01Data controller
- Controller
- Anabasis S.r.l.
- Registered office
- Via del Giordano 37, 00144 Roma (RM)
- Operational headquarters
- Viale Roma 79, 84010 San Marzano sul Sarno (SA)
- VAT no. and tax code
- 17967351002
- Privacy email
- privacy@anabasisholding.com
- PEC (certified email)
- anabasis@pec.it
For any questions about this notice or to exercise your rights, write to privacy@anabasisholding.com. The Controller has not appointed a Data Protection Officer (DPO), because its activities do not require one under Article 37 of the Regulation.
02What data we process
Browsing data
To show you the pages, the server hosting the site automatically records certain technical data for each request: IP address, date and time, page requested, response code, browser and operating system, referring page. This data is not used to identify you and we do not combine it with other information.
Data you provide to us
If you write to us at the email addresses or call us at the number shown on the site, we process your contact details and whatever you choose to tell us: name, role, publication or company, content of the message. Please do not send us special categories of data (health, political opinions, etc.) unless strictly necessary.
Visit statistics, only with your consent
If you accept statistics cookies, we use Google Analytics 4 to find out how many people visit the site, which pages they come from and which sections they read. The data is aggregated. We have disabled Google Signals and ad personalisation. If you do not accept, Google Analytics is not loaded and your browser does not contact Google’s servers.
Cookies
Full details on cookies and similar tools are in the cookie policy.
03Why we process it and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Running the site and protecting it from abuse and attacks | Browsing data | The Controller’s legitimate interest in the security and operation of the site (Art. 6(1)(f)) |
| Replying to the press, investors, prospective partners and anyone who writes to us | Data you provide by email or telephone | Pre-contractual measures taken at your request (Art. 6(1)(b)) or legitimate interest in responding to the requests received (Art. 6(1)(f)) |
| Aggregate visit statistics | Statistics cookie identifiers, site usage data | Your consent (Art. 6(1)(a) and Art. 122 of the Italian Privacy Code), which you may withdraw at any time |
| Remembering your cookie choice | Value of the technical consent cookie | Legal obligation to demonstrate consent (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
| Defending our rights and responding to authorities | The data required in the specific case | Legitimate interest (Art. 6(1)(f)) and legal obligations (Art. 6(1)(c)) |
Providing data by email is optional, but without it we cannot reply to you. We do not use the data for automated decision-making or profiling.
04How we process it
The data is processed using electronic tools, by persons authorised and instructed by the Controller, with appropriate technical and organisational measures: encrypted connection (HTTPS), restricted access, and selected providers that offer sufficient guarantees under Article 28 of the Regulation.
05Who receives the data
We do not sell or transfer data to third parties. The following may process it on our behalf, as data processors:
- Hostinger International Ltd (Larnaca, Cyprus), provider of the website hosting and company email, for browsing data and the emails you send us;
- Google Ireland Limited (Dublin, Ireland), for Google Analytics 4, only if you have given your consent;
- legal, tax and technical advisers, when necessary and only for the data required.
The data may be disclosed to authorities that request it in accordance with the law. Within the group, a request concerning an investee company may be forwarded to that company, which handles it as an independent controller.
06Transfers outside the European Union
Google Analytics may involve the transfer of data to Google LLC, in the United States. Google LLC participates in the EU-U.S. Data Privacy Framework, recognised as adequate by the European Commission in its decision of 10 July 2023 (Art. 45 of the Regulation); in addition, Google applies the standard contractual clauses approved by the Commission. Participation can be verified at dataprivacyframework.gov.
According to Google, Google Analytics 4 does not log or store the IP addresses of users in the European Union.
07How long we keep it
- Browsing data: for the technical period set by the hosting provider and in any case no longer than 12 months, unless it is needed to establish liability in the event of computer crimes.
- Emails and telephone contacts: for the time needed to handle the request. If a relationship arises from it, for the duration of that relationship and then for the periods required by law (up to 10 years for accounting records); otherwise no longer than 24 months from the last contact.
- Google Analytics statistics: 2 months for event-level and user-level data; aggregate reports, which contain no personal data, remain available.
- Cookies: for the durations stated in the cookie policy.
08Your rights
At any time you may ask the Controller for:
- access to your data and a copy of it (Art. 15);
- rectification of inaccurate data (Art. 16) and erasure (Art. 17);
- restriction of processing (Art. 18) and portability of the data you have provided to us (Art. 20);
- to object to processing based on legitimate interest (Art. 21);
- to withdraw your consent, without affecting processing already carried out (Art. 7(3)). For statistics cookies, simply use the “Cookie preferences” link at the bottom of every page.
Write to privacy@anabasisholding.com or by PEC (certified email) to anabasis@pec.it. We reply within one month, which may be extended by two months in complex cases, as provided by Article 12. We may ask you for information to verify your identity.
09Complaint to the Garante
If you believe that the processing infringes the Regulation, you may lodge a complaint with the Garante per la protezione dei dati personali (the Italian Data Protection Authority), Piazza Venezia 11, 00187 Roma, garanteprivacy.it, or with the authority of the country where you live or work, or take legal action before the courts.
10Minors
The site is aimed at the press, investors and professionals. We do not knowingly collect data from children under 14; if we receive any, we delete it.
11Changes to this notice
We may update this notice when the site, our providers or the rules change. The date of the latest version is shown at the top of the page. If the changes concern processing based on consent, we will ask for your consent again.