Privacy Policy

This Privacy Policy (“Policy”) provided by Aaron & Partners Group Ltd. , based in 63-66 Hatton Garden, London EC1N 8LE, England, UK as the owner and data controller (hereinafter, “Aaron&Partners Group Ltd.” or the “Data Controller”) of the site (the “Website”) and the services connected to it (the “Services”). The “Data Processor” is Mrs. Karine.

Aaron & Partners Group Ltd. respects the privacy of every user who visits the Website and uses the Services (“User”). The policy does not apply to third party sites accessible via external hyperlinks on the Aaron & Partners Group Ltd. website.

The processing of personal data of individuals will be in accordance with applicable law, with particular reference to Legislative Decree no. June 30, 2003, n. 196, containing the Code regarding the protection of personal data, as amended by Regulation (EU) no. 679 of 27 April 2016 – applicable from 25 May 2018 (hereafter referred to as “Applicable Privacy Law”).

Links to the sites mentioned above and not to other websites that may be consulted by the user through special links.

Privacy Policy before submitting any personal information and / or completing any electronic form on this site.

This policy and how to use and manage cookies may be subject to updates at any time. In this case, Aaron & Partners Group Ltd. will publish a notice on the homepage of the site. In any case, Aaron & Partners Group Ltd. invites you to periodically check the privacy statement to be informed of any changes.


Navigation data

The computer systems and software procedures used to operate this site acquire, in normal operation, some personal data that are then implicitly transmitted in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects, but which 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:

  • Identification and contact data (ex. name, surname, e-mail, telephone number, etc.);
  • data relating to the content of electronic communications exchanged with Aaron & Partners Group Ltd. for the purposes referred to in paragraph 2 (a);
  • data relating to the IP address or the ID of the device of a User through which the Site is accessed or the Services are used;
  • data relating to the type of browser used by Users, as well as the date and time of use to access the Site or the Services.

Data retention times and conservation purpose

The data referred to in the previous paragraph are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning, as well as for the following purposes:

  • respond to requests from Users sent via the Site;
  • improve the presentation, features and functionality of the Website and the Services, as well as the administration and management of user requests;
  • allow Users to participate in surveys and surveys anonymously;
  • provide assistance on the services offered, at the request of Users;
  • prevent fraud or crimes committed through the Site or Services;
  • fulfill legal or tax obligations pursuant to applicable law;
  • subject to consent, contact Users through automated tools (email, sms, mms, social, unmanned calls) and non-automated (paper mail and telephone with operator) to offer them commercial offers and promotions, as well as involve them in market research and surveys, also by sending regular newsletters;
  • subject to consent, analyze the choices and commercial preferences of Users in using the Site or Services, in order to customize the offer of products and services dedicated to them.

For the purposes referred to in letters A) to F), Aaron&Partners Group Ltd. will process the personal data of Users based on their requests and their legitimate interest. For the purposes referred to in letters g) and h), Aaron&Partners Group Ltd. will process the personal data of Users on the basis of their consent. Personal data processed by Aaron&Partners Group Ltd. on the basis of the User’s consent will be kept for the time strictly necessary to achieve the purposes for which they were originally collected and, in any case, will no longer be processed as a result of any revocation of consent given. Where the processing of personal data should instead take place in compliance with legal, tax or judicial obligations, or to ascertain responsibility in case of hypothetical computer crimes against the site, the data may be stored up to a maximum of ten (10) years. For more information about the criteria and time frame for which we store your data, you can contact the Aaron & Partners Group Ltd Data Protection Officer at the e-mail address: Data provided voluntarily by users / visitors.

If users / visitors, connecting to this site, send their personal data to access certain services, or to make requests in chat and / or email mode, this involves the acquisition by Aaron & Partners Group Ltd. of the address of the sender and / or any other personal data that will be processed exclusively to respond to the request, or for the provision of the service. Personal data provided by users / visitors will be communicated to third parties only if the communication is necessary to comply with the requests of the users / visitors themselves.

“Contact” form

The data that will be provided to us through this form are the name and surname, your e-mail address and telephone number and will be used exclusively to respond to your requests or questions you would like to contact us. Providing such data is mandatory in order to formulate a request to Aaron & Partners Group Ltd. and any refusal to grant them will prevent you from obtaining an answer.

Processing methods

Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. All personal data will be processed mainly through electronic tools and methods, however the treatment by paper means is not excluded a priori by Aaron & Partners Group Ltd. . The Data Controller will take all necessary security measures in order to minimize the risk of destruction or loss, even accidental, of the data, unauthorized access or processing that is not permitted or does not comply with the purposes indicated in this document. However, since it is not possible to guarantee that the measures taken for the security of the Site and the transmission of data are such as to exclude any risk of unauthorized access or loss of data, we urge the user to make sure that his computer is equipped with software updated antiviruses for data network protection – both inbound and outbound – and that your Internet service provider has adopted firewalls and anti-spam filters, or other appropriate measures for the security of data transmission.

Optional supply of data

Apart from that specified for navigation data, users / visitors are free to provide their personal data. Failure to provide such data may entail the impossibility of obtaining what is requested.

Information collected passively

In providing our services we will use software and / or third-party services to collect information passively, without your knowledge, while you are browsing or interacting with the content of our website, as well as information on the device you use. The only purpose of passive collection of this information is to learn more about how you use and interact with the Web, with the aim of improving your experience in the use of our services and identify possible errors during the implementation of the our site. The information collected includes, by way of example and not exhaustively:

  • The IP address of your device
  • The screen size of the device used
  • Device (unique identifier) and browser information
  • Geographical position (country)
  • Selected language with which the website is displayed
  • Pages visited
  • Date and time when the pages were visited

For this purpose, we use the third-party web analysis service, which passively collects information in order to examine the use of the website and, in general, to gather information about the activities of the website. It is also noted that Aaron & Partners Group Ltd. may use third party services such as Google Analytics, which collects information about your browsing through cookies or other mechanisms. Under no circumstances does Aaron & Partners Group Ltd. collect or store identifying data (including, in particular, bank details or payment procedures).

Transfer of personal data abroad

Users’ personal data will not be transferred to countries that do not belong to the European Union and which do not ensure data protection levels in line with the applicable Privacy Law. Processing of personal data of minors The use of the Site and the Services is reserved only for users over 18 years of age. Aaron & Partners Group Ltd. does not process personal data of minors under eighteen (18) years without parental consent.

Place of data processing

The processing operations connected to the web services of the sites indicated above take place at the registered office of Aaron & Partners Group Ltd., 63-66 Hatton Garden, London EC1N 8LE, England, UK and / or at the headquarters of the hosting company and / or management of the website and are only handled by technical staff of the Office in charge of processing, or by persons in charge of occasional maintenance operations. No data deriving from the web service is communicated or disseminated. The personal data provided by users who request dispatch of informative material are used only to perform the service or provision requested and are communicated to third parties only if this is necessary for that purpose.

Data controller

The holder of the processing of personal data, as defined by art. 29 of the Privacy Code, is Aaron & Partners Group Ltd. (

Rights of the interested parties

Pursuant to the Applicable Privacy Law, Users will be entitled to:

  • be informed of the purposes and methods of processing their personal data;
  • access to personal data;
  • obtain a copy of your personal data, where these are stored in countries outside the European Union, as well as obtain information on the place where such personal data is stored or transferred;
  • request the correction, updating or integration of personal data;
  • request cancellation, anonymisation or blocking of the processing of personal data;
  • oppose, in whole or in part, any processing performed through automated decision-making processes, including profiling;
  • revoke your consent to the processing, where provided, freely and at any time;
  • contact the Data Protection Manager of the Data Controller;
  • file a complaint with the Guarantor for the protection of personal data.

Pursuant to the Applicable Privacy Law, from May 2018, Users will also have the right to exercise the following rights:

  • the right to data portability, that is the right to receive personal data in a structured format, commonly used and readable by automatic device, and the possibility of being able to transmit them to another data controller freely and without impediments;
  • the right to request the limitation of the processing of personal data.

Requests for updating, rectification, cancellation or otherwise relating to the processing and storage of data must be forwarded to the Data Controller at our registered office 63-66 Hatton Garden, London EC1N 8LE, England, UK, or via email at indicating as object: “Cancellation of personal data”. The letter must contain:

  • Name and surname of the applicant
  • Written request for cancellation / updating / correction
  • E-mail address used for registration (e-mail)
  • Password to access your personal area (if available)
  • Photocopy of the identity card or passport
  • Address and contact telephone