Information on the processing of personal data of website users Art. 13 and 14 of Regulation 2016/679 / EU (hereinafter also "GDPR")

Why this notice

The22 APS (hereinafter also "The22" or "Owner") is committed to respecting and protecting your privacy and wants you to feel safe both while simply browsing the site and in case you decide to register by providing us with your personal data to use the services made available to its Users and / or Customers.

On this page intends to provide some information on the processing of personal data relating to users who visit or consult the website accessible electronically from the address (the "Site").

The information is provided only for the website of The22 association and not for other websites that may be consulted by the user via links (for which reference should be made to the respective privacy policies / policies).

The reproduction or use of pages, materials and information contained within the Site, by any means and on any medium, is not permitted without the prior written consent of  The22 Association.

Copying and / or printing is permitted for personal and non-commercial use only (for requests and clarifications  please  contact Aparna Thadani at the addresses indicated below).

Other uses of the contents, services and information on this site are not permitted.

With regard to the contents offered and the information provided, The22 will make sure to keep the contents of the Site reasonably updated and revised, without offering any guarantee on the adequacy, accuracy or completeness of the information provided, explicitly declining any responsibility for any errors of omission in the information provided on the Site.

Origin - Navigation data

The22 informs that the personal data provided by you and acquired at the same time as the request for information and / or contact, registration on the site and use of services via smartphone or any other tool used to access the Internet, as well as the data necessary for the provision of these services, including the navigation data and the data used for the possible purchase of the services offered by The22 but also the cd data only of "navigation" of the site by Users, will be treated in compliance with the applicable legislation.

The computer systems and software procedures used for the operation of this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of the Internet. This information is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of data includes the "IP addresses" or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used in the submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the operating system and the IT environment of the user. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check the correct functioning of The22 website.

It should be noted that the aforementioned data could be used to ascertain responsibility in case of computer crimes against The22 site or other sites connected or connected to it: except for this possibility, the data on web contacts do not currently persist for more than a few days.

Origin - Data provided by the user

The Data Controller collects, stores and processes your personal data in order to provide the products and services offered on the Site, or for legal obligations.

With regard to some specific Services, Promotions, etc. the Data Controller may also process your data for commercial purposes. In such cases, a specific, separate, optional and always revocable consent will be requested with the methods and at the addresses indicated below.

The optional, explicit and voluntary sending of e-mails to the addresses indicated in the appropriate section of the website, as well as the compilation of questionnaires (for example, forms), communication via chat, push notification through APP, social network, call center, etc., involves the subsequent acquisition of some of your personal data, including those collected through the use of the Apps and related services, necessary to respond to requests.

We also point out that when using the mobile connection to access digital content and services offered directly by The22 association or by our Partners, it may be necessary to transfer your personal data to such third parties.

We point out that you may access the Site or connect to areas where you may be enabled to publish information using blogs or message boards, communicate with others, for example coming from The22 page on Instagram®, Facebook®, LinkedIn®, YouTube®, and other social networking sites, review products and offers and post comments or content.

Before interacting with these areas, we invite you to read the General Terms of Use carefully taking into account that, in certain circumstances, the published information can be viewed by anyone with access to the Internet, and all information that you include in your publications can be read, collected and used by third parties.

Purpose of the processing and legal basis

The data are processed for the purposes:

1) strictly connected and necessary to register on the site, to the services and / or Apps developed or made available by The22, to use the related information services, to manage contact requests or information regarding the services offered through the site;

2) for ancillary activities related to the management of User / Customer requests and the sending of feedback which may include the transmission of promotional material; updating on the availability of services temporarily unavailable;

3) related to the fulfillment of obligations under EU and national regulations, the protection of public order, the detection and prosecution of crimes;

4) direct marketing, i.e. sending advertising material, commercial communication of services offered  by The22;

this activity may also concern services of other companies belonging to The22 association and be performed by sending information material and / or invitations to participate in initiatives, events and offers aimed at rewarding users, carried out through "automated" systems of contact (through of example WhatsApp, e-mail etc.), pursuant to art.130 c.1 and 2 of Legislative Decree 196/03 and subsequent amendments;

The provision of data for the purposes specified in points 1), 2) and 3) related to the pre-contractual and / or contractual phase or functional at the request of the user or provided for by a specific regulatory provision is mandatory and, if this is not done, it will be impossible to obtain information and get access to the requested services; with regard to point 4) of this Notice, the consent to the processing of data by the user / customer is instead free and optional and always revocable without consequences on the usability of the products and services except for the impossibility for The22 association to keep updated on the new initiatives or on particular promotions or advantages that may be available to users / customers.

The Data Controller may send commercial communications relating to products and / or services similar to those already provided, pursuant to Directive 2002/58 / EU, using the e-mail coordinates, or the paper ones, indicated by you on such occasions to which you can object, with the methods and contact details below.

Methods, logic of processing, storage times and security measures

The processing is also carried out with the assistance of electronic or automated means and is carried out by The22 association and / or by third parties which the Data Controller can use to store, manage and transmit the data. Data processing will be carried out with the logic of organization and processing of your personal data related to the purposes indicated above and, in any case, in order to guarantee the security and confidentiality of the data. The personal data processed will be kept for the times provided for by the legislation in the applicable time.

Still with regard to data security, in the sections of the website set up for particular services, where personal data is requested from the navigator user, the data is encrypted using a security technology called Secure Sockets Layer, abbreviated to SSL. SSL technology encrypts the information before it is exchanged via the Internet between the user's computer and The22's central systems, making it incomprehensible to unauthorized persons and thus guaranteeing the confidentiality of the information transmitted.

With reference to the personal data protection aspects, the user / customer is invited, pursuant to art.

33 of the GDPR to report to the Data Controller any circumstances or events from which a potential "breach of personal data (data breach)" may arise in order to allow an immediate assessment and the adoption of any actions aimed at countering this event by sending a communication to

The measures adopted by The22 association do not exempt the Customer from paying the necessary attention to the use, where required, of a password / PIN of adequate complexity, which must be updated periodically, especially if the subject has been violated / known by third parties, as well as keep carefully and make it inaccessible to third parties, in order to avoid improper and unauthorized use.


A cookie is a short string of text that is sent to your browser and, possibly, saved on your computer (alternatively on your smartphone / tablet or any other tool used to access the Internet); such sending generally occurs every time you visit a website.

The22 association uses cookies for various purposes, in order to offer you a fast and secure digital experience, for example, allowing you to keep the connection to the protected area active while browsing through the pages of the site.

The cookies stored on your terminal cannot be used to retrieve any data from your hard disk, transmit computer viruses or identify and use your e-mail address.

Each cookie is unique in relation to the browser and device you use to access the Website or use the The22 Apps. Generally, the purpose of cookies is to improve the functioning of the website and user's experience in using it, even if cookies can be used to send advertising messages (as specified below).

For more information on what cookies are and how they work, you can consult the “All about cookies” website

For detailed information on Cookies, read the dedicated page (____________-)

Areas of communication and data transfer.

For the pursuit of the aforementioned purposes, the Data Controller may communicate and have the personal data of users / customers processed in Italy by third parties with whom we have relationships, where these third parties provide services at our request. We will provide these third parties only with the information necessary to perform the requested services, taking all measures to protect your personal data. In case of use of services offered directly by Partners we will provide only the data strictly necessary for their execution. In any case, only the data necessary for the pursuit of the intended purposes will be disclosed. We may also disclose personal data to our commercial service providers, for marketing reasons, appointed as external data processors for this purpose. Furthermore, personal data may be communicated to the competent public subjects and authorities for the purposes of compliance with regulatory obligations or to ascertain responsibility in the event of computer crimes against the site as well as communicated to, or allocated to, third parties (as managers or, in the case of suppliers of electronic communication services, autonomous owners), who provides IT and telematic services (for example: hosting, management and development of websites) and which the owner uses for the carrying out tasks and activities of a technical and organizational nature that are instrumental to the working of the website. The subjects belonging to the above categories operate as separate Data Controllers or as Managers appointed for this purpose by The22.

Personal data may also be known by The22 employees / consultants who are specially trained and appointed as Data Processors.

The categories of recipients to whom the data may be communicated are available by contacting The22 at the addresses indicated below

Rights of interested parties

You can exercise at any time the rights that are recognized by the law, including: a) to access your personal data, obtaining evidence of the purposes pursued by the Data Controller, the categories of data involved, the recipients to whom they may be communicated, the applicable retention period, the existence of automated decision-making processes; b) to obtain without delay the correction of inaccurate personal data concerning you; c) to obtain, in the cases provided for, the cancellation of your data; d) to obtain the limitation of the treatment or to oppose it, when possible; e) to request the portability of the data you have provided to the Data Controller, i.e. to receive them in a structured format, commonly used and readable by an automatic device, also to transmit such data to another owner, within the limits and with constraints provided for by art. 20 of the GDPR; Furthermore, you can lodge a complaint with the Guarantor for the Protection of Personal Data pursuant to art. 77 of the GDPR. For the treatments referred to in point 4) of the purposes, the Customer can always revoke the consent and exercise the right to object to direct marketing (in "traditional" and "automated" form). The opposition, in the absence of any indication to the contrary, will refer to both traditional and automated communications.

Data Controller

Data controller, pursuant to art.4 of the GDPR, is Aparna Thadani

The above rights can be exercised at the request of the interested party using the following references: 

Mail Secretariat: Aparna Thadani;

Privacy Referent: Aparna Thadani.

Use of the Website, including for tablets and / or smartphones, by the Customer and / or the User implies full knowledge and acceptance of the content and any information contained in this version of information  published  by the Owner when the site is available and used.

The22 advises that this information is subject to change without notice and therefore recommends periodic reading. 

Data Controller

Aparna Thadani

This privacy statement was updated on 02/04/2021

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