Privacy Policy

The protection of personal data is a matter of trust and your trust is important to us. In order for you to feel comfortable on our web pages, in processing your personal data we strictly comply with the provisions of the law and with the new European Regulation on the protection of personal data - EU Regulation n. 2016/679 (hereinafter GDPR). For this purpose, in this privacy statement you will find all the information that will allow you to understand what data we collect, why we collect it and how we use it. The privacy of our users is important to us and that is why we want you to be fully aware of our practices. For any questions you can in any case contact us at the following email address: This email address is being protected from spambots. You need JavaScript enabled to view it.. We will take care of answering you as soon as possible.

1. OWNER OF THE PROCESSING OF PERSONAL DATA

The data controller of the personal data collected on insightadv.it/insightadv.uk/insightadv.ltd.uk (hereinafter "Site") is:

Insight Adv Ltd
Registered office : 128 City Road, London, United Kingdom EC1V 2NX - Company No: GB14555148 - ICO No: ZB568039
Telephone and fax : +44 020 8133 1493
Email : This email address is being protected from spambots. You need JavaScript enabled to view it.
(hereinafter: "Insight")

2. PERSONAL DATA PROCESSED

Personal data are data about personal or objective circumstances of a specific or identifiable natural person. This definition includes, for example, your name, your telephone number, as well as the personal data that you communicate to us during the registration or creation of your Account.

Insight only collects data that the user voluntarily provides and navigation data. For consultation of the "public" part of the Site (ie the one freely accessible by every user), no provision of personal data by the user is envisaged. For access to the reserved content part of the Site (i.e. the part accessible only through registration), to complete an order or for any contact with Insight by the user through, for example, sending mail, electronic or traditional, to the contact details of Insight indicated on the Site, the user's data must be considered acquired and, therefore, processed in full compliance with current legislation.

2.1 LEGAL BASIS OF THE TREATMENT

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

2.2 TYPE OF DATA

Among the Personal Data collected by this Website, either independently or through third parties, there are: Cookies, Usage and navigation data, personal data for profile creation, billing and shipping data, contact forms, quote requests , collaboration offers and payment management.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.

Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner.

Any use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

2.3 USER PROFILE

For each customer who proceeds to register via the "Create an account" function, we create a "User Profile", i.e. password-protected direct access to his personal data registered on our Site. Here you can see, among other things, the data of your orders processed, in progress, shipped or delivered, as well as manage your personal data, or authorize or withdraw your consent to the sending of the newsletter.

2.3.1 USER PROFILE CREATION

During registration the following data are mandatory (MANDATORY DATA):

- Your email address

- Your name

- Your Surname

- Your Date of Birth

- Your Password

- Consent to the processing of your personal data

2.3.2 BILLING OR SHIPPING INFORMATION

Only when an order on the Site is completed and authorized will other personal data necessary to process the order be requested.

The data necessary for the shipment and invoicing of orders placed on our site are as follows

- Confirmation of your Name

- Confirmation of your Last Name

- The Company Name of your company

- The address of the registered office (Street, House number, City, Province, Postcode, Country)

- Confirmation of your e-mail address

- Telephone number

- Cellphone number

- Tax ID code

- VAT number

- Any shipping addresses of the goods if different from the billing address provided. In this case the following will be required: Name. Surname, Company name, Shipping address (Street, House number, City, Province, Postal code, Country), Telephone number, Mobile number.

- Consent to the Terms and Conditions of Sale.

2.4 CONTACT FORMS

On the institutional website of Insight (insightadv.it/insightadv.uk/insightadv.ltd.uk ) there is a special contact form. The requested data are the following:

- your Name

- your Surname

- your Company

- your email

- your telephone number

- your mobile number

- your message

- consent to the processing of your personal data

The data sent through this form are not stored in the site database, but are sent by e-mail to the Data Controller and are managed and processed by the same in order to respond to the requests of the interested party.

2.5 REQUEST FOR QUOTE

On the Insight corporate website (insightadv.it/insightadv.uk/insightadv.ltd.uk ) there is a form for requesting a quote. The data requested in the form are the following:

- First name

- Surname

- Telephone number

- Cellphone number

- Email address

- Company Name

- Type of company

- Role of the contact within the company

- Company headquarters address (street, city, province, zip code)

- Company telephone number

- Company email

- Company website

- Country code

- VAT number

- Main activity of the company

- Short text description of the company

- Company objectives

- Other stratified data aimed at identifying the services requested and to be estimated

- Further communications

- Consent to the processing of personal data

The data sent through this form are not stored in the site database, but are sent by e-mail to the Data Controller and are managed and processed by the same in order to respond to the request of the interested party for the formalization of a commercial offer (estimate).

2.6 COOPERATION OFFER

On the institutional website of Insight (insightadv.it/insightadv.uk/insightadv.ltd.uk ) there is a form for the offer of collaboration (Collaborate with Us). The data requested in the form are the following:

- First name

- Surname

- Date of birth

- Birth place

- Residential address (street, city, province, zip code)

- Email address

- Telephone number

- Graphic skills

- Web skills

- Photography skills

- Programming skills

- Video skills

- 3D graphics skills

- Expertise in app design and development

- Skills in software and application design and development

- Language skills

- Marketing skills

- Sales (commercial) skills

- Other professional skills

- OS operating environment

- Work condition

- Educational qualification or professional qualification

- Message

- Possibility to attach your curriculum vitae

- Consent to the processing of personal data

The data sent through this form are not stored in the site database, but are sent by e-mail to the Data Controller and are managed and processed by the same to view the User's professional skills, as per his request , for the purpose of a possible collaboration with Insight. These data are printed and stored in a special locked file at the headquarters of the Data Controller.

2.7 PAYMENT MANAGEMENT

Payment management services allow this Website to process payments by credit card, bank transfer or PayPal account. The data used for payment are acquired directly by the operator of the requested payment service without being processed in any way by the Website or by Insight.

Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

PayPal is a payment service provided by PayPal Inc., which allows the User to make payments online. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Consult the Paypal privacy policy – Privacy Policy ( https://www.paypal.com/privacy ).

2.8 NAVIGATION DATA

Among the navigation data, the following may be collected:
• IP addresses;
• URI addresses - Uniform Resource Identifier - of the requested resources;
• time and method used to formulate requests to the server;
• numerical code about the status of the response given by the server (successful, error, etc.); etc.
Navigation data relates to the user's operating system and computer environment, the transmission of which is implicit in the use of Internet communication protocols. Although this information is not collected to be associated with identified interested parties, by their nature they could, through processing and association with data held by third parties, allow users to be identified.

2.9 ADDITIONAL INFORMATION ABOUT PERSONAL DATA

Insight does not sell products or provide services to minors. If you are under the age of 18, you may use the Insight Services only with the involvement of a parent or guardian.

The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery.

This website may send push notifications to you.

2.10 DETAILS ON THE PROCESSING OF DATA IN RELATION TO THIRD PARTY SERVICES USED ON THE SITES

2.10.1 INTERACTION WITH SOCIAL NETWORKS AND EXTERNAL PLATFORMS

This type of service allows you to interact with social networks, or with other external platforms, directly from the pages of this Website. The interactions and information acquired from this Website are in any case subject to the User's privacy settings relating to every social network.
In the event that an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.

PayPal button and widget (Paypal)

The PayPal button and widget are services for interacting with the PayPal platform, provided by PayPal Inc.

Personal Data collected: Cookies and Usage Data. Place of processing: Consult the Paypal privacy policy - Privacy Policy .

+1 button and Google+ social widgets (Google Inc.)

The +1 button and the Google+ social widgets are services allowing interaction with the Google+ social network, provided by Google Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook "Like" button and social widgets are services allowing interaction with the Facebook social network, provided by Facebook, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

Twitter Tweet button and social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are services allowing interaction with the Twitter social network, provided by Twitter, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

Pin it button and Pinterest social widgets (Pinterest)

The "Pin it" button and Pinterest social widgets are services for interacting with the Pinterest platform, provided by Pinterest Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

Linkedin button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network, provided by LinkedIn Corporation. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

YouTube button and social widgets (Google Inc.)

The YouTube button and social widgets are services allowing interaction with the YouTube social network, provided by Google Inc. Personal Data collected: Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

ShareThis (Sharethis Inc.)

ShareThis is a service provided by ShareThis Inc which displays a widget that allows interaction with external social networks and platforms and the sharing of the contents of this Website.
Depending on the configuration, this service can show widgets belonging to third parties, such as social network managers on which to share interactions. In this case, the third parties that supply the widget will also be aware of the interactions performed and of the Usage Data relating to the pages in which this service is installed. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

2.10.2 VIEWING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of this website and to interact with them. If a service of this type is installed, it is possible that, even if the Users do not use the service, it may collect traffic data relating to the pages in which it is installed.

Vimeo Videos (Vimeo, LLC)

Vimeo is a video content viewing service managed by Vimeo, LLC which allows this Website to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

Google Maps widget (Google Inc.)

Google Maps is a map visualization service managed by Google Inc. which allows this Website to integrate such contents within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

Widget ilMeteo (ilMeteo srl)

Widget ilMeteo is a content visualization service managed by ilMeteo and ilMeteo srl. Personal Data collected: Usage Data. Place of processing: Italy – Privacy Policy .

Instagram Widgets (Instagram, Inc.)

Instagram is an image viewing service managed by Instagram, Inc. which allows this Website to integrate such contents within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

YouTube Video Widgets (Google Inc.)

YouTube is a video content viewing service managed by Google Inc. which allows this Website to integrate such content within its pages. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

2.10.3 STATISTICS

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour.

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened within the United States. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out . Subject adhering to the Privacy Shield.

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out . Subject adhering to the Privacy Shield.

Histats (Wisecode)

Histats is a statistics service provided by Wisecode Srl Personal Data collected: Cookies and Usage Data.

Place of processing: Italy – Privacy Policy – Opt out .

ShinyStat Free (Triboo Data Analytics SRL)

ShynyStat Free is a statistics service provided by Triboo Data Analytics SRL. This statistics service makes the User's IP address anonymous. Personal Data collected: Cookies and Usage Data. Place of processing: Italy – Privacy Policy – Opt Out .

2.10.4 TAG MANAGEMENT

This type of service is functional for the centralized management of the tags or scripts used on this Website.
The use of these services involves the flow of User Data through them and, where appropriate, their retention.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

2.10.5 SPAM PROTECTION

This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a SPAM protection service provided by Google Inc. Use of the reCAPTCHA system is subject to Google's privacy policy and terms of use . Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy . Subject adhering to the Privacy Shield.

WebPurify (WebFurther, LLC.)

WebPurify is a SPAM protection service provided by WebFurther, LLC. Personal Data collected: various types of Data as specified in the privacy policy of the service. Place of processing: United States - Privacy Policy .

2.10.6 INFRASTRUCTURE MONITORING

This type of service allows this Website to monitor the use and behavior of its components, to allow for the improvement of performance and functionality, maintenance or problem solving.
The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter the activity of this Website.

Web Performance (Web Performance, Inc.)

Web Performance is a monitoring service provided by Web Performance, Inc. Personal Data collected: Cookies and Usage Data. Place of processing: United States - Privacy Policy .

2.10.7 RECOMMEND PRODUCT TO A FRIEND

This Website may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been authorized - and to suggest friends or connections within it. Personal Data collected: various types of Data.

3. PURPOSE OF THE TREATMENT

We collect, store and process your data for the complete execution of your order, including subsequent warranty procedures, for our services, technical administration, own marketing purposes, as well as to prevent crime and fraud.

The User Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Interaction with external social networks and platforms, Infrastructure monitoring, Registration and authentication, Platform services and hosting, Statistics, Contacting the User, SPAM Protection, Tag Management, Interacting with Live Chat Platforms, Payment Management, Content Commenting and Displaying Content from External Platforms.

3.1 CONTRACTUAL PURPOSES

In order to provide the services requested and fulfill your orders on our site, consent to the processing of data is necessary, as without consent it will not be possible for us to provide the same services or fully execute your orders.

The processing of billing data and for processing payments are mandatory, in compliance with the provisions of the law with reference to the tax obligations of companies. In the processing of payment and billing data, Insight will use the user's personal data only in order to facilitate purchases, issue the related invoices and record payments received. In no way will Insight acquire the user's bank details as each payment will be made via Paypal or by bank transfer.

3.2 MARKETING PURPOSES

We also use your data for the following purposes: to continuously improve your shopping experience and to make it customer- and individual-appropriate; to be able to communicate with you about your purchases, as well as certain products or marketing offers; and to recommend products or services that may be of interest to you.

For this purpose, we use existing information such as e-mail receipt and read confirmations, information about the end device you are using, your internet connection, operating system and platform, date and time of the website visit, or products you have reviewed as well as information, which we receive from you (including automatically generated or transmitted information). We also use the historical data of your orders.

You can object to the use of your personal data for advertising purposes either completely or individually at any time without incurring costs beyond the transmission costs according to the basic rates. A communication in text form to the contact details pursuant to art. 1 (eg: by email, fax, letter) is sufficient.

3.3 NEWSLETTER

For sending the newsletter we use the e-mail address you have provided to us and we only need your consent that you, as owner of the e-mail address, approve the receipt. This consent can be given at the profile creation stage and at any time on your user profile page.

If you subsequently no longer wish to receive our newsletter, you can revoke your consent at any time by accessing your personal page, or you can object to it at any time without incurring costs beyond the transmission costs according to the basic rates. A communication in text form to the contact details pursuant to art. 1 (eg: by email, fax, letter) is sufficient. Of course, every issue of the newsletter also contains an unsubscribe link.

4. CONSERVATION OF PERSONAL DATA

Insight will keep the user's information in the terms required by current legislation and, in any case, for as long as necessary to provide the requested services.

4.1 DATA STORAGE PLACE

The Data is processed at the Data Controller's operational headquarters and in any other place where the parties involved in the processing are located. For more information, contact the Owner.

The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the details indicated in article 1.

4.2 CONSERVATION PERIOD

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the treatment is based on the User's consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

5. SECURITY OF PERSONAL DATA

All data processed and stored at the Data Controller's operational headquarters are stored and maintained in secure facilities that limit access to authorized personnel only. The corporate network is protected by a first firewall installed on the modem for accessing the internet connection and by a second firewall installed on the router that manages the internal network. All computer workstations are protected by their own firewall, antivirus software and several constantly updated anti-malware programs. Access to individual workstations is then limited to only authorized personnel with complex alphanumeric passwords and military quality encryption. All workstations are protected against removal or loss of data, with an automatic weekly backup system.

The transfer, storage and processing of user data that are collected through the Site are ensured through appropriate technical measures. All user information is protected with the password that the user himself has chosen; passwords are not recorded in clear text but protected with 512-bit SHA-2 technology. Furthermore, the site is provided over an HTTPS encrypted connection, using Secure Sockets Layer (SSL) software which encrypts the information you provide.

The website is constantly updated and is regularly checked to check for any security breaches and ensure that all information collected is safe from unauthorized access.

User data is collected, archived and stored on a secure server, protected by a firewall and physically located in the Aruba Business Srl web farm which complies with all the security measures described by the applicable laws and regulations and all the appropriate measures according to the currently most cutting-edge criteria, to ensure and guarantee the confidentiality of users' personal data and minimize, as far as possible, the dangers posed by unauthorized access, removal, loss or damage to users' personal data . For more information, you can consult Aruba's Privacy Policy at the following address https://business.aruba.it/informativa_arubabusiness.pdf

The data on the server and in the database are backed up daily, weekly and monthly.

Each superuser login is protected by military-grade encryption (with 4096-bit DH asymmetric keys).

6. TRANSFER OF DATA TO THIRD PARTIES

Your personal data will only be passed on to third parties insofar as this is permitted by law, including for purposes of contract execution or billing and for marketing purposes, if you have given your prior consent.

As part of the execution of the order, for example, the service providers we appoint (for example: printing house, internet service provider (ISP), Whois (publicly accessible register), Registration Authority competent for the chosen extension (Register of the ccTLD ), carrier or courier, logistics company, banks, accountant) receive the data necessary to carry out the order and the assignment received. The service providers we commission may use the data thus transmitted solely and exclusively for the purpose of fulfilling their task.

THIRD PARTY PROVIDERS OF THE INSIGHT

Purpose: Provision of services (assistance, maintenance, delivery/shipping of products, provision of additional services, suppliers of electronic communication networks and services, typographic and digital printing services) connected to the requested service

CREDIT INSTITUTIONS AND DIGITAL BANK/POST PAYMENT INSTITUTIONS

Purpose: Management of payments, receipts, refunds related to the contractual performance

PROFESSIONALS AND EXTERNAL CONSULTANTS

Purpose: Fulfillment of legal obligations, exercise of rights, protection of contractual rights, credit recovery

FINANCIAL ADMINISTRATION, PUBLIC BODIES, JUDICIAL AUTHORITIES, SUPERVISORY AND CONTROL AUTHORITIES

Purpose: Fulfillment of legal obligations, defense of rights; lists and registers kept by public authorities or similar bodies on the basis of specific legislation, in relation to the contractual performance

PERSONS FORMALLY DELEGATED OR WITH RECOGNIZED LEGAL ENTITLEMENT

Purpose: Legal representatives, guardians, curators, etc.

These third parties will process the user's personal data in full compliance with current legislation.

The Data Controller requires its third-party suppliers and Data Processors to comply with security measures equal to those adopted in relation to the Data Subject, restricting the scope of action of the Data Processor to processing connected to the requested service.

The Data Controller does not transfer your personal data to countries where the GDPR is not applied (non-EU countries) unless otherwise specified, for which you will be informed in advance and, if necessary, your consent will be requested.

The legal basis of these treatments is the fulfillment of the services inherent to the established relationship, compliance with legal obligations and the legitimate interest of the Insight to carry out the treatments necessary for these purposes

Only if Insight is required to do so by law, personal data will be provided to the competent authorities.

7. REFUSAL OF CONSENT TO THE PROCESSING OF DATA

7.1 What happens if the interested party does not provide his/her data identified as necessary for the execution of the requested service? (Article 13, 2nd paragraph, letter e GDPR)

The collection and processing of personal data is necessary to follow up on the services requested as well as the provision of the Service and/or the supply of the requested Product. If the interested party does not provide the personal data expressly provided for as necessary in the order form or registration form, the Data Controller will not be able to proceed with the processing related to the management of the services requested and/or the contract and the Services/ Products connected to it, nor to the obligations that depend on them.

7.2 What happens if the interested party does not provide consent to the processing of personal data for commercial promotion activities on Services/Products other than those purchased?

In the event that the interested party does not give his consent to the processing of personal data for these purposes, said processing will not take place for the same purposes, without this having effects on the provision of the services requested, nor for those for which he has already given their consent, if requested.

In the event that the interested party has given his consent and subsequently revokes it or opposes the treatment for commercial promotion activities, his data will no longer be processed for such activities, without this having consequences or prejudicial effects for the interested party and for the required performance.

8. USER RIGHTS (INTERESTED)

Users can exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

• withdraw consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data, by communicating it to the Owner or simply by accessing his user profile on the site (if he is registered as a user).
• oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.
• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed, by requesting it from the Data Controller or simply by accessing his user profile on the site (if is logged in as a user).
• check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction. You can request verification and rectification, to the contacts referred to in art. 1 of the owner or simply by accessing his user profile on the site (if he is registered as a user).
• obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
• obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of his Data by the Owner or he can himself cancel his account, simply by accessing his personal page on the site (if he is registered as a user).
• receive their data or have them transferred to another holder. The User has the right to receive his Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it. This operation can be performed by the user by accessing his personal page on the site and can download the data in pdf or csv format.
• propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

9. DETAILS ABOUT THE RIGHT TO OBJECT

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

10. HOW TO EXERCISE YOUR RIGHTS

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

Or you can use the appropriate tools available on the site and accessible by accessing your personal page on the site.

11. COOKIE POLICIES

This Website uses Cookies. To find out more and to view the detailed information, the User can consult our Cookie Policy.

12. FURTHER INFORMATION ABOUT THE TREATMENT

12.1 LEGAL DEFENSE

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuses in the use of this Website or related Services by the User.

The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

12.2 SPECIFIC DISCLOSURES

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

12.3 SYSTEM AND MAINTENANCE LOGS

For needs related to operation and maintenance, this Website and any third party services used by it may collect System Logs, which are files that record the interactions and which may also contain Personal Data, such as the User's IP address.

12.4 INFORMATION NOT CONTAINED IN THIS POLICY

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

12.5 RESPONSE TO “Do Not Track” REQUESTS

This Website does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

12.6 CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Therefore, please consult this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

13. CONTACTS

Information and requests regarding privacy can be addressed to Insight Adv Ltd through

- E-mail to box: This email address is being protected from spambots. You need JavaScript enabled to view it.

- Postal mail to: Insight Adv Ltd, 128 City Road, London, United Kingdom EC1V 2NX

- Fax to the following number: +44 020 8133 1493

Last update: 23 January 2024

Code of Ethics

Our Code of Ethics declares our commitment to promote the application of our Ethical Principles by our business partners and suppliers.

1. Strategies and behaviors

Insight Adv Ltd places the customer at the center of every strategic choice. The ambition to earn the esteem of customers takes the form of the Insight Adv Ltd's desire to:

• put all the passion to satisfy customers, understand their desires and offer solutions that are always able to exceed their expectations;
• live in the present but always with an eye to the future, looking for innovative products, services and solutions capable of anticipating the wishes of customers;
• express the daily aspiration to identify and achieve new goals, both towards customers and towards the market. Being ambitious and competitive, being market leaders every day, always striving for excellence.

To make this possible, the people of Insight Adv Ltd are committed to working quickly, professionally, simply and reliably to earn the trust of customers day after day.

2. Company policy

The success of Insight Adv Ltd depends on the commitment to conducting a correct business policy and on the way of interacting with one's interlocutors and/or collaborators, i.e. not only employees, customers, commercial partners and suppliers, but also Authorities, institutions, communities, companies and environment.

The Insight Adv Ltd carries out its activity in full compliance with the law, above all supporting the respect of human rights. The principles on which the company policy is based represent a further commitment of the Insight Adv Ltd towards all those who interact with the company.

This corporate policy also applies to Insight Adv Ltd's relationships with its business partners, customers and suppliers, with whom it endeavors to promote the application and observance of its principles.

Insight Adv Ltd is aware that its commercial success also depends on its ability to adhere to and comply with corporate principles and, consequently, seeks to put these principles into practice with the utmost diligence to constantly improve the consistency of its action with respect to the same principles.

The Insight Adv Ltd requires all employees to know, share and respect with the utmost diligence the corporate principles listed below, as well as promote the application of these principles by collaborators, business partners and suppliers.

3. The creation of value

Insight Adv Ltd believes that in a market economy competition, exercised in an ethical manner, represents the best way to guarantee benefits and contribute to the company's commercial success.

Everyone's commitment must guarantee the best possible results.
The criteria that guide investments, purchases and commercial relationships are primarily of an economic nature, but also include social and environmental considerations.

4. Politics

The directors and employees of the Insight Adv Ltd cannot carry out political activities - excluding trade union activities - during working hours, or use the Company's assets or equipment for this purpose; they must also clarify that any political opinions expressed by them to third parties are strictly personal and therefore do not represent the opinion and orientation of the company.

5. Communication

The Insight Adv Ltd communicates openly and transparently to all the various interlocutors, within the limits of commercial confidentiality.

Relations between the Company and the mass media, as well as - more generally - communications to the various external interlocutors, are the exclusive responsibility of the company functions expressly delegated to do so and must be maintained in compliance with the communication policy defined by the company.

In any case, information and communications relating to the company and intended for the outside world must be accurate, truthful, complete, transparent and consistent with each other.

6. Customers

Insight Adv Ltd is committed to offering its clients safe and reliable products and highly professional services at good value for money.

The Insight Adv Ltd works trying to understand, anticipate and respond to the different needs of customers to offer them innovative products and services.

Insight Adv Ltd values the trust placed in it by clients and protects the information provided in accordance with applicable laws.

Employees, collaborators, business partners and suppliers involved in the commercial activity of Insight Adv Ltd, therefore, must:

• scrupulously comply with the provisions of this Code relating to the management of customer relations;
• align its conduct in relations with all customers with the principles of transparency, reliability, responsibility and quality;
• ensure the quality and reliability of the services and products offered, monitoring that the services and products provided by third party suppliers in general fully comply with the quality standards of the Insight Adv Ltd;
• provide the customer with all information on the contractual conditions and terms relating to the provision of company services, so that the customer is fully aware of it when finalizing the agreement;
• be truthful in advertising communications;
• adopt a behavior based on availability, respect, courtesy, in line with the standards of the Insight Adv Ltd, characterized by the highest professionalism;
• pay particular attention to customer satisfaction activities, with a view to continuously improving the quality of the services and products offered, courteously collecting any suggestions or complaints from customers and making use of suitable and timely communication systems for this purpose.

7. Employees and collaborators

Relations with and between employees and collaborators are based on respect for individuals and their human rights.

The Insight Adv Ltd adopts a policy based on equal opportunities in consideration of the diversity of individuals.

Insight Adv Ltd helps its employees develop to their full potential through training and development activities.

Insight Adv Ltd promotes employee participation in incentive stock plans.

Full respect for the employee and non-discrimination in the workplace for reasons of sex, race, language, religion, political opinions, trade union membership, social and personal status are among the founding values adopted by Insight Adv Ltd.

Professional development and growth are two important objectives of the policy adopted to manage the Company's resources. The Insight Adv Ltd, in fact, aims to attract, reward and develop people of exceptional quality to whom it offers stimulating responsibilities and development opportunities. Attention is paid in particular to the creation of new professional skills, extended to all levels to facilitate the management of the continuous changes required by the market and by the role of the Insight Adv Ltd in society. In this direction Insight Adv Ltd contributes to the growth of skills through significant investments in training, job rotation and mobility, with the construction of a real network of professionals (including programmers, graphics & web designers, photographers, illustrators and journalists), each with their skills and professional experience, who are offered the opportunity to collaborate in the implementation of individual projects or groups of projects of the Insight Adv Ltd.

In order to offer its own contribution to the fight against social hardship, the Insight Adv Ltd periodically organizes and finances free professional training courses for minors and adolescents at risk, unemployed young people and women, in order to facilitate their entry into the world of work.

In the various stages of managing relations with its employees, Insight Adv Ltd is therefore inspired by the following principles.

7.1. Personnel selection

The Insight Adv Ltd offers the same job and/or professional growth opportunities without any discrimination, starting from the moment of personnel selection.

The assessment of the candidates participating in the selection is focused on verifying the fulfillment of the professional, behavioral and aptitude requirements envisaged by the profile requested, with respect for the candidate's dignity, personality, private sphere and opinions.

Favoritism or forms of patronage are not permitted (for example, whoever selects or participates in the selection must not be in a situation of conflict of interest with the candidate).

7.2. Establishment of the employment relationship

Hiring takes place with a regular employment contract in full compliance with the law and the CCNL applied, favoring the worker's integration into the work environment.

Employees are aware of the terms and conditions of their employment, and the Company provides fair and reasonable wages and conditions.

7.3. Personnel Management

Insight Adv Ltd offers the same career opportunities to those who possess the characteristics required for access to functions, without any discrimination and on the basis of merit criteria, acquired professional competence and, in any case, on the basis of strictly professional parameters.

The Insight Adv Ltd considers personnel training and constant updating on specific issues (for example, occupational safety and hygiene) a primary requirement of the company.

Insight Adv Ltd promotes team spirit and mutual collaboration and expects employees, at all levels, to work together to maintain a climate of mutual respect for each other's dignity and reputation.

7.4. Harassment and discrimination in the workplace

Insight Adv Ltd expects no harassment of any kind against employees, suppliers, customers or visitors in its internal and external business relationships. By harassment we mean any form of intimidation or threat that is an obstacle to the peaceful performance of one's duties or the abuse by the hierarchical superior of the position of authority.

The Insight Adv Ltd also demands that in internal and external working relationships there is no discrimination of any kind against employees, suppliers, customers or visitors related to differences of sex, race, language, religion, political opinions, union membership, personal or social conditions.

Whoever, in carrying out his activity in favor of the Company, believes that he has been subjected to harassment or that he has been discriminated against for any reason, can report the incident to the Supervisory Body. Any act of retaliation against an employee who refuses, complains or reports such unfortunate facts is prohibited.

7.5. Abuse of alcohol or drugs

The Insight Adv Ltd prohibits each employee or collaborator from working while drunk or in a state of consciousness altered by the intake of narcotic or hallucinogenic substances or substances which in any case affect the regular performance of the work activity. In any case, the Insight Adv Ltd discourages the abuse of alcohol and the use of drugs by each employee or collaborator even outside working hours and regardless of the influence of such conduct on the regular performance of work .

7.6. Smoke

The Insight Adv Ltd undertakes to guarantee the safety and health of its employees, without prejudice to the smoking bans established by law in places where this could endanger the safety of people and the healthiness of the environments.

7.7. Privacy protection

The Insight Adv Ltd complies with the applicable legal requirements regarding the processing of personal data. With particular regard to the processing of personal data of workers, the Insight Adv Ltd prepares specific precautions aimed at informing each employee about the nature of the personal data processed by the company, the methods of treatment, the areas of communication and, in general, on any data relating to your person.

8. Conduct of employees and collaborators

Insight Adv Ltd expects all employees to act with honesty, integrity and impartiality.

We will not tolerate any form of bribery, including improper offers and payments made to or from employees.

Employees must avoid any contact that could lead to, or suggest, a conflict of interest between their business and that of Insight Adv Ltd.

Employees must avoid accepting gifts or hospitality that could make them feel obligated to others.

8.1. Prohibition of Corrupt Practices

Insight Adv Ltd does not tolerate any form of bribery, including improper payments or illegal offers to pay for or from employees.

In relations with third parties, including the Public Administration, in Italy or abroad, Insight Adv Ltd employees, collaborators and/or representatives, in any capacity, are not permitted to pay or offer, directly or through third parties, sums of money or gifts of any kind and entity to subjects external to the Insight Adv Ltd, whether they are public officials or persons in charge of a public service, government representatives, public employees or private citizens, both Italian and from other countries, with which Insight Adv Ltd has commercial relations , to compensate or repay them for an act of their office or to achieve the execution of an act contrary to the duties of their office.

Acts of commercial courtesy, such as gifts or forms of hospitality, or any other form of benefit (even in the form of donations), are permitted only if of modest value, in accordance with custom and such as not to compromise the integrity and reputation of the parties ; in any case, such deeds must not be able to be interpreted, by a third party and impartial observer, as deeds intended to obtain advantages and favors in an improper manner. In any case, such acts must always be authorized and documented.

8.2. Diligence and good faith

Employees and collaborators, in any capacity, of the Insight Adv Ltd must act loyally and in good faith, respecting the obligations signed in the employment or collaboration contract and ensuring the required services, as well as knowing and observing the ethical rules contained in this Code, own conduct to mutual respect and cooperation and mutual collaboration.

All actions, operations and negotiations and, in general, the behaviors implemented in the performance of the work activity, must be based on the principles of honesty, correctness, integrity, transparency, legitimacy, clarity and mutual respect as well as be open to checks and controls according to current regulations and internal procedures.

All activities must be carried out with commitment and professional rigor. Everyone must provide an adequate professional contribution to the responsibilities assigned and must act in such a way as to protect the prestige of the company.

Insight Adv Ltd personnel, regardless of the function performed and/or the level of responsibility assumed, must know and implement the provisions of the company in terms of environmental protection, occupational safety and hygiene and privacy protection.

8.3. Conflict of Interest

Employees and collaborators, in any capacity, of Insight Adv Ltd must refrain from carrying out activities that are even potentially in conflict with the interests of the company or its customers.

By way of example, the following could constitute cases of conflict of interest:

• the existence - evident or hidden, direct or indirect - of economic or financial interests of the employee or collaborator or his family members in the activities of suppliers, customers, competitors;
• the exploitation of one's functional position for the realization of interests even potentially in conflict with those of the company;
• the use of information acquired in carrying out work activities for one's own benefit or that of third parties in contrast with the interests of the company or its customers;
• the performance of work activities of any kind (services and intellectual services) for customers, suppliers, competitors and/or third parties in conflict with the interests of the company or its customers;
• the conclusion, completion or start of negotiations and/or contracts - in the name and/or on behalf of the company - which have as counterpart family members or associates of the employee or collaborator, or legal entities of which he is the owner or to which he is still interested;
• the acceptance of money or other benefits or favors from natural or legal persons who are or intend to enter into business relations with the Insight Adv Ltd.

It is forbidden to personally take advantage of business opportunities that one becomes aware of in the course of carrying out one's duties within the company.
Before accepting a consultancy, management, administration or other assignment in favor of another person potentially suitable to generate a conflict of interest, or in the event that a situation of conflict of interest arises, each employee is required to communicate it to the Company Management, according to the provisions of the company policies. If the report does not give a result or the employee feels uncomfortable in contacting the Administrative Director, he reports it to the Supervisory Body. Likewise, each employee is required to communicate, in the same manner as above, situations of conflict of interest in which other employees find themselves and of which they have become aware.

8.4. Gifts or other form of benefit/utility

Employees who receive gifts, or other forms of benefit/utility, not directly attributable to normal courtesy relationships, must take all appropriate steps to refuse said gift or other form of benefit/utility, in any case in compliance with company policies.

8.5. Protection of corporate assets and the working environment

Each employee is required to safeguard the company's assets, guarding movable and immovable property, technological resources and IT supports, equipment, company products, information and/or the know-how of Insight Adv Ltd.

In particular, each employee must:

• use corporate assets according to corporate policies, scrupulously observing all security programs to prevent unauthorized use or theft;
• avoid improper use of corporate assets that could cause damage or reduce efficiency, or in any case contrary to the company's interests;
• maintain the secrecy of confidential information concerning the company or business partners of the company, avoiding revealing it to third parties;
• scrupulously comply with the provisions of the corporate security policies, in order not to compromise the functionality and protection of the IT systems;
• not to send threatening or abusive e-mail messages, not to use impolite or unprofessional language, not to make inappropriate comments that may offend a person and/or damage the corporate image;
• keep and not disclose to unauthorized third parties your personal password and your access code to company databases;
• do not reproduce company software for personal use or use the supplied tools for private purposes;
• not to use corporate communication systems (email, intranet, etc.) and the web for purposes other than professional and service ones.

Each employee is responsible for protecting the resources entrusted to him and has the duty to promptly inform his direct managers of potentially harmful events for the Insight Adv Ltd.

The principles set out above are also applicable to collaborators, to the extent that they can be concretely involved in safeguarding the company's assets, insofar as they are allowed to use the company's equipment, resources or assets (as better described above).

8.6. Image protection

The good reputation and/or image of Insight Adv Ltd is an essential intangible asset.

Insight Adv Ltd employees undertake to act in accordance with the principles set out in this Code in relations between colleagues, customers, suppliers and third parties in general, maintaining a decent demeanor in accordance with the standards common to companies of the size and importance of Insight Adv Ltd.

9. The environment

The Insight Adv Ltd undertakes to promote actions that can ensure sustainable development and environmental protection:

• Processes are put in place to actively improve the efficiency with which limited resources (such as energy, water, raw materials) are used.
• Management, operational and technical controls are put in place to minimize the release of emissions dangerous to the environment.
• The use of business practices that reduce the environmental impact of the Insight Adv Ltd's activities is promoted.
• Innovative improvements in products and services that deliver environmental and social benefits are supported.

Environmental protection and the preservation of natural resources are high priority corporate objectives. Insight Adv Ltd has always been attentive to environmental issues, a sensitivity that is expressed through specific initiatives, aimed at protecting and respecting the territory and nature. New ideas in which technological innovation is combined with environmental protection.

Each employee, collaborator, commercial partner and supplier, in carrying out their activity, must collaborate to achieve exemplary results in this sector.

10. Community and society

The Insight Adv Ltd accepts the responsibility to engage with the community and to invest in society in order to effectively use its resources, supporting projects and activities aimed at the development and growth of the economic, social and cultural well-being of the territory.

Insight Adv Ltd has always been very attentive to social issues and continues to assume responsibility in the social field, providing its contribution in various sectors. Consistent with the philosophy that has always distinguished it, the Insight Adv Ltd offers its contribution in the implementation of all those projects that are closest to the heart of the local communities and which offer the possibility of improving people's lives and of overcoming and contrasting all forms of discomfort. The Insight Adv Ltd also promotes Corporate Social Responsibility which is developed through a set of choices and strategies which, while respecting the company, increase the economic value of the company itself.

11. Health and safety

Insight Adv Ltd is committed to safeguarding the health and safety of its clients, employees, contractors and the community in which it operates.

In compliance with current legislation on health and safety, the Insight Adv Ltd undertakes to disseminate and consolidate a culture of health and safety in the workplace by developing risk awareness and promoting responsible behavior by all its employees; it also works to preserve - also through training plans, preventive actions, periodic checks - the health and safety of workers.

12. Business partners, collaborators and suppliers

Insight Adv Ltd builds mutually beneficial relationships with its business partners, contractors and suppliers.

The Insight Adv Ltd promotes the application of its principles of business conduct also by its business partners, collaborators and suppliers.

12.1. Relations with collaborators

The company's external collaborators, however called ("collaborators", "consultants", "representatives", "agents"; hereinafter, for the sake of brevity, the "Collaborators"), are required to comply with the principles contained in the Code.

Each employee, in relation to their duties, will take care of:

• scrupulously observe the operating practices and internal procedures relating to the selection and management of relations with Collaborators;
• select, as company collaborators, only people and companies that are recognized as qualified, with an excellent reputation and/or for which we have not come to know of behaviors in conflict with the principles of this Code;
• promptly contact the Administrative Department in the event of any violations of the Code by Company collaborators; if the report does not give a result, or the employee feels uncomfortable in contacting the Administrative Department to make the report, the employee reports it to the Supervisory Body;
• expressly mention, in all contracts entered into with Collaborators, regardless of the nomen iuris adopted for such contracts ("collaboration", "consultancy", "agency", "private agreement"), the obligation to comply with the principles of the Code, to maintain behaviors suitable for preventing the commission, even attempted, of the crimes in relation to which the sanctions provided for in Legislative Decree 231/2001 apply, sanctioning any non-fulfillment of these obligations with the provision of the faculty for the Insight Adv Ltd to resolve the contract, obviously without prejudice to the right to compensation for any damages suffered.

12.2. Relations with suppliers

The Insight Adv Ltd bases its conduct in relations with suppliers on the principles of transparency, equality, loyalty and competition.

In particular, Insight Adv Ltd employees must:

• scrupulously observe the operating practices and internal procedures relating to the selection of suppliers and the management of relations with them;
• obtain the collaboration of suppliers in ensuring the satisfaction of customer needs in terms of quality, cost and delivery times of goods or provision of services;
• observe and respect, in the supply relationships, the applicable legal provisions and the contractual conditions;
• in relationships with content providers, do not purchase images and/or content that conflict with the provisions of the law (e.g. pedophilia);
• observe the principles of transparency and completeness of information in correspondence with suppliers;
• avoid receiving money or other utilities or benefits from anyone other than Insight Adv Ltd for the performance of an act of one's office or contrary to one's official duties;
• avoid giving or receiving, directly or indirectly, gifts, presents, hospitality, or other advantages, unless the value of the same does not exceed the limits of a normal courtesy relationship.

12.3. Choice of suppliers

The purchasing processes are based on the search for the maximum competitive advantage for the Insight Adv Ltd and on the protection of the quality standards of the Insight Adv Ltd itself.

To this end, the functions participating in these processes must:

• granting suppliers in possession of the necessary requisites equal opportunities to participate in the selection;
• verify, also through the request for delivery of suitable documentation, the existence of subjective requirements relating to the professionalism and integrity of the suppliers;
• verify, also through the request for delivery of suitable documentation, that the suppliers participating in the selection have the means, including financial ones, organizational structures, skills, know-how, quality systems and resources adequate for the needs and quality requirements of the Insight Adv Ltd.
• In particular, contractual clauses are introduced in contracts with suppliers which provide for declarations by the supplier regarding possession of the aforementioned subjective and organizational requirements, know-how and resources adequate to the needs and quality standards of the Insight Adv Ltd, as well as relating to the existence and effective implementation of adequate corporate quality systems.

12.4. Integrity and independence in relations with suppliers

Relations with suppliers are governed by common principles and are subject to constant monitoring by the Insight Adv Ltd.

In particular:

• long-term binding projects based on short-term contracts that require continuous renewals with price revisions, or consultancy contracts, however denominated, without an adequate transfer of know-how must be avoided;
• it is not considered correct to induce a supplier to stipulate an unfavorable contract by giving that supplier an unfounded hope in a subsequent more advantageous contract.

To ensure maximum transparency and efficiency of the purchasing process, the Insight Adv Ltd prepares and/or adopts:

• the separation of roles - where practically practicable - between the unit requesting the supply and the unit stipulating the relative contract;
• operating procedures/instructions that regulate the duty to adequately document the choices made (so-called "traceability");
• the retention of information and official documents relating to the selection of suppliers as well as contractual documents for the periods established by current regulations and referred to in the internal procedures relating to purchases;
• the principle according to which no payment to the supplier can be made:
  - in cash or by means of bearer securities;
  - to a person other than the supplier, with the exception of cases in which payment must be made to third parties, other than the supplier, provided that this is done in a legitimate, transparent and documented manner (for example, in the event of a credit assignment by of the supplier), as well as on current accounts opened with foreign credit institutions, when the supplier is not based abroad, except in exceptional cases which must be adequately justified and documented, it being understood that the relative payments must be duly authorized by the Administrative Department .

Specific clauses are expressly provided for in the individual supply contracts regarding the knowledge and the obligation to observe, on the part of the supplier, the principles contained in this Code of Ethics, the obligation to behave in a manner suitable for preventing the commission, even attempted, of crimes in relation to which the penalties provided for in Legislative Decree 231/2001 apply, as well as express termination clauses that can be enforced by Insight Adv Ltd in the event of non-fulfilment of these obligations, obviously without prejudice to the right to compensation for any damages suffered.

The Insight Adv Ltd brings the content of this Code to the attention of suppliers and encourages all suppliers to adopt an organisation, management and control model pursuant to Legislative Decree 231/2001, as well as a code of ethics, in all their companies and within of their supply chains.

13. Relations with the Public Administration

The relations of the Insight Adv Ltd with the local, national, community and international Public Administration, or in any case relating to relations of a public nature, must be inspired by the strictest observance of the applicable legal and regulatory provisions as well as the general principles of fairness and loyalty as above declined and company procedures.

The assumption of commitments and the management of relations, of any kind, with the Public Administration and/or relations of a public nature are reserved exclusively to the corporate functions responsible for this and duly authorized.

Without prejudice to all the obligations imposed by current legislation on the subject, Insight Adv Ltd and its employees and/or collaborators will abstain, during business negotiations, requests or commercial relations with the Public Administration, as well as in the event of controls/ inspections/verifications by the competent Authorities from time to time, from undertaking (directly or indirectly) the following actions:

• privilege in any way or offer employment and/or commercial opportunities to Public Administration personnel involved in the negotiation, relationship or controls/inspections/verifications, or their family members;
• offer or in any way provide, accept or encourage gifts, presents or any other benefit to personnel of the Public Administration, or their family members, except in the case in which they are acts of commercial courtesy of modest value, compliant with custom and such as not to compromise the integrity and reputation of the parties;
• solicit or obtain confidential information that could compromise the integrity or reputation of both parties or that in any case violate equal treatment and the public disclosure procedures activated by the PA;
• adhere to any request for contributions and sponsorships, which may influence business negotiations or favor the company in the event of checks/inspections/verifications by the Authorities.

In particular, requests for contributions and sponsorships will be evaluated only if proposed by non-profit organizations and associations, or if they are of high cultural or charitable value (by way of example, contributions and sponsorships may concern initiatives in the social, environmental, sport, entertainment, culture, art). In any case, in choosing the proposals to join, the Insight Adv Ltd pays particular attention to any possible conflict of interest of a personal or corporate nature.

Employees who receive offers of gifts or benefits not permitted by a specific procedure are required, according to the established procedures, to refuse them and to immediately notify the Administrative Department which assesses the compliance of the offer with the principles of the Code.

14. Internal Controls

By "internal controls" we mean all the tools necessary or useful for directing, verifying and pursuing the company's activities with the aim of ensuring compliance with the laws and company procedures, protecting company assets, effectively and ethically managing social activities and clearly provide true and correct information on the company's equity, economic and financial situation, as well as identify and prevent the risks that the company may incur.

The Insight Adv Ltd intends to use the highest standards of internal controls and it is its task to disseminate, at all levels, an internal culture characterized by awareness of the existence of controls and oriented towards the exercise of the control itself.

The internal control system of Insight Adv Ltd is subject to formal periodic verification and the results of these verifications are brought to the attention of the Administrative Department.

Insight Adv Ltd employees must, as far as they are responsible:

• contribute to the correct functioning of the control system;
• responsibly guard the company assets instrumental to the activity carried out, whether they are tangible or intangible, and not make improper use of them.

15. Supervisory Body

In order to supervise compliance with the Code, a commission has been set up, called the Supervisory Body, made up of a representative designated by the company and one designated by the workers among the employees and collaborators of the Insight Adv Ltd.

16. Anti-Money Laundering

Employees and Collaborators of Insight Adv Ltd must not, in any way and under any circumstances, receive or accept the promise of cash payments or run the risk of being implicated in events relating to the laundering of money deriving from illegal or criminal activities.

Before establishing relationships or stipulating contracts with non-occasional suppliers and other partners in long-term business relationships, they must ensure the moral integrity, reputation and good name of the other party.

Insight Adv Ltd undertakes to comply with all national and international anti-money laundering rules and regulations.

17. Confidential information and privacy protection

Each employee, collaborator, commercial partner and supplier of the Insight Adv Ltd is required to protect the privacy and confidentiality of the information relating to the company, learned in the course of or during the activities performed on behalf of the Insight Adv Ltd.

In compliance with the law, all information, knowledge and data acquired or processed by employees, collaborators, commercial partners and suppliers through their activities cannot be used, communicated or disclosed without the express authorization of Insight Adv Ltd.

Each employee, consultant, business partner and supplier must therefore:

• acquire and process only the information and data necessary and directly connected to one's own activity;
• keep said data/information in such a way as to prevent unrelated third parties from gaining knowledge of it;
• communicate and disclose the data/information within the framework of the procedures established by the company and with the prior authorization of the Insight Adv Ltd through the person delegated to do so;
• evaluate and determine the confidential nature of the information in accordance with the requirements of the procedures established by the Insight Agency;
• observe the confidentiality obligations even after the termination of the relationship with the Insight Adv Ltd, in accordance with current legislation and/or the contractual commitments previously undertaken.
• The activity of the Insight Agency requires the processing of data (by this meaning any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database ) subject to protection by current legislation on privacy.

The Insight Adv Ltd is particularly attentive to the aspects concerning the privacy of its employees/customers/suppliers and of any other subject interested in the processing of their personal data by the company.

Specific security measures are observed to prevent the loss, illicit or incorrect use of the data being processed by the company and/or unauthorized access to the company's website.

The processing of personal data is permitted only to authorized personnel and in compliance with the rules and procedures established in accordance with current legislation.

The Insight Adv Ltd undertakes to protect the information and data relating to its employees, consultants, business partners, suppliers, customers and third parties, and to avoid any improper use of the same.

18. Sanctions

Observance of the rules contained in the Code constitutes fulfillment by Insight Adv Ltd employees of the obligations established by art. 2104, paragraph 2, civil code 5 (obligations of which the content of the same Code represents a substantial and integral part), as well as an essential part of the contractual obligations envisaged with reference to collaborators, commercial partners and suppliers.

As far as Insight Adv Ltd employees are concerned, the violation of the aforementioned rules will constitute a breach of the obligations deriving from the employment relationship and a disciplinary offence, with all legal consequences, also with regard to the conservation of the employment relationship, and this regardless of any criminal relevance of the behaviors assumed and/or from the establishment of a criminal proceeding where a crime occurs.

The Insight Adv Ltd undertakes to foresee and impose, with coherence, impartiality and uniformity, sanctions proportionate to the respective violations of the Code and compliant with the provisions in force regarding the regulation of labor relations.

In the event of violations of the Code by Insight Adv Ltd employees, the company shall impose the most appropriate disciplinary measures against the perpetrators of the censured conduct, and the disciplinary measures compliant with the provisions of the applied collective bargaining agreement, in compliance with the art. 7 of the law of 20 May 1970, n. 300 and current legislation.

The disciplinary measures that can be imposed are according to the seriousness of the infractions:

• verbal reminder;
• written warning;
• fine up to a maximum of three hours;
• suspension (from service and salary) up to a maximum of three days, except in the case of non-disciplinary precautionary suspension;
• dismissal.

In the event of news of violations of the Code emerging as a result of reports from employees, the Supervisory Body of Insight Adv Ltd informs the Administrative Department. The latter, following an appropriate analysis of the violations reported, decides on the possible existence or otherwise of such violations.

During the assessment phase, the charge will be notified to the employee in advance and he will also be guaranteed a reasonable deadline for replying in order to defend himself.

Once the violation has been ascertained, a disciplinary sanction will be imposed on the perpetrator, in agreement with the Supervisory Body itself, proportionate to the seriousness of the violation committed.

It is understood that the procedures, provisions and guarantees provided for by art. 7 of the Workers' Statute regarding disciplinary measures.

If the violation of the provisions of the Code is carried out by a Person who is not an employee of the Insight Adv Ltd (for example, a self-employed worker, supplier or other person linked by contractual relationships with the company), the right to termination of the related contract or withdrawal for just cause from the same, without prejudice to the right to compensation for any damages suffered, and this regardless of the possible criminal relevance of the behaviors undertaken and/or the establishment of a criminal proceeding where a crime occurs.

Code for ethical purchases

The following Code of Ethical Purchasing should be read in conjunction with our Code of Ethics, of which it forms an integral part, and has been developed to promote safe and fair working conditions, and the responsible handling of environmental and social issues in the Insight Adv Ltd supply chain .

The Code was developed following consultations with employees, contractors, business partners, suppliers and customers. It sets out the standards we intend Insight Adv Ltd and our suppliers to achieve over time.

The principle of continuous improvement is applied in all aspects of the Code.

In accordance with the implementing provisions of the Code, and as a condition of doing business, Insight Adv Ltd will require Tier 1 suppliers to acknowledge their understanding and acceptance of the principles of our Code, and to confirm compliance with them.

Insight Adv Ltd will work closely with its suppliers to implement the Code, which may include joint audits and site visits to continuously evaluate and verify enforcement performance.

Insight Adv Ltd encourages all suppliers to adopt the principles of the Code throughout their businesses and within their supply chains.

1. Child labor

Personnel below the minimum age required to carry out a working activity are not employed.

Minors (persons under the age of 18) are not employed for any dangerous or night work, or in any work activity that is contrary to the personal development of the minor.

Where a minor is employed, primary attention should be paid to the interests of the minor.

Maximum contribution, support and development are made to the policies and programs that assist any child labor or child labor fund.

2. Forced labour

No form of forced, bonded or compulsory labor is used, and employees are free to leave their jobs upon notification within a reasonable time. Employees are not required to deposit money or deposit their identification documents with their employer.

3. Health and safety

A healthy and safe working environment is provided to employees, consultants, temporary workers, partners or other subjects involved in the company's activities, in accordance with international standards and national laws. There are procedures to ensure that health and safety obligations are communicated to those who are required to apply them.

The delivery of goods and the provision of services are carried out in compliance with the general principles of risk prevention for health and safety.

Procedures are implemented to ensure that employees are able to fulfill the health and safety obligations associated with their activities and responsibilities.

Where an employer provides housing, it must be clean, safe, and accommodate the essential needs of employees.

Adequate information and training is provided to employees to deal with accidents, health and safety issues and emergency situations (where foreseeable). There are tools to record, analyze and draw ideas for improvement from any accidents and emergency situations.

4. Freedom of Association

Transparent and direct communication between employees and management is considered the best method for building working relationships and solving problems.

To the extent permitted by applicable law, all employees are free to join or not to join trade unions or similar external representative organisations.

5. Discrimination

Any discrimination in hiring, terms of employment, compensation, access to training, promotions, termination or retirement procedures and decisions is prohibited.

6. Disciplinary practices

Employees are treated with respect and dignity. Any physical or verbal abuse or harassment and other threats or forms of intimidation are prohibited.

7. Working hours

Employee working hours do not exceed the maximum limit established by national laws and the working week does not exceed 60 hours, including overtime.

In exceptional circumstances, where this hourly limit is exceeded, the hours worked cannot be excessive. Overtime must be remunerated with increased compensation and employees must have at least one day off per week.

8. Payment

Employees are aware of the terms and conditions of their work, and fair and reasonable wages and conditions are provided.

9. Individual behavior

We do not tolerate any form of bribery, including illegal offers of payments to or from employees, suppliers, customers, organizations or individuals.

10. Environment

Legislation and international standards for the management of environmental impacts are respected.

Processes are in place to actively improve the efficiency with which finite resources (such as energy, water, raw materials) are used including management, operational and technical controls to minimize the release of environmentally hazardous emissions.

Appropriate measures are put in place to improve the environmental performance of products and services as they are used by the end user, such as considering energy efficiency and end use of the product or service at the design stage.

Innovative improvements in products and services that deliver environmental and social benefits are supported.