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Personal Data Processing Policy

Subject: Information on the processing of personal data, pursuant to article 13 of Lgs. Decree 196/2003 (Italian DP Code).

Lgs. Decree 196/2003 concerns protection of individual and other entities in respect of the processing and protection of personal data, imposing some duties to whoever processes information about other parties.

1.

In compliance with the prescriptions of this law, anyone who treats personal data must supply the person to whom the data is referred to adequate information and, in some cases, obtain the consent to treat his/her data.

2.

Personal data processing refers to the collection, registration, organisation, storage, elaboration, modification, selection, extraction, comparison, use, interconnection, restriction, communication, diffusion, cancellation and distribution of such data or the combination of two or more of the aforementioned operations, connected or instrumental to the activities of our Company.

3.

Please be informed that any personal data provided by yourself, or otherwise acquired during our activity, may be processed either through our computer system or without electronic means, in compliance with the above law, for our Company's institutional purposes, namely:
- performing a service or one or more contractually agreed operations;
- complying with obligations laid down by laws or regulations;
- providing information about commercial communications and promotions, as well as processing statistical analyses and market research.
We therefore point out that the communication of your personal information, as you may understand, is thus necessary, even though not mandatory, for the purposes shown above.

4.

Please note, however, that the refusal to disclose personal information or to give us the consent to your personal data processing could compromise the correct development of the relation with our Company;

5.

All personal data is required. Furthermore, Italian DP Code has introduced special rules in the processing of “sensitive” personal data, namely personal data consisting of information about racial or ethnic origin, physical or mental health conditions, political opinions, religious beliefs or other beliefs of a similar nature. In this case, we must require an explicit consent of the Data Subject to their processing.

6.

Personal data will be treated with electronic, computer and hardcopy tools, in compliance with the norm pursuant to and by effect of the Technical Disciplinary on the minimum security measures, Enclosure B of the Privacy Code.

7.

Navigation data: our Company uses web-tracking systems, such as IP addresses and Cookies. These tools help to facilitate analysis of web traffic, in this case:
a) IP addresses: we keep a record of all our website visitors IP addresses. These data are collected with the aim to extract anonymous statistical information relating to website use, to check its correct functioning and to prevent hypothetical computer crimes against our site. b) Cookies: our Company is entitled to use web-tracking systems, such as cookies, to record data transmitted from a web server to the users’ computer, in order to recognise that computer in future visits to the same website. These tools help to facilitate the web traffic analysis, enable the proper functioning of the website and allow web applications to send information to individual users. The user can delete cookies from his/her system at all times; in this case, however, there is no guarantee of proper operation of all the tools that the web site makes available to you.

8.

Personal data communication and transfer: we may have to communicate your personal data to third parties to which our Company entrusts certain activities (or parts of the same), which are necessary for the supply of the above-mentioned services, for the fulfilment of contractual obligations or commercial interests. Furthermore, the following third parties may also be involved in the processing of your personal data:

9.

Data Controller & Data Processor
- The holder of the data processing, pursuant to and by effect of Legislative Decree 196/03 is: Colarizzo S.R.L. with registered office in Via Torre Lapillo, Torre Columena km 0,7, 73010 Porto Cesareo (LE), 03973250750 - (+39) 0833 565312
- Those legally responsible for the processing of personal data are: Colarizzo S.R.L. our Company’s employees and partners.

10.

Personal data will be treated and processed:
- by means of electronic, computer and hardcopy tools;
- by authorised staff, who is constantly identified, informed and trained on the obligations imposed by Legislative Decree 196/03;
- committing ourselves to constantly update your personal data, erasing and transforming into anonymous form those data processed unlawfully or not required;
- committing ourselves to adopt all the organisational and security measures required to guarantee you privacy and prevent any illegal dissemination of your personal data.

11.

We also stress that, you are entitled, at any time, to exercise your rights towards the Data Controller pursuant to Article 7 of Legislative Decree no. 196/03, which we provide below in its entirety for your convenience. Section 7 of Legislative Decree no. 196 of 30 June 2003 (Right of access personal data and other rights):
1. A Data Subject shall have the right to obtain confirmation as to whether or not personal data concerning him or her exists, even if the data is not yet registered, and to the communication of this data in an intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the data processing if this is carried out using electronic tools;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the people or categories of people to whom the personal information can be communicated or who can come to know the information as designated representatives of the State, managers or assigned operators.
3. A Data Subject shall have the right to obtain:
a) the updating, rectification or, when this is in his or her interests, the integration of the data;
b) the erasure, transformation into anonymous form or blocking of data processed unlawfully, including data which it is not necessary to store for the purposes for which the data was collected or subsequently processed;
c) certification that the operations as per letters a) and b), including regarding their contents, have been brought to the knowledge of those to whom the data have been communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right which is to be protected.
4. A Data Subject shall have the right to object, in whole or in part:
a) for legitimate reasons to the processing of personal data which concerns him or her, even if the data is relevant to the purpose of its collection;
b) to the processing of personal data concerning him or her for the purpose of sending publicity material, direct selling, market research or commercial communication.

To exercise the above mentioned rights , please contact the Data ProcessorColarizzo S.R.L.,with registered office in Via Torre Lapillo, Torre Columena km 0,7, 73010 Porto Cesareo (LE), 03973250750 – Phone Number(+39) 0833 565312.
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