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Gruppo Ginestra
Privacy Policy

The website "" (the "Website") is owned by La Ginestra srl, with registered office in Milan, Corso Indipendenza, 20 (hereafter, also "Ginestra" or the "Company").


Data Controller and Owner


La Ginestra srl

Email address of the owners:

For any explanation, information, exercise the rights listed in this statement, contact the owners at the following email:

Definitions and legal references

Personal Data (or Data)

It constitutes personal data any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

They are the information collected automatically through this Website (also from third party applications integrated into this Website), including: IP addresses or domain names of the computers used by the User that connects to this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (success, error, etc. .), the country of origin, the characteristics of the browser and of the operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page), and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the visited pages, to the parameters related to the operating system and the IT environment of the User.

Navigation Data

In general, users can visit the Website without providing their name or other personal information. However, some navigation data are collected through computer systems and software procedures used for the Website operation, which during their normal operation acquire some personal data whose transmission is necessary and implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested users, but, by their very nature, they could allow users to be identified, through processing and association with data held by third parties. This category of data includes, for example, the IP addresses or the domain names of the computers used by users who connect to the Website, etc. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and in order to check its correct functioning, and they are deleted immediately after their processing.


The individual who uses this Website that, unless otherwise specified, coincides with the Interested Party.

Interested Party

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)


The natural person, legal person, public administration or any other organization authorized by the Data Controller to process the Personal Data, in compliance with this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other organization which, individually or together with others, determines the purposes and means of the processing of personal data and the adopted tools, including the security measures related to the operation and to the use of this Website.

This Website (or this Application)

The hardware or software tool by which the Personal Data of the User is collected and processed.


The Service provided by this Website as defined in the relevant terms (if any) on this website/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document shall be extended to every current member state of the European Union and of the European Economic Area.


Small piece of data stored in the User's device.

Legal references

This privacy policy has been prepared on the basis of the current regulations on the processing of personal data, including the articles 13 and 14 of the Regulation (EU) 2016/679 c.d. GDPR.
Unless otherwise specified, this privacy policy relates solely to this Website.

Types of collected Data

Among the Personal Data collected by this Website, either independently or through third parties, there are: Cookies, Usage data, name, surname, email address, telephone number, address, fiscal code and VAT number, username and website.
Full details about each type of collected data are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Website.
Unless otherwise specified, all the Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service.
In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory, are encouraged to contact the owners.
Any use of Cookies - or other tracking tools - by this Website or by third party service providers used by this Website, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the further purposes described in this document and in the available Cookie Policy.
The User assumes responsibility for the third parties Personal Data, obtained, published or shared through this Website and warrants that he has the right to communicate or spread them, freeing the Data Controller from any liability to third parties.

Mode and place of processing the data

Method of treatment

The Data Controllers take the appropriate security measures in order to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controllers, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal carriers, hosting providers, IT companies, communication agencies) may have access to the Data, also appointed, if necessary, Data Processors by the Data Controllers. The updated list of the Data Processors can always be requested to the Data Controllers.
The owners take all appropriate security measures in order to prevent data loss, illicit or incorrect data use, and unauthorized data access.

The data will be kept for the time strictly necessary to achieve the purposes for which they were collected, and they will be deleted if their conservation is not otherwise justified. The owners arrange suitable automatic data cancellation mechanisms.

Legal basis of the processing

The Data Controllers process the User Personal Data in the event that one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or without another of the legal bases specified below, as long as the User does not object ("opt-out") to this treatment. However, this is not applicable if the processing of the Personal Data is regulated by the European legislation about the protection of the Personal Data:

• the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;

• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

• the processing is necessary for the performance of a public interest task or for the exercise of public authority vested in the Owner;

• the processing is necessary for the pursuit of the legitimate interest of the Owners or of third parties.

It is however always possible to request the Data Controllers to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for in a contract or necessary in order to conclude a contract.


The Data are processed at the Data Controllers operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owners.

The User's Personal Data may be transferred to a country other than that in which the User is located. In order to obtain further information about the processing place, the User can refer to the section concerning the detalis about the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controllers in order to protect the Data.
If one of the transfers described above takes place, the User may refer to the respective sections of this document or ask the Data Controllers information, by contacting them through the address reported at the top of this document.

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.


• The Personal Data collected for purposes related to the execution of a contract between the Data Controllers and the User will be retained until the contract fulfillment is completed.

• The Personal Data collected for purposes related to the legitimate interests of the Data Controllers will be retained until such interest is met. The User can obtain further information regarding the legitimate interest pursued by the Data Controllers in the relevant sections of this document or by contacting the

Data Controllers

When the processing is based on the consent of the User, the Data Controllers may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controllers may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or with an order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of the processing of collected data

The Data concerning the User is collected in order to allow the Owners to provide their Services, and apart from that specified for navigation data, the personal data provided by the users of the Website will be exclusively processed for the following purposes:

(a) allow the access and the registration to the Website and the use of the same by users, and in particular in order to:

• provide assistance and information services, where requested by the user, in relation to the Website (for example, replying to specific requests sent to the e-mail addresses indicated on the Website for information, suggestions, user assistance services, etc.);

• take advantage of all the services offered by the Website and of the advantages provided and/or which will be provided in the future for the registered users (for example, receive a periodic online newsletter, etc.);

The provision of personal data required for the aforementioned purposes is optional, however failure to provide them may result in the inability to access and to use the Website and to obtain what has been requested;

(b) carry out promotional activities and send advertising material related to the Company's initiatives, products and services, both by automated means without operator intervention (for example, newsletters, text messages, mms, e-mails, etc.) and traditional means (telephone, mail) and/or through reserved and private areas of the Website. The provision of the personal data necessary for these purposes is optional, and Your refusal to provide such data would make it impossible for the Company to carry out the activities described above. The consent concerns both the automated and the traditional methods of communication described above. You will always have the right to easily revoke, for free, the processing of your data for said purposes, in whole or in part, excluding, for example, automated methods of contact and expressing your desire to receive commercial and promotional communications exclusively through the traditional contact means;

(c) carry out profiling activities, carried out also through surveys, market research, statistics, reporting, detection of services quality. The provision of the personal data necessary for this purpose is optional, and your refusal to provide such data would make it impossible for the Company to carry out the activities described above.

In order to obtain further detailed information about the purposes of the processing and about the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

Details about the processing of Personal Data

The Personal Data is collected for the following purposes and using the following services:

Contacting the User

Contact form (This Web Site)

By filling out the contact form with his/her Data, the User consents to their use in order to reply to requests for information, for quotes, or of any other kind indicated by the form header.

Collected Personal Data: First Name, Last Name, Email address.

Interaction with social networks and external platforms

These services allow interaction with social networks or other external platforms directly from the pages of this Website.

The interaction and information obtained by this Website are always subject to the User's privacy settings for each social network.

If a service enabling interaction with social networks is installed, it may still collect traffic data about the pages where the service is installed, even when Users do not use it.

Protection from SPAM

This type of service analyzes the traffic of this Website, potentially containing Personal Data of the Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.


The services contained in this section allow the Data Controllers to monitor and analyze the traffic data and are used to keep track of the User's behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data, anonymously collected on this Website, for the purpose of evaluating the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data, anonymously collected on this site, to contextualize and personalize the ads of its advertising network.

Collected Personal Data: Cookie and Usage Data.

Place of treatment: USA – Privacy Policy – Opt Out .

Displaying content from external platforms

These services allow you to view content hosted on external platforms directly from the pages of this Website and interact with them.
If a service of this kind is installed, it may still collect web traffic data for the pages where the service is installed, even when users do not use it.

Rights of the User

Users may exercise certain rights with reference to the Data processed by the Owners.
In particular, the User has the right to:

• withdraw the consent at any time. The User can withdraw his/her previously expressed consent to the processing of his/her Personal Data.

• oppose the processing of his/her data. The User may object to the processing of his/her data when this occurs on a legal basis other than the consent. Further details on the right of opposition are indicated in the section below.

• verify and request the rectification. The User can verify the correctness of his/her Data and request their updating or correction.

• obtain the treatment limitation. When certain conditions are met, the User may request the limitation of the processing of his/her Data. In this case the Data Controllers will not process the Data for any other purpose than their conservation.

• obtain the cancellation or removal of his/her Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controllers.

• propose a complaint. The User can propose a complaint to the competent personal data protection authority or act in court.

How to exercise the rights

In order to exercise the rights of the User, the Users can send a request to the Data Controllers' contact details indicated in this document. The requests are deposited for free and processed by the Data Controllers as soon as possible, in any case within a month.

More information about the treatment

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Website or the related services.
The User declares to be aware that the Data Controller may be required to reveal Personal Data upon request of public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of the Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this Website and any third party services used by it may collect System Logs, which are files that record the interactions and that may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information about the processing of the Personal Data may be requested at any time to the Data Controllers using the contact details.

Person in charge of data protection

Nicola Claudio Matteo Bertolli

Changes to this privacy policy

The Data Controllers reserve the right to make changes to this privacy policy at any time by informing Users on this page. Please therefore regularly consult this page, referring to the date of the last modification stated at the bottom. In case of non-acceptance of the changes made to this privacy policy, the User is required to cease using this Website and may request the Data Controllers to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected until then.

Last update: May 24, 2018.


Information about the use of Cookies

During the consultation of our web pages it is possible that personal information and data are collected through the voluntary compilation of forms in it; in this case, the interested party must first read the information for the treatment of the data associated with this processing and he/she must consent to its management by our company, in the terms indicated in the same information.

In order to provide more information or to facilitate the users browsing, it is possible that we host on our web pages links to other sites not of our own creation (for example, search engines, suppliers of connected solutions, etc.). The policies for the processing of data applied by these sites are not under our control and the protections provided by this information note do not extend to them; our company assumes no responsibility for the personal data that may be collected there.
It is also possible to access the Website without requiring the user to provide any personal data.
However, the computer systems and software used to operate the Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols, through the action of files temporarily or permanently stored on your hard-disk (the so-called Cookies) and thanks to the use of other software components downloaded or activated during navigation.
This information is not collected to be associated with identified interested parties, but also due to their very nature they could, through processing or association, allow the identification of the user.
This category includes the IP addresses of the computers used by the users who connect to the Website, the URL of the requested resources, the time of the request, the size of the file obtained in response, etc.
These data are used only in order to obtain anonymous statistical information about the use of the Site (such as, in particular, the number of accesses), in order to check its correct functioning, in order to speed up, improve or customize the level of service to users and are deleted immediately after processing.

The provision of data is optional; any refusal to provide such data, blocking cookies or other software components could make it impossible for us to send the requested information and/or provide a not completely correct site functionality.

The collected data will be processed exclusively by the company personnel appointed for this purpose and they will not be transferred or communicated to other subjects.

The data could be used to ascertain responsibility in case of hypothetical computer crimes to the detriment of the Website or of third parties: except for this possibility, the data about the web contacts are not permanently stored.

The Data Controller is La Ginestra srl, Registered Office: Corso Indipendenza, 20 - Milano. In order to exercise your rights listed above, you can contact the telephone number +390272002387, the fax number +390272002396 or the email address

Detailed information about the use of cookies and the consent to their use


Cookies are short fragments of text (letters and/or numbers) that allow the web server to store on the client (the browser) information to be reused during the same visit to the site (session cookies) or later, even after days (persistent cookies). Cookies are stored, according to the user preferences, by the single browser on the specific device used (computer, tablet, smartphone). Similar technologies can be used to gather information about the user behavior and the use of services.
In the following of this document we will refer to the cookies and to all the similar technologies simply by using the term "cookies".

Types of cookies

Based on the characteristics and the use of cookies we can distinguish different categories:

• Strictly necessary cookies. These cookies are essential for the proper functioning of our website and are used to manage the login and to access to the reserved functions of the site, in general to speed up, improve or customize the level of service to the users. The duration of cookies is either strictly limited to the working session (they are deleted once the browser is closed), or of longer duration, aimed at recognizing the visitor's computer. Their deactivation may compromise the use of services accessible by login, while the public part of the site is normally usable.

• Analysis and performance cookies. These cookies are used to anonymously collect and analyze the traffic and the use of the site. These cookies, even without identifying the user, allow, for example, to detect if the same user comes back to connect at different times. They also allow to monitor the system and to improve its performance and usability. The deactivation of these cookies can be performed without any loss of functionality.

• Profiling cookies. These are permanent cookies used to identify (anonymously or not) the user preferences and to improve his/her browsing experience, in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.

Third-party cookies

By visiting a website you may receive cookies from both the visited website ("owner") and from websites managed by other organizations ("third parties"). An example is the presence of "social plugins" (for example, Facebook, Twitter, Google+) aimed at sharing content on the social networks. The presence of these plugins involves the transmission of cookies to and from all the websites managed by third parties. The management of information collected by "third parties" is governed by the relevant information to which we ask to refer.

Cookie management

The user can decide whether or not to accept cookies using the settings of his browser.
Attention: the total or partial disabling of technical cookies can compromise the use of the website features reserved for registered users. On the contrary, the usability of public content is also possible by completely disabling cookies.
The disabling of "third-party" cookies does not affect the navigability in any way. The setting can be specifically defined for the different websites and web applications. In addition, the best browsers allow you to define different settings for "owners" cookies and for those of "third parties".
As an example, with Google Chrome, click the wrench in the upper right corner and select "Settings". At this point select 'Show advanced settings' ("Under the hood") and change the Privacy settings.



Internet Explorer:



This website uses

CONCRETE5 (essential general purpose cookie, which is only visible to this website).

Concrete5 Privacy Policy

This cookie allows to link the actions of the user during a browser session.
It is a session cookie, it is temporarily created, and once you close the browser, it is deleted.
A browser session starts when the user opens the browser window, and finishes when the user close it.

Google Analytics

The website uses Google Analytics. It is a web analysis service provided by Google Inc. ("Google") that uses cookies that are stored on the user's computer in order to allow statistical analysis in aggregate form according to the use the website visited.
The website operator has activated the function of anonymization of the IP address and has signed the amendment on the processing of data in accordance with the European regulations dictated by the Directive 95/46/EC.

Advertising cookies (remarketing, segmentation and targeting) of Google and Facebook

These cookies are intended to provide the user with advertising spaces that can be installed by third parties. Some are used to recognize individual advertising messages and to know which ones of them have been displayed and when, then allowing to appear, during the visit on other affiliated websites, banners and/or advertising related to certain products based on the browsing history of the user. The users are given a technical identifier but personal identifying data such as the user's name or address are in no case collected.
Other advertising cookies are used to hypothesize a navigation "profile" of the user, in order to propose advertising messages in line with his/her behavior and interests in the network. This "profile" is anonymous and the information collected through these cookies does not allow to trace the identity of the user.
In particular, the use of "Google Analytics" and "Facebook Ads" is reported, including the so-called "advertising function".
This is a web analytics service provided by Google and Facebook that use analytical cookies that are installed on the user's computer in order to perform statistical analysis in aggregate form about the use of the website visited, as well as to allow to profile the visitors of the websites (which are identified by "detection cookies") on the basis of the information contained in their "advertising cookies", which concern three categories: age group, gender, marketing segments.

On the web page you can find more information about the Google service.

On the web page you can find more information about the Facebook service.

The Google Privacy Policy,, regulates the processing of personal data of users who use Google products and services.

In order to consult the Google Inc. privacy policy, the independent holder of the processing of data relating to the Google Analytics service, see the following link:

The list of cookies used by Google Analytics is, finally, available at the following address:


At this link the additional browser component for deactivating Google Analytics is also made available by Google.

In order to ensure a greater transparency and convenience, for each of these websites we report the web address of the information, where you can find how to manage cookies, in addition to the possible denial of consent to the installation of cookies:

Google Analytics – web services (statistics and profiling) – social (profiling and marketing)

In order to learn more about cookies and about how to manage them or disable those of third parties or of marketing/retargeting, visit: