Privacy & Cookie Policy
1. Subject: Data Processing
This section contains information regarding how the website of Pidiemme Consulting Srl is managed, with reference to the processing of personal data of users who consult it. This notice also has value for the purposes of the Code regarding the protection of personal data (Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018 harmonizing it with the GDPR), and for the purposes of Article 13 of EU Regulation No. 2016/679 (also referred to as the GDPR), concerning the protection of natural persons with regard to the processing of personal data and the free movement of such data, for individuals who interact with the web services available at www.pdm-c.it, corresponding to the homepage of the PDM Consulting Srl website. This notice is provided only for the site in question and not for any other websites that the user may consult through links contained within it. The purpose of this document is to provide guidance on the methods, timing, and nature of the information that data controllers must provide to users upon connecting to the web pages of the PDM Consulting Srl website, regardless of the purposes of the connection itself, in accordance with Italian and European legislation. This notice may be subject to changes due to the introduction of new regulations on the matter; users are therefore invited to periodically check this page.
2. The Data Controller
The data controller is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. It is also responsible for security matters. With respect to this website, the data controller is Pidiemme Consulting Srl, with registered office at Via Pintacuda 2-2/A, 90011, Bagheria (PA), Italy, Tax Code and VAT No. 05820310828, in the person of its Legal Representative, and for any clarification or exercise of user rights it may be contacted at the following email address: privacy@pdm-c.it.
2.2 Location
Data processing generated by the use of this website takes place at the offices of the data controller, with the involvement of persons authorized by it. No data arising from the web service is disclosed or disseminated, and no transfer abroad is planned, with the exception of data acquired through "third-party" cookies processed by non-EU providers, for which reference is made to the relevant section of this document.
2.3 Data Processed, Purposes, and Legal Bases of Processing
2.3.1 Browsing data
The computer systems and software procedures used to operate this website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of internet communication protocols. This information is not collected in order to be associated with identified data subjects, but by its 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 connecting to the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.), and other parameters relating to the user's operating system and computing environment.
Purpose: browsing data is used solely to derive anonymous statistical information about the use of the site, for security purposes, and to monitor its correct functioning; it may also be used to establish liability in the event of computer crimes committed to the detriment of the website.
Legal basis: the legitimate interest of the data controller and, in the case of any requests by Authorities, legal obligation.
2.3.2 Data voluntarily provided by the user/visitor
The voluntary, explicit, and optional submission of data may be necessary in order to respond to specific requests from the user (e.g., when requesting information, quotes, or clarifications by writing to the email addresses, filling out the contact form, or calling the numbers listed on the "Contact" page of the site, as well as when spontaneously sending a curriculum vitae in order to apply as a candidate).
Purpose: data voluntarily provided by the user is used only to respond to any requests made and to fulfill legal obligations and/or pre-contractual and/or contractual obligations arising from the relationship related to any assignment the user may give to PDM Consulting following contact.
Legal basis: the legal obligation to which the controller is subject and the performance of obligations arising from the pre-contractual/contractual relationship. Specific summary notices will be progressively provided or displayed on the pages of the site set up for particular on-request services.
2.3.3 Cookies
The PDM Consulting website uses cookies to make the browsing experience easier and more intuitive for users viewing its pages. Cookies are used for various purposes, have different characteristics, and may be used both by the controller of the site in question and by third parties. Below is all the information about the cookies installed by this site, the purposes pursued with the information acquired, and the necessary instructions on how to manage preferences regarding them.
2.3.3.1 What cookies are
Cookies are small data files that sites visited by the user send to their terminal or device, where they may be deleted at the end of each browsing session or stored to be later retransmitted to the same sites on the user's next visit. During browsing on a site, the user may also receive on their terminal cookies from different sites or web servers (so-called "third-party" cookies); this happens because the visited website may contain elements such as images, maps, sounds, or specific links to web pages of other domains residing on servers other than the one on which the requested page is located. In other words, these are cookies set by a website different from the one currently being visited.
2.3.3.2 What cookies are used for
Cookies are used to perform computer authentication, session monitoring, and storage of specific information regarding users accessing the server, and are typically present in each user's browser in very large numbers. Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary: for example, access to online banking and activities that can be carried out on one's own current account (viewing the account statement, wire transfers, bill payments, etc.) would be more complex to perform and less secure without cookies that allow the user to be identified and remain identified within the session. Cookies can remain in the system for long periods and may also contain a unique identification code. This allows sites using them to track the user's browsing within the site itself, for statistical or advertising purposes, i.e., to create a personalized user profile based on the pages visited and then show them targeted advertising (so-called Behavioural Advertising).
2.3.3.3 Types of cookies
As specified in Measure No. 229 of May 8, 2014 and, subsequently, Measure No. 231 of June 10, 2021 containing "Guidelines on cookies and other tracking tools" (which updated the 2014 guidance in light of the GDPR and the European Data Protection Board guidelines of May 2020), the Italian Data Protection Authority (Garante) identifies two macro-categories of cookies: "technical" cookies and "profiling" cookies. The relevant national regulation is also contained in Article 122 of the Personal Data Protection Code (Legislative Decree No. 196/2003 and subsequent amendments), which implements the ePrivacy Directive 2002/58/EC.
Technical cookies: These are used to enable browsing and to facilitate access to and use of the site by the user. They are necessary for the transmission of communications over an electronic network or for the provider to deliver the service requested by the customer. They are not used for further purposes and are normally installed directly by the site owner or operator. They can be divided into:
- Navigation or session cookies, aimed at ensuring normal browsing and use of the website, and therefore intended to make browsing on the site functional and optimized;
- Functionality cookies, strictly necessary to provide services explicitly requested by the user;
- Analytical or analytics cookies, which the 2021 Guidelines equate to technical cookies only if configured to significantly reduce identifying capability (e.g., masking of relevant portions of the IP address) and used exclusively by the site operator to collect information, in aggregate and anonymous form, on the number of users and how they visit the site. For the installation of such cookies, under current regulations, prior user consent is not required, without prejudice to the obligation to provide adequate notice.
Profiling cookies: These are aimed at creating profiles related to the user and are used in order to send advertising messages in line with preferences expressed by the user while browsing the web. Given the particular invasiveness that such devices can have with respect to users' private sphere, European and Italian regulations (Art. 122 of the Privacy Code and Art. 6 GDPR) require that the user be adequately and clearly informed about their use and express free, specific, and informed consent before their activation: consent is the only legal basis suitable for legitimizing the use of non-technical cookies.
2.3.3.4 Cookies used by the PDM Consulting Srl website
The website www.pdm-c.it does not use cookies for profiling purposes. The site uses technical cookies in the strict sense (navigation/session and functionality cookies), for which, pursuant to Art. 122 of the Privacy Code and the Garante's measures of May 8, 2014 and June 10, 2021, no prior consent from the data subject is required, as well as third-party cookies (analytical and service cookies) which, not falling within the exemption provided for technical cookies, are installed only with the user's express consent, collected via the banner described in paragraph 2.3.3.5 below, and are in any case not activated before such consent has been given. Below are the specific categories of cookies used, their purpose, and the consequence of deselecting them:
Navigation or session cookies
- Purpose: site management, as they enable safe and efficient operation and exploration of the website
- Retention period: valid for the browsing session
- Consequence of deselection: these are cookies essential to the use of the website, so blocking them would prevent it from functioning
Functionality cookies
- Purpose: to facilitate navigation and the service provided to the user based on a series of criteria selected by the user
- Retention period: valid for the browsing session
- Consequence of deselection: it would not be possible to maintain the choices made by users during browsing
Analytical cookies
- Purpose: to collect information in aggregate form on user browsing in order to optimize the browsing experience and the services themselves
- Retention period: set by "third parties," as specified further below
- Consequence of deselection: it would no longer be possible for the controller to acquire the aggregate information
There are also "third-party" cookies which, for the reasons stated above, do not fall within the category of technical cookies exempt from consent and are therefore installed only with the user's consent, given through the banner described in paragraph 2.3.3.5. Details are provided below, along with links through which the user can obtain further information and request their deactivation:
- Google Analytics: the site includes components transmitted by Google Analytics (Google Analytics 4), a web traffic analysis service provided by Google Ireland Limited / Google LLC ("Google") that uses cookies deposited on the user's computer to enable statistical analysis, in aggregate form, of the use of the visited website. For further information, see: https://www.google.it/policies/privacy/partners/. Data generated by Google Analytics is retained by Google as indicated in the notice available at: https://developers.google.com/analytics/devguides/collection/ga4/cookies-user-id. See also https://support.google.com/analytics/answer/6004245 for Google's privacy notice. Place of data processing: European Union and United States. The transfer to the United States takes place, since July 10, 2023, on the basis of the European Commission's adequacy decision regarding the new EU-U.S. Data Privacy Framework, which Google has joined, replacing the previous Privacy Shield (invalidated by the "Schrems II" ruling of the EU Court of Justice in July 2020). For transparency, it should be noted that the validity of the Data Privacy Framework is the subject of a pending appeal before the Court of Justice of the European Union (case C-703/25 P), following its dismissal at first instance by the EU General Court in September 2025; the outcome could affect the validity of the data transfer in the future. The controller of this site has activated the IP anonymization/minimization function made available by Google (details at: https://support.google.com/analytics/answer/2763052?hl=it) and has not linked Google Analytics to any additional advertising service, nor has it activated data-sharing options with other Google services. Users can selectively disable Google Analytics by installing the opt-out component provided by Google on their browser, available at: https://tools.google.com/dlpage/gaoptout.
- Google Maps: the site uses certain Google Maps services and/or components offered by Google, in particular the geographic map display service and local search. These components may use cookies generated directly by Google Maps servers. See https://www.google.com/intl/it/policies/technologies/types/ for Google's privacy notice regarding this service. Place of data processing: European Union and United States, on the basis of the EU-US Data Privacy Framework which Google has joined (see above regarding Google Analytics).
- Google reCAPTCHA: an anti-SPAM protection service provided by Google that analyzes traffic on this website, potentially containing users' personal data, in order to filter traffic, messages, and content recognized as SPAM. See https://www.google.com/intl/it/policies/technologies/types/ for Google's privacy notice regarding this service. Place of data processing: European Union and United States, on the basis of the EU-US Data Privacy Framework which Google has joined (see above regarding Google Analytics).
2.3.3.5 Cookie management
Technical cookies (navigation/session and functionality) are active from the moment the site is accessed, without requiring consent. For the third-party cookies indicated above (Google Analytics, Google Maps, Google reCAPTCHA), however, upon first access to the site a banner is shown containing a short notice, through which the user can give express consent to the use of such cookies, or refuse it, consistent with the Garante's Guidelines of June 10, 2021, which require a banner without pre-selected buttons and with equal prominence given to the acceptance and refusal options; such cookies are not installed before the user has made their choice. Users can decide whether or not to accept cookies using their browser settings, although, as stated, fully or partially disabling technical cookies could compromise optimal use of the site. Disabling "third-party" cookies does not in any way impair navigability. The setting can be defined specifically for different sites and web applications. Browsers also allow different settings to be defined for "first-party" cookies and for "third-party" ones. For example, in Firefox, through the Settings -> Privacy & Security menu, you can access a control panel where you can define whether or not to accept different types of cookies and proceed to remove them. Documentation on how to set cookie management rules for one's browser is easily available online; some links for the main browsers are provided below by way of example:
- Google Chrome
- Mozilla Firefox
- Microsoft Edge
- Opera
- Safari
A useful tool for checking which cookies are installed on your computer (and blocking them, removing any consent given) is available at: http://www.youronlinechoices.com/it/le-tue-scelte.
Data processing methods: This site processes user data lawfully and correctly, adopting appropriate security measures aimed at preventing unauthorized access, disclosure, alteration, or destruction of data. Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the stated purposes. In some cases, in addition to the controller, external parties (e.g., IT consultants) that the controller uses for maintenance and support activities may have access to data collected by this website; these parties are appointed as data processors pursuant to Art. 28 GDPR, where applicable.
Data retention period: Data is processed and retained for five years. Accordingly: personal data collected for purposes related to the performance of a contract between the controller and the user will be retained until performance of that contract is complete; personal data collected for purposes related to the legitimate interest of the controller will be retained until that interest is satisfied. Users can obtain further information regarding the legitimate interest pursued by the controller in the relevant sections of this document or by contacting the controller. When processing is based on the user's consent, the controller may retain personal data for longer, until such consent is revoked. Furthermore, the controller may be required to retain 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, personal data will be deleted. Therefore, once this period has expired, the rights of access, erasure, rectification, and data portability can no longer be exercised.
User rights: Users may exercise certain rights with respect to data processed by the controller, by contacting them at: info@pdm-c.it. In particular, the rights recognized by EU Regulation No. 679/2016 are:
- Right of access: the user has the right to obtain information about data processed by the controller, on certain aspects of the processing, and to receive a copy of the data processed;
- Right of rectification and integration: the user can verify the accuracy of their data and request that it be updated or corrected;
- Right to erasure ("right to be forgotten"): the user has the right to request the deletion of their personal data by the controller where there is no longer a legal need for further retention;
- Right to restriction: under certain conditions, the user can request restriction of the processing of their data. In such case, the controller will not process the data for any other purpose except its storage;
- Right to data portability: the user has the right to receive their data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision applies when data is processed using automated tools and processing is based on the user's consent, on a contract to which the user is a party, or on contractual measures connected to it;
- Right to object: the user can object to the processing of their data when it is based on a legal basis other than consent. When data is processed in the public interest, in the exercise of public authority vested in the controller, or to pursue a legitimate interest of the controller, users have the right to object to the processing for reasons related to their particular situation. Users are informed that, where their data is processed for direct marketing purposes, they may object to the processing without providing any justification. To find out whether the controller processes data for direct marketing purposes, users may refer to the relevant sections of this document.
Users are also informed that they have:
- the right to revoke, at any time, consent given, without affecting the lawfulness of processing based on consent given before the revocation;
- if they believe that the processing of their personal data carried out through this site violates the GDPR, the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it), as provided for in Art. 77 of the EU Regulation, or to take legal action (Art. 79 of the EU Regulation).
Changes to this privacy and cookie policy: The data controller reserves the right to make changes to this privacy and cookie policy at any time, informing users on this page and, where technically and legally feasible, sending users a notification through one of the contact details held by the controller. Users are therefore requested to check this page regularly, referring to the date of last update indicated at the bottom.
Last updated: July 2026.