you better. We also use personal data to:
    • facilitate the creation and protection of your account on our network;
    • identify you as a user in our system;
    • provide better administration of our Site and Services;
    • provide the requested services;
    • improve the quality of the experience when interacting with our Site and Services;
    • send a welcome e-mail to verify ownership of the e-mail address provided when your account is created;
    • send administrative email notifications, such as safety or service and maintenance alerts;
    • respond to your requests for information relating to job opportunities or otherwise;
    • send newsletters, surveys, offers and other promotional material relating to our services and for other GhiniAssociati marketing purposes.

    (b) User testimonials and feedback.
    We often receive, and from time to time publish, testimonials and comments from users who have had positive experiences with our services. When we publish this content, we can identify our users by first and last name, job title, company, country, or other information provided for the testimonial. We obtain the user’s consent before publication. We may post user feedback on the site from time to time. We will share your comments with your name and surname initial only. If we choose to post your first and last name with your feedback, we will obtain your consent prior to posting. If you make any comments on a blog or forum associated with the site, you should be aware that any personal information you submit to us may be read, collected or used by other users of these forums, and may be used to send unsolicited messages. We are not responsible for any personal information you choose to post in these blogs and forums.

    (c) Creation of anonymous data.
    We may create anonymous data and personal data records by excluding personal information (such as name) that makes the data traceable to you. We use anonymous data to gain a better understanding of how our services are working, to conduct research on global trends and to advance understanding of emotions, emotional intelligence, and positive change. We also use anonymous data to analyze usage requests and patterns so that we can improve the content of our services and improve site navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.
  2. Disclosure of Personal Information. We disclose personal information as described below and as described in other paragraphs of this Privacy Policy.

    (a) Users.
    We will share personal information with other users for the sole purpose of providing the services. Some users – such as Certified Assessors – must have certain information, such as name, email address, and assessment information, in order to provide the services to you.
    (b) Third Party Service Providers.
    We may share personal information with third party service providers to: offer the services we offer you through our site; third party assessment tools; carry out quality tests; facilitate the creation of accounts; provide technical support; provide other services to the Company. These third party service providers are required not to use personal data other than to provide the services requested by the company.
    (c) Affiliates.
    We may share some or all of your personal information with our parent company, affiliates, joint ventures, or other companies under common control (“Affiliates”), in which case we will require you to honor this Privacy Policy.
    (d) Corporate restructuring.
    We may share some or all of your personal information in the event of or during merger, financing, acquisition or dissolution negotiations, proceedings involving the sale, transfer, divestiture, or disclosure of all or any portion of our business or goods. In the event of insolvency, bankruptcy or receivership, personal information can be transferred as an asset of the business. If another company acquires our company, our business, or our assets, the company that will come into possession of the personal information collected by us will assume the rights and obligations regarding personal information as described in this Privacy Policy.
    (e) Social Networking Sites.
    Some of our applications – or services – may allow you to send content to SNS (for example, Facebook or Twitter). If you choose to do this, we will provide information to that SNS in compliance with your choices. The User acknowledges and agrees that he is solely responsible for the use of such websites and that it is his responsibility to review the terms of use and the privacy policy of the third party provider of this SNS. We will not be responsible for: (i) the availability or accuracy of such SNS; (ii) the content, products or services, or the availability of such SNS; or (iii) the use of this SNS.
    (f) Disclosure to third party companies.
    We may enter into agreements with companies that provide our services through a website or companies that offer their products and / or services on our website, co-branded or privately- labeled (“Third Party Company”). A third party company may wish to access the personal information we collect from its customers. As a result, we may disclose your personal information to third party companies; however, we do not disclose personal information to third party companies for their direct marketing purposes, unless the “opt-in” option has been chosen, following the instructions we provide to allow such disclosure. If you have opted in to receive email communications from a third party company and then wish to stop receiving these emails, please contact the third party company directly to update your preferences. The privacy policies of these third-party companies may require the use and disclosure of the personal information we collect and disclose to such third-party companies. Because we do not control the privacy practices of third-party companies, we recommend that you read and understand their privacy policies.
    (g) Other Disclosures.
    Regardless of any choices made regarding personal information (as described below), we may disclose personal information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on GhiniAssociati; (c) to protect or defend the rights or property of six or more second users of the Site or the Services; and / or (d) to study or help prevent any violation or potential violation of the law, this Privacy Policy, or the Terms of use websites.
  1. Third parties. Our site may contain links to third party websites. When you click on a link to any other website or location, you leave our site and go to another site, and another person may collect personal information or anonymous data from you. We have no control over, do not review, and cannot be held responsible for, these external sites or their content. As such terms of this Privacy Policy do not apply to these external sites or content. We invite you to read the privacy policies of each website you visit. Links to third party websites or locations are for your convenience and do not signify our endorsement of those third parties or their products, content or websites.
  2. Your rights and choices. There are several options available regarding the use of information on our service:

(a) Opt-out.
You can contact us at any time to opt-out of: direct marketing communications, including newsletters and e-mails; or the transfer of personal information outside your country. Please note that the use of some of the Site or Services may be ineffective upon opt-out.
(b) Access.
You can access the data in our possession at any time through your profile / account or by contacting us directly.
(c) Amendment.
You can also contact us, using the contact information above in paragraph 1, to update or correct any inaccuracies in your personal data.
(d) Transfer.
Your data is portable – meaning you have the flexibility to move your data to other service providers as you wish.
(e) Elimination.
In certain situations, for example when the data we hold is no longer relevant or incorrect, you can request that we delete the data.
(f) Applications; De-Linking SNS.

It can stop all line of information from applications by uninstalling them, either through standard uninstall processes that may be available as part of your mobile device or via the mobile or network application marketplace. You can also de-link the SNS account in the “preferences” section in the account settings if you want to de-link your account from the SNS account. You may also manage the sharing of certain personal information with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the SNS privacy settings to determine how we can adjust our authorizons and manage interactivity between the Services and your social media account or mobile device.
If you wish to exercise any of these rights, please do not hesitate to contact us using the contact information above. In the request, please specify: (i) which personal information is concerned; and (ii) which of the above rights you wish to apply. For your protection, we may only implement requests regarding personal information associated with the particular email address you used to submit your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably possible and, in any case, within one month of the request. Please note that we may need to keep certain data for data retention purposes and / or to complete any transactions that you initiated prior to requesting such modification or cancellation.

  1. Safety
    • for online payments, you can choose to use the payment services to follow on our sites; For more information on how payments are handled, or to understand the data security and privacy guaranteed such information, please refer to the links for each payment processor
    • GhiniAssociati is committed to protecting the security of your personal data. We use a variety of industry standard security technologies and procedures to help protect personal data from unauthorized access, use or disclosure. We also need to enter a password to access account information. Please do not disclose your account password to unauthorized persons. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Six Seconds uses all reasonable efforts to protect personal information, Six Seconds cannot guarantee absolute security.
  2. Reserve. We will retain your personal information as long as reasonably required in order to use the Site / Application (s) and / or to provide the services and / or until you close your account / cancel your subscription, unless a retention period is more required or permitted by law (for example for supervisory purposes).
  3. Changes. This Privacy Policy may be updated from time to time for any reason. We will post any changes or changes to our privacy policy at privacy/ and change the “Last Updated” given above. It is advisable to consult this Privacy Policy regularly for any changes.

    In the event of a conflict, the Italian version of this policy takes precedence.
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