Re: Statement on the processing of your personal details, pursuant to Article 13 of Italian Legislative Decree No. 196/2003 (the Italian Data Protection Act), requiring your consent for the processing of certain pieces of data.
- Legislative Decree No. 196/2003 introduced the code for the protection of personal details. Pursuant to the terms of that code, the processing of your personal details by our organisation is based on the principles of fairness, legitimacy and transparency, and is geared towards protecting the confidentiality and rights of the data subject (i.e. you).
2. In this context, we hereby provide the statement envisaged by Article 13 of Legislative Decree No. 196/2003 and we request that you grant your consent for the processing of the personal details specified below for the following purposes: a. to handle information and/or booking requests with a view to supplying the necessary responses
3. The supplying of your details is compulsory for the pursuit of the aforementioned purposes; refusal to supply said details, or their partial or erroneous supply, may make it impossible to deliver the requested services.
4. In the event that you have granted your consent and until you withdraw that consent, the personal details you have supplied will be processed for the following additional purposes: a. to conduct statistical studies and market research; b. to send you by post, e-mail and/or telephone, advertising, informative and commercial material; c. to conduct direct and indirect sales and positioning operations; d. to implement interactive commercial communications; e. to monitor levels of customer satisfaction in relation to the quality of the services provided (directly and through third parties). You may withdraw any consent you have grand for these purposes at any time by contacting the Data Manager indicated at Point 10. Consent for the processing operations and the purposes set out at Point 4 is not compulsory; following a refusal, your details will be processed for the sole purposes indicated at Point 2.
5. As customers or potential customers, the details subject to processing are generally common in nature, since they essential consist of elements for personal identification. In the event that you provide, in those fields that do not require it, specific details that, pursuant to Article 4, Letter d) of Legislative Decree No. 196/2003, are considered sensitive in nature and, as such, require particular levels of protection, we hereby inform you that said details will be processed by us within the limits set out by the code of for the protection of personal details. We would remind you that in general, Article 4, Letter d) of Legislative Decree No. 196/2003 defines as "sensitive details" those personal details that "may disclose the subject's racial and ethnic original, religious, philosophical or other convictions, political opinions, membership of parties, trades unions, associations or organisations of a religious, philosophical, political or trades union-affiliated nature, as well as personal details that may disclose the subject's state of health or information on his or her sexual life".
6. The processing of the compiled data will be carried out using paper-based and/or electronic tools and, in any case, will be compliant with the relevant applicable legislation.
7. We hereby clarify that our organisation has put in place the necessary organisational, physical and logistical information to ensure the security of the details, with particular reference to the content of Appendix B of Italian Presidential Decree No. 196/2003, Technical Regulatory Framework on the Minimum Security Measures.
8. As well as by the company's employees, certain processing operations relating to your personal details may be carried out by third parties, based in Italy and/or overseas, to which our organisation entrusts certain activities (or parts thereof) relating to the provision of the aforementioned services. In such cases, the same parties will operate as Independent Data Managers or will be designated as Data Managers or Data Management Appointees. Any designated Data Managers or Data Management Appointees will receive appropriate operating instructions, with particular reference to the implementation of the minimum security measures, with a view to guaranteeing the confidentiality and security of the details. The aforementioned third parties essentially fall into the following categories: debt-recovery companies, companies that process traffic data for invoicing, companies responsible for printing and sending out invoices to the customers, consultancy companies, debt-transfer companies, agents and brokers, franchisees, suppliers of technology services and content providers.
9. We have included below an extract from Article 7 of Legislative Decree No. 196/2003 to remind you that you can exercise the following rights in relation to us: a. be informed as to whether any of your personal details are being held, even if not yet saved, and receive a copy of them in an intelligible form b. be informed as to the source of the personal details held, the purpose(s) for which they are being processed and the method(s) used c. be informed of the systems used (when the processing operations are carried out electronically) d. be informed of the contact details of Data Controller and the Data Manager(s) e. the parties to which the details may be disclosed, or which may be given access to the details as the designated local representatives of the State, as managers or functionaries f. obtain the updating, correction or, where necessary, completion of the details g. obtain the cancellation, making anonymous or blocking of access to any details processed unlawfully, including those details that are not required to be held in relation to the original purpose for which the details were collected and subsequently processed i. obtain confirmation that the updating, correction, completion, cancellation, making anonymous or blocking of access have been communicated to all those to whom the details were disclosed, except when the act of fulfilling this obligation would be impossible or would require the expenditure of funds that are clearly disproportionate to the right being protected j. oppose, fully or partially, for legitimate reasons, the processing of your personal details, even if relevant to the purpose for which they were collected k. oppose, fully or partially, the processing of your personal details for the purposes of sending out publicity or direct sales material, or for the completion of market research surveys or for commercial communications.
10. To exercise these rights, you should contact the Data Controller. The Data Manager is Matteo Lucio Lonis - Via Cesare Battisti, 4 - 20122 Milano.