Privacy and cookie policy pursuant to former art 13 of the EU General Data Protection Regulation 2016/679 (GDPR)

Topgraf srl, with registered office in via Cremasca 24/A 24052 Azzano San Paolo (BG) – Italy (hereinafter “Topgraf”) is constantly committed to protecting the online privacy of its users.

A)     Source of personal data and data controller

This document was drawn up pursuant to art. 13 of EU General Data Protection Regulation 2016/679 (hereinafter: “Regulation”) in order to inform you on our privacy policy. General methods of processing personal data and cookies and how personal information is managed when using our website  [] (hereinafter the “site”) are described. Information and data provided by the user or otherwise acquired when registering to Topgraf srl services – such as: accessing to the private area of the website, newsletters, etc. hereinafter “services” – will be processed in compliance with the provisions of the Regulation and the obligations of confidentiality that govern the activity of Topgraf srl.

In accordance with the Regulation, data gathered and collected by Topgraf srl will be processed with respect to principles of fairness, lawfulness, transparency, purpose limitation and retention periods, data minimisation, accuracy, integrity and confidentiality.

The controller of the data processed through the site is Topgraf srl, with registered office in via Cremasca 24/A 24052 Azzano San Paolo (BG) – Italy as mentioned above, which can be addressed for any information concerning personal data processing.

The Data Protection Officer (DPO) is available at the following address: TQSI SERVIZI INTEGRATI S.R.L. – Via Don A. Mazzucotelli, 2 – 24020 Gorle (BG),

Please note that this notice is rendered strictly with respect to the aforementioned website and not with respect to other web sites that can be consulted via external links. Please refer to the specific sections of the site to find specific information and requests for informed consent for any processing.

B)      Data type

When navigating the website, please be informed that Topgraf srl will collect the following personal data (art. 1 of the Regulation)

1.      Navigation data

IT systems and software procedures granting the good functioning of the website, when the user navigates the site, collect some personal data whose transmission is implicit in the communication protocols of the Internet. These information are not collected to be associated to certain users but, for their own nature, through elaborations and associations with data owned by third parties, they could allow the identification of the visitor users. Examples are IP addresses, the domain names of users who connect to the site, URI (Uniform Resource Identifier) addresses of the resources required, the timetable of the requests, the method used to submit the request to the server, the size of the file obtained as an answer, the numeric code indicating the state of the answer given by the server (successful conclusion, error, etc.) and other parameters concerning the operating system and the IT environment of the user. This data are used for the exclusive purpose of obtaining anonymous statistical information regarding websites usage and […] to monitor correct websites functioning, and they are erased immediately after processing. The data in question could be used by competent authorities to determine responsibility in the event of computer crimes to the detriment of the web site.

2.      Data provided voluntarily by users

In addition to what mentioned for navigation data, the user can voluntarily provide personal data by filling in forms on the website (e.g. for activating newsletters, free registration, purchase, etc). Lack of their submission may entail the impossibility of obtaining the requested service. In such cases, only the information which are essential to the requested service will be asked (check the technical information in detail).

When using some web services, the personal data of third parties that you send to Topgraf srl might be processed. In such a case, you act as an independent data controller, assuming all consequent obligations and liability under the law: any dispute, claim, request for compensation for damage from processing, etc. that should be raised to Topgraf srl from third parties whose personal data have been processed when using web services in violation of the applicable rules on the protection of personal data, will be entirely responsibility of the user. In any case, should the user provide or otherwise process personal data of third parties when browsing the site, he guarantees – assuming all related responsibility – that this particular hypothesis of processing is based on an appropriate legal basis pursuant to art . 6 of the Regulation which legitimizes the processing of the information in question.

C)      Purpose of the processing and legal bases

The processing of personal data we are intended to manage, with your specific consent where necessary, has the following purpose:

  • Allow the provision of the site services.

The legal basis of the processing is the execution of pre-contractual measures adopted at the request of the same (Article 6 (1) (b) of the Regulation) as the processing is necessary for the provision of the service. The provision of personal data for this purpose is optional but failure to provide it would make it impossible to activate the requested services.

D)     Recipients of personal data

Your personal data may be shared, for the aforementioned purposes, with:

  • Persons authorized by Topgraf srl to process personal data necessary to carry our activities strictly related to the provision of the services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees and system administrators).
  • Third parties possibly involved in the management of the site who typically act as data controllers (the complete and updated list of data controllers is present and available at
  • Subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data by virtue of legal provisions or orders of the authorities.

E)      Transfer of personal data

Some of your personal data are shared with recipients who could be based ourside the European Economic Area. Topgraf srl ensures that the processing of your personal data by these recipients is managed in compliance with the Regulation. Indeed, transfers can be based on an adequacy decision, on the Standard Contractual Clauses approved by the European Commission or other suitable legal basis.

F)      Your privacy rights pursuant to art. 15 and subsequent of the Regulation

Pursuant to articles 15 and subsequent of the Regulation, you have the right to ask Topgraf srl, at any time, to access your personal data, to rectify or cancel them or to oppose their processing, you have the right to request the limitation of processing in the cases provided for by art. 18 of the Regulation, as well as to obtain the data concerning you in a structured format, commonly used and readable by an automatic device, in the cases provided for by art. 20 of the Regulation.

Requests must be sent in writing to the data controller at the following address via Cremasca 24 / A 24052 Azzano San Paolo (BG) – Italy or to the DPO (Data Protection Officer) at the following address TQSI SERVIZI INTEGRATI S.R.L. – Via Don A. Mazzucotelli, 2 – 24020 Gorle (BG), – Italy.

In any case, you are always entitled to lodge a complaint with the competent Supervisory Authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the Regulation, if you believe that the processing of your personal data is contrary to the legislation in force.

G)    Changes

This privacy policy is effective from 25/05/2018. Topgraf srl reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Topgraf srl will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the site.

Topgraf srl therefore invites you to regularly visit this section to be aware of the latest version of the privacy policy in order to always be updated on the data collected and on the use made of it by Topgraf srl.


Definitions, characteristics and application of the legislation

Cookies are small text files that websites visited by the user send and record on the user computer or mobile device, to be then re-transmitted to the same websites on the next visit. Thanks to cookies, a website can recall user’s actions and preferences (such as, for example, login data, the chosen language, font size, other display settings, etc.) so that they do not have to be defined again when the user visits that website next time or browse from one page to another of the website. Cookies, therefore, are used to perform computer authentication, session monitoring and storage of information regarding the activities of users who access a website and may also contain a unique identification code that allows to keep track of the user’s navigation on the website for statistical or advertising purposes. While browsing a website, the user may also receive on his computer cookies from sites or web servers other than the one he is visiting (so-called “third party” cookies). Some operations could not be performed without the use of cookies, which in some cases are therefore technically necessary for the good functioning of the website.on potrebbero essere compiute senza l’uso dei cookie, che in certi casi sono quindi tecnicamente necessari per lo stesso funzionamento del sito.

There are various types of cookies, depending on their characteristics and functions, and these can remain on the user’s computer for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user’s device until a set deadline.

According to current legislation in Italy, the user’s express consent is not always required for the use of cookies. In particular, “technical cookies”, ie those used for the sole purpose of transmitting a piece of communication over an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require this consent. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

Among technical cookies, which do not require express informed consent for their use, the Italian Data Protection Authority (see Provision for the identification of simplified procedures for the information and the acquisition of consent for the use of cookies May 8, 2014 and subsequent clarifications, hereinafter only “Provision”) also includes:

  • “analytics cookies” when used directly by the website administrator to collect information, in an aggregate form, on the number of users and how they browse the website,
  • navigation or session cookies (to authenticate),
  • functionality cookies, which allow the user to browse according to a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.

For “profiling cookies”, vice versa, ie those aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior informed consent of the user is required.

Types of cookies used by the website

We have classified the cookies we use based on their type of use in:



These are cookies that allow the normal use of the website and the services provided such as creating a purchase, authenticating to access restricted areas or saving your personal preferences. This type of cookie can then be distinguished by their persistence on the user’s terminal: those that are automatically deleted at the end of each navigation are called “session cookies” (for example the aforementioned online shopping cart). If, on the other hand, they have a longer life, we speak of “permanent cookies”. These cookies are essential for the proper functioning of the site and the prior consent of users is not required for installation.

Here is a list of the aforementioned cookies:

Name cookies Domain Category Purpose
PHPSESSID session Website operation


We use these cookies to provide services or to remember your settings, to improve visit and the browsing experience on our website. Thanks to them we can manage navigation based on the selected products and / or manage the wish list. The prior consent of the user is not required for the installation of these cookies.

Here is a list of cookies:

Name cookies Domain Category Purpose
PHPSESSID functionality Language selection
wpml_browser_redirect_test functionality Language selection


These cookies anonymously collect information on how our website is used and allow us to have a better knowledge of users and to improve the functioning of the site. Analytics cookies are similar to technical cookies when used directly by the website administrator to collect information, in an aggregate form, on the number of users and how they visit the site: for the installation of these cookies, the prior consent of the user is not required.

Here is a list of the aforementioned cookies:

Name cookies Domain Category Purpose
__utma analysis Tracking pseudonyms
__utmb analysis Tracking pseudonyms
__utmt analysis Tracking pseudonyms
__utmz analysis Tracking pseudonyms
_gat analysis Tracking pseudonyms
_ga analysis Tracking pseudonyms
_gid analysis Tracking pseudonyms


“Third party” cookies are linked to services provided by third parties: they are used for various purposes such as analysing the progress of marketing campaigns and / or delivering customized advertising on our website and partner websites. This activity is called retargeting and is based on navigation activities, such as the selected destination, the structures viewed, etc. The third party provides these services in exchange for information regarding the user’s visit to our website. This means that third-party cookie suppliers are required to comply with the relevant legislation as well. For this reason, please refer to the link third party websites, where you can find the cookie consent forms and all relevant information.

Social plug-ins

These “social buttons” are visible on our website to allow you to share our content through social networks, including Facebook, Pinterest, Twitter, LinkedIn, YouTube and Google Plus. Cookies are stored by these platforms on our website, which allows them to collect information about your browsing.

For more information on cookie management and Facebook’s privacy policy click here, Twitter click here, Youtube click here, Google Plus click here.

Web beacons

Web beacons are tiny invisible images that Topgraf srl uses in its newsletters. These images allow the collection of statistical information relating to the use of newsletters and allow Topgraf srl to improve this service. If you want to prevent such statistical information from being collected, you must deactivate the HTML setting in the e-mail system so that Topgraf srl newsletter is read only as text. All newsletters sent by Topgraf srl also contain a link that allows you to cancel the reception.

Your decisions on cookies

You can select a functionality according to which your computer will notify you whenever a cookie is set, or you can decide to disable all cookies. You can select these features through your browser settings. Each browser is slightly different, so we invite you to identify in the “Help” menu of your browser the correct way to change the cookies settings. If you decide to disable cookies, you will not have access to many features that make your experience on our site more efficient and some of our services may not work properly.

Instructions for managing cookies

If you have a different browser type or version, please refer to the browser’s “Help” menu.

Internet Explorer 7 and 8

  1. Click on the Tools menu, and select Internet Options
  2. Click on the Privacy tab
  3. Move the slider to choose your preferred settings
  4. For more specialized cookie settings, click on Sites or Advanced
  5. For instructions on deleting cookies on Internet Explorer, click here

Google Chrome

  1. Click on the Chrome menu, and then select Settings
  2. Click on Show advanced settings
  3. Click on Content Settings to choose your preferred settings
  4. For instructions on deleting cookies on Chrome, click here

Mozilla Firefox 14, 15, e 16

  1. Click the Firefox button (or Tools menu), then select Options. For Mac OS X users, click on the Firefox menu, and then select Preferences
  2. Click on the Privacy panel to choose your preferred settings
  3. For more specialized cookie settings, set Firefox: use the customized settings for storing browsing data
  4. For instructions on deleting cookies on Firefox, click here

Safari 5.1 and later (Mac OS X)

  1. Click on the Safari menu, and then select Preferences
  2. Click on the Privacy tab to view the cookie settings
  3. Choose your preferred settings
  4. For more specialized cookie settings, click on Details
  5. For instructions on deleting cookies in Safari, click here


  1. Open the Tools menu, and then select Preferences
  2. Click on the Advanced tab
  3. In the Cookies section: click Manage cookies
  4. Select the options you want
  5. For instructions on deleting cookies in Opera, click here