NEWSLETTER REGISTRATION POLICY

ON THE PROTECTION OF PERSONAL DATA 
 
PURSUANT TO ART. 13 OF LGS. D. NO. 19 OF 30.06.2003
 
In compliance with the provisions of art. 13 of Lgs.D. of 30 June 2003, Altaeco S.p.a., with registered office in Via Giovanni Pascoli 4/6, 20010 Vittuone, Milan (MI), as data controller, hereby informs the data subjects about the processing purposes and methods of the personal data collected, its scope of disclosure and dissemination, as well as the nature of its provision.
  
PURPOSE
 
The personal, identification and IT data collected from data subjects, subject to processing, is used to directly fulfil the request to send the newsletter and related entry in the mailing list concerning the sending of information messages and commercial and promotional communications relating to the activities carried out by the Data Controller, in full compliance with the principles of legality and correctness and with the provisions of law. 
 
PROCESSING METHODS
 
Data is processed using paper, IT and electronic means by specially assigned in-house individuals. The data is stored in IT and electronic, and marginally paper, files, with full assurance of the implementation of the minimum security measures required by law. 
 
DISCLOSURE AND DISSEMINATION
 
The data collected will not be disclosed or disseminated. Disclosure, other than to the Data Controller, Data Processors, both internal and external to the corporate structure, and persons in charge of processing identified and appointed pursuant to articles 29 and 30 of Lgs.D. no. 196/2003, as amended and supplemented, is envisaged, where necessary for the above purposes, to third parties (such as IT Supply and Support companies, Sales Managers and Agents for Brands under ALTAECO Group ownership, Marketing and Telemarketing companies) engaged in the proper and due pursuit of the described purposes. In all cases data processing by third parties must be performed lawfully and in compliance with the laws currently in force.   
 
RIGHTS OF THE DATA SUBJECT
 
The Data Subject may exercise his/her rights as provided for by articles 7, 8, 9 and 10 of Lgs. D. no. 196 of 30 June 2003 by contacting the Data Controller. In particular, according to art. 7, the data subject has the right to obtain confirmation of the existence or otherwise of personal data related to him/her, including data that has not yet been recorded and to obtain that data in a clearly understandable form. The data subject has the right to obtain information regarding: a) the source of any personal data; b) the purposes and methods of processing; c) the logic applied in the event of electronic processing; d) identification details relating to the Data Controller, the data processors and the representative designated in compliance with article 5, paragraph 2; e) the subjects and categories of subjects to whom the personal data may be communicated or who may become acquainted with said data, in their capacity as data processors, persons in charge of data processing and appointed representatives in Italy. The data subject has the right to obtain: a) that said data is updated, amended and, if in the interest of the data subject, completed; b) that any data processed in violation of the law be cancelled, made anonymous or blocked, including any information that does not need to be held for the purposes for which it was collected or subsequently processed; c) receive confirmation that the operations in a) and b) have been made known, also as regards their content, to the parties to whom the data has been communicated or disclosed, except in cases where this is impossible or requires the use of means that are clearly disproportionate with the protected right. The data subject has the right to object, either in full or in part a), for legitimate reasons, to the processing of personal data relating to him/her even if relevant to the purposes it was collected for; b) to the processing of personal data relating to him/her for the purposes of delivering advertising material, direct sales, market surveys or for marketing communications.
 
DATA CONTROLLER 
 
The Data Controller is Altaeco S.p.A., with registered office in Via G. Pascoli 4/6, 20010 Vittuone, Milan (MI).
An updated list of data processors, appointed by the Data Controller pursuant to art. 29 of Lgs. D. 196/2003, is available at the registered office of the Data Controller.
For any communication regarding articles 7 et seq of Lgs.D. no. 196/2003, as amended and supplemented, the Data Controller has provided the e-mail address privacy@altaeco.com
 
RETENTION TIMES
 
The data is kept until any request of the data subject objecting to sending and intention of the latter to renounce receiving the newsletter, and in any case no later than two years from the recording of such personal data. 
 
NATURE OF PROVISION
 
The provision of data is optional; however, any refusal to reply will make it impossible for the data controller to fulfil requests for sending the newsletter. 
 
CONSENT
 
Pursuant to art. 23 of Lgs.D. 196/2003, consent to the processing of such data is necessary since it is collected outside previous contractual agreements and those for sending newsletters regarding commercial and promotional communications.  
It is pointed out that consent is considered freely granted by checking the "I consent" box. Otherwise, it will not be possible to proceed with subscription to the newsletter service.
 
Provision of consent
 
In relation to the policy provided, and specifically with reference to the processing purposes concerning sending of the newsletter regarding information messages and commercial and promotional communications
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