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PRIVACY
OF SKITSCH S.p.A., WITH OFFICEWS AT VIALE BIANCA MARIA 25, MILAN, AND TAX CODE/VAT REGISTRATION NUMBER 05924100968.
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1. Data Controller
The Data Controller is SKITSCH S.p.A., with offices at Viale Bianca Maria 25, Milan, with Tax Code and VAT Registration no. 05924100968 (to be referred to hereinafter for short simply as the “Company”), in the person of its legal representative. The operative business premises of the Company are at Corso di Porta Nuova 14, Milan (postcode 20121).
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2. Guidelines adopted by the Company when processing data
In accordance with the provisions of Legislative Decree no. 196 of 30th June 2003 (designated, in full, as the “Personal Data Protection Code” and referred to herein, for short, merely as the “Privacy Code”), the Company intends to keep and control the personal data to be processed having regard to knowledge gained through technical progress, the nature of the data, and the specific characteristics of the processing, in order to minimize - by adopting appropriate and preventive security measures - the risk that the data is destroyed or lost, by accident or otherwise, or is subject to unauthorised access or processed in a manner not allowed or not consistent with the purposes for which it was gathered.
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3. The in-house Data Processors – Other Data Processors – Supervisor of Information System Security – Persons authorized to carry out the data processing.
3.1 The Company has appointed as Data Processor one of its own personnel, Mr. Marco Baschirotto, with an office at the operating premises of the Company, at Corso di Porta Nuova 14 (postcode 20121), Milan.
3.2 In addition, the Company draws on third parties for the processing of personal data in specific areas of activity.
Said entities, already chosen for their reliability, have also been formally appointed as Data Processors.
They are:
- ND Logistics Italia S.p.A. [Strada Barianella, 29015 – Castel San Giovanni (PC)], which carries out data processing solely with regard to merchandise-related logistical operations;
- Hen Italia S.r.l. Idee e soluzioni nel marketing [Largo Lido Duranti, 1 – 00128 Roma], which runs the Company’s Call Center: contact number 199.411.411 (calls from Italy) and +39 06 51763106 (calls from abroad);
- Web Science S.r.l., with offices at Viale Edoardo Jenner, 51, Milan, which handles the Company’s information system.
You are asked to read this section at regular intervals to check for any changes in the data processors listed above.
3.3 The appointed Supervisor for electronics systems security is Software Solutions S.r.l., with offices at Via Toscanini, 2 – 2002 Cesate (Milano), with tax code and VAT registration number 09711750159, tel. +39 02 99068228, fax +39 02 99668230, e-mail softsol@softsol.it
3.4 The data is also subsequently processed by specific persons, in given departments, authorized to carry out the data processing.
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4. Purposes of the processing.
Regarding the purposes and manner of the processing, the data shall be used for forwarding advertising material, for campaigning, promotion, and marketing activities, for performing market research, for direct sales, and for providing sales-related information. The data may be gathered and held through the creation of data banks, involving the possible use of data-processing and electronic equipment. Lastly, the data may be disclosed – solely for the above-stated purposes – to third-party partners, to forwarding agencies, to post offices, and to subsidiary and associated companies.
Additionally, the data will be used for registration on the company website and for using the respective services (such as – purely by way of example – our newsletter and similar services, the execution of orders, tracking the progress of orders, etc.).
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5. The obligatory nature – for all practical purposes – of providing the data
As to whether provision of the data is optional or otherwise, you are advised that there shall be no processing of your data where that data and the necessary consent are withheld. The effect, accordingly, is that on the one hand, each data subject is entirely free to provide their data or otherwise and/or to give their consent to the processing of their data but, on the other hand, where the data and the necessary consent are withheld processing – as already noted – is impossible.
Similarly, the effect of a refusal to reply may be that the processing is not executed or is executed incompletely.
Where consent to processing the data is not given but products are purchased at our website, the data subject concerned must, in any case, provide certain items of personal data so that their purchase order can be handled. Said data will be processed solely for the purpose of carrying out the order and by accepting the General Conditions of Contract the data subject provides their consent for this restricted purpose.
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6. Other entities, in addition to the Data Controller, to which the data could be disclosed.
Regarding the entities/persons or types of entities/persons to which the personal data may be disclosed or that may gain knowledge of it in one capacity or another, and the extent of circulation of said data, the data may (as detailed more fully above) be disclosed to third-party partners, to forwarding agencies, to post offices, and to subsidiary and associated companies. Their circulation will in any case be limited to what is necessary for the processing. It will be limited solely to what is necessary for enabling the forwarding of advertising material, for campaigning, promotion, and marketing activities, for performing market research, for direct sales, and for sales information.
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7. The rights of the data subject
As to the rights of the data subject under Article 7 of the above-stated privacy code, they comprise:
- the right to obtain a statement as to the existence or otherwise of personal data concerning them, even if not yet recorded, and release to them of that data in an intelligible form;
- the right to be informed of: the source of the personal data, the purposes and method of the processing, the logic applied in the case of processing with electronic equipment, the particulars that identify the Data Controller, the Data Processors, the Representative, the entities/persons and the types of entities/persons to which the personal data may be disclosed or that may gain a knowledge of the data in their capacity as appointed Representative in Italy, as Data Processors, or Persons authorized to carry out the data processing;
- the right to obtain: the updating, correction - or where it is in the interest of the data subject - the supplementing of the data; their cancellation, their conversion into a form that ensures anonymity, the blocking of data processed in possible breach of the law (including data that need not be held for the purposes for which the data was gathered or subsequently processed); and to obtain certification that the above operations (updating, correction, supplementing of the data, conversion into a form that ensures anonymity, or blocking), including their respective content, have been made known to those to whom the data were disclosed or disseminated, barring where such compliance is impossible or entails a use of resources that is obviously disproportionate to the right being protected;
- the right to oppose, wholly or in part and for lawful reasons, the processing of the personal data concerning the data subject, even though they are pertinent to the aim for which they were gathered;
- the right to oppose, wholly or in part, the processing of personal data concerning the data subject for the purposes of forwarding advertising material or for direct sales or for performing market research or for sales-related information.
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8. Security measures
With the aim of minimizing the risk of destroying or loosing data, whether by accident or otherwise, or of unauthorised access to the data, the Company has put in place certain minimum security measures.
With regard in particular to data processed through the use of data processing equipment, the Company has – for example – provided for a computerised authentication system and adopted procedures for the safekeeping of back-up copies and the restoration of the data.
As to processing performed without electronic equipment, the Company has, inter alia, provided for procedures that ensure the proper safekeeping of records and documents, as well as ensuring that certain records are held in restricted-access filing systems.
Self evidently, however, the Company cannot provide data subjects with a guarantee that the measures adopted to make the site secure can entirely eliminate all risk of unauthorised access or of loss of the data.
Accordingly, data subjects are advised to check that their computer has software that provides for protection for on-line data transfer.
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9. Cookies. – Links to other sites – Applicable legislation – Amendments and updates to our Privacy Policy.
9.1 A cookie is a mechanism that is transferred to the hard disk of the user and establishes contact with the website of the Company. It does not contain messages that are instantly decipherable but enables the user to be automatically matched with the personal data they have released on the site.
Our website makes use of automatic arrangements for collecting data not voluntarily released by the user, such as cookies.
Links to other website
9.2 The website of the Company may include links to other websites that may have no association with the Company.
In no sense is the latter responsible for the content of these sites or for whatever may happen if users connect to them.
9.3 This Privacy Policy is governed by Italian law and, in particular, by Legislative Decree no. 196 of 30th June 2003 referred to above (designated, in full, as the “Personal Data Protection Code” and shortened to the “Privacy Code”).
9.4 The Company may amend or update, wholly or in part, this Privacy Policy within the terms of the applicable legislation.
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10. Information.
For additional information, please contact SKITSCH S.p.A., Corso di Porta Nuova n. 14 (postcode 20121), Milan.
You are also advised to visit the website of the Regulator for personal data protection (the “Garante per la protezione dei dati personali”) at http://www.garanteprivacy.it/.