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Why A Privacy Policy?

In this page is described the management of the web site www.consulenteindipendente.com, including respective third level web addresses, to which is also re-directed the web site www.diawonds.com and of the web site www.myopennote.com (as a whole more simply the “Site”)  - specifically with regards to the processing of personal data of users that visit (within the areas of The studio DIAWONDS ® di S.Fumagalli Romario, or Mr Simone Luigi Maria Fumagalli Romario - hereinafter referred to as "DIAWONDS ®"). The hosting service for DIAWONDS ® is provided by a third company bound to respond within the areas of its competences in regards to processing collected Site users’ personal data. This information is provided - also in pursuance of Section 13 of Legislative Decree no. 196/2003 - to any entity having to do with the web-based services that are made available by DIAWONDS ® via electronic networks from the following addresses: www.diawonds.com, www.consulenteindipendente.com and www.myopennote.com, which correspond to the home pages of the Site. The information provided only applies to the Site and does not concern any web sites that may be visited by a user via external links.


Visiting this site may result in the processing of data concerning identified or identifiable persons. The data controller, within the areas of his competences, is DIAWONDS ®, with an operative office in Milan (Italy), Via Santa Maria Valle n. 3, 20123.


Navigational Data    

The information systems and software procedures relied upon to operate this Site acquire personal data as part of standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties. This data category includes IP addresses and/or the domain names of the computers used by any user connecting with this web site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user's operating system and computer environment. This data is only used to extract anonymous statistical information on website usage as well as to check its functioning. DIAWONDS ® in his quality of user of a specific “statistical service” provided by the hosting firm adopted by the Site (even without having direct access to access logs) may consult codification extracted by the server which is held for 90 days.


With reference to the policy of treatment of “cookies” (cookie identifiers) by the Site, please refer to the privacy policy of the Hosting firm used by DIAWONDS ®. DIAWONDS ® doesn’t have complete or direct control over the hosting server but can only upload or download Site contents.

Data Provided Voluntarily by Users

Sending e-mail messages to the addresses mentioned on this website, which is done on the basis of a freely chosen, explicit, and voluntary option, entails acquisition of the sender's address, which is necessary in order to reply to any request, as well as additional personal data contained in the message(s). Specific summary information notices will be shown and/or displayed on the pages that are used for providing services on demand.

Data protection – Google Analytics, Google AdSense and use of social plugin of Facebook, Google, Twitter – Declaration referred to the Site included the third level domain denominated opinioni.consulenteindipendente.com, hosted on an e-commerce platform provided by the hosting firm

- This Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google").

- This Site uses plugin/functions of the social networks Facebook, Twitter and Google+.

- This Site uses Google AdSense, an advertising product provided by Google. Link to how Google uses data:


For further information on terms of use and data protection/privacy, please see:

http://www.google.com/analytics/terms/us.html, http://www.google.com/analytics/learn/index.html, https://www.facebook.com/about/privacy/, or https://twitter.com/privacy.


Subject to the specifications made with regard to navigational data, users are free to provide the personal data either to be entered in the application forms submitted to DIAWONDS ® or referred to in contacting DIAWONDS ® to request delivery of information materials and other communications. Failure to provide such data may result in the failure to be provided with items requested.


The Data supplied shall be treated by DIAWONDS ®, with data processing or by hard copy, with the following scope:

- Collection of contractual information;

- execution of fulfilments connected with contractual relationships established, correct management of the contract and its obligations, administrative and correspondence management, as well for purposes strictly connected and necessary in order to be able to fulfil related outstanding obligations;

- Fulfilment of the obligations set forth by laws, regulations and EC legislation or orders of Authorities or Controlling bodies of administrative practices;

- Detection of the degree of customer satisfaction about quality of the services provided, the execution of marketing research and surveys, statistical or scientific information purposes, marketing purposes, advertising products and/or services, and performance of public relations activities. In these cases, the provision of data is optional and voluntary.

Data is only available to the processing owner.


DIAWONDS ® may communicate personal data for the same purposes for which they were collected, to:

- Supervisory bodies, or to other designated subjects, in accordance with their own requirements or set forth by local or EU laws or regulations;

- Third parties that support DIAWONDS ® for the purposes strictly related and connected to those previously mentioned. Names and addresses of said subjects are available on demand by interested parties;

- External third parties who perform functional or instrumental activities with respect to those of DIAWONDS ®, for example, subjects that perform public relation activities or carry out market research.


Non-sensitive personal data of the interested subject may also be transferred abroad, even outside the European Union for the same purposes of the preceding points.


Personal data is processed via electronic or hard copy for no longer than is necessary to achieve the purposes for which it has been collected. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately, and accessed without authorization.

8. DATA SUBJECTS' RIGHTS - rights set forth in Article 7 of Personal Data Protection Code, Legislative Decree no. 196 of 30 June 2003  (hereinafter the Code)

Right to Access Personal Data and Other Rights

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form. 

2. A data subject shall have the right to be informed 

a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) of the identification data concerning data controller, data processors and the representative designated as per Section 5, paragraph 2, of the Code; e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain

a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part,

 a) on legitimate grounds, 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/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.


Inquiries need to be sent by post to DIAWONDS® to the attention of Dott. Simone Luigi Maria Fumagalli Romario, at: Milan (Italy), Corso di Porta Romana 87 - 20122, or via the e-mail address info@diawonds.com.

This document, published at the addresses http://www.consulenteindipendente.com, http://www.myopennote.com, http://opinioni.consulenteindipendente.com represent the “Privacy Policy” of the Site and will be, if necessary, subject to updates as a consequence of legal, organizational changes or due to technological evolution.

DIAWONDS® is currently taking advantage (for the Site), of hosting, emailing and  statistical services provided by the company Aruba S.p.A. (www.aruba.it) and of the service Google Analytics and AdSense, as well as using Facebook, Google+ and  Twitter plugins, as better specified in point 2.


Reference data: Rev. August 1, 2017