Cookies & Privacy Policy



De Wave Srl as Data Controller (hereinafter “De Wave” or “Controller“), pursuant to EU Regulation 2016/679 (hereinafter “Regulation“) considers privacy and the protection of Personal Data are an important goal of their business. We therefore invite you, before transmitting any personal data to the Data Controller, to carefully read this Notice: it contains important information on the processing of your Personal Data.

“Personal Data” means any information concerning an identified or identifiable natural person (“interested party”); the natural person who can be identified, directly or indirectly, with particular reference to an identifier such as the name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity is considered identifiable, physiological, genetic, psychic, economic, cultural or social.



• is valid only for (hereinafter: “Website”);
• forms an integral part of the Website and the services we offer;
• is provided pursuant to Article 13 of the Regulation, to those who interact with the web services of the Website and the Data Controller, both through simple consultation and through the use of specific services made available through the Website.


The Data Controller can be contacted at the address: [email protected]. The Data Controller has not, for now, formally designated a Data Protection Officer pursuant to art. 37 of EU Regulation 2016/679, since it does not fall within the mandatory cases.


This document was drawn up pursuant to art. 13 of EU Regulation 2016/679 (hereinafter: “Regulation“) in order to allow you to know our privacy policy, understand how your personal information is treated when using our Website and, if necessary, to give consent to the processing of your Personal Data free and aware. The information and data provided by you or otherwise acquired in the context of the use of the services of the Data Controller – such as for the spontaneous sending of a communication through the form – hereinafter “Services” -, will be processed in compliance of the provisions of the Regulation and of the confidentiality obligations that inspire the activity of the Data Controller.


According to the rules of the Regulation, the treatments carried out by De Wave will be based on the principles of lawfulness, correctness, transparency, purpose limitation and retention, data minimization, accuracy, integrity and confidentiality.



1. Data Controller

The Controller is De Wave Srl in the person of its pro-tempore legal representative, with registered office located in Via Manzoni 38, 20121 – Milan (MI), and operational headquarters in Via De Marini 60, 16149 Genova (GE) CF / P. VAT number 02206870996

2. The Personal Data object of the treatment

Following navigation of the Website, we inform you that De Wave will process your Personal Data which may consist of an identifier such as the name, an identification number, an online identifier or one or more characteristic elements of your physical identity suitable for making the subject identified or identifiable interested party.
Other Personal Data freely provided by you in the information request forms may be processed (for example to obtain information or for collaboration requests). Any sensitive data, referred to in art. 9.1 Reg. 2016/679 / EU should not be processed without the explicit consent given by the interested party.


a. Navigation data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Website, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit 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 relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning, to identify anomalies and / or abuses, and are deleted immediately after processing.
The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Website or third parties: except for this possibility, the data on web contacts do not currently persist for more than seven days.


b. Data provided voluntarily by the interested party

We may process personal and / or contact data such as name, surname, email and telephone. Data relating to training and education degrees contained in the curricula. Data and meta-data relating to training courses and services, including test and exam results and related information on date, time and methods of use of training services and / or test execution. Data relating to payments and other banking information, for example contained in receipts for payment of registration fees for training courses. Data relating to the identifier of the compiler of the comic information generator.
If you communicate Personal Data of third parties to De Wave, you must ensure – assuming all responsibility – that this particular hypothesis of treatment is based on an appropriate legal basis pursuant to art. 6 of the Regulation, which legitimizes the communication to De Wave and the related processing of the information in question.


3. Purpose of the treatment

The data processing that we intend to carry out may have the following purposes:
a. Allow the provision of the Services requested by you such as:
• generic request for information;
• collection and analyses of curricula vitae for the purpose of collaboration with De Wave;
b. respond to requests for assistance or information;
c. fulfil any legal, accounting and tax obligations;
d. to action or enforce in court any abuse or illegal utilization of the Website and/or of our Services or in connection with any dispute or litigation in contract or in tort;


4. Basis of legitimacy and mandatory or optional nature of the processing

The legal basis for the processing of Personal Data for the purposes referred to in section 3 (a-b) is art. 6.1.b) of the Regulations as the processing is necessary for the provision of the Services or for the response of requests from the interested party. The provision of Personal Data for these purposes is optional but failure to provide it would make it impossible to activate the Services provided by the Website.
The purpose referred to in section 3 (c) represents a processing of Personal Data carried out pursuant to art. 6.1.c) of the Regulations, for compliance with a legal obligation. Once the Personal Data has been provided, the processing is indeed necessary to fulfil a legal obligation to which the Data Controller is subject. The processing for the purposes referred to in section 3 (d) would be carried out pursuant to art. 6.1.f) of the Regulations.


5. Recipients of Personal Data

Your Personal Data may be shared, for the purposes referred to in section 3 above, with:
a. persons who typically act as data processors pursuant to art. 28 of the Regulation, namely: i) people, companies or professional firms that provide assistance and consultancy to De Wave in accounting, administrative, legal, tax, financial and credit recovery matters relating to the provision of the Services; ii) subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers); iii) or subjects delegated to carry out technical maintenance activities (including the maintenance of network equipment and electronic communication networks); (collectively “Recipients”); the list of data processors who process data can be requested from the Data Controller.

b. persons, bodies corporate or authorities, independent data controllers, to whom it is mandatory to communicate your Personal Data by virtue of provisions or orders of the authorities.

c. persons authorized by De Wave to process Personal Data pursuant to art. 29 of the Regulations necessary to carry out activities strictly related to the provision of the Services, which are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the Data Controller).


6. Data retention

The Personal Data processed for the purposes referred to in section 3 (a-d) will be kept for the time strictly necessary to achieve those same purposes in compliance with the principles of minimization and limitation of conservation pursuant to art. 5.1.e) of the Regulations. In any case, the Data Controller will process the Personal Data for the time necessary for contractual and legal obligations.
More information about the data retention period and the criteria used to determine this period can be requested by writing to the Data Controller.


7. Transfer of data abroad in case of use of platforms for live streaming or for the provision of content and training materials in training courses

In the event that through the Website you accessed social network systems such as Facebook, Instagram or LinkedIn, it should be noted that this use of services could necessarily involve the export outside the territory of the European Union of the data of the interested party (identification data, contact details, data and meta-data relating to the days, times and contents of the training sessions) that requires this service. This transfer takes place on the basis of the exception referred to in Article 49 paragraph 1 letter b) of the Regulations, as the transfer is occasionally necessary for the execution of the training service contracted by the interested party with the Data Controller.


8. Rights of the data subject

Pursuant to articles 15 and following of the Regulation, you have the right to request access to your Personal Data, the correction or cancellation of the same, the limitation of processing in the cases provided for by art. 18 of the Regulation, obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation. At any time, you can revoke pursuant to art. 7 of the Regulation the consent given; lodge a complaint with the competent supervisory authority pursuant to Article 77 of the Regulation (Guarantor for the Protection of Personal Data pursuant to art. 77 of the Regulation, if you believe that the processing of your data is contrary to the legislation in force.
You can make a request for opposition to the processing of your data pursuant to article 21 of the Regulation in which to give evidence of the reasons justifying the opposition: the Data Controller reserves the right to evaluate the request, which would not be accepted in the event of the existence of binding legitimate reasons to proceed with the processing that prevail over your interests, rights and freedoms.
Requests must be sent in writing to the Data Controller.


9. Changes

This privacy policy is effective from 25 May 2018. De Wave reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. De Wave will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Website. De Wave therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be updated on the data. collected and on the use made by the Data Controller.


10. Cookies and online trackers

This cookie policy refers exclusively to the Website (“Website“) and must be understood as an integral part of its Privacy Policy.

1. Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on their computer or mobile device, to be then re-transmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) so that they do not have to be indicated again. when the user returns to visit said site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a site and may also contain a unique identification code that allows you to keep track of the user’s navigation within. of the site itself for statistical or advertising purposes. While browsing a site, the user can also receive cookies from sites or web servers other than the one they are visiting on their computer or mobile device (so-called “third-party” cookies). Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the site to function itself.
There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; CD. persistent cookies, which remain on the user’s equipment until a predetermined deadline.
Under current legislation in Italy, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, ie those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require this consent. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.
Among the technical cookies, which do not require express consent for their use, the Italian Personal Data Protection Authority (i.e. Act for Identification of simplified procedures for the information and the acquisition of consent for the use of cookies dated May 8, 2014, hereinafter only “Provision“) also includes:
• “analytics cookies” when used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site,
• navigation or session cookies that guarantee normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas);
• functionality cookies, which allow the user to navigate according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
For “profiling cookies”, vice versa, i.e. those aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent of the ‘user.


2. Types of cookies used by the Website

The Website uses the following types of cookies, and offers the possibility of de-selecting them, except for third-party cookies for which the user must refer directly to the relative methods of selection and de-selection of the respective cookies , indicated by means of links:
• Technical cookies – navigation or session – strictly necessary for the operation of the Website or to allow the user to take advantage of the content and services requested by them.
• Analytics cookies, which allow the Website manager to understand how this is used by users. These cookies do not collect information on the user’s identity, nor any personal data. The information is treated in an aggregate and anonymous form.
• Functional cookies, used to activate specific features of the Website and a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.
• Profiling cookies aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed by the user while surfing the net.
ATTENTION: by disabling technical and / or functional cookies, the Website may not be available for consultation or some services or certain functions of the Website may not be available or may not work properly, and the user may be forced to modify or manually enter some information or preferences every time you visit the Website.
De Wave uses third-party cookies, i.e. cookies from websites or web servers other than that of the Data Controller, used for the purposes of these third parties, including analytical and profiling cookies. It should be noted that these third parties, listed below with the relative hypertext links to the privacy policies, act as independent data controllers of the data collected through the cookies they send, therefore, the user must refer to their processing policies of Personal Data, information and any consent collection forms (selection and de-selection of the respective cookies.
The links to the respective information on the use of cookies by accessing and the consent forms provided (as required by the Provision) are listed below:
Google Analytics:
In detail, the cookies sent directly through the Website are indicated below:
Cookies present on the Website:
At present there are no cookies on the Website.
In view of the possible insertion of some cookies such as Google Analytics, this Cookie Policy has been prepared.
There are trackers referable to LINKEDIN, INSTAGRAM and FACEBOOK:


3. How to view and modify cookies through your navigation program (so-called browser)

The user can select and authorize which cookies through the appropriate procedure set up in the Settings section relating to cookies, as well as authorize, block or delete (in whole or in part) cookies through the specific functions of their navigation program (cd browser) . In the event that all or some of the cookies are disabled, it is possible that the Website cannot be consulted or that some services or certain functions of the Website are not available or do not work properly and / or the user may be forced to modify or manually enter some information or preferences every time you visit the Website.
For more information on how to set preferences on the use of cookies through your browser, you can consult the relevant instructions:
• Internet Explorer
• Firefox
• Chrome
• Safari


4. Cookie settings

Below it is possible for the user to make a choice and specifically indicate which cookies to authorize.
The user is informed that not authorizing technical cookies could make it impossible to use the Website, view its contents and use the related services. Inhibiting functionality cookies could mean that some services or certain functions of the Website are not available or do not work properly and the user may be forced to modify or manually enter some information or preferences each time they visit the Website.
Failure to authorize the other third party cookies indicated will not affect the functioning of the Website; however, since these types of cookies are sent exclusively by third parties, and the Website manager cannot exercise control over the sending of these cookies to the user’s terminal, the relative opposition can only be exercised by accessing the consent forms prepared by the aforementioned third parties, if present, or through the settings of your browser. The links to the privacy policies and any forms of consent to receive cookies prepared by third parties that send cookies through the Website are provided in the Types of cookies used by the Website.
Regarding the cookies sent directly by the Website manager, as well as through the procedure made available on this page, the user can block or delete (in whole or in part) the cookies also through the specific functions of their browser. (in this regard, see the above).
The choices made by the user in reference to the Website’s cookies will in turn be recorded in a specific technical cookie, having the characteristics listed in the appropriate cookie table. This cookie may, however, in some circumstances not work properly: in such cases, the user is advised to delete unwanted cookies and to inhibit their use also through the functionality of their browser.
The user’s preferences regarding cookies will be reset if different devices or browsers are used to access the Website.

Last update 02 December 2020

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