Privacy Policy
1. Data Controller
The Data Controller is Algorethics, in the person of the legal representative pro tempore, with registered office in 128 City Road, London, England, EC1V 2NX.
2. Type of data processed
Browsing Data
During normal operations, the computer systems and software procedures used for the functioning of the website acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols (internet domain and IP protocol, type of browser and computer operating system used, date, time and length of time spent on site, pages viewed, the search engine used to enter the website). This information is not collected to be associated with identified subjects, but by its very nature could, by processing and association with data held by third parties, allow users to be identified.
IP address or domain names of the computers used by the Users connecting to the website, URI (Uniform Resource Identifier) addresses of requested resources, the request time, the method used when making the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc) and other parameters regarding the operating system and the User's IT environment are all included in this category. These data are used solely to obtain anonymous statistical information regarding the use of the website and will be deleted immediately after processing, unless required for the ascertainment of crimes by the Judicial Authorities.
3. Processing of Users' Data
The Data Controller guarantees that the Users’ data are processed in full observance of the current data protection legislation.
Personal data acquired by Algorethics will be processed by expressly authorized people, appointed by the Data Controller, in full observance of the principles of correctness, legality, transparency, protection of confidentiality and the data subject’s rights. Algorethics will only process the data subject’s information for the period strictly necessary for the pursuit of the processing purpose, in full observance of the storage obligations established by law.
Personal data will be processed with the aid of information/computerized or paper instruments, with a guarantee of the use of suitable technical and organizational safety measures, pursuant to and in accordance with article 32 Regulation (EU) 2016/679, that can reduce the risk of destruction, loss, unauthorized access or non-permitted/non-compliant use with regard to the relative collection.
4. Data Processing Purposes
Purpose of the processing Registration of the User profile
Personal data: email address, password (stored only as a salted hash) and preferred language, processed by Algorethics to create the User profile needed to access the services offered by the Website.
Legal basis of the processing: Performance of the service requested by the User (Article 6 paragraph 1, letter b) EU Reg. 2016/679).
Consequences of refusal: Without these data the User cannot register on the Website and access the services offered by Algorethics.
Duration of the treatment: For the entire duration of the User's registration. The profile is deleted when the User deletes the account (Settings) or asks for its deletion.
Purpose of the processing Data Maturity Assessment and benchmark
Personal data: business email, company name and website, country, industry, business unit, job title and, if provided, number of employees, revenue and holding company, together with the answers to the assessment.
Purposes: (a) to calculate the result of the assessment and make it available to the User (results page, PDF and email); (b) to calculate anonymous, aggregated benchmark statistics (for example by country, industry and year); (c) to show the company view: the averages of the respondents with the same business email domain, shown only to colleagues who took the assessment with an email of that domain and only when at least 3 colleagues completed it. The company view never shows individual answers or the names of the colleagues.
Legal basis of the processing: Performance of the service requested by the User for (a) and (c) (Article 6 paragraph 1, letter b) EU Reg. 2016/679); legitimate interest in producing an anonymous benchmark for (b) (Article 6 paragraph 1, letter f) EU Reg. 2016/679).
Duration of the treatment: For the entire duration of the User's registration. When the account is deleted, the assessments are anonymised: emails, company name, website, job title and business unit are removed. The anonymous answers remain in the benchmark statistics and are no longer part of any company view.
Purpose of the processing Sending communications and/or newsletters relating to the activities carried out by Algorethics
Personal data: Sending the User of e-mails and/or newsletters relating to the activities and initiatives promoted and organized by Algorethics (training events, conferences and webinars) and/or containing informative material or report.
Legal basis of the processing: Consent of the Data subject (Article 6 paragraph 1, letter a) EU Reg. 2016/679).
Consequences of refusal: Impossibility to send information to the User and to update the latter on the activities and initiatives promoted by Algorethics
How to give or withdraw consent: with the dedicated option in the assessment form, and at any time in the Settings page of the User profile or by email to the address below. Consent is optional and is not a condition for using the services.
5. Scope of data communication
Who can see the assessment data
The individual results of an assessment are visible to the User who took it, to the benchmark administrators and to the staff appointed for the country of the assessment (Country Admin and Consultant roles). Outside the User list of the administrators, the emails of the respondents are always shown masked (*@domain). Other Users only see the aggregated company view described in section 4.
Service providers
The personal data may be communicated to public, institutional or professional entities authorized by law to request their acquisition, and to third-party companies or professionals that Algorethics uses for its activity, such as IT service providers (website hosting by Netsons, in Italy, and email delivery), accounting, tax and legal consultants. These third parties, unless they act as Data Controllers, have the role of Data Processors, in accordance with Art. 28 of EU Reg. 2016/679, by virtue of a specific contractual agreement. The list of third parties is available upon express request sent to Algorethics at the address indicated at the end of this privacy policy.
Chat assistant
The chat assistant shown on the pages of the Website is provided by FIT Strategy. The messages typed in the chat are sent to the provider to generate the answers and are processed according to the provider's terms. Please do not enter personal or confidential information in the chat.
Transfers outside the European Union
Google Analytics (Google), used only with the User's consent, and the Google Fonts service used to display the text of the Website may process data, such as the IP address, outside the European Union, including in the United States, on the basis of the EU-U.S. Data Privacy Framework and the Standard Contractual Clauses adopted by the European Commission.
6. Cookies
Cookies are short text strings (usually in .txt o .xml) sent by a web server to the User’s browser, stored by the latter on the browsing device and automatically re-sent to the server during the same visit to the website (session cookies) or at the next access (persistent cookies). Cookies store information about visitors’ preferences to improve the functionality of the website and simplify navigation, automating procedures (e.g., login, website language).
Based on the characteristics of the cookies, they can be:
Persistent cookies: these cookies remain stored, until their respective expiry dates, on the user/visitor's device. They are used to facilitate navigation within the Website and proper use of the latter, to facilitate access to services that require login (avoiding that users must re-enter their login credentials each time they access the services), for statistical purposes, to know which areas of the website have been visited, and, in some cases, for optimal management of advertising spaces and pages or to provide content and advertising in line with the choices made by visitors.
Session cookies: these cookies remain active for the reference session only, i.e., until the browser is closed. They are used to transmit session identifiers necessary to allow the safe and efficient exploration of the website.
First-party cookies: these can be either persistent or session cookies; they are generated and managed by managers who are not part of the Website visited by the user and are used, for example, to find out the number of pages visited on the same website (so-called "statistical cookies" or "analytics cookies") or to publish content or advertising on the website you are visiting. Third-party cookies include those related to external domains such as social media plugins from Facebook, Twitter, Google+ and LinkedIn. The presence of these plugins involves the transmission of cookies to and from the websites managed by third parties. The management of information acquired by third parties is governed by the relevant privacy policies.
Third-party cookies: these can be either persistent or session cookies; they are generated and managed by managers who are not part of the Website visited by the user and are used, for example, to find out the number of pages visited on the same website (so-called "statistical cookies" or "analytics cookies") or to publish content or advertising on the website you are visiting. Third-party cookies include those related to external domains such as social media plugins from Facebook, Twitter, Google+ and LinkedIn. The presence of these plugins involves the transmission of cookies to and from the websites managed by third parties. The management of information acquired by third parties is governed by the relevant privacy policies.
According to their main purposes, cookies may be:
Technical cookies: these are necessary for the Website to work (for example the login session, the language and the cookie choice) and do not require consent.
Analytics cookies: these are used to collect statistics on the use of the Website, such as the number of visitors and the pages visited. They are used only with the User's consent.
Profiling cookies: profiling cookies are designed to create profiles of the User and are used to send advertising messages in line with the preferences expressed by the same during web browsing. Users' prior consent is required for the installation of such cookies.
This Website uses technical cookies and, only with the User's consent, Google Analytics cookies for statistics. It does not use profiling cookies. Google Analytics is loaded only after the User allows the cookies in the banner. The choice can be changed at any time with the "Cookie settings" link at the bottom of each page.
| Cookie | Purpose | Type | Duration | Required / Optional |
|---|---|---|---|---|
| Login session | Keeps the User signed in | Persistent - Technical | 30 days | Required |
| Login security | Protection of the login form and return to the requested page | Session - Technical | Session | Required |
| Language | Language of the Website chosen by the User | Persistent - Technical | 1 year | Required |
| Cookie Banner Consent | Choice made in the cookie banner | Persistent - Technical | 6 Months | Required |
| Google Analytics 4 | Website statistics | Persistent - Analytics (Google) | Up to 2 years | Optional - only after consent |
Local storage: while an assessment is in progress, the answers of the current section are also saved in the browser (local storage), so that they are not lost if the page is reloaded. They are removed when the assessment is completed.
The User has the right to deactivate/block cookies by following the instructions provided by the browser (generally found in the "Help", "Tools" or "Edit" menus), it being understood that failure to provide consent/deactivation of technical cookies could compromise access to the contents of the Website.
The final cancellation of a cookie or of a category of cookies must be carried out directly by accessing the browser, since the mere deactivation does not determine the elimination of cookies from the browser itself. To delete, disable or reset cookies on your computer, User may use the cookie configuration pages provided by third-party content providers, or their browser options.
Third-party disclosure list:
- Google (Google Analytics, Google Fonts): https://policies.google.com/privacy
- FIT Strategy (chat assistant)
Below are instructions on how to manage cookies in relation to the most popular browsers:
- Internet Explorer:https://support.microsoft.com/en-us/kb/278835
- Chrome:https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647
- Safari:https://support.apple.com/kb/PH17191?viewlocale=en_US&locale=en_US
- Firefox:https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Opera:https://www.opera.com/help/tutorials/security/cookies/
For more information on cookies and to manage preferences regarding cookies (first and/or third-party), Users are invited to visit the website www.youronlinechoices.com.
7. Rights of the data subject
In accordance with the provisions of articles 15 et seq. of EU Reg. 2016/679, the Users may at any time exercise towards the Data Controller their rights, as follows: "Right of access" which allows the data subject to access their personal data and obtain a copy thereof; "Right of rectification" which allows the data subject to obtain the rectification of their data, if they are inaccurate, or the integration of their data, if they are incomplete; "Right to erasure" which allows the data subject to obtain the erasure of their data in the cases provided for by art. 17 of EU Reg. 2016/679; "Right to restriction of processing" which allows the data subject to obtain the restriction of processing in the cases provided for by art. 18 of EU Reg. 2016/679; "Right to data portability" which allows the data subject to receive in a structured, commonly used and machine-readable format, their personal data as well as to request the transmission of such data, by Algorethics, to another Data Controller; "Right to object" which allows the data subject to object, at any time, for reasons related to his/her personal situation, to the processing of personal data concerning him/her carried out pursuant to art.6 par. 1 lett. e) or f) of EU Reg. 2016/679, as well as to object to the processing of data carried out for direct marketing purposes; "Right to lodge a Complaint" which allows the data subject to lodge a complaint with the Italian Data Protection Authority pursuant to and for the purposes of art. 77 of EU Reg. 2016/679.
For the purposes of exercising the rights referred to in articles 15 et seq. of EU Reg. 2016/679, or to obtain further information on the Privacy Policy, the data subject may contact Algorethics by registered letter with return receipt or contact the Data Controller by sending an email to the following address info@embrace-transformation.com.
Please note that before we can provide or change any information, we may need to verify the identity of the data subject.
8. Changes to the Privacy Policy
Algorethics reserves the right to modify, update, add or remove parts of this Privacy Policy at its discretion and at any time. The data subject is required to periodically check for any changes. In order to facilitate this verification, the Privacy Policy will contain the date of the last update.
It is expressly specified that Algorethics is in no way liable for the contents and services provided by websites managed by third parties and accessible through links on the Website
9. Legal Compliance
We comply with the General Data Protection Regulation (GDPR) and are committed to upholding the privacy rights of our users.
10. Contact Us
For more information or if you have questions about our privacy practices, please contact us at info@embrace-transformation.com