admin_gg4, Autore presso Solve.it

Il NIST analizza i rischi ransomware

News28 December 2021

Durante la premiere del Cybersecurity Framework Profile for Ransomware Risk Management (NISTIR 8374) il NIST ha rilasciato la bozza preliminare…

Rapporto GSE 2020 sui consumi rinnovabili in Italia

News13 December 2021

Nello scorso anno, il 2020, i consumi da fonti energetiche rinnovabili in Italia hanno raggiunto quota 20%. Il rapporto GSE…

La versione 4.0 dell’industria italiana in crescita

News27 November 2021

Nel 2020 sono stati raggiunti i 4,1 miliardi di euro nel mercato delle industrie italiane, c’è stata infatti una crescita…

Sicurezza e produttività con Google Workspace

News18 November 2021

Google Workspace nell’anno passato ha dovuto evolversi in maniera esponenziale per poter soddisfare le esigenze di tutti gli utenti che…

MIGRAZIONE AL CLOUD DI SUCCESSO

Business Technology Optimization, Data Center Change Management, News18 November 2021

Migrare al Cloud è diventato un passaggio importante per completare il processo di Trasformazione Digitale per ottimizzare costi e risorse dell’IT sia delle imprese che del settore della…

L’ Intelligenza aziendale come obbiettivo 2024

News5 November 2021

Le aziende che non sono in grado di gestire con l’intelligenza aziendale i dati e silos decisionali saranno incapaci di…

La nuova tecnologia Veeam trasforma i dispositivi IoT

News20 October 2021

Il Senior Director di Veeam software, Rick Vanover sostiene che nel futuro prossimo sarà possibile che i dispositivi IoT e…

Il Data Masking e come si applica

News15 October 2021

Spesso occorre condividere i propri dati personali all’interno dei database, soprattutto nello sviluppo di processi aziendali e amministrativi ma questo…

A guidare il mercato del cloud in Europa sono sempre i big player

News7 October 2021

Synergy Research ha rivelato che Microsoft, Aws e Google detengono il 69% di quote fra i provider di cloud in…

L’alfabetizzazione dei dati e Data literacy

News29 September 2021

Una delle priorità per i dipendenti aziendali è sicuramente l’alfabetizzazione dei dati. La data literacy è una parte cruciale di…

1. PREMISE

The management wishes to use the Code of Ethics to underline the fundamental ethical values upon which Solve.it s.r.l., hereinafter Solve.it, is based and to which all employees and external contractors (consultants, agents, service providers) must adhere in performing the tasks and functions they have been assigned. The ethical principles in the Code apply to both company employees and external contractors bound by any type of contractual relationship (hereinafter also referred to as “Recipients”). Commitment on behalf of everyone is essential to ensure that Solve.it’s business is performed in compliance with the law, in a framework of fair competition, honesty, integrity, correctness and good faith, while respecting the legitimate interests of customers, employees, business and financial partners and the communities in which the company operates. It is therefore indispensable that the importance of observing and enforcing these principles in the context of their duties and responsibilities is clear to those working to achieve Solve.it’s goals without making any distinctions or exceptions. In no way can the belief of acting in the interests of the company justify any behavior that is contrary to these principles. Observance of the Code of Ethics is considered an essential part of contractual obligations, not only for employees, but also the company’s external contractors, pursuant to and for the purposes of the law. To this end, supplier contracts provide for express resolution in the event of violation of the rules contained in the Code of Ethics or the corporate organizational model by third parties. Within the framework of the internal control system, the Code of Ethics is a prerequisite and point of reference – subject to the offence-risk assessment related to the activities performed – of both the preventive Model of Organization, Management and Control (the “Model”) and the disciplinary system for violations of the rules it establishes, adopted by Solve.it pursuant to the provisions of articles 6 and 7 of Italian Legislative Decree 231 of 2001 and on the basis of the Code of Conduct published by Confindustria (association of Italian industries) pursuant to art. 6(3) of the aforementioned legislative decree. The implementation of the Code of Ethics is the responsibility of Solve.it’s directors and employees who shall report any breaches or failure to apply the Code to the Supervisory Board.

2. GENERAL PRINCIPLES AND ETHICAL PRINCIPLES

The content of the Code is the basis used by Solve.it’s management for the proposal and implementation of projects, actions and investments aimed at increasing the economic value of the company and the well-being of its employees over the long term. As per its business purpose, the company performs: The study, design, creation, production, distribution and sale, direct and/or indirect, in Italy and abroad, of information systems and application programs for all types of companies and entities. In particular, the company may also use and adapt licensed products or products available on the market, as well as promote IT application solutions including any technical infrastructure necessary for the operation of said applications. The company may, in relation to the previous activity, carry out commercial activities, both retail and wholesale, by correspondence and electronically, of products and services for automation in general and the computerization of data, as well as renting computers or other equipment to third parties.

Omitted In the first instance, it is the task of the directors to promote the values and principles of the Code, taking responsibility for doing so both internally and externally, as well as strengthening trust, cohesion and team spirit. Solve.it expects Recipients of the Code to strictly apply the ethical principles listed below, which are grouped into two distinct (albeit related) subsets: one containing coded principles (the so-called principle of legality) and the other containing principles of common experience (the so-called ethical and behavioral principles).

2.1 PRINCIPLES OF LEGALITY

The behavior of the Recipients of the Code must, above all, comply with the laws in force in the State in which the Recipients themselves operate, including the supranational and international ones that the State adopts. Solve.it operates and wishes to operate in full compliance with said regulations: the directors and employees of Solve.it, and those who interact with it in various capacities, are required, within thee scope of their respective responsibilities, to know and observe the codified rules (laws, equivalent acts, regulations) by international, state, regional and local institutions and, in particular, the regulations concerning:

company law with specific focus on the regulations for accounting records and financial statements, free competition,

protection of industrial property,

copyright protection of personal data in compliance with the legislation in force, health, hygiene and safety at work (in particular following the changes brought by Italian Legislative Decree 81/2008) and environmental legislation.

2.2 ETHICAL AND BEHAVIORAL PRINCIPLES

Any professional activity performed by anyone working for Solve.It must be performed with professional commitment, moral rigor and fairness, also in order to safeguard the company’s image. During the performance of their tasks and the length of their time working for the company, all Recipients are required to adhere to the following ethical and behavioral principles:

the implementation of differentiated waste collection and recycling programs for reusable materials;
the reduction of all forms of pollution

All employees and contractors are directly responsible to colleagues and the company for maintaining the quality of the work environment by observing the procedures and instructions established by company policy. Employees are tasked with preventing and limiting situations that may adversely affect said quality. Solve.it is committed to taking care of individuals and maintaining their physical and moral integrity, promoting the dissemination of ethical and behavioral principles, encouraging compliance and punishing non-compliance. Recipients must conform to and apply the above principles by referring to the common understanding of morality and conscientiousness when carrying out any task and under in all circumstances. In particular:

All employees are required to know the Code, to actively contribute to its implementation and to report any shortcomings or breaches. The company promotes employee knowledge of the Code by publishing its content on the corporate intranet and/or posting a copy at a location accessible to employees.
In the event of doubts on how to proceed, the employee must report the matter to their supervisor or, if dissatisfied by the outcome, to the Board of Directors who shall act to provide solutions and responses in compliance with the Code of Ethics.
The Board of Directors closely monitors compliance with the Code through suitable information, prevention and control instruments to ensure the transparency of the operations and behavior employed and, where appropriate, take corrective action.
The employee is urged to report any information relating to breaches of the Code or the Corporate Organization Model to the Supervisory Board promptly (see Chapter 5).

3. CONFLICT OF INTEREST

In order to avoid conflicts of interest, all operations and activities must be undertaken in a lawful, transparent, correct manner and in Solve.it’s sole interest. As far as conflicts of interest are concerned, no employee or service provider working for Solve.it shall:

perform activities in favor of the competition;
become a consultant, member, member of the Board of Directors or the Board of Statutory Auditors of a rival company;
perform work in favor of rival parties, nor use, at work or during non-working hours, company assets or provide services that Solve.it offers its customers without prior authorization by a member of the Board of Directors;
perform other activities that are inconsistent with their tasks or organizational responsibilities during working hours, nor use company assets for tasks other than those mentioned above;
accept money, favors or benefits from individuals or companies that are in or intend to enter into a business relationship with Solve.it.

More generally, given the relationship of trust between Solve.it and those who work for the company, all Recipients must avoid any situation and refrain from any activity that may counterpose personal interests to those of the company or that may interfere or hamper the ability to take impartial and objective decisions in the interests of Solve.it.

4. APPLICATION OF PRINCIPLES AND RULES OF BEHAVIOR

In order to allow the rigorous application of the principles outlined above, the Code attempts to identify the areas in which the can be applied, focusing attention on the main types of employment relationships that involve Recipients. To this end, it is necessary to distinguish two major groups: one concerning relationships within the company and the other concerning relationships that are external to the company.

4.1 RELATIONSHIPS WITHIN THE COMPANY

By relationships that are internal to the company, we mean relationships between individuals who have senior management positions in Solve.it (administrative bodies, corporate bodies, governing bodies; henceforth “senior managers”), between individuals who have lower positions in the company compared to those mentioned above (henceforth “employees”), between senior managers and employees and, lastly, between all of the above and the Supervisory Board. In general, Solve.it expects all those who work in the company to:

respect the personality and dignity of all individuals, even during the selection process, avoiding:
- the creating of situations in which individuals can find themselves uncomfortable;
- any type of discrimination;
- abuse of any kind;
undergo the appropriate training for their role;
have defined roles, responsibilities, delegations and the availability of information to enable each of them to take the decisions under their responsibility in the interests of the company and in compliance with the regulations that it has adopted, avoiding the creation of unofficial positions that, if discovered, shall be eliminated;
exercise their authority in a prudent, balanced and objective manner during the performance of their responsibilities;
use both personal and corporate data in a proper and confidential manner.

4.1.1 RELATIONS BETWEEN SENIOR MANAGERS

Due to the responsibilities that are inherent in their functions (management, supervision and control), senior managers working in Solve.it must strictly observe the principles mentioned above. In particular, they must comply with the confidentiality and non-competition obligations, performing their duties with complete loyalty to Solve.it. They have a duty to operate with full transparency in order to permit for the complete reconstruction of all their actions, with particular reference to financial transactions. Being the front-line representatives of the company, they are required to cooperate fully and reciprocally with each other in order to promote the co-ordination and pursuit of company goals. In addition to reflecting an image of the company that fully complies with the principles of the Code, individuals in senior management positions are required to direct employees and contractors towards compliance with the Code, so that everyone may comprehend its reasons and objectives.

4.1.2 RELATIONS BETWEEN EMPLOYEES

Solve.it employees are the workforce that spends its time in daily contact with the outside world.

As they are all Solve.it employees – albeit organized hierarchically – they shall observe and apply the principles of diligence, honesty and equality, promoting mutual cooperation and solidarity, promoting the creation of a working environment that is suitable for safeguarding individual personalities both from a professional and a relational point of view. They are required to use Solve.it resources and trademarks within the limits permitted by the duties they are required to perform, without ever abusing them for other purposes or outside working hours; Lastly, they are called upon to comply with all the requirements set out in the collective agreement that governs their employment and all the trade union guidelines concerning the kind of behavior required between employees.

4.1.3 RELATIONS BETWEEN SENIOR MANAGERS AND EMPLOYEES

Senior managers are required to exercise their powers over employees in a balanced, fair and non-discriminatory manner, while respecting the person and their dignity. They must not abuse their position in any way, either during the employee selection process (which must take place exclusively on merit and/or on a mechanism imposed by law), or during the course of the employment relationship. They must only issue instructions that comply with the law and the principles of the Code and must refrain from any harassing and/or intimidating behavior aimed at inducing employees to violate the aforementioned principles. Employees, for their part, are required to comply with the directives given to them by senior managers and to diligently execute them, provided that said directives are not clearly contrary to the laws in force and/or the principles of this Code; they must also report any actual situations – which they might encounter – that are contrary to the laws in force and/or the principles of this Code.

4.1.4 RELATIONS BETWEEN SENIOR MANAGERS, EMPLOYEES AND THE SUPERVISORY BOARD

Both senior managers and employees are required to accept and pay attention to any communication by the Supervisory Board, scrupulously assessing the indications received. They are also urged to report to the any situation, behavior, event or circumstance that do not comply with applicable laws and/or the Code to the Supervisory Board. They may also turn to the Supervisory Board to obtain anonymous and confidential recommendations on the behavior required to comply with the Code.

For further information on the Supervisory Board, please refer to the specific section.

4.2 RELATIONS THAT ARE EXTERNAL TO THE COMPANY

Solve.it is a company that has daily relations with third parties in the form of suppliers, customers (private, hereinafter “customers”, or public administrations, hereinafter “P.A.”). In general, in the above-mentioned business relations with third parties, Recipients are required to behave in a manner that is ethical and observant of the law, characterized by the utmost transparency, clarity, correctness, efficiency and fairness, as defined in the standards of the Code.

4.2.1 RELATIONS WITH CUSTOMERS/CONTRACTING AUTHORITIES AND SUPPLIERS

Correct and transparent relations with customers, P.A. and suppliers are a major aspect of the company’s success.

The selection of suppliers and purchases of property, goods and services shall take place in accordance with the principles of the Code of Ethics and internal procedures, using the written form and in observance of the hierarchical organization of the company. In any event, selection shall only take place in accordance with objective parameters such as quality, convenience, price, ability and efficiency. Donations, benefits (both direct and indirect), gifts, courtesies and hospitality are prohibited in business relationships with customers, P.A. and suppliers, unless they are of a nature and value that does not compromise the image of the company and cannot be interpreted as influencing choices or even just to raise awareness in order to obtain favorable treatment that is not determined by market rules. Gifts must satisfy the dual requirement of being minor (i.e. of modest symbolic value) and equality (i.e. equal cost in the choice of gift for all public and private customers). However, any gift made by personal initiative or using personal or corporate funds that have not previously been allocated for such a purpose are not permitted: only Solve.it has the right to decide on corporate policy in terms of gifts and the allocation of its finances; it involves a strict procedure for documenting the expenses incurred and their transparent reporting. Any employee receiving gifts or favors from customers, P.A. or suppliers that exceed normal courteous relations shall promptly notify their supervisor, who will inform the competent company organs accordingly. The latter shall perform appropriate checks and will manage outward communications, informing the issuer of the gift, donation, etc., of company policy on the matter. Solve.it and its collaborators, without distinction and in whatever capacity, shall do everything in their power to avoid being involved in activities that may involve the laundering (i.e. acceptance or transfer) of proceeds of criminal activities in any form or manner. Therefore, the company and its collaborators, without distinction and in whatever capacity, are required to check the information available on the commercial counterparts (customers and suppliers), financial partners and other business partners in advance in order to ascertain their respectability and the legitimacy of their business before establishing business relationships. Solve.it and its employees shall observe and enforce national and international regulations for the prevention of money laundering and receiving, in whichever jurisdiction they may be operating. Given the particular attention required for relationships that involve the receipt or transfer of sums of money, credit and securities in general, Solve.it, also in accordance with specific protocols, shall not:

receive payments in cash, bearer securities or by means of intermediaries that are not authorized or through the mediation of third parties that make it impossible to identify the payer,
maintain relationships with subjects based or operating in countries that do not guarantee corporate transparency and, more generally,
perform operations that prevent the reconstruction of the financial flow of funds,

in order to prevent the risk of performing, albeit involuntarily or unconsciously, any kind of transaction involving money, property or other benefits resulting from the commission of unlawful behavior.

4.2.2 RELATIONS WITH AUTHORITIES AND PUBLIC ADMINISTRATIONS

Relations with Public Institutions are the exclusive preserve of the functions and the responsibilities the latter are accorded. Employees are not authorized to make direct or indirect payments to public officials and/or public administrations that are not linked to services or contracts that have been formally authorized by the business functions responsible for managing said services. The relations between Solve.it and public officials or individuals in charge of a public service – operating on behalf of the P.A., whether central or local, or legislative bodies, EU institutions, international public organizations or any foreign State – , the judiciary, State supervisory bodies, other independent authorities or private partners providing a public service, shall be undertaken and managed in strict and absolute observance of the laws and regulations in force, the principles established in the Code of Ethics and internal procedures and protocols. With particular reference to:

contracts for tenders,
contracts, authorizations, licenses, concessions, requests and/or management and use of funds of public origin (regional, national and/or EU),
order management,
relations with supervisory bodies or other independent authorities, social security institutions, tax authorities, bankruptcy, civil, criminal or administrative bodies and the like,

any contact with third parties shall be performed by the expressly authorized corporate bodies and individuals, according to corporate strategy and in writing. All written exchanges with the public bodies mentioned above shall be recorded and classified, making sure that objectively relevant verbal communications shall also be traced. Subjects delegated to the abovementioned tasks shall report to the delegating party in accordance with the law and internal organizational procedures.

4.2.3 RELATIONS WITH POLITICAL ENTITIES AND TRADE UNIONS

Solve.it does not directly or indirectly favor nor discriminate against any political or trade union organization.

The company shall refrain from making any kind of contribution, whether direct or indirect, in any form, to political parties, movements, political organizations or trade unions, their representatives or candidates, except as required pursuant to specific provisions of law.

4.2.4 RELATIONS WITH THE MASS MEDIA AND INFORMATION MANAGEMENT

Relations with the press, communication and information media and, more generally, external representatives shall only be held by subjects that have been expressly delegated to do so in accordance with the procedures and provisions adopted by Solve.it.

Employees shall not provide information or opinions or make representations on behalf of the Company to representatives of the media (such as the press, television, radio, etc.) and shall not do so without the necessary authorization from the relevant functions.

Any request for information from the mass media received by Solve.it staff must be sent to the company function that is expressly authorized to deal with the issue. In any event, all outward communication shall adhere to the guiding principles of truth, fairness, transparency and prudence in order avoid partial, distorted, ambiguous or misleading interpretations. Any form of investment, whether made directly or via a mediator, based on confidential company information is strictly forbidden. Regarding the management of information, in no event is it permissible to adopt behavior attributable to insider trading or use data, information or business opportunities learned during the exercise of a role for personal or third-party benefit or to adopt behavior of any other nature that may negatively affect company assets or is likely to result in undue personal or third-party benefits. All those who work on behalf of Solve.it in whatever capacity are required to maintain the utmost confidentiality and not to unduly disclose or request information concerning documents, know-how, research projects, business operations or, in general, any information learned through their working role. Information subject to specific laws or regulations (such as those relating, for example, to national security, the military, inventions, scientific discoveries, protected technologies and new industrial applications) and information that is contractually classified constitute confidential or secret information. In addition, any information learned during the performance of work activities and the dissemination or use of which may give rise to danger or damage the company and/or undue benefit to the employee or third parties constitutes confidential information.

5. THE SUPERVISORY BOARD

5.1 RESPONSIBILITIES AND CHARACTERISTICS

The task of supervising the operation and observance of the Model adopted by the company pursuant to Italian Legislative Decree 231/01, as amended, and the Code of Ethics is entrusted to the Supervisory Board, which has autonomous powers of initiative and control. The Supervisory Board operates with impartiality, authority, continuity, professionalism, autonomy and to this end:

is free to access any Solve.it sources of information;
is authorized to view documents and consult data;
may recommend updates to the Code of Ethics or internal protocols, including those based on reports made by employees, to the Board of Directors;
may perform checks, even periodically, on the operation and observance of the Model and the Code of Ethics;
is equipped with adequate human and material resources to enable it to operate quickly and efficiently.

The Supervisory Board also operates with broad discretion and with the full support of the Solve.it hierarchy, with which it cooperates in absolute independence.

5.2 REPORTS TO THE SUPERVISORY BOARD

In order to ensure the effectiveness of the Model and the Code of Ethics, Solve.it has implemented information channels which – while respecting the privacy and rights of individuals – allow anyone who becomes aware of any unlawful behavior taking place in the company to freely, directly and confidentially report it to the Supervisory Board. The board is responsible for the timely and careful verification of the information transmitted and the sharing of the results with the Board of Directors regarding any action aimed at ensuring behavior consistent with the Model and the Code of Ethics.

6. USE OF COMPANY EQUIPMENT AND INSTRUMENTS

Employees are required to ensure the utmost respect for the infrastructure, means, tools and materials belonging to the company, promptly notifying the Supervisory Board of any abnormal use of said equipment by others. By way of example, these categories include the following:

premises and furnishings;
operating equipment and instruments such as: company cars, utensils, personal computers, printers, calculating or writing instruments and the like;
photocopying, reproduction, printing and collating machines;
communication tools such as telephones, faxes and e-mails;
personal stationery, paper, office stationery and the like;
functions provided by the company information system such as: processing procedures, software, access to the Internet and databases and the like; books, newspapers, magazines and publications in general;
any personal protective devices and the equipment to which they are attached.

Employees are required to use the company’s facilities only for the performance of the tasks that they have been assigned. It is therefore strictly forbidden for employees to use company means – whether computers, technical or any other type – for the purpose of private ends or interests or in competition with company business.

Employees are allowed to use company equipment and/or material outside the corporate premises only when necessary for business purposes, such as: business trips to premises other than the usual premises, working on a secondment basis at other locations and the like. In all other cases, express permission by the employee’s supervisor or a company manager required.

7. OPERATING TRANSPARENCY

The company Model provides specific protocols aimed at preventing injurious events and resulting potential negative impacts on the company. The protocols are based on the Code of Ethics and are prepared – or appropriately integrated and modified – as a result of analysis of the corporate context, aimed at highlighting the risks inherent in the company, the existing control system and its actual suitability. The correct implementation of the protocols guarantees the ability to identify the company entities responsible for the process of decision-making, authorization and execution of operations: to this end, it is necessary for individual tasks to be performed at various stages by different parties, whose responsibilities are clearly defined and known within the organization, so that unlimited and/or excessive powers shall not be attributed to individual parties. Directors, with particular reference to executive directors, employees and anyone involved in a business relationship with Solve.it, each within their respective responsibilities and functions, are subject to strict compliance with the procedures set out in the protocols. Observing the guidelines provided by the specific protocols on the procedural process regarding the formation, decision and recording of company phenomena and their effect allows, among other things, the dissemination and encouragement of a culture of control at all levels of the company, contributing to the improvement of management efficiency and represents a tool in support of the management. Any non-compliance with the procedures provided by the protocols and the Code of Ethics – which should be reported promptly to the Supervisory Board) – may compromise the relationship of trust that exists between Solve.it and those who, in whatever capacity, interact with the company. All computer and electronic communication systems, including e-mail, Internet/intranet access and voice mail, form part of Solve.it’s computing assets and should be used exclusively for professional and work purposes. The truthfulness, accuracy, completeness and clarity of elementary information represent the necessary conditions for a transparent accounting activity and are a key value for Solve.it, also in terms of ensuring that members and third parties have a clear picture of the economic, equity and financial situation of the enterprise. In order for this value to be observed, it is first and foremost necessary that the documentation of the elementary facts is complete, clear, truthful, accurate and valid, as well as being kept on record for any necessary verifications, thereby ensuring traceability. The related accounting record shall reflect in a complete, clear, truthful, accurate and valid manner that which is described in the supporting documentation. In the case of financial assets based on assessments, the related record must be performed according to criteria of reasonableness and prudence, clearly explaining the criteria that guided the determination of the asset’s value in the relevant documentation. Anyone who becomes aware of possible omissions, falsifications, irregularities in the accounting process or in the documentation, or any breach of the principles set out in the Code of Ethics and the specific protocols, is required to promptly report the issue to the Supervisory Board. Said breaches strain the relationship of trust with the company, are important in disciplinary terms and shall be appropriately sanctioned.

8. BREACH OF THE CODE OF ETHICS - DISCIPLINARY SYSTEM

8.1 REPORTS OF BREACHES

With reference to information on an actual, attempted or requested breach of the rules contained in the Code of Ethics and related protocols, the company will ensure that no one in the workplace shall suffer retaliation, unlawful pressure, inconvenience or discrimination of any kind for having reported that the Code of Ethics or internal procedures have been breached to the Supervisory Board. Indeed, following the report, the company will promptly perform the appropriate checks and take any appropriate disciplinary measures.

8.2 DISCIPLINARY SYSTEM GUIDELINES

Breaches of the principles set out in the Code of Ethics and the procedures set out in the internal protocols compromise the relationship of trust between Solve.it and its directors, employees, consultants, contractors in whatever capacity, customers, suppliers, business and financial partners. Such breaches will therefore be incisively pursued by the company, promptly and quickly, using appropriate and proportionate disciplinary measures, irrespective of the penal relevance of the behavior and the initiation of criminal proceedings in cases in which it constitutes a criminal offence. In addition to being available on the corporate intranet, the Code of Ethics is also published on the company’s website to allow those who have a relationship with Solve.it to take it into the utmost consideration and assess the effects of any breaches. Further information on the company Model is available upon written request. In order to safeguard its image and protect its resources, the company shall not engage in any kind of relationship with parties that do not intend to operate in strict compliance with current legislation and/or refuse to adopt behavior that is consistent with the values and principles set forth in the Code of Ethics and to abide by the procedures and regulations provided for by the related protocols.

POLITICA PRIVACY
DEL SITO WEB
SOLVE.it S.r.l.

INFORMATIVA WEB

POLITICA PRIVACY DEL SITO WEB SOLVE.it S.r.l.

In questa politica si descrivono le modalità di gestione del sito Solve.it, in riferimento al trattamento dei dati personali degli utenti che lo consultano. Si tratta di un’informativa resa anche ai sensi dell’art. 13 del Regolamento Generale (UE) 2016/679 sulla Protezione dei Dati Personali (GDPR) e al D.lgs.196/2003 Codice in materia di protezione dei dati personali e successive modifiche, a coloro che interagiscono con i servizi web di Solve.it S.r.l., accessibili per via telematica a partire dall’indirizzo: www.solve.it. L’informativa è resa unicamente per il sito Solve.it e non copre altri siti raggiungibili tramite link dalle pagine Solve.it.

L’informativa si ispira anche alla Raccomandazione n. 2/2001 emessa dalle Autorità Europee per la protezione dei dati personali, che individua alcuni requisiti minimi per la raccolta di dati personali on – line e, in particolare, le modalità, i tempi e la natura delle informazioni che i titolari del trattamento devono fornire agli utenti quando questi si collegano a pagine web, indipendentemente dagli scopi del collegamento.

La presente Politica fornisce indicazioni sul trattamento dei dati acquisiti tramite la consultazione del sito web; per una panoramica completa sul trattamento dei dati da parte dell’azienda, si invita l’utente a consultare l’Informativa Solve.it sul trattamento dei dati.

IL “TITOLARE”
DEL TRATTAMENTO

INFORMATIVA WEB

IL “TITOLARE” DEL TRATTAMENTO

A seguito della consultazione di questo sito possono essere trattati dati relativi a persone identificate o identificabili. Il “Titolare” del loro trattamento è Solve.it S.r.l., che ha Sede Legale in Torino, Lgo Dora P. Colletta, 81, nella persona dei suoi legali rappresentanti pro-tempore.

I trattamenti di dati connessi ai servizi web di questo sito sono effettuati solo dal personale di Solve.it, incaricato del trattamento. Nessun dato personale derivante dal servizio web viene diffuso. I dati personali forniti dagli utenti sono utilizzati al solo fine di eseguire il servizio o la prestazione richiesta e sono comunicati a terzi nel solo caso in cui ciò sia necessario per conseguire quel fine.

TIPI DI DATI
TRATTATI

INFORMATIVA WEB

TIPI DI DATI TRATTATI

3.1 DATI DI NAVIGAZIONE

I sistemi informatici e le procedure software utilizzate per il funzionamento di questo sito web acquisiscono, nel corso del loro normale esercizio, alcuni dati personali la cui trasmissione è implicita nell’uso della rete Internet, che risulta basata sul protocollo TCP/IP.

Si tratta di informazioni che non sono raccolte per essere associate a interessati identificati, ma che per loro stessa natura potrebbero, attraverso elaborazioni ed associazioni con dati detenuti da terzi, permettere di identificare gli utenti navigatori.

In questa categoria di dati rientrano gli “indirizzi IP” o i nomi a dominio dei computer utilizzati dagli utenti che si connettono al sito, gli indirizzi in notazione URI (Uniform Resource Identifier) delle risorse richieste, l’orario della richiesta, il metodo utilizzato nel sottoporre la richiesta al server web, la dimensione del file ottenuto in risposta, il codice numerico indicante lo stato della risposta data dal server web (buon fine, errore, ecc…) ed altri parametri relativi al sistema operativo ed all’ambiente informatico dell’utente. Questi dati vengono utilizzati al solo fine di ricavare informazioni statistiche anonime sull’uso del sito e per controllarne il corretto funzionamento.

Si evidenzia che i predetti dati potrebbero essere utilizzati per l’accertamento di responsabilità in caso di reati informatici ai danni del sito web di Solve.it o ad altri siti ad esso connessi o collegati: salva questa eventualità, i dati sui contatti web vengono conservati per il tempo necessario al compimento dell’attività richiesta, oppure non oltre novanta giorni dalla data di acquisizione.

3.2 MINORI

Il sito web di Solve.It, può essere consultato anche da parte di minori di diciotto anni in quanto raccoglie solo contenuti informativi di tipo tecnico e commerciale, nell’ambito della fornitura di servizi informatici.

3.3 DATI FORNITI VOLONTARIAMENTE DALL’UTENTE

La richiesta di informazioni prevista nella pagina Contatti del sito web di Solve.it, comporta l’acquisizione di alcuni dati personali, compreso l’indirizzo e – mail del richiedente.

3.3.1 COOKIES

Nessun dato personale degli utenti viene in proposito acquisito dal sito.

Non viene fatto uso di cookies per la trasmissione di informazioni di carattere personale, né vengono utilizzati cosiddetti cookies persistenti di alcun tipo, ovvero sistemi per il tracciamento degli utenti.

L’uso di cosiddetti cookies di sessione (che non vengono memorizzati in modo persistente sul computer dell’utente e svaniscono con la chiusura del browser) è strettamente limitato alla trasmissione di identificativi di sessione (costituiti da numeri casuali generati dal server) necessari per consentire l’esplorazione sicura ed efficiente del sito.

I cosiddetti cookies di sessione utilizzati in questo sito evitano il ricorso ad altre tecniche informatiche potenzialmente pregiudizievoli per la riservatezza della navigazione degli utenti e non consentono l’acquisizione di dati personali identificativi dell’utente.

3.3.2 FACOLTATIVITÀ DEL CONFERIMENTO DEI DATI PERSONALI

A parte quanto specificato per i dati di navigazione, l’utente è libero di fornire i dati personali riportati nell’apposito modulo elettronico di richiesta. Tuttavia, il loro mancato conferimento comporta l’impossibilità di dare seguito alla richiesta di contatto.

3.4 MODALITÀ DEL TRATTAMENTO E MISURE DI SICUREZZA

Solve.it ha predisposto le necessarie misure per garantire che il trattamento si svolga nel pieno rispetto dei diritti degli interessati e della legislazione vigente. Per quanto riguarda la sicurezza delle informazioni, Solve.it dispone di un sistema di gestione certificato secondo la norma ISO 27001.

3.5 CONSERVAZIONE

I dati personali sono conservati ai soli fini dell’attività per cui sono stati registrati e, naturalmente, in ossequio ad eventuali disposizioni di legge in merito. Ciò significa che, quando tali dati non siano più funzionali a quei principi, vengono cancellati in modo permanente. Il Titolare si adopererà, entro i limiti previsti dalla legislazione, affinché anche gli eventuali destinatari dei medesimi dati provvedano alla cancellazione.

3.6 DIRITTI DEGLI INTERESSATI

Gli interessati a cui si riferiscono i dati personali eventualmente raccolti nella sezione specifica, potranno esercitare i diritti previsti dal CAPO III del RGPD e più specificatamente:

1.ottenere l’accesso ai suoi dati personali;

2.ottenerne:

a.l’aggiornamento, la rettifica ovvero, l’integrazione;

b.la cancellazione, o la limitazione del trattamento;

3.opporsi per motivi legittimi al trattamento dei propri dati personali;

Vista la modalità del trattamento è assai improbabile che si verifichino richieste rispetto alla portabilità dei dati. Nel caso specifico, Solve.it valuterà le motivazioni della richiesta per ottemperare alle disposizioni del RGPD.

Qualora le azioni conseguenti all’esercizio dei diritti di cui ai punti 2.b. e 3. siano incompatibili con la gestione del rapporto contrattuale, Solve.it provvederà ad evidenziarlo per trovare un accordo in merito.

Resta fermo il diritto dell’interessato di sottoporre reclamo all’Autorità di Controllo qualora non si reputi soddisfatto dal comportamento tenuto da Solve.it s.r.l. nei suoi confronti.

Solve.it non effettua processi decisionali automatizzati e non diffonderà i dati personali raccolti.

Per l’esercizio dei diritti, o qualsiasi necessità contattare il Titolare direttamente (Solve.it S.r.l. – Lungo Dora P. Colletta, 81 10153 Torino e-mail: info@solve.it), o attraverso l’indirizzo mail dedicato: privacy@solve.it.

Corporate management system policy

CONFIDENTIALITY

INTEGRITY

AVAILABILITY

Law 231 (Legislative Decree 231/2001)

ADDENDUM TO THE POLICY ON PERSONAL DATA PROCESSING REGARDING GREEN PASS CHECKS

PERSONAL DATA PROCESSING POLICY

PURPOSES OF DATA PROCESSING

SENSITIVE DATA

PROCESSING PROCEDURE

THIRD-PARTY COMMUNICATION

DATA CONTROLLER

RIGHTS OF THE DATA SUBJECT

WEBSITE POLICY

PRIVACY POLICY WEBSITE SOLVE.IT SRL

WEBSITE POLICY

DATA CONTROLLER

WEBSITE POLICY

TYPES OF DATA PROCESSED

3.1 BROWSING DATA

3.2 MINORS

3.3 DATA PROVIDED VOLUNTARILY BY THE USER

3.3.1 COOKIES

3.3.2 OPTIONAL NATURE OF PERSONAL DATA TRANSFER

3.4 PROCESSING PROCEDURES AND SECURITY MEASURES

3.5 STORAGE

3.6 DATA SUBJECT RIGHTS

1. PREMISE

2. GENERAL PRINCIPLES AND ETHICAL PRINCIPLES

2.1 PRINCIPLES OF LEGALITY

2.2 ETHICAL AND BEHAVIORAL PRINCIPLES

3. CONFLICT OF INTEREST

4. APPLICATION OF PRINCIPLES AND RULES OF BEHAVIOR

4.1 RELATIONSHIPS WITHIN THE COMPANY

4.1.1 RELATIONS BETWEEN SENIOR MANAGERS

4.1.2 RELATIONS BETWEEN EMPLOYEES

4.1.3 RELATIONS BETWEEN SENIOR MANAGERS AND EMPLOYEES

4.1.4 RELATIONS BETWEEN SENIOR MANAGERS, EMPLOYEES AND THE SUPERVISORY BOARD

4.2 RELATIONS THAT ARE EXTERNAL TO THE COMPANY

4.2.1 RELATIONS WITH CUSTOMERS/CONTRACTING AUTHORITIES AND SUPPLIERS

4.2.2 RELATIONS WITH AUTHORITIES AND PUBLIC ADMINISTRATIONS

4.2.3 RELATIONS WITH POLITICAL ENTITIES AND TRADE UNIONS

4.2.4 RELATIONS WITH THE MASS MEDIA AND INFORMATION MANAGEMENT

5.1 RESPONSIBILITIES AND CHARACTERISTICS

5.2 REPORTS TO THE SUPERVISORY BOARD

6. USE OF COMPANY EQUIPMENT AND INSTRUMENTS

7. OPERATING TRANSPARENCY

8.1 REPORTS OF BREACHES

8.2 DISCIPLINARY SYSTEM GUIDELINES

INFORMATIVA WEB

POLITICA PRIVACY DEL SITO WEB SOLVE.it S.r.l.

INFORMATIVA WEB

IL “TITOLARE” DEL TRATTAMENTO

INFORMATIVA WEB

TIPI DI DATI TRATTATI

3.1 DATI DI NAVIGAZIONE

3.2 MINORI

3.3 DATI FORNITI VOLONTARIAMENTE DALL’UTENTE

3.3.1 COOKIES

3.3.2 FACOLTATIVITÀ DEL CONFERIMENTO DEI DATI PERSONALI

3.5 CONSERVAZIONE

3.6 DIRITTI DEGLI INTERESSATI

Per l’esercizio dei diritti, o qualsiasi necessità contattare il Titolare direttamente (Solve.it S.r.l. – Lungo Dora P. Colletta, 81 10153 Torino e-mail: info@solve.it), o attraverso l’indirizzo mail dedicato: privacy@solve.it.