PRIVACY POLICY

LEVANTECH S.r.l. develops a mobile application called CICEROS, which provides interactive multimedia reviews and audio-guides, even on smartphones, based on the User's current position (GPS), enabling the smart retrieval of information on historic buildings located in public places. The reviews and multimedia audio-guides are also accessible through the Website at http:// www.ciceros.it. These reviews and audio-guides are provided by other subjects, such as museums, cities and passionate users, through a content management system. When using the Service, LEVANTECH S.r.l. collects personal information about the User. This document describes the way in which LEVANTECH S.r.l. manages this personal information.

1. Definitions
The capitalized terms used in these Privacy policy have the following meaning:
-          Personal Data (or Data): any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.
-          Usage Data: information collected automatically by this Application (or the third-subjects applications that this Application uses), including: IP addresses or domain names of the computers used by the User that connects with this Application, the addresses in the notation URI (Uniform Resource Identifier), the time of the request, the method used in submitting 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 (good order, error etc.), the country of origin, the characteristics of the browser and 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 of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, to the parameters related to the operating system and the IT environment User.
-          User: individual who uses this Application, which must coincide with the interested subject or be authorized by him and whose Personal Data are being processed.
-          Interested: natural or legal person to whom the Personal Data refer.
-          Data Processor: natural or legal person, public administration and any other association appointed by the Data Controller to process Personal Data, as established by this Privacy policy.
-          Data Controller: natural person, legal entity, public administration and any other association to which they are responsible, even together with other Data Controller, decisions regarding the purposes, methods of processing Personal Data and tools used, including the security profile, in relation to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
-          Application/ App: hardware or software tool through which the Personal Data of the Users are collected.

2. Who is LEVANTECH S.r.l.?
Pursuant to art. 28 of Legislative Decree No. 196 of June 30, 2003, holder of the Application and Data Processing is LEVANTECH S.r.l. (hereinafter referred to as "Holder"), a limited liability company established and existing under Italian law, with registered office in Bari, at via Tenente Cesare Suglia, n. 50 - 70126 (BA) (VAT number: IT08045730721). The Data are processed at the operational headquarters of the Data Controller and in any other place where the subject involved in the processing are located and are only handled by personnel in charge of processing, or by persons in charge of occasional maintenance operations. For further information, please contact the Holder.

3. Privacy
This privacy statement is prepared in fulfillment of the obligations under and pursuant to and for the purposes of art. 13 et seq., EU Regulation no. 679/2016 of 27 April 2016 (General Data Protection Regulation – GDPR), "on the protection of individuals with regard to the processing of personal data, as well as on the free movement of such data and repealing Directive 95/46/EC (Regulation general data protection)”, as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, concerning Cookies. Below is a useful link if User wants to deepen the new legislation: https://www.eugdpr.org/.
This Privacy policy is intended to describe how the Website is managed with regard to the processing of Personal Data of users who use the Services offered. This is an information that is provided pursuant to art. 13 of the "Code regarding the protection of personal data", pursuant to Legislative Decree no. 196/2003, of the provision issued by the Authority "Identifying the simplified procedures for the information and the acquisition of consent for the use of cookies" of May 8, 2014, and the Recommendation n. 2/2001 that the European Authorities for the protection of Personal Data gathered in the Group established by the art. 29 of the Directive n. 95/46/EC, adopted on 17 May 2001.
Pursuant to and for the purposes of article 13 of Legislative Decree No. 196 of June 30, 2003, "Code regarding the protection of personal data", we specify the following. The Data provided by the visitor, including mail, will be processed, communicated and disseminated, also with the aid of electronic or automated means, directly from LEVANTECH S.r.l. and/or through subjects appointed by and/or by third-subjects companies, for: the purposes connected to the use of the Website and/or the provision of the services requested; for statistical purposes; for the sending of advertising material and marketing of the Products and Services of LEVANTECH S.r.l. and/or associated companies; for the fulfillment of all obligations under the law, regulations and European legislation and/or for the implementation of provisions issued by public authorities and/or for the conduct of activities aimed at preventing or suppressing computer fraud. By providing the Data by completing the registration form and accepting the conditions of access to the Website, the visitor expresses his consent to the processing of his Personal Data for the purposes connected to the aforementioned access. These Data are considered mandatory as they allow you to correctly perform the access to the requested Services and any lack or revocation could result in the non-continuation of the relationship. The use of Data for commercial purposes (sending advertising, promotional material etc.) is, instead, subject to an express consent, having an optional nature, on the part of the visitor and any lack will have no consequence with respect to the access modalities to the Services of the Website. Every time LEVANTECH S.r.l. intends to collect Data for these purposes, the visitor will be asked to provide or not give the consent to the processing. The above Data, as well as those developed by third-subjects, will not be communicated and distributed outside the cases provided for by law and the treatment will be based on principles of correctness, lawfulness and transparency, to protect the privacy and rights of the User. LEVANTECH S.r.l. is entitled, in accordance with Legislative Decree No. 196 of June 30, 2003, the processing of Personal Data, in the person of the Legal Representative pro tempore and is, therefore, obliged to all the obligations by the same law provided. At any time the User may exercise his/her rights towards the Data Controller, pursuant to Article 7 (“Right to access personal data and other rights”) of Legislative Decree No. 196 of 30 June 2003, which for the sake of clarity reports in full: "1. The interested subject has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and their communication in intelligible form. The interested subject has the right to obtain the indication: a) of the origin of the personal data; b) of the purposes and methods of the processing; c) of the logic applied in case of treatment carried out with the aid of electronic instruments; d) of the identifying details of the holder, of the responsible and of the designated representative according to article 5, paragraph 2; e) of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the territory of the State, managers or agents.The interested subject has the right to obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right. The data subject has the right to object, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication". In order to exercise the above rights, please contact LEVANTECH S.r.l.
If the User has not yet reached the age of sixteen (16), he is obliged to obtain the consent of the parents or legal guardians before using the mobile App and/or the Website. Using the mobile App and/or the Website, the User warrants that he/she is 16 years or older or have the permission of parents/legal guardians to use these services.

4. Intellectual Property Rights
All contents and/or documents and/or images and/or trademarks and/or logos and/or names of Products and systems on this Website are the exclusive intellectual property of LEVANTECH S.r.l. Such contents and/or documents and/or images and/or brands and/or logos and/or names of Products and systems can not - even partially - be copied and/or reproduced and/or transferred and/or uploaded and/or published and/or distributed by any means without the prior written consent of LEVANTECH S.r.l., except and within the limits of what is necessary for their on-line viewing. It is possible to print the pages of the Website only for personal use, subject to the following conditions: that no changes are made to the contents and/or documents and/or images and/or trademarks and/or logos and/or product names; that the contents and/or the documents and/or images and/or the trademarks and/or the logos and/or the names of the Products on the Website are not used separately from the corresponding text; that the copyright and/or the trademark and/or the commercial logo and/or the name of LEVANTECH S.r.l., and/or other notes, appear on all printed copies. Without prejudice to the above, always subject to the written authorization of LEVANTECH S.r.l., the documents made available may be downloaded from the Website. These downloads are in any case subject to the conditions above. It is strictly prohibited any use, for any purpose, of parts extracted from the Website, unless in accordance with the aforementioned conditions. LEVANTECH S.r.l. reserves the right to prosecute any violation of these provisions before the competent judicial authorities.

5. Access to the Service
Although LEVANTECH S.r.l. doing its best to ensure that the Website is available 24 hours a day, it will not be liable in any case if, for any reason, the Website is not available at any given time and/or for a certain period of time. Access to the Website may also be suspended and/or interrupted, without notice, in the event of a system failure, for maintenance or repair activities, or for reasons beyond the control of LEVANTECH S.r.l., and in any case in which LEVANTECH S.r.l. consider it appropriate or necessary.

6. Types of Data collected
LEVANTECH S.r.l. offers two types of Services: it provides Users with reviews and multimedia audio-guides and allows people to create reviews and multimedia audio-guides. Among the Personal Data collected by this Application, independently or through third-subjects, there are: cookies, Usage Data, name, surname, mail. Full details on each type of Data collected 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, collected automatically during the use of this Website. All the Data requested by this Website are mandatory and, in the absence of their contribution, it could be impossible to this Webite 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. Other Personal Data collected may be indicated in other sections of this Privacy policy or through informative texts displayed simultaneously with the collection of the Data. Personal Data may be entered voluntarily by the User, or collected automatically during the use of this App. Any use of cookies - or other tracking tools - by this App or third-subjects service providers used by this App, unless otherwise specified, has the purpose of identifying the User and recording the related preferences for purposes strictly linked to the provision of the Service requested by the User. Failure to provide the User with some Personal Data may prevent this App from providing its Services. Users who have doubts about which data are mandatory, are encouraged to contact LEVANTECH S.r.l. The User assumes the responsibility of the Personal Data of third-subjects published or shared through this App and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third-subjects.
            - Data collected if the CICEROS App is used
If User wants to use the App to listen to reviews and multimedia audio-guides, he/she can do so without creating an Account. The App can offer the possibility of creating a User Account. In this case, the User must provide the name, age, mail address, Account name, password and preferred language. Alternatively, he/she can log in using his/her Twitter, Facebook or Google+ account. In this case, the App will have access to the information stored and/or accessible in these Accounts, including chronology and/or newsfeeds, in accordance with the permissions granted. Some information is automatically collected when using the App: browsing history, location, IP address, mobile device and operating system. This information is collected via Google Analytics (see below for more information). LEVANTECH S.r.l. can use this information to: allow the User to use the App; suggest information, in particular based on your position; configure the App according to User preferences; communicate with the User on the App and answer any complaints and/or questions; communicate with the user on LEVANTECH S.r.l. and/or on its Products; analyze the use of the App (also through Google Analytics) and protect, regulate and update the services of LEVANTECH S.r.l., in particular the App.
LEVANTECH S.r.l. can also process the information collected through the App to share aggregated information with certain Publishers. However, it will not be possible for Publishers to identify certain Users from this aggregated data. If the User uses the in-app payment system to purchase Content, the applicable platform provider (Google, Apple, or Windows) will collect payment information in accordance with its privacy policy. LEVANTECH S.r.l. will obtain from Google, Apple or Windows information on which Content has been purchased and will use this information to manage its payments to the Publishers.
            - Data collected if the Website is used
If User wants to listen to reviews and audio-guide multimedia without downloading the App, he/she can also visit the Website. User does not need to create an Account for this. If he/she uses the Website, the browsing history, IP address and information on the browser and the operating system are collected through Google Analytics. LEVANTECH S.r.l. may use this personal information to: suggest information to the User; analyze the use of the Website; protect, regulate and update the Services.
            - Data collected through the Content management system
It is possible to upload reviews and multimedia audio-guides and other information for publication through the content management system. To do so, the User must create an Account, providing the name, the name of the organization and the mail address. After logging in and registering as "Publisher" in the Content management system, the User will send additional information (such as the name of the organization, his/her country, city, post code, address, telephone number and owner copyright). The main function of the Content management system is to allow information to be uploaded. If the uploaded Content contains the User's personal information, it is assumed that he/she consents to the processing of this information, in line with this Privacy policy. If User plans to upload third-subject personal information and there is a significant risk that permission is required for processing described in this policy, he/she must obtain prior authorization. Many of the information that is provided through the Content management system, such as the name and the uploaded Content, will be publicly available through the App and the Website during the publication of the contribution.
            - Data collected to communicate with the User
To be updated on CICEROS developments, User can register for the newsletter on the Website www.ciceros.it, providing his/her mail address. If User no longer wish to receive mail from LEVANTECH S.r.l., he/she can, at any time, delete it from the Website. Furthermore, in every mail sent by LEVANTECH S.r.l. an exclusion option is provided.

7. Specific information and Information not contained in this policy
At the request of the User, in addition to the information contained in this Privacy policy, the App may provide additional and contextual information regarding specific services, or the collection and processing of Personal Data. More information in relation to the processing of Personal Data may be requested, at any time, to the Data Controller using the contact information.

8. Data Protection
LEVANTECH S.r.l. respects the confidentiality of Personal Data of those who visit the Website, in accordance with the regulatory provisions of Legislative Decree No. 196 of June 30, 2003, "Code regarding the protection of personal data". In accordance with this legislation, Personal Data will be collected and processed by those who visit and registered in the online forms of the App, in relation to the purpose for which the registration took place (request for information, services, receipt of promotional material etc). LEVANTECH S.r.l. reserves the right to preserve any correspondence with visitors to the Website, who, when filling out online questionnaires, consent that LEVANTECH S.r.l. use the answers to these questionnaires for commercial purposes and market research.

9. Material and Conduct of visitors
Apart from the Personal Data that will be managed according to the laws that regulate the Privacy and cookies, the Contents and/or materials exchanged and/or transmitted and/or posted on the Website will be considered non-confidential and not owned by LEVANTECH S.r.l., which, therefore, will have no obligation and/or liability with respect to such Contents and/or materials. LEVANTECH S.r.l. and the subjects designated by the same may freely copy, disclose, distribute, insert, and otherwise use these materials and/or Data and/or images and/or sounds and/or texts and/or other elements contained therein for any purpose. Anyone who sends material guarantees that it is publishable and agrees to hold LEVANTECH S.r.l. from any related action by third-subjects. It is strictly forbidden for Users to post on and/or exchange on and/or transmit to the Website or from the Website any material: that is threatening, defamatory, obscene, indecent, seditious, offensive, pornographic, abusive, anti-racial, discriminatory, scandalous, instigating, blasphemous, which violates confidentiality and privacy, or that may create disturbances or discomforts; or in relation to which all the necessary licenses and/or authorizations have not been obtained; or that it constitutes or instigates a conduct considered as a crime, which generates a civil liability, which otherwise is contrary to the law, or that violates the rights of third-subjects, in any country in the world, or that is technically harmful (including, but not limited to and non-exhaustive, computer viruses, logic bombs, Trojan horses, worms, harmful components, altered data or other malicious software or malicious data). LEVANTECH S.r.l. will cooperate fully with the Judicial Authorities that may request and/or order to make the identity known and/or to locate anyone places of the material that violates this paragraph and/or the current legislation, without prejudice to the right of LEVANTECH S.r.l. to act for damages.

10. Account cancellation
If User deletes the Account, all personal information provided during registration and administration will be deleted. LEVANTECH S.r.l. reserves the right to retain the Data collected regarding the use of the App, in order to provide aggregated statistics to others. However, LEVANTECH S.r.l. guarantees that the Data no longer contains references to the Account. If the User wishes to know what information LEVANTECH S.r.l. has collected about him or if he wishes to modify the Data which he/she can not modify alone through the Website or the App, please send a request to ciceros.it@gmail.com.

11. Transfer to third-subjects
LEVANTECH S.r.l. can provide aggregated data on the use of the App (including location data), the Website and the Content management system to others. These Data are sufficiently aggregated to be anonymous. LEVANTECH S.r.l. it can also give the parties that develop apps based on reviews and multimedia audio-guides access to information uploaded through the Content management system. User login data will not be shared with third-subjects. LEVANTECH S.r.l. may provide Personal Data to third-subjects if it is obliged to do so due to laws and/or national or international regulations or if it deems it necessary to do so to defend its rights. LEVANTECH S.r.l. will not provide personal information to third-subjects for direct marketing purposes without explicit consent.
The Data Controller may present or offer third-subject products or services on its App. Regarding privacy, the sites of said subjects adopt different criteria and independent from ours. Therefore, the Owner declines all responsibility for the content or activities of these linked sites.

12. Methods of processing collected Data
The Owner treats Users' Personal Data by taking appropriate security measures to prevent unauthorized access, disclosure, modification or destruction. 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 Controller, in some cases, may have access to the Data categories of persons involved in the organization of the Website (administrative, commercial, marketing, legal, system administrators) or external subjects (as suppliers of third subject technical services, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller. Personal Data are processed according to principles of relevance, lawfulness and correctness, through the use of appropriate security measures and following the granting of consent by Users, where provided for. The processing of Data may consist, as well as in their collection, even in their registration, storage, modification, communication, cancellation, and/or dissemination and will be made both with the use of paper support, both with the aid of electronic tools informatic and telematic or in any case innovative, according to methods and with suitable tools to guarantee the security and confidentiality of the Data, in compliance with the provisions of articles 31 and following of Legislative Decree no. 196/2003, concerning "minimum security measures for the processing of personal data". In particular, all technical, IT, organizational, logistic and procedural security measures will be adopted, as required by Legislative Decree no. 196/2003, "Attachment B" (so called “Technical Disciplinary”), as well as by the various measures issued after integration, so that at least the minimum level of Data protection required by law is guaranteed. Furthermore, the applied methodologies guarantee that access to the Data is allowed only to the persons in charge of the processing.

13. Place and time of processing of the collected Data
The Data are processed at the operational headquarters of the Data Controller and in any other place where the subjects involved in the processing are located. For more information, please contact the Owner.
The Data are processed for the time necessary to perform the Service requested by the User, or required by the purposes described in this document, and the User can always ask for the interruption of treatment or deletion of Data.

14. Purposes of the processing of collected Data
Unless the communication of Personal Data is imposed by legal obligations or is strictly pertinent and necessary for the fulfillment of requests or contractual obligations for the execution of the Service, Personal Data is provided voluntarily and optionally by Users at the time of activation of the Service. Personal Data may be entered voluntarily by the User or collected automatically during the use of this App. The User assumes the responsibility of the Personal Data of third-subjects published or shared through this App and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third-subjects. The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Commercial Affiliation, Content Commentary, Contacting the User, Interaction with external social networks and platforms, Analytics, Displaying Content from external platforms, Payment management, Address management and sending of email messages, Advertising, Remarketing and Behavioral Targeting, Backup and Heat mapping. The types of Personal Data used for each purpose are indicated in the specific sections of this document, below.
            - Contact the User
            Contact form
            By filling out the contact form with his/her Data, the User consents to their use to respond to       requests for information, quotes, or any other kind indicated by the form header. Personal         Data collected: Surname, Name, Mail, City.
            Mailing List or Newsletter
            By registering with the mailing list or the newsletter, the User's mail address is             automatically added to a list of contacts to which mail messages containing information,    including commercial and promotional information, relating to this Website may be          transmitted. User mail could also be added as a result of registration to this App or      after making a purchase. Personal Data collected: mail and name.
            - Address management and sending of e-mail messages
            These services allow you to manage a database of mail, telephone or any other contacts,         used to communicate with the User. These services may also allow the collection of Data      relating to the date and time the messages are displayed by the User, as well as to the User's           interaction with them, such as information on clicks on links inserted in the messages.
            - Interaction with social networks and external platforms
            These services allow interaction with social networks, or other external platforms, directly           from the pages of this App. The interactions and information acquired by this      Application are in any case subject to the User's Privacy settings relating to each social network. In the case where an interaction service with social networks is installed, it is      possible that, even if the Users do not use the service, the same collect traffic Data relating           to the pages in which it is installed.
            "Like" button and Facebook social widgets (Facebook, Inc.)
            The "Like" button and Facebook social widgets are services of interaction with the       Facebook social network, provided by Facebook, Inc. Personal Data collected: cookies and     Usage Data.
            Place of processing: USA - Privacy Policy.
            Tweet button and Twitter social widgets (Twitter, Inc.)
            The Tweet button and the social widgets of Twitter are services of interaction with the       Twitter social network, provided by Twitter, Inc. Personal Data collected: cookies and Usage       Data.
            Place of processing: USA - Privacy Policy.
            +1 button and Google+ social widgets (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: cookies and Usage Data.
            Place of processing: USA - Privacy Policy.
            Button and social widgets of Linkedin (Linkedin Corporation)
            The button and social widgets of Linkedin are services of interaction with the social network            Linkedin, provided by Linkedin Corporation. Personal Data collected: cookies and Usage            Data.
            Place of processing: USA - Privacy Policy.
            - Remarketing and Behavioral Targeting
            These services allow this Application and its partners to communicate, optimize and serve        advertisements based on the past use of this Application by the User. This activity is carried        out through the tracking of Usage Data and the use of cookies, information that is      transferred to the partners to whom the activity of remarketing and behavioral targeting is           connected.
            AdWords Remarketing (Google Inc.)
            AdWords Remarketing is a Remarketing and Behavioral Targeting service provided by    Google Inc. that links the activity of this Application with the Adwords advertising network   and the Doubleclick Cookie. Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            Twitter Remarketing (Twitter, Inc.)
            Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter,      Inc. that connects the activity of this Application with the Twitter advertising network. Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            Remarketing with Google Analytics for display advertising (Google Inc.)
            Google Analytics for display advertising is a Remarketing and Behavioral Targeting service        provided by Google Inc. that links the tracking activity carried out by Google Analytics and       its Cookies with the Adwords advertising network and the Doubleclick Cookie. Personal           Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            Facebook Remarketing(Facebook, Inc.)
            Facebook Remarketing is a Remarketing and Behavioral Targeting service provided by    Facebook, Inc. which connects the activity of this Application with the Facebook advertising network. Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            Facebook Custom Audience (Facebook, Inc.)
            Facebook Custom Audience is a Remarketing and Behavioral Targeting service provided by    Facebook, Inc. which connects the activity of this Application with the Facebook advertising network. Personal Data collected: cookies and mail.
            Place of processing: USA - Privacy Policy - Opt Out.
            DoubleClick for Publishers Audience Extension (Google Inc.)
            Doubleclick for Publishers Audience Extension is a Remarketing and Behavioral Targeting        service provided by Google Inc. that tracks visitors to this Application and allows selected           advertising partners to show them personalized ads within the Web. Personal Data collected:        cookies and Data of use.
            Place of processing: USA - Privacy Policy - Opt Out.

            Google AdWords Conversion Tracking is a statistics service provided by Google Inc. that          links Data from the Google AdWords network with actions taken within this Application.         Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy
            Tracking Twitter Ads Conversions (Twitter, Inc.)
            Twitter Ads Conversions Tracking is a statistics service provided by Twitter, Inc. that links         Data from the Twitter ad network with actions performed within this Application. Personal            Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy.
            Google Tag Manager (Google Inc.)
            Google Tag Manager is a statistics service provided by Google Inc. Personal Data collected:        cookies and Usage Data.
            Place of processing: USA - Privacy Policy.
            - Comment of contents
            The comment services allow Users to formulate and make public their comments regarding        the content of this Application. Users, according to the settings decided by the Owner, can           leave the comment also anonymously. In the case of Personal Data issued by the User there         is a mail, this could be used to send notifications of comments regarding the same content.         Users are responsible for the content of their comments. In the event that a comment service       provided by third-subjects is installed, it is possible that, even if the Users do not use the           comment service, the same collect traffic Data relating to the pages in which the comment         service is installed. .
            - Display of content from external platforms
            These services allow to view content hosted on external platforms directly from the       pages of this Application and interact with them. In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, the same collect traffic Data relating to the pages in which it is installed.
            Youtube Video Widget (Google Inc.)
            Youtube is a video content visualization service managed by Google Inc. that allows this      Application to integrate such contents within its pages. Personal Data collected: cookies and            Usage Data.
            Place of processing: USA - Privacy Policy.
            Vimeo (Vimeo, LLC)
            Vimeo is a video content visualization service managed by Vimeo, LLC that allows this      Application to integrate such contents within its pages. Personal Data collected: cookies and     Usage Data.
            Place of processing: USA - Privacy Policy.

15. Cookies
The App uses cookies that the Guarantor Authority defines as small text strings that the sites visited by the User send to their terminal (usually the browser), where they are stored before being re-transmitted to the same sites at the next visit of the same User. During the navigation on the App, the User can receive on his terminal also cookies that are sent from different websites or web servers, on which some elements (images, maps, links etc.) can be found on the site that the User is visiting. The User, at the first access, has the possibility to confirm the installation or not of cookies available, or alternatively, to view the Cookie policy http://www.levantech.it/ciceros_privacy_en.html, containing all the modes of manifestation and denial of consent and to which reference is made in full.

16. Defense in judgment and Exercise of rights by Users
The User's Personal Data may be used for the defense by the Owner in court or in the stages leading to its eventual establishment, against abuse in the use of the same or related services by the User. The User declares to be aware that the Data Controller may be required to disclose the Data at the request of the public authorities.
The subjects to whom the Personal Data refer have the right, at any time, to obtain confirmation of the existence or otherwise of the same with the Data Controller, to know its content and origin, to verify its accuracy or request's integration, cancellation, updating, correction, transformation into anonymous form or blocking of Personal Data processed in violation of the law, and to oppose in any case, for legitimate reasons, to their processing. Requests should be addressed to the Data Controller. This App does not support "Do Not Track" requests. To find out if any third-subject services used support them, please consult the respective Privacy policy.

17. Applicable law, Jurisdiction and Online dispute resolution for Consumers
All disputes arising in connection with the use of the Website as well as the execution, interpretation and validity of this document are subject to Italian law and to the exclusive jurisdiction of the court of the place in which the Data Controller is located (Court of Bari). If the User is a Consumer, pursuant to Article 3 of the Consumer Code, the mandatory territorial jurisdiction lies with the judge of the place of residence or domicile of the Consumer, if located in the territory of the Italian State, without prejudice to the right to Consumer/User to refer a court other than the "consumer forum", pursuant to art. 66 bis of the Consumer Code, competent for the territory according to one of the criteria set forth in articles 18, 19 and 20, Code of Civil Procedure. The Consumer/User residing in Europe must be aware of the fact that the European Commission has established an online platform that provides an alternative dispute resolution tool. This tool can be used by the Consumer/User to resolve in a non-judicial manner any dispute relating to and/or deriving from contracts for the sale of goods and services stipulated on the network. Consequently, the Consumer/User can use this platform for the resolution of any dispute arising from the online contract stipulated with the Owner. The platform is available at the following address: http://ec.europa.eu/consumers/odr/.

18. Changes to the Privacy policy
The Data Controller reserves the right to make changes to this Privacy policy, at any time, by giving notice to Users on this page. Therefore, please consult this page often, referring to the date of the last modification indicated at the bottom. In case of non-acceptance of the changes made to this Privacy policy, the User is obliged to cease using this App and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous Privacy policy will continue to apply to Personal Data collected up to that time. Of all the changes will be given timely indication on http://www.ciceros.it.

19. Accuracy of information
The information on the Website is as comprehensive and up-to-date as possible. However, LEVANTECH S.r.l. assumes no responsibility for the correctness, completeness and updating of the information itself. LEVANTECH S.r.l. furthermore reserves the right to make any changes to the Website and to the information contained therein, at any time and at its own discretion. Links that appear on the Website may refer to sites owned and/or managed by third-subjects. Who decides to visit a site linked to that of LEVANTECH S.r.l. all relative risks are assumed. LEVANTECH S.r.l. does not guarantee and can not be held responsible for the information contained in these linked sites.

20. Responsibility
LEVANTECH S.r.l. and the respective directors, employees, collaborators and/or agents exclude any responsibility for any damage of any nature that may occur to visitors and/or to third-subjects, arising and/or related in any way from the use and/or inability to use and/or the unavailability of the Website or any site related to the Website and/or the material contained therein. Access to the Website is subject to the use of appropriate protection systems against viruses or other malicious components and software. Visitors then raise LEVANTECH S.r.l. from any liability for loss and/or damage caused by viruses or other components and software contracted as a result of the use and/or navigation of the Website and/or after downloading material from the Website and/or from linked sites.

21. Users' rights and questions
Users have the right to contact LEVANTECH S.r.l. for any information on their Personal Data, to obtain confirmation of the existence or otherwise of such Data and to know its content and origin, verify its accuracy or request its integration or updating, or correction, deletion, transformation into anonymous form or blocking of those Data that are treated in violation of the law, as well as to oppose in any case, for legitimate reasons, to their treatment. Requests can be transmitted in the following ways: mail to be sent to: levantech.srl@gmail.com; or recommended to be sent to the registered office of LEVANTECH S.r.l.

COOKIE POLICY



This cookie policy applies to all Websites, branded pages on third-subject platforms (such as Facebook or YouTube) and to applications accessed or used through such third-subject Websites or platforms operated by or on behalf of LEVANTECH S.r.l. By using the Website, the User consents to the use of cookies in accordance with this policy on cookies. If the User does not accept this use of cookies, he/she must set his/her browser settings accordingly or we recommend that he/she does not continue to use the Website.

1. Definitions
-          Personal Data (or Data): any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.
-          Usage Data: information collected automatically from this Website (or from third-subject applications that this Website uses), including: IP addresses or domain names of the computers used by the User that connects with this App, the addresses in the notation URI (Uniform Resource Identifier), the time of the request, the method used in submitting 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 (good order, error etc.), the country of origin, the characteristics of the browser and 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 of the itinerary followed within the Website, with particular reference to the sequence of pages consulted, to the parameters relating to the operating system and to the User's IT environment.
-          User: individual who uses this Website, which must coincide with the interested subject or be authorized by him and whose Personal Data are being processed.
-            Interested: natural or legal person to whom the Personal Data refer.
-           Data Processor: natural person, legal person, public administration and any other body or association appointed by the Data Controller to process Personal Data, as established by this Privacy policy.
-          Data Controller: natural person, legal entity, public administration and any other body or association to which they are responsible, even together with other Data Controller, decisions regarding the purposes, methods of processing Personal Data and tools used, including the security profile, in relation to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.
-          Website: hardware or software tool through which the Personal Data of Users are collected.
-          Cookies: small portion of Data stored in the User's device.

2. What are cookies?
Cookies are a small portion of data stored in the User's device. Cookies, as defined by the Guarantor Authority, are small text strings that the applications visited by the User send to their terminal (usually to the browser), where they are stored before being sent back to the same applications at the next visit of the same User. The term "cookies" refers to both cookies, properly so-called, and all similar technologies. Cookies are used to access the online services more quickly and to improve User's browsing by monitoring sessions, storing User's information and uploading Content faster. A cookie, for example, allows the Website to recognize a User's device once a link has been created between the Web server and the Web browser. The main purpose of a cookie is to allow the Web server to present to the User customized web pages, which make the experience of visiting the LEVANTECH S.r.l. Website more personal and corresponding to his/her individual needs.

3. Use of cookies
This Website, mail messages, online services, advertising and interactive applications may use cookies to optimize the Services. The Website complies with the Provision No. 229 of May 8, 2013, "Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies", issued by the Guarantor for the Protection of Personal Data, which for clarity it reports partially: "the Guarantor (pursuant to articles 122, paragraph 1 and 154, paragraph 1, letter h) of the Code – for the purpose of identifying the simplified procedures for the disclosure that the Website operators, as better specified in the introduction, they are required to provide users in relation to cookies and other devices installed by or through their site – establishes that when you access the home page (or other page) of a Website, must immediately appear in the foreground a banner of appropriate size containing the following indications: a) that the Website uses profiling cookies in order to send advertising messages in line with the preferences shown by the user in the context of surfing the net; b) that the Website also allows the sending of third-subject cookies (where this obviously happens); c) the link to the extended information, which must contain the following additional information regarding: use of technical and analytics cookies; possibility to choose which specific cookies to authorize; possibility for the user to express his options regarding the use of cookies by the Website also through the browser settings, indicating at least the procedure to be performed to configure these settings; d) the indication that on the extended information page it is possible to refuse consent to the installation of any cookies; e) the indication that the continuation of navigation through access to another area of the Website or selection of an element of the same (for example, an image or a link) involves the provision of consent to the use of cookies; pursuant to art. 154, paragraph 1, letter c), of the Code - in order to maintain the responsibility of the Website operators, as better specified in the explanatory statement, than that of the third parties - prescribing to the same managers to acquire the connections already in the contract phase (link) to the web pages containing the information and the forms for acquiring the consent related to the cookies of the third parties (with this also meant the dealers)".

4. Types of cookies
Cookies can be:

• First subject Cookies: these are the proprietary cookies used by the Owner of the Website in order to allow the User to navigate more efficiently and/or monitor the actions exercised by the same;
• Third subject cookies: cookies are set by a Website other than the one User is currently visiting in order to allow him/her to navigate more efficiently and/or monitor the actions exercised by the same.

Furthermore, we distinguish different types of cookies:
-          Technical Cookies: used for the sole purpose of "transmitting a communication over an           electronic communications network, or to the extent strictly necessary for the provider of an       information society service explicitly requested by the subscriber or user to provide such          service" (Article 122, paragraph 1, Legislative Decree No. 196/2003). Technical cookies            include:
Session or Navigation cookies: they are used to track User activity on the Web. They guarantee the normal navigation and use of the Website, allowing for example to surf more quickly, to make a purchase or to authenticate to access restricted areas, and are in fact necessary for its proper functioning.
Functionality Cookies: allow the User to navigate according to a series of selected criteria (for example, the language, the Products selected for purchas  etc.), in order to improve the service provided.
           Analytical cookies of the first subject: similar to the regulatory technical cookies, if used directly by the Owner of the Website without profiling the User, but only to collect             information, in an aggregate and anonymous mode, the number of Users and how they visit         the Website for statistical purposes and to improve the performance of the Website.
            Third-subject analytical cookies: they are made available by third-subjects and are       assimilated to technical cookies if the third-subjects do not profiling the User, through the     use of appropriate tools to reduce the power of identification of cookies (for example, through the masking of significant portions of the IP address) and without crossing the    information gathered with others already available.
            For technical cookies only the release of the cookie policy is required without the need to            request consent (Article 13, Legislative Decree No. 196/2003).
-          Technical cookies and aggregated statistics: activities strictly necessary for the operation,       for which this Website uses cookies to save the User session and to perform other activities            strictly necessary for the functioning of the same, for example in relation to the distribution     of traffic; activities of saving preferences, optimization and statistics, for which this Website       uses cookies to save browsing preferences and optimize the User's browsing experience.     These cookies include, for example, those for setting the language and currency or for the       management of statistics by the owner of the Website.
-          Profiling cookies: they are used to monitor the User's Web browsing and to create a profile          of his habits:
            Profiling cookies of the first subject: installed by the Owner of the Website to create profiles related to the User, in order to send advertising messages in line with the             preferences shown during surfing the net. Given their particular invasiveness in the private       sphere of Users, the European and Italian legislation requires that the User must be           adequately informed about the use of the same, that express their consent and that the     notification is made to the Privacy Guarantor.
            Third subject profiling cookies: used by third-subjects who access the information in clear    text, therefore not in anonymous and aggregated mode, and cross them with other Data already in their possession. The Website does not have direct control of individual third-    subjects cookies and can not install them directly or delete them. The User is, therefore, invited to check the relevant information on cookies on the Website of the third-subjects. For      these cookies, the law requires that the User must be adequately informed about the use of           the same, that express their consent and that the notification is made to the Privacy          Guarantor by the person using the Data.

5. Third-subjects cookies
LEVANTECH S.r.l. can resort to third-subjects  advertisers, for advertising or in order to optimize communication related to marketing. Third-subjects advertisers use cookies to estimate the effectiveness of advertisements and to personalize advertising content. The information collected by third-subjects advertisers may include Data such as geolocation data (obtained from the IP address), or contact details such as the mail address when it is obtained through this Website.

6. List of cookies used on the Website
"Session cookies", "persistent cookies" and " third-subjects cookies" may be used on this Website. Session cookies are temporary cookies that remain on the device until User leaves the Website. Persistent cookies remain on the device for a long more time (depending on the duration of the specific cookie and browser settings) or until the User manually deletes it. When the User visits the Website, he/she may receive cookies from third-subjects websites or domains. Below is a list of cookies on This Website:
            - Site cookies
            Country: session cookies, type of functionality. It maintains information about the User's        country (which is identified by IP). The Website is used in the presentation on the main page        in order to determine and show specific images based on the User's location.
           Language: session cookies, type of functionality. It maintains the User's language, which is          identified on the basis of AcceptLangage HTTP (language, set by the browser settings) or    based on the language selection made manually by the User in the Website menu. This    cookie is used to identify the language of the User.
            Order: session cookies, type of functionality. It maintains specific order of slides in a      presentation. It is used in order to maintain the slide order: User can continue to look at the       photos from the one he has interrupted.
            Hide-cookie-policy-notice: defines if the cookie policy warning has been closed.
-          Session cookies
            Session cookies are temporary cookies that remain on the device until the User leaves the        CICEROS' Website.
            _CICEROS_session: session cookies, type needed. This is a session identifier, service            parameter.
            _session: #hash number (18 digits): session cookies, type of functionality. It is a session            identifier, which is created on the client's side. It is used as a namespace for two other   parameters (below) of the session. It is generated automatically.
            _session: # {} hash_number: slideshow_finished: session cookies, type of functionality. It           is a flag, which shows if a User has finished watching the presentation. It is used to identify     if we should continue to show the presentation or stop on the current slide.
           _session: # {} hash_number: current_slide: session cookies, type of functionality. This     cookie is a number of a current slide in a presentation. It is used to continue the presentation    with a correct slide (in cases where the page is reloaded).
-          Third-subjects cookies
            There are 4 third-subjects cookies on the Website, all generated by Google Analytics.
            _utma: persistent cookie. It stays on the device for 2 years since it was installed or updated.      It is used to distinguish Users and sessions. The cookie is created when the javascript library        is executed and there are no existing _utma cookies. The cookie is updated every time the           data is sent to Google Analytics.
            _utmb: persistent cookie. It stays on the device for 30 minutes since it was installed or      updated. It is used to determine new sessions/visits. The cookie is created when the         javascript library is executed and there are no existing _utmb cookies. The cookie is updated       every time the Data is sent to Google Analytics.
            _utmz: persistent cookie. It stays on the device for 6 months since it was installed or        updated. It stores the traffic source or the campaign that explains how the User has reached     the Website. The cookie is created when the javascript library is executed and is updated            every time the Data is sent to Google Analytics.

7. Cookie analytics with anonymized IP
For the purpose of continuous optimization of communication related to marketing, LEVANTECH S.r.l. employs Google Analytics analytical software by Google Inc. It allows User to follow online behavior at the level of time, geographic location and use of the Website. Google Analytics installs cookies to measure visits to the Website and any purchases made for analysis purposes. The IP address of the Users will be anonymized. For more information and to disable cookies, see the page: https://www.google.com/intl/it/policies/privacy/. In relation to third-subjects cookies, these may perform profiling activities of the User even without the knowledge of the Owner. For more information, please read carefully the Privacy policy of the services listed. The information in question is collected via tracking pixels and/or cookies. The information obtained is anonymous and will not be linked to Personal Data. All the information necessary for this analysis is stored on servers located in Italy. LEVANTECH S.r.l. will not share this information with third-subjects for independent use.

8. Other types of cookies or Third-subjects tools that could make use of them
Some of the services listed below collect statistics in aggregate form and may not require the consent of the User or could be managed directly by the Owner - depending on what is described - without the help of third-subjects. If among the tools indicated below there were services managed by third-subjects, these could - in addition to what is specified and also without the knowledge of the Owner - perform tracking activities of the User. For detailed information on this, it is advisable to consult the Privacy policy of the services listed.
            Advertising
            This type of service allows the Usage Data to be used for commercial communication          purposes in various forms of advertising, such as the banner, also in relation to the User's          interests. This does not mean that all Personal Data is used for this purpose. Data and      conditions of use are indicated below. Some of the services listed below may use cookies to        identify the User or use the behavioral retargeting technique, that is to display personalized      advertisements based on the interests and behavior of the User, also detected outside this        Application. To get more information about this, we suggest User to check the Privacy         information of the respective services.
            Google AdSense (Google)
            Google AdSense is an advertising service provided by Google Inc. This service uses the           "Doubleclick" Cookie, which tracks the use of this Application and the User's behavior in      relation to advertisements, products and services offered. The User can decide at any time           not to use the Cookie Doubleclick providing for its             deactivation:   http://www.google.com/settings/ads/onweb/optout.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            Criteo (Criteo SA)
            Criteo is an advertising service provided by Criteo SA.
            Personal Data collected: cookies and Usage Data.
            Place of processing: France - Privacy Policy - Opt Out.
            DoubleClick for Publishers (Google Inc.)
            DoubleClick for Publishers is an advertising service provided by Google Inc. with which the        Owner may conduct advertising campaigns jointly with external advertising networks with      which he has no direct relationship, other than as otherwise specified in this document.    Users who do not wish to be tracked by the different advertising networks can use             Youronlinechoices. For an understanding of the use of data by Google, please see the      Google Partner Policy. This service uses the "Doubleclick" cookie, which traces the use and       behavior of the User in relation to advertisements, products and services offered. The User     can decide at any time not to use the cookie Doubleclick providing for its deactivation:             www.google.com/settings/ads/onweb/optout?hl=it.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy.
            AppNexus (AppNexus Inc.)
            AppNexus is an advertising service provided by AppNexus Inc.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt out.
            Statistics
            The services contained in this section allow the Data 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 uses Personal          Data collected for the purpose of evaluating the use of This Website, compiling reports and            sharing them with other services developed by Google. Google may use Personal Data to     contextualise and personalize the advertisements of its advertising network.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.
            ComScore Analytics (ComScore, Inc.)
            ComScore Analytics is a statistical service provided by ComScore, Inc.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt out.
            Nielsen Audience Measurement (The Nielsen Company)
            Nielsen Audience Measurement is a statistical service provided by The Nielsen Company.
            Personal Data collected: cookies and Usage Data.
            Place of processing: USA - Privacy Policy - Opt Out.

8. Manifestation of consent
For cookies that require consent, at the first visit of the Website the User automatically displays a banner, containing both the link to this complete information and the request for consent to the use of cookies. The consent can be given by the User by clicking the OK button on the banner, by performing scroll actions on the page and/or by accessing other sections of the Website, by clicking on the links in the Web page below the banner itself.

9. Enabling and Disabling cookies and Similar technologies
Most browsers have the automatic acceptance of cookies by default. You can change the settings to block cookies or to notify the User when cookies are sent to the device. User can manage cookies easily, by referring to his/her browser's instructions or to the help screen for more information on how to adjust or change his/her browser settings. In case of acceptance of the cookies, subsequently, the User will have the possibility to refuse them, modifying the settings of the Internet browser. The User can find information and exercise his right to oppose the tracking of cookies in his browser to the following addresses:
Internet Explorer: http://windows.microsoft.com/it-IT/internet-explorer/delete-manage-cookies;
Google Chrome: http://support.google.com/chrome/answer/95647?hl=en;
Mozilla Firefox: http://support.mozilla.org/it/kb/Gestione%20dei%20cookie;
Opera: http://help.opera.com/Windows/10.00/it/cookies.html;
Apple Safari: http://support.apple.com/kb/PH19214?locale=it_IT.
In addition User can proceed with the cancellation of cookies by requesting the opt-out directly to third-subjects or through the site http://www.youronlinechoices.com/it, where he/she can manage the tracking preferences of most advertising tools.
Please note that some features and full functionality of this Website will not be available once the cookies have been disabled. If the User disables the cookies used, this could affect the navigation through CICEROS (for example, it may not be possible to visit certain areas of the Website or the User may not receive personalized information when visiting the Website). If he/she uses different devices to view and accessing the Website (for example, laptops, PCs, smartphones, tablets etc.), User will need to make sure that each browser on each device is adjusted to his/her preferences.

10. Changes
Any future changes to this policy will be reported on this page. It is suggested to regularly check the policy of LEVANTECH S.r.l. to check for updates and/or changes.

11. Legal references
This privacy statement is prepared in fulfillment of the obligations under art. 13 et seq., EU Regulation no. 679/2016 of 27 April 2016 (General Data Protection Regulation – GDPR), as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, concerning cookies. This privacy statement concerns exclusively this Website.

12. Users' rights and contacts
The User has the right, at any time, to exercise the rights recognized by the art. 7, Legislative Decree n. 196/2003. In particular, he/she may, among others, obtain a copy of the Data processed, their updating and origin, the purpose and method of processing, their rectification, integration, cancellation and/or transformation into anonymous form or blocking for the treatments in violation of the law and can oppose, for legitimate reasons, to the treatment. To exercise these rights or in case of questions, comments and requests related to this policy, contact with the following methods:
mail to be sent to: levantech.srl@gmail.com; or recommended to be sent to the registered office of LEVANTECH S.r.l.
Since the installation of cookies and other tracking systems operated by third-subjects, through the services used within this Website, can not be technically controlled by the Owner, any specific reference to cookies and tracking systems installed by third-subjects parts is to be considered indicative. To obtain complete information, consult the privacy policy of any third-subjects services listed in this document.
Given the objective complexity of identifying technologies based on cookies and their very close integration with the operation of the Web, the User is invited to contact the Owner if he/she wants to receive any further information on the use of cookies and any use of the same - for example by third-subjects - carried out through this Website.