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Privacy

Personal Data Protection Code

Published in the Official Gazette of 29 July 2003, General series no. 174, Ordinary supplement no. 123/L
http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/export/1311248


a) The law in question regulates the confidentiality of personal data (Disclosure) and imposes a series of obligations on those who "process" information concerning other parties. The disclosure is provided for the Website only and not for other websites accessed by the User through links. b) The law in question considers "processing" of data, "any operation or set of operations, carried out without the aid of electronic instruments, concerning databases, preparation of accounting and other statements, completion of reporting models of substitute tax limited to sections not related to employees and possibly workers, the collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not registered in a database, including system passwords and tax protection and all other claims expressly required by the activities carried out by our Company". c) In relation to the positions listed below that may concern you in dealings with our Company, we inform you that your data is indispensable in order to initiate the normal typical operations regarding said relations and therefore, the conferment of data is considered obligatory. d) Any refusal to provide data may imply the impossibility to proceed with as listed in point c). e) All information requested is obligatory. During processing, we may become aware of information that the Privacy Code defines as "sensitive", as appropriate to detect health status, membership of trade unions, religious and philosophical convictions. For all the reasons above, we kindly require express written consent to processing.

1. Processing Purposes

Personal data of voluntarily provided by the User to Koobcamp S.r.l. will be collected and used to:

- contact the User who has made a request by entering information in this section of the Website, for the presentation of products, offers and other by Koobcamp S.r.l. and network connected to Koobcamp S.r.l. worldwide and/or entities collaborating in the commercial activities of Koobcamp S.r.l. and/or by Companies and/or associated companies of Koobcamp S.r.l., even by sending information or promotions, also for commercial purposes, advertising materials and/or offers of goods and services, by mail, Internet, telephone, e-mail, MMS, SMS from Italy or abroad; - sending of the newsletter/s requested by the User; - elaboration of studies and statistical and market research.

2. Types of data processed

Browsing data
The IT systems and software procedures for operation of the Website acquire, during normal operation, some personal data the transmission of which is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified parties concerned, but that by its very nature could, through processing and association with data held by third parties, allow identifying Users. This category of data includes: IP addresses or domain names of computers used by Users that connect to the Website, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and the User's IT environment. This data is only used to obtain anonymous statistical information regarding use of the Website and to verify its correct operation and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical cyber crimes against the Website: at present, with the exception that the data on web contacts are not stored for more than seven days.

Data provided voluntarily by the User
The optional, explicit and voluntary sending of e-mail to the addresses indicated on this Website involves the subsequent acquisition of the sender's address required to reply to the requests, and any other personal data included in the communication. The data will be mainly processed with electronic and computer instruments and stored on computer media and on paper and on any other kind of support, which can be accessed only by authorized personnel, in compliance with the minimum security measures under the Technical Regulations regarding minimum security measures, Annex B of the Privacy Code.

3. Information on IP addressing and the use of Cookies

Users are informed that the Website uses tracking technologies of IP addresses and cookies in order to report visits to its website, in particular:

a) IP addresses
collection of the addresses of all visitors who access the Website. The data obtained is used for the management of the technical and administrative operations of our Company, the diagnosis of any technical problems and the prevention of intrusion and abuse of the service.

b) Cookies
information that may be registered by the browser on the User's hard drive in order to track browsing on the Website, with the consequence that every time the User returns to the website, it could be identified in advance together with the eventual preferences expressed in a previous visit. These files allow customizing a Website, providing Users with easier browsing and, through a quantitative verification of visits to the various web pages, better presentation of the most requested information. The cookies used only pick up anonymous information and, therefore, do not allow the processing of data relating to the person. Nevertheless, cookies may be used to store the User's login data and therefore make User recognition automatic (avoiding the username and password entry procedure). Most current browsers automatically accept cookies, but Users can configure their browser so as to exclude, display before accepting and eliminate cookies. However, it will always be possible to disable cookies by changing the browser settings, but this may slow down or prevent access to certain parts of the Website. In any case, in addition to the aforementioned browsing data, no other personal information will be collected, with the obvious exception of data provided voluntarily. The processing of personal data of the User will be by means of suitable electronic and/or paper-based instruments, with logics strictly related to the purposes mentioned above and, in any case, so as to ensure the security and confidentiality of the data. This site also uses third-party cookies, created and subject to external domains, in order to collect information about your activities. For example, if you have interacted with the "Like" button on Facebook, your browser sends information about these cookies to the social network. These cookies are used by Social Networks to provide you with a personalized experience on our website, to maintain and improve the service and to protect both you and your site from malicious activity. In particular:
- Facebook:  www.facebook.com/policies/cookies/
- Google:  www.google.com/intl/en/policies/privacy

4. Provision of data and consequences of eventual refusal

Providing personal data is optional; however, any refusal and/or provision of incorrect and/or incomplete information will make it impossible to send out newsletters or information or promotions, also for commercial purposes or for the User's participation in the elaboration of studies and statistical and market research.

5. Communication of data

The User's personal data provided may be subject to disclosure and/or dissemination to fulfil contractual relations with our Company, for purposes related to them, for purposes related to the exposure of references, for commercial and promotional activities of our Company's products.

The data will be processed:
- on printed and electronic media of all kinds;
- by authorized persons, constantly identified, properly trained and made aware of the constraints imposed by law;
- with the commitment to promptly update the data, eliminating obsolete, unnecessary or irrelevant data;
- zobowiązując- with the commitment to adopt the organizational and security measures required by law, to ensure the confidentiality of the party concerned and to prevent undue access by third parties or unauthorized persons. The User's personal data may also be communicated to any qualified persons who provide to Koobcamp S.r.l. services or functions for the purposes described above in article 1 herein, including parties and companies that manage and/or participate in the management and/or maintenance of our websites and the electronic equipment used. In pursuit of the activities referred to in article 1, Koobcamp S.r.l. can resort to the following categories of parties that may become aware of the User's personal data: qualified parties, such as banks, firms and insurance companies, suppliers and subcontractors, which provide to Koobcamp S.r.l. services related to sending of newsletters, information and promotions, also for commercial purposes, conduct of statistical and market research, organization and holding of events, also promotional; to legal, tax, insurance, accountancy, organizational aspects; any other party to which the information must be disclosed in accordance with an express provision of law.

The personal data may be transferred abroad, in compliance with the regulations in force, even in countries outside the EU, where Koobcamp S.r.l. has business interests

6. Disclosure of data

User's personal data will not be disclosed or communicated to third parties other than the ones indicated herein.

7. Rights of the Interested Party

In relation to the processing referred to in article 1, the User may exercise the rights under article 7 of Legislative Decree 30 June 2003, no. 196, which, for convenience, we have transcribed in full below.

Article 7 - Right of access to personal data and other rights

1. The party concerned has the right to obtain confirmation of the existence of related personal data, even if not yet recorded, and related communication in intelligible form.

2. The party concerned has the right to obtain the indication of:
a) the origin of personal data;
b) the purposes and methods of processing;
c) the logic applied in case of processing with the aid of electronic instruments;
d) the identity of the controller, processor and the representative appointed under article 5, paragraph 2;
e) the subjects or categories of subjects to whom personal data may be communicated or who acquire it as appointed representative in the State, as managers or agents.

3. The party concerned has the right to obtain:
a) the updating, correction or, when required, integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data for which storage is unnecessary for the purposes for which the data was collected or subsequently processed;
c) certification that the operations under letters a) and b) have been notified, also as regards their contents, to those to whom the data was communicated or disclosed, except where this requirement is impossible or involves the use of means that are disproportionate to the protected right.

4. The party concerned has the right to object, in whole or in part
a) for legitimate reasons to the processing of personal data, pertinent for collection purposes;
b) doto the processing of related personal data for purposes of sending advertising or direct selling materials or for carrying out market research or commercial communication.

8. Information for promotional activities

UdziałParticipation in marketing activities is voluntary and in accordance with article 7, 4th paragraph, letter b) and article 130 of the Code concerning the protection of personal data, in particular as regards electronic communications via e-mail, telefax, MMS (Multimedia Messaging Service) or SMS (Short Message Service), or otherwise.

9. Data Controller and Data Supervisor

WłaścicielemThe Data Controller of personal data is Koobcamp S.r.l., with registered office in Turin, C.so Duca degli Abruzzi 2, operating office in Via XXV Aprile 179/b, 10042 Nichelino (To), Tax ID/VAT VAT 09476090015. The Data Supervisor of personal data on behalf of Koobcamp S.r.l. is the Legal Representative pro tempore, domiciled for the role at the operating office of Koobcamp s.r.l. in Via XXV Aprile 179/b, 10042 Nichelino (To). Any request relating to personal data processed by Koobcamp S.r.l. may be addressed to the latter at the registered office of the company, or by writing to the e-mail [email protected] or to the fax number +39 011/37.16.927.