Cookies Policy

Dear Data Subject,

cookies are small text files sent by the site to the Data Subject’s terminal (usually the browser), where they are stored and then transmitted back to the site the next time the same User visits. A cookie cannot retrieve any other data from the User’s hard drive or transmit computer viruses or acquire e-mail addresses. Each cookie is unique to the User’s web browser. Some of the functions of cookies may be delegated to other technologies. In this document, the term ‘cookies’ is intended to refer both to cookies, properly so-called, and to all similar technologies. By means of cookies, it is possible to record information related to preferences, such as pages browsed or file downloads from the site or other similar actions performed while browsing the site.


Cookies can be first-party or third-party cookies:

– “First Party” means cookies developed by the Site Owner itself,

– “Third Party” means cookies developed by Third Parties other than the Site Owner.


Relative to the nature of cookies, there are different types:

Technical cookies

Technical cookies are those used for the sole purpose of “carrying out the transmission of 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” (see Article 122(1) of the Code). They are not used for any further purposes and are normally installed directly by the website owner or operator.

They can be divided into:

– navigation or session cookies, which ensure normal navigation and use of the website

website (allowing, for example, to make a purchase or authenticate to access restricted areas

reserved areas); they are in fact necessary for the proper functioning of the site;

– analytics cookies, assimilated to technical cookies where used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site itself, in order to improve the performance of the site;

– functionality cookies, which allow the User to navigate according to a set of criteria

selected (for example, products selected for purchase, language, etc.) in order to improve the service rendered to the same. Users’ prior consent is not required for the installation of such cookies.

Profiling cookies

Profiling cookies are aimed at creating profiles related to the User and are used in order to send advertising messages in line with the preferences expressed by the same in the context of web browsing.

The consent of the Data Subject is required for the use of profiling cookies.

According to Order No. 229 of May 8, 2014, the User must be able to authorize or deny consent to the installation of profiling cookies if they are present.

In the case of third-party cookies, the site does not have direct control over individual cookies and cannot control them (it can neither install them directly nor delete them). However, the User can manage these cookies through the browser settings (follow the instructions below), or the sites indicated in the “Cookie Management” section.

The User is therefore invited to check the relevant cookie policies on the Third-Party sites.

The updated list of cookies in use on the platform can always be accessed through the following process:

  1. Click on the lock icon next to the url;
  2. Select the “Cookies” button;
  3. View the various categories and subcategories of cookies in use;
  4. Opt “block” or “remove” from each unwanted cookie.


Cookies have a lifetime dictated by the expiration date (or a specific action such as closing the browser) set when they are installed.

Cookies can be:

  • temporary or session “session cookies”: these are used to store temporary information, allow you to link actions performed during a specific session, and are removed from your computer when you close your browser;
  • permanent “persistent cookies”: these are used to store information, such as the login name and password so that the user does not have to type them in again each time he or she visits a specific site. These remain stored on the computer even after closing the browser.

The so-called session cookies, once the connection to this website is terminated, are not stored. The computer systems used for this website use temporary cookies and permanent cookies.


Users can disable cookies on websites by downloading special software such as Ghostery ( for your browser and disabling the use of individual cookies. Or they can activate the “anonymous browsing” mode – this is a function that allows you to browse without leaving a trace of your browsing data in your browser. This function only allows them not to keep their browsing data in the browser.

Alternatively, they will be able to disable/delete cookies by accessing the configuration panel of your browser.


By continuing to browse this site, closing the information wrapper or clicking anywhere on the page or scrolling down to highlight further content, you agree to the Cookie Policy and cookies will be set and collected. If you do not accept cookies by quitting browsing, any cookies already registered locally in your browser will remain registered there but will no longer be read or used by us until you later accept the policy. Users will always have the option to remove such cookies at any time through the aforementioned methods.



The User (hereinafter “Owner” or “Customer” or “Data Controller”),

by express acceptance of the Terms and Conditions of ADMIRABLY (hereinafter “Provider” or the “Data Processor”), accepts this addendum on the processing of personal data, which constitutes an integral part of the relationship between the Parties. This Addendum is signed pursuant to Article 28 of Regulation 679/2016 and governs the manner in which the Data Processor will process personal data on behalf of the Data Controller. Data Controller and Data Processor may also be referred to individually as the “Party” and jointly as the “Parties”.


-the processing operations of personal data carried out by the Data Controller are listed in the register of processing operations kept by the Data Controller;

-for some processing operations the Data Controller makes use of the cooperation of the Supplier;

-the Supplier, as part of the services offered to the Data Controller, as better detailed in the specific contract in place, may carry out personal data processing on behalf of the Data Controller;

-the Data Controller and the Provider have signed an agreement for the provision of an integrated web and tablet for creating, managing and sending review requests (“Service”), of which this document is an integral part;

-with reference to the Service made available by the Provider, the latter may process data personal data owned by the Controller and, more specifically, common data (first name, last name, contact details) of the Holder’s end customers;

-the purpose of the processing is to provide a technological solution that allows the Holder to be able to take advantage of the Service;

-in accordance with Article 28.1 of Regulation (EU) 2016/679, General Data Protection Regulation (henceforth “GDPR”), “where a processing is to be carried out on behalf of the Controller of the Processing, the latter shall only use data controllers.”

-the Data Controller has verified that the Provider, again pursuant to Article 28.1 of the GDPR, presents “sufficient guarantees to put in place appropriate technical and organizational measures so that the processing meets the requirements of the Regulation and ensures the protection of the rights of the data subject.”

The Data Controller appoints the Provider as the “PERSONAL DATA PROCESSING RESPONSIBLE” (henceforth also simply “Processor” or “Processor”), with respect to the personal data that the Supplier may process in the performance of its activities and those that may be entrusted to Supplier in the future.

In accordance with the GDPR, the activity performed by the Processor will be governed as follows:

  1. DURATION. This appointment shall be effective for the duration of the Processor’s relationship with the Controller and shall be deemed automatically revoked in the event of termination of the same.


  1. PURPOSE OF THE PROCESSING. The data that are entrusted to the Manager, as part of the activities entrusted to him/her for the use of the Service, may be processed only for the purposes indicated in the mandate entrusted and/or in the contract entered into with the Owner. In particular, the data will be processed by the Provider only for the purpose of being able to guarantee the provision of the Service to the Owner who, in any case, will remain the only entity obliged to have to communicate to the end customer the purposes and obtain consent to the processing, as well as the communication of the data to third parties.


  1. METHODS OF PROCESSING. The data may be processed on paper or digital media, depending on the activities carried out, provided that the tools are properly identified and inventoried by the Manager and systematically communicated to the Owner for his approval. In particular, the data will be processed by means of the ADMIRABLY software platform.


  1. DUTIES AND TASKS OF THE RESPONSIBLE PERSON. The Data Processor, as stipulated in Article 28 of the GDPR, undertakes to:


(a) process the entrusted personal data only on the documented instruction of the Controller, even in case of transfer of personal data to a third country, unless otherwise provided by law. In this case, the Responsible Party is still obliged to inform the Controller;


(b) ensure that the persons authorized to process have committed to confidentiality, or have an appropriate legal obligation of confidentiality. To this end, the Responsible Party to periodically verify that the persons in charge: (i) carry out the processing in a lawful and correct manner, exclusively for the purpose of providing the services covered by the contractual relationship between the Parties; (ii) process personal data solely for purposes inherent to the tasks assigned to them; (iii) do not communicate or disseminate personal data without the prior authorization of the Data Controller; (iv) verify, in case of even temporary interruption of work, that the processed personal data are not accessible to unauthorized third parties; (v) guard and keep authentication credentials strictly confidential; (vi) comply with the security measures required by the Data Controller and/or the Data Controller;


(c) ensure adequate and proven training for persons authorized to process, pursuant to Article 29 of the GDPR;


(d) take, pursuant to Article 32 of the GDPR, all appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art and the costs of implementation, as well as the nature, object, context and purposes of the processing, as well as the risk of varying likelihood and severity to the rights and freedoms of natural persons, so as to minimize the risks of destruction or loss, including accidental loss of the data themselves, of unauthorized access or processing that is not permitted or not in accordance with the purposes of collection


  1. e) to inform the Data Controller, in accordance with Article 28 GDPR, if it is necessary to use another Data Processor;


  1. f) assist the Controller in complying with the legal obligations under Articles 32 (Security of Processing), 33 (Notification of a Personal Data Breach to the Supervisory Authority), 34 (Notification of a Personal Data Breach to the Data Subject), 35 (Data Protection Impact Assessment), 36 (Prior Consultation), taking into account the nature of the processing and the information available to the Controller.


  1. g) provide for the updating, modification, rectification of personal data if this is necessary in relation to the purposes of the processing, and delete or return promptly, upon the request of the Controller, all personal data and existing copies of which the Responsible is in possession without being able to retain any copies, unless expressly agreed otherwise or provided for by law. In any case, delete and/or destroy, as required by law (such as “wiping” for digital data), personal data when the purposes for which the data were collected and processed have been achieved in the absence of a legal obligation or the need for further retention;


  1. h) allow the Controller to exercise the power of control under Article 28 GDPR: in this context, make available to the Controller all information necessary to demonstrate compliance with the obligations of this Addendum and to demonstrate compliance with legal obligations and allow verification activities (Audit), carried out by the Controller or by third parties commissioned by the Controller, in order to ascertain the observation of these data processing methods and compliance with legal requirements. The Data Controller shall have the right to verify, with at least 20 (twenty) working days’ notice, also at the Data Controller’s premises, the compliance of the procedures adopted by the latter with what is indicated in this Addendum or required by law;


  1. i) undertake to comply with the General Provision of the Guarantor for the Protection of Personal Data of November 27, 2008 “Measures and expedients prescribed for the holders of data processing carried out with electronic instruments in relation to the attributions of the functions of system administrator” as amended by the Order of the Guarantor of June 25, 2009 “Amendments to the order of November 27, 2008 on prescriptions to the holders of processing carried out with electronic tools with regard to the attributions of system administrator and extension of the time limits for their fulfilment,” as may be amended or replaced by the same Guarantor, and to any other relevant measure of the Authority;


  1. j) to cooperate for the purposes of the exact application of the law, including through periodic meetings and to act within the scope and limits of their duties, autonomously, but always in accordance with the directives established by the Controller.


  1. SUPERVISION. The Data Controller may supervise the punctual compliance with the instructions given herein to the Data Processor and will verify the continuation of the requirements of experience, capacity and reliability that influenced the designation of the Data Processor.


  1. VIOLATION. The Processor is hereby made aware that if he/she violates the provisions of the law by independently determining the purposes and means of the Processing, or disregarding the instructions received from the Controller, he/she will be considered the Controller of the Processing in question;


  1. ASSISTANCE TO THE CONTROLLER IN CASE OF A BREACH. In the event of a personal data breach, the Provider agrees to inform the Controller without undue delay from the time it has knowledge of the breach. The Supplier shall assist the Holder by initiating a preliminary analysis aimed at collecting data concerning the anomaly and compiling an event sheet, containing all information collected and at that time available, such as, but not limited to:

– Date of event, also the presumed date of occurrence of the violation (in which case it should be specified)

– Date and time when knowledge of the violation was obtained;

– Reporting source;

– Type of violation and information involved;

– Description of abnormal event;

– Number of data subjects involved;

– Numerousness of personal information alleged to have been breached;

– Indication of the date, including alleged date, of the breach and when it became Knowledge;

– Indication of the place where the data breach occurred, also specifying whether it occurred as a result of loss of devices or portable media;

– Concise description of the data processing or storage systems involved, with

indication of their location.


  1. CONFIDENTIALITY. The Processor agrees to keep strictly confidential and

confidential and to use only for the performance of the obligations under the contract, any information relating to the other Party and/or those involved in the processing of personal data and/or products, services, organization, business or technical strategy received from the other Party or of which come to their knowledge during the execution of the contract related to the Service (hereinafter referred to as “Confidential Information”). The Responsible Party undertakes not to use the Confidential Information outside the purposes envisaged by this agreement, nor to disclose it to parties not envisaged by this agreement, without the written approval of the Owner. The Manager shall take all necessary measures not to disclose or make available in any way the Confidential Information of the Owner and/or interested parties to third parties, and shall in any case be held directly liable to the Owner for any violation by its employees and/or subcontractors of the confidentiality obligations set forth in this article. The provisions of this Article shall not apply or shall cease to apply to those individual pieces of information that the Controller can prove: (i) have already become public knowledge for reasons other than the breach by the Controller itself; (ii) were already known prior to having been received by the Controller; (iii) were disclosed or disclosed in compliance with a lawful order of any authority or by virtue of a legal obligation. Disclosed Confidential Information shall remain the property of the Data Controller. Upon written request by the Owner itself such information shall be returned or destroyed by the Responsible Party.


  1. AMENDMENTS AND ADDITIONS. The Parties shall have the right to make such amendments and adjustments to this Agreement as may be necessary at any time, including to comply with any regulatory updates. Notice of any request for amendment will be given to the Manager by registered letter with return receipt or certified e-mail. Following the aforementioned change request, the Manager will have 60 days to withdraw from the agreement. After this period, the changes will be deemed accepted by the Processor. For anything not expressly provided for in this agreement, please refer to the general provisions in force regarding the protection of personal data.


  1. APPLICABLE LAWS. In the event of any dispute concerning the validity, interpretation, performance and termination of this Addendum, the Parties agree to seek a fair and amicable settlement among themselves. Should the dispute not be settled amicably, it shall be deemed to fall under the exclusive jurisdiction of the Judicial Authority of the English legal system. For the resolution of any dispute concerning the validity, interpretation, execution and termination of this agreement the English Laws will be applied.


It is understood that this appointment does not imply any right of the Supplier to any specific compensation and/or indemnity and/or reimbursement arising from this appointment, beyond what is already provided for in the terms and conditions.