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Information notice concerning the processing of personal data, in accordance with article 13 of Legislative Decree no. 196/20003

In accordance with Legislative Decree - June 30, 2003, No. 196 and subsequent changes, we hereby supply you all the information concerning the purposes and methods for the processing of personal and sensitive data.
This information is not valid for other websites which might be visited through links contained in the web sites of data controller’s domain name. The data controller shall not be considered responsible for third parties’ web sites.
This privacy policy is given pursuant to art. 13 Legislative Decree 196/2003. It’s inspired also to Recommendation n. 2/2001 adopted by Data Protection European Authorities gathered in the Group established from art. 29 of the Directive no. 95/46/CE on the 17th of May 2001, in order to identify minimum requirements for on line personal data collection, and in particular, methods of data processing, terms and nature of the information that Data Controller must provide to the users when they connect to web pages, regardless of the purpose of the connection, and also in reference to European Directive 2002/58/CE, updated with Directive 2009/136/CE related to Cookies, and in accordance with Italian D.P.A. Main Decisions 08.05.2014 about cookies.


1. DATA CONTROLLER pursuant to Article 28 of the Italian Personal Data Protection Code is Claind S.r.l.in the person of its legal representative pro tempore, headquarter: Tremezzina (CO) – via Regina n. 24 – loca Lenno.
DATA PROCESSOR, pursuant to Article 29 of the Italian Data Protection Code, is Ramona Bonfatti Gerola, marketing employee.

LOCATION OF DATA PROCESSING
The data processing related to the services on this website (physically hosted at the Ovosodo srl) is performed by the Company headquarters - the data controller. Data will be processed only by the staff in charge of data processing or by any third parties for maintenance and updating operations on the website pages


2. CATEGORIES OF PROCESSED DATA
Personal data and identification data
Personal data shall mean any information related to natural person that is or can be identified, even indirectly, by reference to any other information, including a personal identification number. Identification data shall mean personal data allowing a subject to be identified directly (for example, name, surname, place and date of birth, address, email address, telephone number, etc.).
Navigation data
Computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. These pieces of information are not collected to be associated with identified interested parties, but, through elaborations and associations with data held by third parties, due to their own nature, may allow the user’s identification.
This data category shall including IP addresses or computers’ domain names used by users who surf the present website, the URI-mapped addresses (URI stands for Uniform Resource Identifier) of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (successful, error, and so on) and other parameters related to the operating system and to the computing environment of the user.
These data are used only to obtain anonymous statistical information on site usage and to check its correct functioning and they are immediately deleted after processing.
Judgment defence
The User's Personal Data may be used  by the Data Processor for legal defence in judgment or in the preparatory phases of the judgment, in order to defence Data Processor’s rights in case of  improper use of this website or to solve matters related to an improper use of services provided by the Data Processor.
Data could be used to determine the responsibility in case of computer crimes to the detriment of the website.
Maintenance
 The User's Personal Data may be processed with additional methods and objectives related to system maintenance.
Data voluntarily provided by the user
Sending explicit voluntary emails to the addresses listed on the website entails the subsequent acquisition of the sender email address, necessary to reply to the user’s request, and also of any other personal data.
Specific information notice
The special information notice are present in the web pages related to particular processing or services of the data provided by the user or by the person.
Cookies
What are cookies?
Cookies are small text files that the visited websites send to the devices, where they are stored and relayed once the user visits the website again. Cookies may perform different functions and have got different features. Cookies can be used both by manager of the site you are visiting and by the third parties.
Here below you’ll find all the information related to cookies used by this website, together with the instructions to manage your cookies preferences.
For further information about cookies please visit www.allaboutcookies.org; www.youronlinechoices.eu.
Cookies used by this website Technical cookies that do not require user consent:
The present website uses technical cookies, and in particular cookie related to activities strictly necessary to operate the site and to provide the service, as well as third part statistic cookie (Google analytics) to collect information in aggregate form in order to handle anonymous statistical information, without IP tracking (no user data profiles at the IP level) and without data sharing with the third part.
Access to information of the third part:
Privacy Policy: http://www.google.com/policies/privacy/ 
Cookie Policy: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage 
Opt out: https://tools.google.com/dlpage/gaoptout?hl=it
All the technical cookies do not require user’s consent, that’s why they are automatically installed following the access to the website by the user.

3. PURPOSES OF DATA PROCESSING FOR WHICH YOU GRANT CONSENT WHERE REQUIRED (ARTICLE 23 D. LGS. 196/03.)
The personal and sensitive data voluntary provided, will be processed for the following purposes:
with your prior consent and until your objection, subscription to the commercial and informational newsletters through e-mails and related activities.

4. METHODS OF DATA PROCESSING - DATA RETENTION
The personal data processing will be carried out by electronic, automated and / or manual instruments, with methods and tools to ensure maximum security and confidentiality, by persons duly appointed in accordance with the provisions of Art. 31 and following of D. Lgs 196/03. Personal Data will be kept for a period not exceeding the purposes for which the data were collected and subsequently processed.
Thanks to the reports, Claind will know, for example: the number of unique users, the openings, the unique clickers and clicks, the devices used to read the message (iPhone, Blackberry, Nokia); operating systems used to read the message (Windows, Apple, Linux, android), details on the activities of individual users for at least 90 days; Users that have not yet confirmed the subscription; emil sent by date / time / minute; email delivered and not delivered; forwarded email; list of unsubscribed for newsletters; list of person who opened the email or who clicked a single link in real time; users with problems viewing the message; link tracking, that is, the number of clicks made on the message link; click tracking, that is links that were clicked on and by whom; graphical map of the links to view the area that has received major interest; quality benchmarks relating to the sector to compare, and possibly improve, the results of communications.

5. COMMUNICATION AND DATA DIFFUSION
Your personal data will not be disseminated. Data may be disclosed to Companies contractually tied to Claind S.r.l., abroad in the European Union, according to and for the effect of Section 42 L. Decree No. 196/2003, in order to comply with contractual obligations or related purposes. The data may be disclosed to third parties in the following categories:
- providers of services for the management of the IT system used by Claind S.r.l. and telecommunications networks;
- firms or companies relevant to service or consultation’s contracts;
- competent authorities to execute the relevant laws and / or requirements of public bodies, on request.
Entities in the above categories are considered data processor, or are acting independently as data controller. The list of data controller is constantly updated and is available at the registered office of Claind S.r.l.. Any other communication will be disclosed only with your prior consent.

 
6. NATURE OF UNDERWRITING AND REFUSAL
Except for what specified about navigation data, the user is free to provide personal data. Providing personal data is optional but mandatory. In the event of absent data, Claind S.r.l. may not be able to provide the services or to take advantages of the Data Controller’s services.


 7 . RIGHT TO ACCESS PERSONAL DATA AND OTHER RIGHTS
You can exercise your rights according to articles 7, 8, 9 and 10 of Legislative Decree no. 196 of 30th June 2003, by contacting the Data Controller - Claind S.r.l.  in person of its legal representative – or the Data Processor by sending an email to marketing@claind.it  or by contacting the following number +39 (0) 344 56603.
You have the right, at any time, to obtain confirmation of the existence of your data and ask for their content and origin, verify their accuracy or request their integration or updating, or correction (Article 7 of the Italian Data Protection Code). For the purposes of this Article you can ask the cancellation, the transformation into anonymous form or the arrest of the personal data processed in violation of the law, and you can object for legitimate reasons to their processing. When contacting the Data Controller you are asked to provide your email address, name, address or phone number, to enable the correcting handling of your request. In order to stop all the direct marketing communications (e-mail, sms, mms, fax), you are only asked to use our e-mail unsubscribe systems, and you will be bothered no more.

8. MODIFICATIONS TO PRIVACY POLICY
The Data Controller reserves the right to modify, update, add or remove portions of the current Privacy Policy at his discretion and at any time. We encourage you to periodically review this page for the latest information on our privacy practices. To make this review easier for you, our privacy statement will contain the date of the publication and subsequent updating on the website. The use of the website, despite of the subsequent changes, will result as a tacit approval of the privacy policy.




Updating date: 27th of July, 2016

Data Controller