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Corporate management system policy

At Solve.it, we believe in expertise, personal and corporate credibility, quality, teamwork and enthusiasm for our work. The ultimate goal is greater customer satisfaction. Our chosen path was to implement management systems certified according international standards:
The quality management system (qms), introduced in 2005 in accordance with UNI EN ISO 9001:2000, subsequently amended to UNI EN ISO 9001:2008 and 2015 version re-certification in July 2017.
The ICT service management system, i.e. the service management system (SMS) based on the ISO/IEC 20000-1 standard, with certification obtained in 2014 and re-certification in July 2017.
The information security management system (isms) based on the ISO/IEC 27001 standard, with certification obtained on 3 December 2015.
In particular, the ISO/IEC 27001:2013 Standard states that data security is based on three aspects:
This expresses the guarantee that any given piece of information is only accessible to the processes that have to process it and the user who objectively needs it and is therefore authorized to use it.
This expresses the guarantee that any information is the one originally entered into the information system or legally modified.
This expresses the guarantee of the availability of information based on the need for business process continuity and for the purpose of complying with regulations (both legal and non-statutory) that require the data to be retained.
The security of data and information is based on the observance of organizational, procedural and technical measures that guarantee advance protection from unauthorized access, destruction, loss, alteration or disclosure of data, unauthorized or non-compliant processing.
An effective SGSI must:
Safeguard the interests of Solve.It and its customers
Guarantee the integrity and confidentiality of corporate information, as well as the continuity (availability) of business activities, ensuring that the expected level of protection is implemented according to the importance of the information requiring protection
Guarantee a virtuous and uniform behavioral model
Ensure tracking of the authorization processes and the activities carried out for legal, fiscal and operational purposes

Law 231 (Legislative Decree 231/2001)

Corporate Responsibility, Code of Ethics and Responsibility of Legal Persons pursuant to Italian Legislative Decree 231/01. – Corporate responsibility of companies and organizational, management and control models.
The activity of most companies and, consequently, their organization must take into account legislation and, in particular, the regulations provided for by the law in question. Legislative Decree 231/2001 extends the responsibility for offences committed in Italy and abroad by natural persons working for the company to legal persons.
In addition to the responsibility of the natural person who performs an unlawful deed, the law has introduced the penal liability of companies for certain offences committed in their interest or to their benefit by persons acting as representatives or working in the administration or management of the company or one of its organizations with financial or functional autonomy or by persons managed or supervised by one of the above mentioned subjects.


Solve.it Srl, L.go Dora P. Colletta, 81 10124 Turin, in its capacity as Data Controller, hereby informs you that your personal data, acquired to allow compliance with the anti-contagion measures relating to SARS Covid-2 will be managed using electronic and hardcopy means. All Data Subjects who access Solve.it’s headquarters (workers, maintenance technicians, visitors, etc.) will be subject to the checks.

The check is restricted to verifying the authenticity, validity and integrity of the certification and does not involve the collection of data in accordance with the provisions of Prime Ministerial Decree dated June 17, 2021, Legislative Decree 127 dated September 21, 2021 or the provisions of the Personal Data Protection Authority.

Since collection does not take place, data retention is not necessary.

The check is necessary in order to access Solve.it’s offices in full compliance with current legislation.

This check does not give rise to any automated decision, nor to profiling. Solve.it will ensure that this processing is carried out in full compliance with the aforementioned regulations and confidentiality obligations, providing precise instructions regarding any persons in charge of the checks. In case of need, a Data Subject party may exercise the rights provided for in Articles 15-22 of GDPR 679/2016, which are detailed in the information available on the website www.solve.it and displayed at the reception desk at the entrance to the offices. To exercise their rights, or any need, a Data Subject may contact the Data Controller directly at the operational headquarters or by using a dedicated e-mail address: sprivacy@solve.it.

Should the Data Subject not be satisfied with the behavior of Solve.it s.r.l., they may contact the Supervisory Authority in accordance with the instructions listed on the page



Solve.it Srl, Lgo Dora P. Colletta, 81 10124 Turin, in its capacity as Data Controller, hereby informs you that your personal data shall be processed both manually and with the aid of electronic tools, according to the regulations in force regarding the protection of personal data.
Solve.it s.r.l. collects and processes the personal data of the Data Subjects for: the performance of obligations arising out of contractual relationships, the performance of pre-contractual activities or by virtue of laws/regulations with which it must comply and/or decides to adhere to, more specifically:
  • information on their products and services;
  • relationship management with existing and potential customers;
  • contractual obligations;
  • fulfilment of accounting, tax and legal obligations;
  • after-sales management.
The provision of personal data for said purposes is strictly necessary and refusal to provide it means that Solve.it shall be unable to establish relations and/or perform said activities. Solve.it s.r.l. shall provide detailed information, if necessary. Processing is related to obligations of a contractual nature or to specific requests by the Data Subject, therefore consent is not required.
Solve.it does not collect sensitive data for its business purposes. Should an unforeseeable event result in Solve.it acquiring said data without consent, the Data Subject shall be contacted urgently in order to resolve the issue immediately.
Processing is performed using manual, computer and electronic instruments, with logic strictly related to the purposes stated. Solve.it possesses ISO 27001 standard certification and has established technological, organizational and procedural support to ensure that data is processed legally and securely. Personal data is stored for the period strictly necessary to carry out the contractual activity, unless the data is required for business needs (e.g.: data sheets) or legal requirements.
The pursuit of the aforementioned purposes may lead to the transmission and communication of data to third parties that have been appointed to carry or provide specific services strictly functional to the execution of obligations, such as:
  • banks and credit institutions;
  • consultants, professionals, external suppliers of business services;
  • suppliers of technological services;
  • carriers.
Data may be transferred to recipients headquartered in a third country or to international organizations with offices abroad. Solve.it will carry out said transfers after verifying compliance with the articles of the domestic and European legislation in force.
The Data Controller is Solve.it S.r.l., whose operational headquarters at Lungo Dora Colletta, 81 – 10153 – Turin, in the person of its legal representatives.
The Data Subject may exercise the rights provided for, more specifically:
  1. obtain access to their personal data;
  2. obtain: a. updating, rectification or addition of further data; b. ldeletion or limitation of processing;
  3. oppose for legitimate reasons: a. processing of personal data that concerns them; b. processing of personal data for the purpose of sending advertising or direct sales material or for conducting market research or commercial communications;
  4. Request that their data be transferred to another Data Controller, providing the necessary information and reasons.
If the actions resulting from the exercise of the rights referred to in points 2.b. and 3. are incompatible with the management of the business, Solve.it will highlight the fact in order to reach an agreement on the matter. If the exercise of the rights referred to in points 2.b and 4 proves impossible or too burdensome, Solve.it shall inform you without undue delay in order to agree upon a solution. Your right to submit a complaint to the Supervisory Authority remains unaffected if you are not satisfied with the behavior of Solve.it s.r.l. in your regard. Solve.it does not carry out automated decision-making processes and shall not disclose your personal data. To exercise your rights, or for any need you may have, please contact the Data Controller directly (info@solve.it), or through the dedicated e-mail address: sprivacy@solve.it


This policy describes how the Solve.It site is managed in terms of the processing of personal data belonging to the users visiting it. This informational notice is provided under art. 13 of the Genral Regulations (EU) 2016/679 regarding Personal Data Protection Code (GDPR) and Italian Legislative Decree 196/2003, to those interacting with Solve.It S.r.l. webservices, which are accessible electronically at the address: www.solve.It. The informational notice only refers to the Solve.It site and does not cover other sites accessible via links from Solve.It’s pages. The informational notice is also based on Recommendation no. 2/2001 issued by the European Data Protection Authorities, which identifies certain minimum requirements for online personal data collection and, in particular, the methods, times and nature of the information that data controllers are required to provide to users when the latter connect to web pages, regardless of the purpose of the visit. This Policy provides guidance on the processing of data acquired through consultation of the website; for a complete overview of the data processing by the company, you are invited to consult Solve.It’s informational notice on data processing.


Data relating to identified or identifiable individuals can be processed following a visit to the site. The “Data Controller” responsible for processing the data is Solve.It S.r.l., whose headquarters are in Turin, at Lgo Dora P. Colletta, 81, in the person of its legal representatives pro tempore. The processing of data related to the web services on the site is performed exclusively by Solve.It staff that have been assigned the task of processing. No personal data deriving from the web service shall be disseminated. Personal data provided by users is used solely for the purpose of performing the service requested and is only communicated to third parties in case in which doing so is necessary to achieve said purpose.


During the course of normal operation, the computer systems and software procedures used for the operation of the website acquire certain personal data, the transmission of which is implicit in the use of the Internet network, which is based on the TCP/IP protocol. The information is not collected so that it may be associated with identified individuals, but which by their very nature could, through processing and associations with data stored by third parties, allow the identifi This category of data includes “IP addresses” or the domain names of the computers used by the users who browse the website, the URI (Uniform Resource Identifier) notation addresses of the required resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numeric code indicating the response status provided by the web server (successful, error, etc.) and other parameters related to the operating system and the user’s computing environment. The data is only used for the purpose of obtaining anonymous statistical information on the use of the site and to check its proper functioning. Please note that the aforementioned data may be used to establish liability in the event of cybercrimes perpetrated on the Solve.It website or other related or linked sites: this exception aside, web contact data is retained for the time required to complete the activity requested and no longer than 90 days from the date of acquisition.
The Solve.it website can also be visited by minors under eighteen years of age, since it only collects technical and commercial information data for the provision of IT services.
The request for information on the Solve.It website Contacts page involves the acquisition of certain personal data, including the applicant’s e-mail address.
No user personal data is acquired by the site. No cookies are used for the transmission of personal data, nor are there any so-called persistent cookies of any kind, i.e. user tracking systems. The use of so-called session cookies (which are not persistently stored on the user’s computer and vanish when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) needed to allow the site to be browsed safely and efficiently. The so-called session cookies used on the site avoid the use of other potentially damaging computer techniques for the confidentiality of user browsing and do not allow the acquisition of the user’s personal identification data.
Aside from that specified for browsing data, users are free to provide the personal data shown in the specific electronic application form. However, their non-provision means it shall not be possible to satisfy the contact request.
Solve.it has implemented the necessary measures to ensure that processing is carried out in full compliance with the rights of the Data Subjects and the legislation in force. As regards information security, the Solve.it management system is certified according to the ISO 27001 standard.
Personal data is stored solely for the purposes of the activity for which it was recorded and, of course, in compliance with any relevant legal provisions. This means that, when such data is no longer functional to those principles, it is permanently deleted. The Data Controller will make every effort, within the limits established by legislation, to ensure that any recipients of said data shall also delete it.
The Data Subjects to whom the personal data collected in the specific section refers shall be able to exercise the rights provided for by CHAPTER III of the GDPR, more specifically:
  1. obtain access to their personal data;
  2. obtain: a. updating, rectification or integration; b. cancellation or limitation of processing;
  3. oppose processing of their personal data for legitimate reasons.
Given the method of processing, it is very unlikely that there will be requests regarding data portability. In any specific cases, Solve.it shall assess the reasons for the request to comply with the provisions of the GDPR. Should the actions resulting from the exercise of the rights referred to in points 2.2 and 3 be deemed incompatible with the management of the contractual relationship, Solve.it shall highlight the fact in order to reach an agreement on the matter. The right of the Data Subject to submit a complaint to the Supervisory Authority remains unaffected if they are not satisfied with the behavior of Solve.it s.r.l. in their regard. Solve.it does not carry out automated decision-making processes and shall not disclose the personal data collected. To exercise your rights, or for any need you may have, please contact the Data Controller directly (Solve.it S.r.l. – Lungo Dora P. Colletta, 81 10153 Turin e-mail: info@solve.it), or through the dedicated e-mail address: privacy@solve.it.  
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.

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).
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.
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:
  1. Equity, in other words, the behavioral regime based on the common understanding of substantive justice;
  2. Equality, in other words, the same treatment and social relationships towards all individuals, regardless of age, gender, race, physical handicap, religion, company position, financial status or social influence;
  3. Safeguard and appreciation of the individual, in other words, respect for each individual, appreciation of their abilities, establishment of mechanisms of trust and empowerment of individuals to develop Recipient consensus and a common corporate mission;
  4. Diligence, in other words, the fulfilling of an individual’s tasks with care and attention;
  5. Honesty, in other words, the inability to commit unlawful, illicit or even merely malicious acts, in observance of the legal principles, the Code and the moral principles, as well as due to a deep-seated sense of justice: Recipients must be aware of the ethical importance of their actions, must not pursue personal or business gain to the detriment of applicable laws and of the rules set forth herein, or even merely carry out actions which go against the common understanding of honesty;
  6. Transparency, in other words, the performance of an individual’s tasks in a manner that is fully intelligible by anyone; any task performed by a Recipient must be able to be fully reconstructed and each of its steps easily identified, so that every relationship is comprehensible and the respective actions justifiable;
  7. Impartiality, in other words, a manner of working and judging that is objective and unbiased, without favoritism towards any of the parties involved, whether public or private, linked to the Recipient by personal relationships or not;
  8. Confidentiality, in other words, the non-disclosure of any business data (whether technical, logistic, strategic or economic) or personal data, in compliance with all applicable privacy laws (Italian Legislative Decree 196/2003). The collection and processing of data is strictly reserved to the authorized bodies and are strictly performed according to company regulations. It is also expressly forbidden to divulge third-party privileged information pursuant to consolidated banking and financial regulations;
  9. Opportunities, in other words, the critical assessment of each action or omission according to criteria which, should they not fall under any other specific ethical or behavioral principle, reflect the common understanding of appropriateness and relevance;
  10. Protection of health, in other words, continuous focus by the company through a commitment to guarantee and maintain a safe, healthy and productive working environment, also through the dissemination of a culture of safety and risk awareness, as well as encouraging responsible behavior by employees. In order to protect the health and safety of its employees and social communities, the company tries to ensure that similar safety conditions are also guaranteed by third parties (contractors) when performing tasks managed through them;
  11. Protection of the environment, in other words, scrupulous care and attention paid to any behavior that, even minimally, offends the common understanding of environmental education. The company also promotes the dissemination of a culture of environmental protection and pollution prevention through the training of personnel to promote the development of awareness of the risks and responsible behavior regarding:
  1. the implementation of differentiated waste collection and recycling programs for reusable materials;
  2. 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).
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.
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.
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.
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.

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.
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.
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.

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.

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.
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.
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.

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.
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.
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.
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.
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.
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.
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.



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.



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.



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.


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.


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.


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.


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.


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.


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.


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;
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.