This English version is provided for convenience only. In the event of any discrepancy, the Italian version shall prevail.
This notice describes, pursuant to and for the purposes of Regulation (EU) 2016/679 on the protection of personal data (“GDPR”), how and why the data provided by users of the website are processed. It is provided in accordance with Articles 13 and 14 of the GDPR and is addressed to everyone who accesses the website. Unless otherwise stated, everything set out in this notice applies to this website only. The operators and authors of the website are not responsible for the content of third-party websites linked directly or indirectly, including through links from this website.
Data controller
The data controller is H&A srl, with registered office at Via Durini 23 — Milan, Italy, tax code and VAT number 11325700158. Email: info@hamotivation.com.
Data processed and purposes of processing
Simply browsing the website does not in itself involve the collection of users’ personal data, except for browsing data and technical cookies. The optional and voluntary submission of data through a contact form involves the collection of identification and contact details (e.g. name, email, phone number). The purposes of the processing are:
- handling requests for information and contact (legal basis: Art. 6(1)(b) GDPR – performance of pre-contractual measures);
- compliance with legal and tax obligations (legal basis: Art. 6(1)(c) GDPR);
- IT security and abuse prevention (legal basis: Art. 6(1)(f) GDPR – legitimate interest of the controller).
The data will be kept for as long as necessary to respond to requests and in any case for no longer than 12 months after the request has been closed, unless legal obligations apply or a contractual relationship is established.
Methods of processing
Data are processed using electronic and paper-based tools, in accordance with the principles of lawfulness, fairness and transparency, by authorized personnel of H&A srl. Where necessary, data may be disclosed to technical and IT service providers appointed as data processors pursuant to Art. 28 GDPR.
Scope of disclosure and recipients
Personal data may be disclosed to third parties providing services strictly related to the purposes indicated, including: hosting providers, email service providers, Google LLC (Google Tag Manager and Google Analytics 4, USA), Vimeo Inc. (embedded video player, USA) and Cloudflare/cdnjs (delivery of JavaScript libraries). Where these providers are located outside the European Economic Area, data will be transferred on the basis of the legal instruments provided for by the GDPR (Articles 44 et seq.), such as Standard Contractual Clauses (SCCs) and/or the EU-US Data Privacy Framework.
Rights of the data subject
Users may at any time exercise the rights provided for by Articles 15–22 of the GDPR, including: access to data, rectification, erasure, restriction of processing, portability and objection. Data subjects also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it).
Browsing data
The IT systems and software procedures used to operate the website acquire, during their normal operation, certain personal data (e.g. IP addresses, access logs, URIs of the requested resources). These data, which are not collected in order to identify users, may nonetheless allow them to be identified indirectly. They are used solely to obtain anonymous statistical information and to check that the website is working properly, and are kept for the periods established by law.
Third-party video content (Vimeo)
The homepage embeds a video hosted on Vimeo (provider: Vimeo Inc., 330 West 34th Street, New York, USA). The player is loaded when the page opens and, in order to deliver the content, sends Vimeo your IP address and some technical information about your browser (user agent). The player is configured in Do Not Track mode (dnt=1): Vimeo does not set profiling cookies or track the session for advertising purposes. Any transfer of data to the United States takes place on the basis of appropriate safeguards pursuant to Articles 44 et seq. of the GDPR (Standard Contractual Clauses and/or the EU-US Data Privacy Framework). For more information: vimeo.com/privacy.
Cookies
The website uses the following categories of cookies:
Technical cookies (always active)
Necessary for the website to work and to be used. They do not require consent.
- Session cookies: ensure correct browsing; they are deleted when the browser is closed.
- cdnjs CDN (Cloudflare): used to load the JavaScript libraries needed for the website to work. It does not use profiling cookies but may process the IP address and browsing metadata in order to provide the service. Fonts are hosted directly on our servers and do not involve any transfer to third parties.
Analytics cookies (subject to consent)
Subject to acceptance via the banner, the website uses Google Analytics 4 (provider: Google LLC, USA) to collect anonymous statistics on visits. Tags are managed through Google Tag Manager (Google LLC, USA), a tag management tool that does not in itself collect personal data. Data are transferred to the USA on the basis of the Standard Contractual Clauses (SCCs) approved by the European Commission. Google Consent Mode v2 is implemented: without consent, analytics and advertising storage remain disabled (default state «denied») and GA4 does not collect identifying personal data.
Users may withdraw their consent at any time by deleting cookies from their browser or by using the Google Analytics opt-out browser add-on: tools.google.com/dlpage/gaoptout.
For any category, users can manage cookies through their browser settings (Chrome, Firefox, Safari, Edge). Blocking technical cookies may affect the proper functioning of the website.