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Cookie Policy

This page describes the procedures of website management regarding the processing of users’ personal data.
This information on privacy policy is provided pursuant to section 13 of Legislative Decree n. 196/2003 – Code Regarding Personal Data Protection to those interacting with the web services of this website.

Springlet Finance & Consulting Sa
Piazza Nuova 25
6537 Grono (GR) Svizzera
This email address is being protected from spambots. You need JavaScript enabled to view it.
T +41 91 225 15 26

The Data Controller is responsible for this privacy policy.

For any inquiries and/or to exercise your rights in compliance with section 7 of Legislative Decree n. 196/03, you can contact the Data Controller at the e-mail listed above.
The installation of cookies and other tracking systems operated by third parties, through the services used within this website, cannot be technically controlled by the Data Controller. Therefore, any specific reference to cookies and tracking systems installed by third parties is to be considered as indicative. For complete information, see the privacy policy of any third part services listed in this document.
Given the objective complexity related to the identification of cookies-based technologies and their integration with web functioning, the user is encouraged to contact the Data Controller in case he/she would like to receive in-depth information regarding the use of cookies and their possible usage, for example by third parts, through this website.
The information provided only applies to this website and does not concern any websites, which may be accessed through links.
The information on privacy policy is also based on the Recommendation n. 22001, which was adopted on 17 May 2001 by the European authorities for personal data Protection, within the Working Group established under Article 29 of the European Directive n. 95/46/EC. These guidelines define minimum requirements for the collection of personal data online as well as arrangements, timing and nature of the information to be provided by Data Controllers to users connecting to web pages, regardless the purpose of the connection.
The following list describes the contents that will be explained below:

  • the types of data that can be collected
  • how and for what purposes personal data will be handled
  • the consequences of refusing to provide personal details
  • who will be informed about personal data and if they will be disseminated
  • user rights

Among the data collected from this website, either independently or through third parts, there may be:

Navigation data
As part of their standard functioning, computer systems and software procedures relied upon to operate this website acquire personal data, whose transmission is implicit in the usage of Internet communication protocols.
Such information is not collected with the purpose of being associated with specific individuals; however its very nature might allow user identification, after being processed and matched with data held by third parts.
This category of data includes IP addresses or domain names of computers used by users connecting to the website, URI (Uniform Resource Identifier) addresses of requested resources, time of request, method used for submitting the request to the server, return file size, the numerical code indicating the server response status (successfully performed, error, etc.) and other parameters related to the user’s operating system and computer environment.
These data are only used to collect anonymous statistical information on the website usage as well as to check its correct functioning; they are deleted immediately after processing. The data may be used to ascertain responsibility in case computer crimes are committed against the website. Except for this circumstance, any data on web contacts is retained for no longer than seven days.
Data provided voluntarily by users
Among the data provided voluntarily in this website there can be: E-mail, First Name, Surname, Username, Password, Image, Gender, Date of Birth, Phone Number, Province, State, Country, Zip Code, City, Profession, VAT Number, Fiscal Code, Company Name, Workplace, Address, Fax Number, Data regarding Usage, Cookies.
An optional, explicit and voluntary sending of e-mail to addresses associated with this website entails the acquisition of the sender’s address, which is necessary to respond to requests, as well as of any other data voluntarily included in the message.
In case of specific summary information notices, they will be reported or displayed on the web pages dedicated to particular services on demand.
User’s failure to report certain personal data may prevent this website to provide its services.
The user is responsible for third parts’ personal information published or shared through this website and warrants to have the right to communicate or disseminate them, freeing the Data Controller from any liability towards third parts.
Processing arrangements
The Data Controller processes users’ personal data with the help of security measures designed to prevent unauthorized access, disclosure, modification or destruction of personal data. Data processing is performed with computer and/or telematics tools, organizational methods and following a logic that is strictly related to the purposes indicated. In addition to the Data Controller, data may be accessed, in some cases, by officers involved in the website organization or external parts (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies), which may be appointed as responsible for data processing by the Data Controller. The Data Controller can request an updated list of who is in charge of data processing.
Data is processed in the Data Controller’s operational headquarters, and in any other place where the parts involved in the processing are located. For more information, contact the Data Controller.
Data is processed within the time required to perform the service requested by the user, or required for the purposes described in this document. The user can ask the interruption of processing or the cancellation of data.
User’s personal data are collected to allow the Data Controller to provide its services, as well as for some of the following purposes:

  • Protection against SPAM
  • Contents’ comment
  • Registration and authentication
  • Statistics
  • Interaction based on location
  • Content’s visualization from external platforms
  • Contact the user
  • Management of addresses and sending e-mail
  • Interaction with Social Networks and external platforms

For more information, see the section “In-depth information on the Processing of Personal Data”.
Providing personal data is not compulsory, except for using the contact form or registering on the website where it is required to access certain services.
In the two cases mentioned above, failure to provide the required personal data may block the functioning of the contact form and/or the Registration process. The data provided during the Registration process are not granted to third parts. Their collection is intended only for sending informative e-mail.
Defence in court
User’s personal data may be used by the Data Controller for defence in court or in the stages leading to possible legal acton, from user’s usage abuses or related services.
The user declares to be aware that the Data Controller may be required to disclose data on public authorities’ request.
The types of personal data used for each purpose are provided in the section “In-depth information on the Processing of Personal Data” of this document.
Cookies are pieces of code installed in the browser that assist the Data Controller in providing a service according to the described purposes. In some cases, the installation of cookies may also require the user’s consent.
Technical cookies
These cookies are used to fulfil the navigation or to provide a service requested by the user. They are not used for other purposes and are normally installed directly by the owner of the website. Certain operations might not be performed without such cookies.
To install these cookies users are not required to give their prior consent, while it is compulsory to provide the information pursuant to article 13 of the Code, which the website manager may provide in the ways considered as most appropriate – in case he/she uses only such devices.
Data profiling cookies
These cookies are used to track the users’ web navigation and to create profiles on their tastes, habits, choices, etc. Advertising messages can be transmitted with these cookies to users’ terminal according to the preferences they have already expressed when navigating online.
article 122 of the Code refers to these cookies, where it considers that “the storage of information in a contractor’s or user’s terminal, or the access to information already stored are only allowed under the condition that the contractor or the user has given the consent – after being informed with the simplified arrangements pursuant to article 13, paragraph 3?(art. 122, paragraph 1, of the Code).
The collected data do not identify the user of the website, but they are used only to obtain statistical information about navigation: visited pages, time spent on the website, browser used, geographic data.
In case the user wants to deny cookies installation performed by Google Analytics on his/her terminal, it is possible to install the following additional browser.
Users’ Rights regarding Privacy
Users have the right to obtain confirmation from the Data Controller about the existence of personal data concerning them; to know the contents and origin of data, to verify their accuracy or request an integration; to cancel, update, correct personal data or to convert their status into anonymous; to block personal data if treated unlawfully and oppose to their processing in any case for legitimate reasons. Requests should be addressed to the Data Controller as described above.
Users’ Rights regarding Cookies
In addition to what is stated in this document, the user can manage cookies preferences directly within his/her own browser and prevent, for example, third parts from installing them.
Through browser preferences, the user can also delete cookies installed in the past, including the ones in which the installation consent was saved by this website.
It is important to note that disabling all cookies may mean to compromise the functioning of this website.
It is possible to find information about how to manage cookies in one’s browser at the following addresses:
Chrome, type “chrome://settings/content” in the address bar (without quotation marks) and change cookies settings as preferred.
Safari, select “Preferences” and then “Privacy”. In the section Block Cookie, specify how Safari has to accept cookies from websites.
Internet Explorer: click on “Tools” in the menu bar and then on “Internet Options”. Afterwards, access the “Privacy” tab settings to change preferences regarding cookies.
Firefox, click on “Tools” in the menu bar and then on “Options”. afterwards, access “Privacy” to change preferences regarding cookies.
Safari Mobile, go to “Settings” and then find “Safari” on the left menu. From here, click on “Privacy and Security” to manage Options on cookies.
To disable cookies from external services it is necessary to operate on their settings.
The following list describes the major services used; for other ones please consult the list of services in the section “In-depth information on the Processing of Personal Data” and access each individual policy to disable cookies:

  • Google
  • Facebook
  • Twitter
  • Pinterest

In-depth information on the Processing of Personal Data
What follows is a detailed explanation of the purposes for which personal data and the services used for their collection can be requested:
These services allow the Data Controller to monitor and analyze traffic data and are used to track the user’s behavior.
Google Analytics – Google Analytics is a web service of analysis provided by Google Inc. (“Google”). Google uses the personal data collected with the purpose of evaluating the use of this Application, of filling out reports and share them with other services developed by Google. On this website Google Analytics is set up to turn the user’s IP address anonymous. Personal data collected: Cookies and Data regarding Usage. Place of processing: USA – Privacy Policy — Cookie Policy
Interactions based on location
Non-continuous geolocation – The user’s geographical location occurs in a non-continuous way if requested by the user or when the user does not indicate the place where he/she is in the specific entry and does not allow the Application to Automatic detect the position. Personal data collected: Geographic location.
Displaying content from external platforms
These services allow to view contents hosted on external platforms directly from the pages of this website as well as to interact with them. In case this type of service is installed, it is possible that, even if the users do not use it, the service collects traffic data relating to the pages in which it is installed.
Google Fonts – Google Fonts is a service of font styles displaying run by Google Inc. that allows this website to integrate such contents within its pages. Personal data collected: Cookies and Data regarding Usage. Place of processing: USA – Privacy Policy – Cookie Policy
Widget Google Maps – Google Maps is a service of maps displaying run by Google Inc. that allows this website to integrate such contents within its pages. Personal data collected: Cookies and Data regarding Usage. Place of processing: USA – Privacy Policy
Widget Video Youtube – Youtube is a service of video content viewing managed by Google Inc. that allows this website to integrate such contents within its pages. Personal data collected: Cookies and Data regarding Usage. Place of processing: USA – Privacy Policy
Addresses and sending e-mail
These services enable the management of a database containing e-mail, phone or any other types of contacts used to communicate with the user. They may collect data relating to the date and time the user displays messages, as well as user’s Interaction with them – such as information on the clicking of links included in the messages.
Contact form
By filling out the contact form with personal data, users give consent to their use in response to a request of information, budget estimation, or as stated in the form’s heading. Personal data collected: Surname, E-mail, Name, Phone number and various types of data as specified by the privacy policy of the service.
Interaction with social networks and external platforms
These services enable the pages of this website to directly interact with social networks or other external platforms. Interactions and information acquired by this website are in any case subject to the user’s privacy settings related to each social network. In case a service of Interaction with social networks is used, it is possible that, even if users do not use it, the service collects traffic data about the pages in which it is installed.

Additional information on data processing
System log and maintenance
Out of necessities related to functioning and maintenance, this website and any third party services it uses may collect system Log – these are files that record interactions, which may also contain personal data, such as the user’s IP address.
Information not included in this policy
In relation to the processing of personal data, further information can be requested to the Data Controller by using the contact information mentioned above.
Changes to the privacy policy
The Data Controller reserves the right to make changes to this privacy and cookie policy at any time by notifying users of this page. Therefore, please check this page often and use as reference the date of last modification indicated below. In case users do not accept the changes to privacy and cookie policy, they have to stop using this website and, if considered appropriate, require that the Data Controller removes their personal data. Unless otherwise specified, the previous privacy and cookie policy will continue to be applied to personal data collected until this moment.