Privacy Policy

This page describes how the site is managed with regard to the processing of personal data concerning users of the site. This policy is required in accordance with Article 13 of Italian Legislative Decree no. 196/2003 – Data Protection Code for anyone who interacts with the company’s web services, which can be accessed via the Internet at www.vadolibero.com, which corresponds to the homepage of the official site.

The policy applies to this site only and does not include other sites that may be visited by the user via links. Moreover, this policy draws on Recommendation no. 2/2001, which the European personal data protection authorities, along with the Group established under Article 29 of European Directive no. 95/46/EC, adopted on 17 May 2001 in order to identify certain minimum requirements for the collection of personal data online, including the methods, timescales and nature of the information in particular, which data controllers must notify to users when they visit web pages, regardless of the purpose of their visit.

DATA CONTROLLER

When visiting this website, personally identified or identifiable data may be processed. The data controller is Vadolibero s.r.l., with headquarters in via Franchetti 4, 20124 – Milan – Italy

LOCATION OF DATA PROCESSING

Any data regarding the web services of this website shall only be handled by authorised technical staff or by any employees in charge of occasional maintenance operations. No data from the web service shall be distributed or disclosed. Personal data supplied by users requesting the sending of information materials, shall be used exclusively for the purposes of providing such service or the requested actions.

TYPES OF DATA PROCESSED

Browsing data: during their ordinary course of operations, the IT systems and software procedures used to run this website will acquire certain personal data. This acquisition is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects. However, by its very nature, it could identify users through processing and cross-referencing with data held by third parties. This data category includes the IP addresses or domain names of computers of users who visit the website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment of the user. This data is used only to obtain anonymous statistical information on site usage and to check its correct functioning and are immediately deleted after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site. Except for this circumstance, the data on web contacts is not held for more than seven days.

Data voluntarily supplied by the user: the elective, explicit and voluntary sending of e-mails to the addresses posted on the website entails the subsequent acquisition of the sender’s address, which is necessary to answer any requests, as well as the acquisition of any other personal information included in the message. Specific summary information dedicated to particular services on request will be gradually provided or displayed on the pages of the website.

OPTIONAL PROVISION OF DATA

Apart from what has been specified for browsing data, the user is free to decide whether to provide personal data. Failure to provide it may render the provision of the services requested impossible.

DATA PROCESSING METHODS

Personal data is processed with automatic instruments for the time strictly required to achieve the purposes for which it has been collected. Specific safety measures are in place to prevent loss of data, illegal or improper use and unauthorised access.

RIGHTS OF THE DATA SUBJECTS

The subjects to whom the personal data refers are entitled to receive, at any time, confirmation of the existence or non-existence of the data, information on the content and source, to verify the correctness of the data or request data integration, update or correction (for completeness sake, please see Article 7 of Italian Legislative Decree no. 196/2003).

Pursuant to the same Article, data subjects have the right to request the cancellation, anonymization or blocking of any data being processed illegally. They are also entitled to reject any processing of their data on legitimate grounds.

Requests should be sent to the Data Controller. This document constitutes the “Privacy Policy” of this site and may be subject to change (the various versions can still be viewed at the same address).

LIST OF DATA PROCESSORS FOR PRIVACY (Article 13 of Italian Legislative Decree 196/2003)

The subsequent list of Data Processors for Privacy at Vadolibero s.r.l., is published in accordance with Article 13, paragraph 1, letter f, of the “Data Protection Code” (Italian Legislative Decree no. 196/03), so that all the concerned parties can be informed about the Persons assigned to personal data processing within this company. This list is constantly updated by the Data Controller.

Subject: Customers’ privacy policy issued by Vadolibero s.r.l. pursuant to Article 13 of Italian Legislative Decree 196/2003

Given that, after compiling our questionnaires, forms and cards, after participating in any of our prize competitions, due to the establishment of the business relationship and during the course of said relationship, our company will collect and process your personal data.

We hereby specify the following definitions given by Italian Legislative Decree 196/2003 for the sake of clarity:

processing: any operation, including those made without the use of electronic instruments, concerning the collection, recording, organisation, storage, consultation, processing, adaptation, selection, retrieval, comparison, use, interconnection, blocking, communication, dissemination, deletion and distribution of data;

personal data: any information concerning a natural or legal person, entity or association, identified or identifiable, even indirectly, through reference to any other personal information, including a personal identification number.

Therefore, pursuant to Article 13 of Italian Legislative Decree 196/2003 (Data Protection Code), we hereby inform you that the collection and processing of personal data will be carried out by this company in compliance with the following:

general purposes: data will be processed correctly for administrative, accounting, fiscal, commercial and technical fulfilment and for all corporate activities in general that are related to the existing relationship;

“direct marketing” purposes: (non-sensitive) data may be used, solely and exclusively following on from specially provided, explicit and free consent that can be withdrawn at any time, even when sending advertising material/communications via post, e-mail, telephone, fax, SMS, MMS and the like; after having given consent, you have the right to object to the processing of your data, at any time and at no cost, for these purposes;

methods: data will be processed both with hard copy instruments/aids, as well as electronic/computer/Internet instruments/aids, in complete compliance with the law, according to the principles of lawfulness and civility and to safeguard your privacy;

optional provision: the provision of data is optional and not compulsory;

consequences of a possible refusal: the refusal to provide your data or the integral objection to its processing for the purposes referred to in paragraph a), could entail the impossibility of carrying out some commercial undertakings or other with our company; refusal to allow the use of the data for the purposes referred to in paragraph b), (sending of advertising material/communications), will have no affect on existing or future relationships;

the subjects or categories of subjects to which the personal data may be distributed or disclosed: the data may be shared with subjects that are external to the company, such as subsidiary/parent companies and affiliated companies, mail distribution bodies, marketing companies, layers, accountants, employment consultants, credit institutions, debt recovery companies, factoring companies, agents and representatives, trade associations, etc. that our company makes use of. In no instance will data be disclosed;

company data processors or employees assigned to processing: data will be processed exclusively by the company data processors and designated employees in the administrative and commercial sector that have been especially authorised;

rights of the data subjects: the data subject is entitled to all the rights under Article 7, which is attached in full below this privacy policy and constitutes an integral part;

controller: the data controller is Vadolibero s.r.l. with headquarters in via Franchetti 4, 20124 Milan – Italy in the person of the pro tempore legal representative;

data processor/s: the data processor designed to respond to data subjects is Vadolibero s.r.l., any request for clarification and information should be addressed to this data processor. The complete and constantly updated list of data processors is available for consultation on the company website and/or in relevant hard copy held at company headquarters.

The present privacy policy can be integrated, verbally or in writing, with additional elements and indications, in order to fully satisfy any question related to the issue of “Privacy” and in order to favour changes in regulation.

Date: 01.09.2015

Data controller: Vadolibero s.r.l.