Privacy and cookie policy


As required by European Union Regulation n.679/2016 ("GDPR") and in particular in Article 13, below we provide the information required by law regarding the processing of personal data.

This information is provided to users who interact with the web services of the Site ("Data Subjects") not only to comply with legal obligations, but also because transparency and fairness towards data subjects is a fundamental part of our business.

1. Roles in data processing

The Data Controller pursuant to article 4, paragraph 7 of the GDPR is



Sede legale

Via Trentola 205, 80056, Ercolano, NA Italia


VAT Number:


Contact details:


owner of the website www …………, defines the basis on which we collect, process and protect your referred personal data.

The processing of personal data will be based on principles of correctness, lawfulness and transparency and will be carried out by protecting the fundamental rights and freedoms of the data subject in compliance with current legislation on the security and protection of personal data (GDPR).

2. Data category

Pursuant to Article 4 of the GDPR, personal data are defined as any information relating to an identified or identifiable (idata subject) natural person, directly or indirectly, with particular reference to an identifier such as a name, an identification number, data relating to location, an online identifier or one or more characteristic elements of your physical, physiological, genetic, psychic, economic, cultural or social identity.

In this case, it concerns the personal data of users who access this Website and which are collected, through the registration form, in order to participate in the Events (name, surname, email address, telephone number), (of hereinafter "Personal Data") which are provided voluntarily by the user.

3. Provision of data

Personal data will be acquired directly from the data subject, through:

3.1) Direct conferment of the same

3.2) Automatic acquisition

(sections 4 "Navigation data" and 5 "Cookies" or similar technologies).

4. Navigation data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data (such as IP addresses or domain names of the computers used by users, the pages visited and the date/time of the visit) whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subject but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

These data, recorded anonymously, are used for the sole purpose of obtaining statistical information on the use of the Site and to check its correct functioning.

The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site.

5. Cookies

To make navigation on this site more efficient and immediate, cookies are used when users access this website: small text strings that allow you to maintain a connection to the site.

This section illustrates the characteristics and purpose of the cookies we use, as well as the instructions for denying consent to their use. What are cookies: Cookies are small alphanumeric strings that are sent by the websites that the user visits and stored on the physical unit of his terminal to then be re-transmitted to the same websites at the next visit.

In application of the "Cookie Guidelines and other tracking tools", Provision of the Guarantor for the Protection of Personal Data n.231 of 10 June 2021.

The types of cookies we use

We use various types of cookies in order to optimize the use of our site:

-Technical cookies: These are cookies used for the sole purpose of "carrying out the transmission of a communication over an electronic communications network, or as strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service”. These include navigation, analytical and functionality cookies. Attention: disabling these cookies can compromise the full functionality of the site, limiting its interactivity.

Anonymous statistics services
The services in this section allow the Owner to process and manage statistics anonymously thanks to the use of first-party Tracking Tools.

Google Analytics with anonymized IP (Google LLC)
Google Analytics is a web analytics service provided by Google LLC ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.

Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened within the United States.

Personal Data processed: Usage Data and Tracking Tools.

Place of processing: United States -  Privacy Policy.


There are various ways to manage preferences relating to Trackers and to give or withdraw consent, where necessary:

Users can manage Tracker preferences directly through their device settings - for example, they can prevent the use or storage of Trackers.

In addition, whenever the use of Trackers depends on consent, the User can give or withdraw this consent by setting their preferences in the cookie information or by updating these preferences via the tracking settings widget, if present.

Thanks to specific browser or device functions, it is also possible to remove previously saved Trackers.

Other Trackers present in the browser's local memory can be removed by deleting the browsing history.

As regards third-party Tracking Tools, Users can manage preferences and revoke consent by visiting the relevant opt-out link (if available), using the tools described in the third party's privacy policy or by contacting it directly.


Users can, for example, find information on how to manage Cookies in some of the most popular browsers at the following addresses:

Users can also manage some Trackers for mobile applications by disabling them through the appropriate device settings, such as the mobile advertising settings or general tracking settings (Users can consult the device settings to identify the relevant one).

Consequences of refusal of consent

Users are free to decide whether or not to give consent. However, please note that Trackers allow this Application to provide a better experience and advanced features to Users (in line with the purposes outlined herein). Therefore, in the absence of the User's consent, the Owner may not be able to provide the related functions.

6. Processing methods and purposes

The processing of Personal Data will take place using manual or electronic methods suitable to guarantee, in relation to the purposes for which they were communicated and collected, security and confidentiality, as well as to avoid unauthorized access to the data, for the time strictly necessary to achieve the purposes for which they were collected.

Apart from what is specified for cookies, the Personal Data provided by users are processed for the following purposes:

  1. Respond to your "Contact" contact requests;
  2. Fulfill legal obligations or regulations in force; 
  3. Sending of newsletters by VARIABILE K concerning the products, services, offers or events, general or personalized, based on my choices and my interests indicated or supposed, through the contact methods mentioned above.

This purpose requires your explicit consent (art.6.1, letter a, GDPR), without which you will not be able to receive the requested service.

Failure to provide Personal Data may make it impossible for the user to obtain the services requested from VARIABILE K. The processing of data for the purposes c) involves the request for consent from the data subject.

7. Legal bases

- sending of advertising material (examples of activities are: sending of advertising material on new services to your e-mail; the legal basis of this purpose is identified in the acquisition of your consent to the processing of personal data for a purpose (art.6.1, letter a, GDPR);

- activities related to the execution of the contract of which you are a part, including the pre-contractual phase (examples of activities are: the provision of a service: Participation in the Events; the legal basis of the aforementioned purpose is identified in the contract and pre-contractual measures ( art. 6.1, letter b, GDPR), but also (when applicable) in the legitimate interest (art. 6.1, letter f, GDPR) as regards the need to defend a right and as well as in the fulfillment of a legal obligation or regulations in force or to fulfill an obligation imposed by the Authorities (art. 6.1, letter c, GDPR);

- maintenance of IT systems and devices (the subjects in charge of carrying out maintenance and repairs on the Site could accidentally have access to your personal data. These are completely occasional and unpredictable events and in any case without identification purposes and of limited duration to the execution of the maintenance/repair operation); the legal basis of the aforementioned purpose is identified in the legitimate interest (Article 6.1, letter f, GDPR).

8. Categories of subjects who may process personal data (Recipients)

VARIABLE K undertakes to ensure that the Personal Data of which it becomes aware will be treated in a manner suitable to guarantee its security and confidentiality, as well as to avoid unauthorized access to the data itself. The personal data and information provided by users by registering on the page may be communicated, for the aforementioned purposes, to the following categories of subjects:

  1. The personnel of VARIABILE K, who will process the data as persons in charge;
  2. The public authorities competent to carry out the checks required by law in relation to prize competitions (e.g. Ministries, Notary or guardianship officer, Chambers of Commerce and others).

9. Transfer of your personal data abroad

We share your Personal Data with the named individuals, who may be located in Switzerland or other countries within or outside the European Economic Area (EEA), including in countries whose laws may not provide the same level of protection as data provided in the EEA or Switzerland. We guarantee that various security measures are in place, adequate to protect your Personal Data in accordance with our legal obligations and that the recipient will only process your Personal Data in accordance with our instructions. Where necessary, we use data transmission agreements with recipients, which are based on the standard contractual clauses approved by the European Commission (in Article 46 (2) of the General Data Protection Regulation) and/or the Federal Data Protection Act and the Swiss transparency commissioner.


The new adequacy standard of July 10 u. s. (adopted pursuant to Article 45, paragraph 3 of the GDPR) establishes a certain legal basis for the transfer of personal data from the EU to US companies participating in the Data Privacy Framework, without having to put in place additional safeguards for data protection The previous adequacy decision on the Privacy Shield had been the “subject” of the Schrems II judgment. The adequacy decision establishes a certain legal basis for the transfer of personal data from the EU to US companies participating in the Data Privacy Framework, without having to set up additional data protection guarantees by introducing new binding guarantees including the limitation of access to EU data by US intelligence services. In light of the new EU-US data transfer decision, US companies will be able to join the Data Privacy Framework on EU-US data transfers by committing to comply with a detailed set of privacy obligations similar to how previous standards did basis were self-certifications of adequacy. First, member companies will have the obligation to erase personal data when it is no longer necessary for the purpose for which it was collected and to ensure continuity of protection when personal data is shared with third parties; in other words, they will have to operate according to the rules of the GDPR in terms of CONSERVATION, correctness, minimisation, privacy by design and by default. There are also several dispute resolution tools for European citizens for unlawful data processing, such as free and independent dispute resolution mechanisms and an arbitration board.

10. Data Retention

Personal data will be processed by persons authorized to process who benefit under the authority of the Data Controller, adequately instructed by the Data Controller himself, in compliance with the provisions of art. 29 of the GDPR through automated tools for the time strictly necessary to take into account the purposes for which they were collected, as well as for any further period necessary to fulfill specific legal obligations.

Retention of data for the respective purposes (6. Processing methods and purposes)



Data life cycle

Process applied at the end of treatment


Duration equal to the fulfillment of your Contact request



Until withdrawal of consent


11. Rights of Data Subject

Within certain limits based on applicable law, you have the right (which you can exercise at any time):

  • to withdraw your consent for the sending of marketing material, eg. to object to the processing of your personal data for direct marketing purposes, including customer profiling to the extent that it is related to such direct marketing purposes;
  • to access your personal data and receive information on how they are treated;
  • to rectify your personal data;
  • to obtain the cancellation of your personal data;
  • to limit the processing of your personal data;
  • to oppose their treatment;
  • to oppose an automated decision-making process relating to natural persons including profiling;
  • to oppose the treatment at any time;
  • the portability of personal data;
  • to request confirmation of the existence or otherwise of their personal data;
  • to lodge a complaint with the supervisory authority.

Furthermore, you may lodge an appeal before the judicial authority (in accordance with the provisions of article 80 of the GDPR and article 13 of Legislative Decree 101/2018) or a complaint to the Guarantor for the Protection of Personal Data, by:

  • Registered mail with return receipt addressed to the Guarantor for the Protection of Personal Data, Piazza Venezia, 11, 00187 Rome
  • E-mail address: or
  • Fax to the number: 06696773785

It should be noted that the complaint to the Guarantor cannot be lodged if, for the same object and between the same parties, an appeal has been lodged before the Judicial Authority.

If you have any questions or comments regarding this Privacy Policy, the way in which we process your Personal Data or the way in which you wish to exercise one of your aforementioned rights, please contact the Data Controller at the following e-mail address .

Naples (NA), 24/07/2023