COOKIE AND PRIVACY POLICY

Last Update: July 2018

U-Start SA (“U-Start” or “we”, “us”, “our”) commits to protect and respect your privacy and to provide you with all required information concerning the processing of personal data that we collect about you or that you provide us, in compliance with the relevant applicable data protection laws, both European and Italian.

First of all, to make this disclosure clearer, definitions of the key words contained in the Privacy Policy are provided below:

• Personal data: any information relating to a natural person who is identified or identifiable, including indirectly, by making reference to any other information, including a personal identification number or an online identifier;
• Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means (e.g. the collection, registration, storage, consultation, processing, modification, use and disclosure of information);
• Controller: natural person or legal entity, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data (in this case, U-Start);
• Processor: natural person, legal entity, public authority, agency or other body appointed by the controller to process personal data on behalf and in the interests of the controller;
• Data subject: the party to whom the personal data refers.

For the purposes of this Privacy Policy, the data controller is U-Start SA, with legal offices in Switzerland, Piazzetta San Carlo 2, 6900 Lugano, Telephone: +41 79 107 79 06 and an establishment based in Italy, Viale Luigi Majno, 15 – 20122 Milano, Telephone : +39 02 83 474 836.

YOUR INFORMATION SUBJECT TO COLLECTION AND PROCESSING

1. Information that you provide to us directly
You may provide us with data about yourself such as your name and surname, email address, telephone number, professional information (i.e. if you are an investor or an entrepreneur) and any other personal information that you choose to share with us in one or more of the following ways:

• by filling out the fields on our website http://www.u-start.biz/ (the “Website”) in the “Contact Us” section
• by contacting us by telephone, email or in another manner.

When filling out the fields, you will be asked to provide your consent to the processing of your information for the purposes laid out in this Privacy Policy; however, if you communicate with us by telephone, email or in another manner, we will process the data that you voluntarily provide us only to give you a response to your request.

2. Navigation data
Every time you visit our Website the following data will be gathered automatically:

• technical information, including IP addresses or domain names used to connect to our Website, the type and version of the browser you are using, the time/zone settings, the type and version of browser plug-ins, the operating system and the platform you are using;
• information on your visit to our Website and online navigation records, including the entire URL, data on the series of clicks generated (clickstream), navigation dates and time; the resources requested and the size of the file obtained in response, the time and the status of the reply given by the server (successful, error, etc.), the methods used to exit webpage navigation.

Navigation information is not collected with the primary aim of identifying users, however due to its very nature it may allow for the identification of users.

COOKIES
Our Website uses cookies to distinguish you from other users of our Website. This enables us to ensure that you have a good experience as you navigate on our Website and to improve it. For detailed information on the cookies we use and the reasons they are used, please refer to our cookie policy.

PURPOSES OF PROCESSING
Personal data will be processed for the following purposes:

• to satisfy the requests you submitted us by contacting us through the section “Contact Us” of our Website or by telephone, e-mail or another manner;
• to ensure that our Website content is presented in the most effective manner for you and your devices, by continuously improving the navigation experience, design and layout of the Website, as well as web analytics tools;
• to administer our Website and for internal operations, including checking the proper functioning of the Website and resolving problems;
• to enable you to use some of our service’s interactive functions (such as those with social networks), should you choose to do so;
• to guarantee our Website’s security;
• to ascertain liability in the case of any cybercrimes to the detriment of our Website.

PROVISION OF INFORMATION AND REFUSAL OF PROCESSING BY THE DATA SUBJECT
You are always free to decide whether to provide your personal data. However, any refusal to provide the information necessary for navigation purposes on our Website may make activities closely connected and instrumental to navigation impossible. Any refusal to provide personal data requested at the section “Contact Us” may make difficult (where not impossible) to get back to your requests.

DATA PROCESSING AND RETENTION
The processing will be carried out using automated and manual means, with methods and tools meant to guarantee the utmost security and privacy, by parties made responsible for this in compliance with the provisions of the relevant applicable laws, both European and Italian.
Unless we need to exercise or to defend one of our rights, your data will be stored for the time strictly necessary for us to respond to your requests, and in any case no longer than 3 years.

SHARING YOUR DATA
We may share your data with advisors and service providers who collaborate with us in order to ensure the correct performance of the Website and to allow you to interact with us and to access – through the personal area – all the information you may be interested in.
Such service providers will process your data according to our instructions and for the sole purposes you provide us your data for.

TRANSFER OF DATA OUTSIDE THE EEA
We may share your personal data with recipients located in countries outside the European Economic Area (“EEA”).
Any such transfer of your personal data will be carried out in compliance with applicable laws.
We will carry out all these international transfers in accordance with the mechanisms set out in Articles 44-50 of the Regulation 679/2016/EU (the “GDPR”), subject to appropriate or suitable safeguards as required by the GDPR or other relevant laws. As regards data transfers in Switzerland, your personal data are protected according to the relevant adequacy decision issued by the EU Commission.

RIGHTS OF THE DATA SUBJECT
In accordance with the provisions of GDPR and other applicable legislation of data protection, you have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data, to the extent permitted by Article 17 of GDPR.
• To restrict: you can request the restriction of the processing of your personal data, to the extent permitted by Article 18 of GDPR.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

You may exercise your rights by contacting at the following e-mail address: info.privacy@u-start.biz.

If you decide to contact us for these purposes, please provide your email address, name, address and/or telephone numbers in order to allow for the proper management of the request.

AMENDMENTS TO THE PRIVACY POLICY
We reserve the right to update and/or modify this Privacy Policy at any time.
As the data subject of the data processing, you are required to periodically check for any changes. In order to facilitate this verification, the most recent date of updating will be specified on the Privacy Policy.

SOCIAL PLUG-INS AND RELATIONS WITH SOCIAL NETWORKS
Our web pages allow for interaction with social networks by means of sharing buttons and also may contain social network plug-ins (e.g., Facebook, Twitter, YouTube).
If you access one of our web pages equipped with this type of plug-in, the web browser connects directly to the servers of the social network and the plug-in is displayed on the screen thanks to the connection with the browser. If a data subject who uses a social network visits our web pages while connected to a social account, his or her personal information may be associated with the social account. The information will also be associated with the social account if the plug-in functions are used.

As regards the methods of privacy protection and the processing of the personal information collected by those social networks to allow for the above-mentioned interaction, please refer to the pages of the individual social networks. If the user of our Website does not want to associate the visit to our web pages with a social account, he or she must log off from the social network before visiting them.

Please take note that if a service for interaction with social networks is installed, it is possible that, even if you are not using the service, they may collect traffic data relating to the pages on which it is installed.

NOTICE
This Privacy Policy should not be considered valid for any other third-party websites that may be consulted via the links present on our Website.

Cookie Policy

Last update: July 2018

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good, personalised experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies, even with regard to the installation of those cookies for which your prior consent is legally requested.

What is a cookie
A cookie is a small file of letters and numbers containing information that we store on your browser or the hard drive of your computer.

http://www.u-start.biz uses the following cookies:

• Technical and session cookies
  Technical cookies are essential for using the services provided by our site. They remember the information you fill out in forms as you navigate through pages.
  These cookies are used for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network, or as strictly necessary in order to provide an information society service explicitly requested by the user of this website.
  Our website uses technical cookies http called “session” to handle authentication to online services and restricted areas. The use of session cookies (which are not stored permanently on the user’s computer and are deleted when closing the browser) is strictly limited to transmitting session identifiers (consisting of random numbers generated by the server) necessary to enable a safe and efficient site. The session cookies used on this website avoid the use of other technologies that could compromise the privacy of the users and not allow the acquisition of personal identification data.
  The installation of technical cookies on your browser do not require your prior consent.
  However, you can refuse consent to the use of cookies by selecting the appropriate settings on your browser (see below): navigation unauthenticated on the site will be available in all of its features.
  Please be aware that disabling technical cookies does not allow the use of the services of the site.
• Tracking analytic cookies
  Analytic cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  Analytic cookies require user’s consent if they are created by a third party (so called “third parties cookies”) and installed on the website you are visiting, unless such third parties cookies allow to collect the statistic information in aggregate and anonymised form.
  For example, we use Google Analytics cookies
  The service provided by Google Analytics helps generating site usage statistics; Google Analytics uses cookies that do not store personal data and IP address are anonymized. The information derived from the cookie about the website usage by users (including IP addresses) will be transmitted by the user’s browser to Google, with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, and stored by server of the company.
  According to the terms of service in use (please consult the latest version from time to time available at http://www.google.com/analytics/terms/it.html), Google will use this information, as autonomous data controller, for the purpose of evaluating your use of the website, compiling reports on website activity for use by site operators and providing other services related to the site, the connection mode (mobile, pc, browser etc) and the methods of research and achievement of the pages. Google may also transfer this information to third parties unless required by law or where such third parties process the information on Google’s behalf. Google will not associate IP addresses with any other data held by Google. To consult the privacy policy of the company Google on the Google Analytics service, please visit the website http://www.google.it/intl/it/analytics/privacyoverview.html
  To learn about the privacy policies of Google, please visit the website http://www.google.it/intl/it/policies/privacy/.
  By using this website, you consent to the processing of personal data by Google in the manner and for the above purposes. The cookie monitoring can be turned off without any consequence on navigation.
Alternatively, you can disable cookies only to Google Analytics, using the add-in to opt-out provided by Google for major browsers (https://tools.google.com/dlpage/gaoptout?hl=it). This way you can also use the online services of the site that require authentication.
• Profiling cookies
  Profiling is the use of persistent or permanent cookies to track a user’s overall activity online, in order to create a single “profile” of a user and are used in order to send advertising messages in line with the preferences shown by the same part of surfing the net.
  Profiling cookies are those that record your visit to a website, the pages you have visited and the links you have followed.
  
  On our website we have installed services of third parties, that may profile you for their marketing purposes. The installation of profiling cookies always requires your prior consent.

How to disable cookies via browser
Below we provide links that explain how to disable cookies for popular browsers (for other browsers might be used may want to try this option in the help of the software normally available via the F1 key):

You can find a complete list of all cookie used by this site here: