Privacy Policy

Privacy Policy of according to the law and the 2016/679 EU Regulation (GDPR)

Why information

This page describes how to manage the site in relation to the processing of personal data of users who consult it. The information is directed, in accordance with the relevant laws and the EU Regulation 2016/679 (GDPR), to those who interact with the web services of the website having a web address:

Data Controller

The “Data Controller” of Personal Data processing (hereinafter only “Data Controller”) is: Lucrezia Manfredi, email address:


Voluntary data

This Website on the page relating to “Contacts” and “Book a consultation” presents a form that can be voluntarily filled in by the User. The requested data (name, surname, email) become part of the Data Base automatically prepared by the Site; they are used only for the purpose of the necessary response to the request of the User. The data will be transmitted to the Data Controller only upon reading by the User of this Privacy.


The Site also presents portions of code (so-called “Cookies”) that serve to improve the user’s browsing experience. Some cookies are necessary for site management functionality; others have been prepared by third parties. The third-party cookies used by this site concern:

a) Google Fonts, which are used to display texts with characters not available on the User’s device;

b) Google Maps, necessary to geolocalize a place;

c) Google Analytics, to define, on the basis of anonymous data, some statistics regarding visits to the Site.

Data retention

The Data will be stored only to manage the functions described above and will never be transferred to third parties

User Rights

Each user can deactivate all or individual cookies, or exercise their rights to rectify data, deletion, limitation and any other right in more detail below specified.


I – Information relating to the site’s privacy policy

  1. This section contains information on how to manage Floema Consulting in relation to the processing of data of users of Floema Consulting.
  2. This information is also valid for the purposes of art. 13 of Legislative Decree n. 196/2003, Code regarding the protection of personal data, and for the purposes of Article 13 of EU Regulation no. 2016/679, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, for persons interacting with Floema Consulting and can be reached at the address corresponding to the home page:
  3. The information is provided only for Floema Consulting and not for other websites that may be consulted by the user through links contained therein.
  4. The purpose of this document is to provide information on the methods, timing and nature of the information that the data controllers must provide to users when connecting to the Floema Consulting web pages, regardless of the purpose of the connection, according to the Italian and European legislation.
  5. The information may undergo changes due to the introduction of new rules in this regard, therefore the user is invited to periodically check this page.
  6. If the user is under the age of 16, pursuant to art. 8, c.1 EU regulation 2016/679, will have to legitimize its consent through the authorization of parents or guardians.

II – Data processing

1- Data Holder

The data controller is the natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data. He also deals with safety profiles.

With regard to this website, the data controller is Lucrezia Manfredi, and for any clarification or exercise of the user’s rights he may contact him at the following email address:

2- Responsible for data processing

The controller is the natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.

Pursuant to Article 28 of EU Regulation no. 2016/679, upon the appointment of the data owner, the data controller of the Floema Consulting site is Lucrezia Manfredi.

3- Place of data processing

Data processing generated by the use of Floema Consulting takes place at Via Stradella del caffè 24/6, 70124 Bari.

In case of necessity, the related data can be processed by the person in charge of the treatment or subjects appointed by it for this purpose at the relative headquarters.

The data collected are used exclusively to facilitate communications between the Floema Consulting and users who wish to stay and have filled out the forms for booking or requesting information. There is no Newsletter service or transfer to third parties of this data. To request the cancellation of your data, simply send an email to the address with the subject “Request to delete your personal data”.

III – Cokies

1- Type of Cookies

The Floema Consulting website uses cookies to make the user’s browsing experience easier and more intuitive: cookies are small text strings used to store some information that may concern the user, his preferences or the access device to the Internet (computer, tablet, or mobile) and are mainly used to adapt the operation of the site to its user’s expectations, offering a more personalized browsing experience and memorizing the choices made previously.

A cookie consists of a reduced set of data transferred to the browser by the user from a web server and can only be read by the server that made the transfer. it is not executable code and does not transmit viruses.

Cookies do not record any personal information and any identifiable information will not be stored. If you wish, you can prevent the saving of some or all cookies. however, in this case, the use of the site and the services offered could be compromised. To proceed without changing the options related to cookies, simply continue browsing.
Below are the types of cookies that the site uses:

2- Technical cookies

There are many technologies used to store information on the user’s computer, which are then collected by the sites. Among these, the best known and used is that of HTML cookies. They are used for navigation and to facilitate access and use of the site by the user. They are necessary for the transmission of communications on the electronic network or the supplier to provide the service requested by the customer.

The settings to manage or deactivate cookies may vary depending on the internet browser used. In any case, the user can manage or request the general deactivation or cancellation of cookies, modifying the settings of his internet browser. This deactivation can slow down or prevent access to some parts of the site.

The use of technical cookies conducting the safe and efficient use of the site.

The cookies that are inserted in the browser and retransmitted by Google Analytics or by the service of statistics of bloggers or similar are technical only if used for the purpose of optimizing the site directly from the owner of the site, which will collect information in aggregate form on the number of users and how they visit the site. Under these conditions, for analytics cookies the same rules apply, in terms of information and consent, provided for technical cookies.

From the point of view of duration, we can distinguish temporary session cookies that are deleted automatically at the end of the browsing session and serve to identify the user and thus avoid login to each page visited and those that remain, which remain active in the PC up upon expiry or cancellation by the user.

Session cookies may be installed in order to allow access to and access to the reserved area of ​​the portal as an authenticated user.

They are not stored permanently but only for the duration of the navigation until the browser is closed and disappear when the browser is closed. their use is strictly limited to the transmission of session identifiers consisting of random numbers generated by the server necessary to allow the site to be explored and efficient.

3- Third-party cookies

In relation to the provenance we distinguish the cookies sent to the browser directly from the site you are visiting and those of third parties sent to the computer from other sites and not from the one you are visiting.

Persistent cookies are often third-party cookies.

The majority of third-party cookies consists of tracking cookies used to identify online behavior, understand the interests and then customize the advertising proposals for users.

Third-party analytical cookies may be installed. They are sent from the domains of the aforementioned third parties external to the site.

Third-party analytical cookies are used to find information on user behavior on Floema Consulting. The survey takes place anonymously, in order to monitor the performance and improve the usability of the site. The third-party profiling cookies are used to create profiles relating to users, in order to propose advertising messages in line with the choices expressed by the users themselves.

The use of these cookies is governed by the rules set by the third parties themselves, therefore, users are invited to read the privacy policies and indications to manage or disable the cookies published on the related web pages.

4- Profiling cookies

Profiling cookies are those that create profiles related to the user and are used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net.
When these types of cookies are used, the user must give explicit consent.
Article 22 of EU Regulation 2016/679 and Article 122 of the Code on data protection will apply.

IV – Process Data

Like all websites, this site also makes use of log files in which information collected in an automated manner is kept during user visits. The information collected could be the following:
– internet protocol (IP) address;
– type of browser and device parameters used to connect to the site;
– name of the Internet service provider (ISP);
– date and time of visit;
– web page of origin of the visitor (referral) and exit;
– possibly the number of clicks.

The above information is processed in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the holder.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may possibly also include personal data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the site itself or to cause damage to other users, or in any case harmful activities or constituting a crime. Such data are never used for the identification or profiling of the user, but only for the protection of the site and its users, such information will be treated according to the legitimate interests of the owner.

The site allows to register the user’s email address. This data is voluntarily provided by the user at the time of the request for the provision of the service. by entering all the requested data, the user expressly accepts the privacy policy. The data received will be used exclusively for the provision of the requested service and only for the time needed to provide the service.

The information that users of the site deem to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violation of laws. It is up to the user to verify that they have permission to enter personal data of third parties or contents protected by national and international standards.

2- Purposes of data processing

The data collected by the site during its operation are used exclusively for the purposes indicated above and kept for the time strictly necessary to carry out the activities specified, and in any case not later than 5 years. Alternatively, you can request cancellation by sending an email to quoting in the subject of the email “Cancellation of personal data”.

The data used for security purposes (block attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated end.

3- Data provided by the user

As indicated above, the optional, explicit and voluntary sending of e-mails to the addresses indicated on this website entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message.

Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request.

4- Support in the configuration of your browser

The user can also manage cookies through browser settings. However, deleting cookies from your browser may remove the preferences you have set for the site.

For more information and support you can also visit the specific help page of the browser you are using.