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Privacy Policy www.iwolm.com

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This Privacy Policy describes how we protect Personal Data of our Customers and Users. We appreciate the trust you put in us, and we assure you that we make every effort to give you full control over your Personal Data. Below we have described, as transparently as possible, the scope of data we process when through our Site and Services, the purposes and methods of processing, security measures, and your rights connected with the processing of your Personal Data.
By using our Services and Website, you accept all rules applied by GeV SRLS, so please read this Privacy Policy carefully beforehand. If you don’t agree to this Policy or can’t comply with it, you shouldn’t begin to use our Services or our Site.

Data Controller

GeV SRLS – Via T.L. Burattini, 95 32100 Belluno (Italia)
Email address of data controller: worklifemanagement@iwolm.com

Types of collected data

Among the Personal Information collected by this Application, either independently or through third parties, there are: Cookies, usage data, email and name.
Other collected Personal Information may be listed elsewhere in this privacy policy or through information texts displayed together with the collection of data themselves.
The Personal Data may be voluntarily entered by you, or automatically collected when using this application.
Any use of cookies – or other tracking tools – by this application or the Controllers of third party services used by this application, unless otherwise specified, aims to identify the User and register his preferences for purpose closely tied to the provision of the service you request.
Failure to provide by you of some personal data could prevent this Application to provide its services.
The user assumes the responsibility of the third parties Personal Data published or shared through this application and warrant the right to communicate or broadcast them, freeing the Controller from any liability to third parties.

How and where we process your Data

The rules of how we process your Data, along with the purposes and scope of the processing vary depending on whether you are our Customer or Website User. Below, we list the information about the Data we process concerning the specific purposes we need it for.

Processing methods

The Controller uses the Users’ Personal Information taking all necessary security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Personal Information.
The treatment is carried out using information tools and/or telematic, with organizational methods and logic strictly related to the indicated purposes. In addition to the Controller, in some cases, they may have access to the data categories of personnel involved in the Site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, responsible for processing by the Controller. The updated list of Managers may be requested to the Controller.

Place

The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the treatment are located. For more information, contact the Controller.

Times

The Data are kept for the time required to perform the service requested by you, or required by the objectives described in this document, and the User can always ask for discontinuation of treatment or deletion of data.

Why do we process your Data? The legal basis.

  1. To provide our Services or for the correct usage of our Web Site
    We process your data because it is necessary to enable you to use our Service or Website. In other words, we need to process your Personal Data to enable you to sign up as our Customer, or order our materials as our User. Otherwise, we wouldn’t be able to provide the Service or enable you to use the Website. We need to process your data to perform the contract and provide our services. Art. 6.1(b) of GDPR).
  2. For legitimate business interests
    Our legitimate interests constitute the legal basis for processing your personal data (Art. 6.1(f) of GDPR). Below you’ll find a list of our legitimate interests.

    • For analytical purposes. We believe we have a legitimate interest in analysing Services and Website operations and Customer and User satisfaction. We consider processing this data beneficial to Customers and Users. Our aim is to constantly develop the Website and to provide Services of the highest quality.
    • To exercise legal claims. We believe we have a legitimate interest in processing your Data if it’s necessary to exercise claims concerning the use of the Services or the Website that’s unlawful or incompatible with the Terms of Service.
    • To answer your questions. We believe we have a legitimate interest in replying to questions made through one of the available channels. We consider processing this Data beneficial for you because it allows us to help you and respond to your queries.
    • To conduct customer satisfaction surveys. We believe we have a legitimate interest in verifying if our Customers and Users are satisfied and what would help us improve the quality of Services and the Website.
    • To prevent fraud and abuse. We believe we have a legitimate interest in conducting necessary verification to detect and prevent potential fraud and abuse, including spam detection.
  3. To send you marketing communication
    This processing is based on your consent (Art. 6. sec. 1(a) of GDPR).
  4. For marketing purposes including creating your profile
    The legal basis for processing your Personal Data are legitimate interests of Gev SRLS (art. 6 sec. 1 (f) GDPR).
    We have a legitimate interest in analysing how our Customers and Users use our Services and Website, to improve and expand our customer base. Users of the Website who have expressed their interest in receiving newsletters and marketing communication to their email address give us their free, specific, informed, and unambiguous consent. Hence, we have inferred that they would have a reasonable expectation to receive such communication. At the same time, they expect that the communication we will send should be consistent with their interests. Personalized marketing communication allows our Customers to use our Services more effectively and benefit from our offers.

How do we use the data?

The User Data are collected to allow the Controller to provide his services, as well as for the following purposes: Social Applications, Interaction with external social networks and platforms, Statistics, Addresses management and Email messages sending, RSS feeds management, user contact, Payment management, Infrastructure Monitoring, display of content from external platforms and content comments.
The rules of how we process your Data, along with the purposes and scope of the processing vary depending on whether you are our Customer or Website user. Below, we list the information about the Data we process concerning the specific purposes we need it for.

  1. To provide the Services or to allow You to properly use Our Website
    While providing the Services or the Website, we carry out a set of operations that include: administrative activities related to concluding an agreement based on the acceptance of the Terms of Use, creating a Customer Account and Customer authentication within the Account, providing materials requested by Customers or Users (also those who do not have an Account, but use our Website), activities related to the performance of our Services, including sending you communication related to use or functioning of Services (in particular system and transactional e-mails), providing Customer support, handling complaints and other requests, charging due fees, seeking redress, and monitoring the quality of Our Services and Website.
    What Data do we use and for what purposes?
    To create your account and provide the Services, we process the following Data:

    • Registration Data and the password you set up.

    We only store encrypted passwords and we do not have access to them.
    To provide you with our Services (i.e., after you log in to your Account as our Customer), we process the following Data:

    • Data provided as Account details: Name, Surname – Address, Phone, VAT, Fiscal Code (when necessary to provide the service),
    • Number of access to Our Platform,
    • Data concerning activity within the Platform or Service (only if necessary).

    As a Data processor, we also process Personal Data entrusted to us by the Customer for the purpose of using the Service.

    You can use the Website without creating an Account, e.g., by downloading e-books and other training materials, by signing up for our newsletter on new articles on our blog or in Resources, by signing up for a webinar, training, or another event we organize or participate in, by submitting a draft to our blog.

    To enable you to use our Website, we process the following Data:

    • Data concerning activity within the Website or Service,
    • Registration Data (only if necessary)..
  2. For legitimate interests
    We process the data for legitimate interests of GeV SRLS described below, taking into consideration the relationship with our Customers or Users.
    What Data do we use and for what purposes?

    1. For analytical purposes. To keep statistics on the use of Our Services and the Website, helping us to improve Services and the Website, and to ensure network and information security, we process the following Data:
      • email address,
      • Data concerning activity within the Website or Service.
    2. To exercise legal claims. If necessary, to establish, exercise, or defend legal claims, we process the following Data:
      • Data provided as Account details,
      • Data concerning activity within the Website or Service necessary to establish a claim,
      • other data necessary to support the claim, establish the scope of damage and other circumstances regarding the damage.
    3. To answer your questions. To respond to your questions, petitions, and complaints, we may process the following Data:
      • Data provided as Account details,
      • Data concerning activity within the Website or Service that’s the subject of your question, petition, or complaint,
      • data included in the question, petition, or complaint and the attached documents.
    4. To conduct Customer satisfaction surveys. To verify Customer satisfaction with the Platform or Service, we may process the following Data:
      • Registration Data,
      • answers to our survey questions.
    5. To prevent fraud and abuse. To monitor, prevent, detect, and combat fraud and abuse, including SPAM, we may process the following Data:
      • Data provided as Account details,
      • Data concerning activity within the Website or Service necessary to verify potential fraud or abuse,
      • Data entrusted by the Customer for the purposes of providing the Service.
  3. To send marketing communication
    What Data do we use and for what purposes?
    To send our Customers and Users newsletter, marketing and promotional communication regarding our Services or Website, we may process the following Data:

    • Registration Data
  4. For marketing purposes, including creating your profile
    1. Tailoring our Website and Services to your preferences
      We want our Services and Website, including our newsletter and marketing communication (as long as you agreed to receive it), to be tailored to your needs and preferences (profiling). We describe the nature of the profiling we carry out below.
      What Data do we use and for what purposes?
      To develop sales and marketing of our services, including creating Customer or User profiles, tailored to your interests and preferences, we process the following Data:

      • Registration data,
      • Data provided as Account details,
      • Data concerning activity within the Website or Service.

      If you have agreed to receive marketing and promotional materials, we will match the marketing and promotional content related to our products and services to your profile based on the above data. We will not send you communication about third-party products or services.

    2. Remarketing (displaying ads outside of the Platform)
      To reach you with our marketing communication outside of our Website, we use the services of third-party providers. These services display our marketing communication on websites other than the Website. To do this, we use codes to download information about your activity within the Website or Service. You can find more information on this topic in the Cookies Policy.

The types of Personal Data used for each purpose are given in the specific sections of this document.

Various types of data as specified by the privacy policy of the service

Facebook authorizations required by this Application

This application may take a few Facebook authorizations in order to perform actions with the Facebook User account and to collect information, including Personal Information.

For more information on permissions that follow, please refer to the documentation of the Facebook permissions and the Facebook privacy policy.

The required permissions are:

Basic information
The basic information of the registered User on Facebook that normally include the following data: id, name, picture, gender and language and, in some cases, Facebook “Friends”. If the user provided more publicly available data, they will be available.

Sharing
Share instead of the user.

Insight
Insight provides data access to pages, domains and applications that the user owns.

I like
It provides access to the list of all the pages that the user has marked as “I Like”.

Addresses Management and Email Sending

These services allow us to manage a database of email contacts, phone contacts or any other type of contacts, used to communicate with the user.
These services may also enable to collect data on the date and time of user messages, as well as the interaction of the User with them, such as information about clicks on the links included in messages.

Getresponse
Getresponse is a service that allows you to manage the database of email contacts. Privacy Policy

SPAM protection

These services analyze the traffic of this site, potentially containing Personal Users data, in order to filter it from parts of traffic, content and messages recognized as spam.

Antispam Bee (pluginkollektiv)
Antispam Bee is a service of SPAM protection provided by pluginkollektiv.
Personal data collected: Various types of data as specified by the privacy policy of the service.
Place of treatment: USA – Privacy Policy

Thirds parties services access

These services allow this site to collect data from your account on third party service and act with them.
These services are not activated automatically, but require the express authorization of the User.

Access to Twitter (Twitter, Inc.)
This service allows this site to connect with the User’s account on the social network Twitter, provided by Twitter, Inc.
Personal data collected: Various types of data as specified by the privacy policy of the service.
Place of treatment: USA – Privacy Policy

Access to Facebook (This Site)
This service allows this site to connect with the User’s account on the social network Facebook, provided by Facebook, Inc.
Authorizations required: Sharing, Insight and “I Like”.
Place of treatment: USA – Privacy Policy

Comments of contents

The comments services allow Users to formulate comments and publish your comments on the content of this Website.
Users, depending on the settings chosen by the Controller, can leave comments even anonymously. In the case the User provides the email, it could be used to send notifications of comments concerning the same content. Users are responsible for the content of their comments.
In the case in which is installed a service of comments provided by third parties, it is possible that, even in the case where the Users do not use the service of comment, the same collect traffic data relating to the pages in which the service

WpDiscuz (Gvectors)
This site manages the comments using WpDiscuz (Gvectors) and stores the following data directly on its servers: Nick Name, Email, Web Site (optional), IP Address.
WpDiscuz Privacy Policy

Feed management RSS

These services allow the handling of RSS feeds and the distribution of their contents. Depending on the characteristics of the service used, these services can also be used to place advertisements within the content and to collect statistical data on them.

Feedburner (Google)
Feedburner is a management service of RSS feeds provided by Google Inc. that allows you to gather statistics on the consultation of contents and to integrate advertising into them.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Payments management

The management services for donations allow this site to process donations by credit card, wire transfer or other means. The data used for the payment are acquired directly by the operator of the payment service required without being processed in any way by this site.
Some of these services may also allow the sending of programmed messages to the user, such as emails containing invoices or notifications relating to the payment.

PayPal (PayPal)
PayPal is a payment service provided by PayPal Inc., which allows the user to make donations or payments online using their PayPal credentials.
Personal data collected: Various types of data as specified by the privacy policy of the service.
Privacy Policy

Stripe Payments Europe, Ltd
Stripe is a payment service provided by Stripe Payments Europe, Ltd, which allows the user to make donations or payments online using the most common credit cards.
Personal data collected: Various types of data as specified by the privacy policy of the service.
Privacy Policy

Interaction with external social networks and platforms

These services allow you to make interactions with social networks or other external platforms directly from the pages of this site.
The interaction and information obtained from this website are in any case subject to the User’s privacy settings related to any social network.
In the case a service for the interaction with social networks is installed, it is possible that, even if the users do not use the service, the same collect traffic data about the pages in which it is installed.

+1 Button and social widgets Google+ (Google Inc.)
The +1 button and Google+ social widgets are services of interaction with the social network Google+, provided by Google Inc.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Button and social widgets LinkedIn (LinkedIn Corporation)
Button and social widgets are services of Linkedin interaction with the social network LinkedIn, provided by LinkedIn Corporation.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

I like button and social widgets for Facebook (Facebook, Inc.)
The Button “I Like” of Facebook and the social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Tweet button and social widgets for Twitter (Twitter, Inc.)
The Tweet button and social widgets are services of Twitter to interact with the social network Twitter, provided by Twitter, Inc.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Pinterest button (Pinterest, Inc.)
The button options are services of interaction with the social network Pinterest, provided by Pinterest, Inc.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Statistics

The services contained in this section are used by the Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the collected Personal Information for the purpose of evaluating the use of this application, fill in reports and share them with other services developed by Google.
Google may use this personal information to contextualize and personalize the ads of its own advertising network.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy – Opt Out

Content on external platforms

These services allow to view content hosted on external platforms directly from the pages of this site and to interact with them.
In the case in which a service of this type is installed, it is possible that, even in the case the Users do not use the service, it collects traffic data relating to the pages in which it is installed.

Widgets Video Youtube (Google Inc.)
Youtube is a video content viewing service run by Google Inc. that allows this site to integrate those contents within its pages.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Google Font (Google Inc.)
Google Fonts is a service of displaying font styles run by Google Inc. that allows this site to integrate those contents within its pages.
Personal data collected: Cookie and usage data
Processing location: USA Privacy Policy

Displaying content from external platforms

These services allow you to view content hosted on external platforms directly from the pages of this application and interact with them.
In the case in which a service of this type is installed, it is possible that, even in the case the Users do not use the service, it collects traffic data relating to the pages in which it is installed.

Widgets Video Youtube (Google)
Youtube is a video content viewing service run by Google Inc. that allows this application to integrate video contents within its pages.
Personal data collected: Cookie and data usage.
Place of treatment: USA – Privacy Policy

Your rights. You have control over your Data.

We make sure that our Customers and Users can exercise their rights concerning their Data.
You may exercise your rights by filing a demand to the following email address: worklifemanagement@iwolm.com. All you need to do is to inform us about the reason for your motion and the right you want to exercise. If you have an Account, you can exercise some of your rights directly after you log in to your Account.
If we decide it’s necessary, we may ask you some additional questions or ask you to provide us with additional documents to confirm your identity.

It may sound obvious, but for the sake of clarity, we would still like to point out that exercising your rights described below is free of charge, with the possible exception of providing additional copies of your Data.

Under GDPR you have the following rights:

Right to express and withdraw your consent

If we ask for consent to process your Data, you can always choose to give it or not. In our Website, we never ask for one consent for different personal data processing operations, and we never depend on the consent to execute the contract, although consent is not necessary for its execution.
Additionally, you are entitled to withdraw any consent previously given at the point of creating an Account or using the Website, including:

  • processing your email address to send you our newsletter or marketing communication to your email address,
  • collecting your data by cookies. Read more in the Cookies Policy.

Withdrawal of your consent is effective upon execution, and it does not affect the lawfulness of processing based on the consent before you withdraw it. You can always withdraw your consent without detriment. It may, however, render you unable to use some of the features of the Website or the Services which we may legally render only with your consent (e.g., receiving the newsletter).

You may withdraw your consent in one of the following ways:

  • by clicking “unsubscribe” in the email you received,
  • if you agreed to the use of cookies – in your browser settings,
  • contacting us as defined in section Data Controller.

We treat withdrawing your consent to receive marketing communication as objecting to profiling for marketing purposes.

Right of access

You have the right to obtain confirmation if we process your Personal Data. If we do, you have the right to:

  • receive information on the rules of such processing,
  • access your Personal Data,
  • receive a copy of your Data.

If you have an Account with Us, you can directly access your personal data you provided at all times, after logging into your Account.

The first copy of your Data is free of charge. For any further copies you request, we may charge you a reasonable fee based on the administrative costs resulting from preparing this information.

Right to rectification

You have the right to rectify and complete the Personal Data you provide. You can do it yourself in your Account on Our Website or by clicking the link in the email you receive. Concerning other personal data, you have the right to have us rectify inaccurate personal data concerning you or complete your incomplete personal data.

Right to erasure (“right to be forgotten”)

On the grounds described by the law, you have the right to have us erase your Personal Data. We’ll treat your demand to erase all your Personal Data as a demand to delete your Account.

You have the right to have us erase your Personal Data if:

  • the Personal Data has been unlawfully processed or has to be erased to comply with a legal obligation;
  • your Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
  • you have withdrawn consent to the processing of your Data (and when there are no other legal grounds for processing);
  • you have objected to the processing of your Data for marketing-related purposes;
  • you have objected to the processing of your Data for statistical purposes of using the Website or the Service and surveying customer satisfaction, and the objection has been considered legitimate.

We will keep some of your Data despite the demand to erase it if it’s necessary for performing our legal duties or establishing, pursuing, or defending a claim. It especially refers to Personal Data concerning your name, surname, email address, phone and the Website or Service use history, which we keep to be able to address complaints and claims connected to the Website or use of the Service.

Right to restriction of processing

If you file such a demand, we will make some of the features of the Website or Service connected to the processing of the Data covered by your demand unavailable to you while we review it. During that time, we will not send you any communication including marketing communication.

You have the right to have us restrict the processing of your Data when one of the following applies:

  • you contest the accuracy of your Data;
  • the processing of your Data is unlawful, and you request the restriction of its use instead of erasing it;
  • we no longer need your Personal Data to process it, but you require it to establish, exercise, or defend legal claims;
  • you object to the processing of your Data.

Right to object

You have the right to object, on grounds relating to your specific situation, at any time, to the processing of your Data, providing that we are processing your Data based on our legitimate interests.

These cases are pointed out in the sections regarding the processing for legitimate interests and marketing purposes, including creating your profile.

In particular, you have the right to object to the processing of your Data for direct marketing purposes, including profiling. In such a case, we will no longer process your Data for these purposes and you will no longer receive any marketing information from us. Additionally, we’ll treat the withdrawal of the consent to receive marketing communication about our products or services as an objection to the processing of your Data for direct marketing purposes, including profiling.

Regarding the processing for legitimate interests as pointed out above, if your objection turns out to be legitimate and we don’t have any other legal grounds for processing your Data, we will remove the Data you don’t want us to process.

Right to data portability

If you set up a Customer Account or you consented to the processing of your Data, you have the right to receive your Personal Data you provided to us and transmit it to another controller in a structured, commonly used, machine-readable format. We will send your Personal Data in .CSV format. This format is commonly used and machine-readable, and enables the transmission of your Data to another data controller.

  • If you are our Customer or not, you may exercise your right contacting us as defined in section Data Controller.

Right to lodge a complaint with a supervisory authority

You have the right to complain to a supervisory authority concerning the processing of your Data.

Cookie Policy

This application makes use of cookies. To learn more and for a detailed policy, you can consult the Cookie Policy.

Further information on personal data

Selling goods and services online

Personal Data collected will be used for the provision of services to the User or for the sale of products, including the payment and the eventual delivery. Personal Data collected to refine the payment may be those relating to credit card, the account used for the bank or other payment instruments provided. The data collected from this payment application depend on the payment system used.

Defend the case

The User’s Personal Data may be used by the Controller for the defense in case or in the leading stages to a possible legal action. The Controller can use these data against their improper use or for services related to the User.

The User declares to be aware that public authorities can require to the Controller to disclosure the Data.

Specific information

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

System logs and maintenance

For its correct working and maintenance, this site and any third party services used by it, may collect system logs, which are files that record the interactions and which may also contain personal data, such as IP address User.

Information not contained in this policy

More information in relation to the processing of Personal Information may be requested at any time to the Controller using the contact information.

Data Subjects’ Rights

Data subjects are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified. The above Section also provides for the right to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data. Requests should be addressed to the Controller.

This site does not support requests “Do Not Track”. To know whether any third-party services support them, consult their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time informing the Users on this page. Please therefore check this page often, by reference to the date of last modification indicated at the bottom. In case of rejection of the changes made to this privacy policy, the User must cease the use of this Site and may ask to the Controller to remove their Personal Data. Unless otherwise indicated, the previous privacy policy will continue to apply to personal collected data until then.

Information about this privacy policy

The Data Controller is responsible for this privacy policy.

Definitions and legal references

Personal Information (or data)

Personal data are any information relating to an individual, identified or identifiable, even indirectly, by reference to any other information including a personal identification number.

User Data

Are personal data collected automatically from the Site (or by third-party applications), including: IP addresses or domain names of the computers used by the users who connect to the site, the addresses in URI notation (Uniform Resource Identifier), the time of request, the method used to submit the request to the server, the file size obtained in response, the numerical code indicating the status of response from the server (successful, error, etc.) the country of origin, the browser features and the operating system used by the visitor, the various time details per visit (for instance the time spent on each page) and the details about the path followed within the site (in particular the sequence of visited pages), the parameters related to the operating system and computer environment.

User

The individual using this site. His Personal Data are the one processed.

Person concerned

The natural or legal person to whom the Personal Data refer.

Data Processor (or Manager)

The natural person, the legal person, the public administration or any other organization and association designated by the Controller to the processing of Personal Data, as defined by this privacy policy.

Data Controller (or Controller)

The natural person, the legal person, the public administration or any other organization and association that is responsible for decisions regarding aims and methods of the processing of personal data and the used tools. The Data Controller, unless otherwise specified, is the owner of this site.

This Site

The hardware or software by which the Users Personal Information collected.

Cookie

Small piece of data stored within the user’s device. Read the Cookies Policy

Legal information

Notice to European Users: This site complies with the rules set by the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and this privacy policy has been prepared in fulfilment of the obligations under Art. 10 of the Directive n. 95/46 / EC and with the provisions of Directive 2002/58 / EC, as updated by Directive 2009/136 / EC, with regard to Cookies.

This privacy policy only covers this website.

This page is visible through the link at the bottom of all the pages of the Site in accordance with art. 122 seconds paragraph of Legislative Decree no. 196/2003 and following the simplified procedures for information and acquisition of consent for the use of cookies published in the Official Gazette 126 of June 3, 2014 and its record of the action 229 of 8 May 2014.

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