Dear User,
This page describes how the website is managed with reference to the processing of your personal data.
Pursuant to Articles 13 and 14 of European Regulation No. 679/2016 on the protection of personal data (hereinafter referred to as GDPR) and Law of the Republic of San Marino No. 171/2018, we hereby provide the following information in order to inform you, in a correct and transparent manner, about the data collected through our website and how it is used.
This notice also draws inspiration from Recommendation No. 2/2001, adopted on 17 May 2001 by the European data protection authorities gathered in the Working Group established under Article 29 of Directive No. 95/46/EC, which identified certain minimum requirements for the online collection of personal data, particularly regarding the methods, timing, and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purposes of the connection.
Data Acquisition
The personal data processed are freely provided by you and acquired by us during navigation of our website pienissimo.com, as well as through interaction with our services (e.g. applying for a job through the “Work with Us” section, contacting our agents via LiveChat, expressing interest in our courses and webinars, or downloading free materials available online).
Data Subject to Processing
The processing will involve the following information:
a) Browsing data:
When you visit our website, we send cookies or similar technologies to your device, allowing us to monitor your behavior. These cookies transmit data to our analytics tools. We are therefore able to track which marketing channel generated your visit (e.g. Google Ads, email, Meta Ads, TikTok Ads), which pages you visited, and other similar information.
We also use multi-device analysis tools (Google Signals, GA4, Microsoft Clarity), enabling us to identify if you visited our website multiple times with different devices. We receive information on how you use and interact with the site, as well as how long you stay.
The server collects basic information about your browser search at the time of your visit, such as date and time of the visit, IP address, basic HTTP header info (e.g. referrer URL, user agent), and previously searched URLs.
Some features on this site allow you to share personal data with third parties (such as Facebook, LinkedIn, etc.). These functions transmit data to unrelated third parties, which may use personal information according to their own privacy policies. We strongly recommend that you review those third-party privacy policies.
Further details on the use of cookies and similar tools can be found in our Cookie Policy available online.
b) Identification and contact data:
When you request information or assistance via online LiveChat or through one of our contact forms related to courses, webinars, or free material available online, you will be asked to provide some personal and contact details in order for us to respond to your requests.
If you register for one of our webinars or in-person courses, we may also request information regarding your venue, and if you apply for the Pienissimo Mastery program, we may ask whether you have attended other courses organized by our company.
When entering third-party data, you are fully responsible for providing such data, guaranteeing you have the right to share it, and releasing the Controller from any liability.
When you choose to receive updates and information about our products/services, we collect your email address and store a history of the communications we send you.
Processing Methods
Processing will be carried out, including but not limited to, with the aid of IT and/or automated tools, in ways that ensure the security, protection, and confidentiality of data, preventing and limiting risks of loss, alteration, theft, and guaranteeing timely recovery in case of data breach.
Processing may include: collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication, comparison or interconnection, restriction, erasure, and destruction of data.
Purpose of Processing
Your personal data will be processed:
Without your explicit consent for the following purposes:
a) To allow the technical and functional management of our website (including IT security), e.g. identifying parts of the site with low latency.
b) To process your requests for assistance via LiveChat, information via published contacts, or the various online forms, including requests for free material or course/webinar registration.
c) For soft-spamming: if you have already purchased a product or service from us, we may use your email address to send communications about similar products or services, without requiring further consent, provided you do not object.
With your explicit consent for the following purposes:
d) For direct commercial purposes: providing commercial and advertising information (including via remote communication techniques) about our products/services or initiatives.
e) For profiling: creating individual and/or aggregated profiles based on preferences and consumer choices, for market analysis, statistics, and personalized communications.
Legal Basis for Processing
Except for browsing data, essential for the website’s functioning, the processing of your personal data is based on:
a) The pursuit of the legitimate interest of the Controller.
b) The necessity to fulfill pre-contractual and contractual obligations (e.g. managing requests for information).
c) Consent freely given (for marketing and profiling).
Mandatory or Optional Nature of Data
Providing your data for purposes under points a), b), and c) above is mandatory; refusal would make it impossible to browse our website or process your requests.
Providing data for purposes d) and e) (marketing and profiling) is optional; refusal will not affect your relationship with our company.
Data Recipients
Personal data will be processed by the Controller, duly authorized and trained staff (per GDPR Art. 29 and RSM Law Art. 30), and by consultants acting as Data Processors carrying out technical or support tasks.
An updated list of Data Processors is available at our headquarters upon request.
Data will not be disclosed but may be communicated to regulatory authorities for compliance checks.
Data Transfer Outside the EU
Data will not be transferred to non-EU countries. However, if necessary for technical/organizational reasons, the Company may transfer data outside the EU in compliance with applicable laws and under GDPR Articles 44 et seq. and RSM Law Articles 46 et seq.
Data Retention
- Browsing data: processed only for statistical purposes and site functionality checks, then deleted after processing.
- Other personal data: processed as long as necessary to provide the requested service.
- Data for marketing: retained up to 2 years from consent (unless revoked earlier).
- Data for profiling: retained up to 1 year from consent (unless revoked earlier).
Data Subject Rights
At any time, under Articles 15–22 GDPR and San Marino Law No. 171/2018, you may exercise your rights:
- Right of access
- Right to rectification
- Right to erasure (“right to be forgotten”)
- Right to restriction of processing
- Right to data portability
- Right to object (including direct marketing and profiling)
- Right to withdraw consent at any time
- Right to lodge a complaint with the Data Protection Authority
Data Controller and EU Representative
To exercise your rights, you may contact the Data Controller:
PIENISSIMO S.r.l.
- Email: pienissimo@pec.it
- Address: Strada Rovereta No. 6 – 47891 Falciano, San Marino – RSM
or its EU Representative:
Dr. Nathaniel Casadei
- Email: pienissimo@novapoesis.it
- Address: Via Pomposa No. 43/I, 47924 Rimini (RN), Italy
Changes
In compliance with applicable regulations, the Controller reserves the right to amend this privacy notice at any time, ensuring adequate and equivalent data protection. Please check this page regularly for updates.
Data Controller: PIENISSIMO S.r.l.
Last Updated: 30.04.2024