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Privacy Policy– Information concerning the processing of personal data provided under Legislative Decree no. 196/2003, Section 13.
Pursuant to Legislative Decree No. 196 adopted on 30th June 2003 (“Data protection Law”) and subsequent amendments, we hereby supply you all due information about the processing of your personal data provided during your browsing activity on this website. This privacy statement applies exclusively to this website. Such statement does not apply to the other websites that the user may consult via links on the websites under the Data Controller’s domain name. Valtur S.p.A. (Sole-Shareholder Company) shall not be held liable under any circumstances for third parties’ websites. Such information has been provided according to L. Decree 196/2003, Section 13 as well as pursuant to the Recommendation 2/2001 on certain minimum requirements for collecting personal data on-line in the European Union, adopted on 17 May 2001 by the Working Party 29, the independent EU Advisory Body on Data Protection and Privacy that has been established by Directive 95/46/EC, Section 29. Namely, this Recommendation states what are that information that Data Controller shall supply to the User while visiting the website.

1. DATA CONTROLLER, under Legislative Decree no. 196/2003, Section 28, is Valtur S.p.A. (Sole-Shareholder Company) with its registered office in Milan (MI), at Via Conservatorio 15, 20122 duly represented by its authorized person. DATA PROCESSOR, under Section 29 of the aforementioned law is inter alia Valtur S.p.A.’s Group General Counsel.

2. CATEGORIES OF PROCESSED DATA
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, e-mail phone number.
Data provided on a discretionary basis means those voluntary data provided by filling the data collection form.
Personal data of children. Children may not give their personal data. Data Controller may not be held liable in case of any false statements made by children. Anyway, Data Controller will immediately erase such statements, if proven to be false, and consequently the relevant personal data together with any material acquired in accordance with L. Decree 196/2003, Sections 7, 8, 9 e 10.
Third-Party data. If you supply us with personal data belonging to third parties (relatives and interested parties in general), please be sure that those third parties have been correctly informed and consented to the processing of their personal data, if required in compliance with this policy statement.
Cookies
Please refer to the cookie policy at the following link

PURPOSES OF DATA PROCESSING WITH SPECIFIC CONSENT WHEN NEEDED (pursuant to D.LGS. 196/03, Section 23)
Data Controller processes your voluntarily provided data for the following purposes, unless you object to such processing:
A) – direct marketing: Data Controller may send you advertising materials, direct sale materials, market surveys and commercial information through electronic means, such as e-mail, SMS (Short Message Service), instant messages and the like as well as through mails.
In order to compare the marketing communication results and improve them, Data Controller may use automated means to send newsletters and advertising communications with a related report. Through these reports, Data Controller may access to any information such as: readership, information on a lead’s behaviour, the number of openings, clickers, and clicks; through which operating system and device the user reads marketing communication; any further details about the emails effectively sent, those that have been received or not received and the forwarded emails. Data Controller processes such data aiming at comparing the marketing communication results and potentially improve them.

4. MEANS OF DATA PROCESSING – DATA RETENTION
Personal data will be processed by electronic, automated and/or manual instruments through means and tools that may ensure the utmost security and confidentiality, by authorized persons in compliance with those requirements provided by D. Lgs. 196/03, Section 31 and subsequent. Your personal data will be kept for a period not exceeding the purposes for which the data have been collected and subsequently processed.

5. COMMUNICATION AND DATA DISCLOSURE
Your processed data will be kept confidential and will not be communicated or disclosed to any other person or legal entity except those companies contractually bound to Valtur S.p.A. (Sole-Shareholder Company), based in EU countries in compliance with and within the limits set out by L. Decree n. 196/2003, Section 42. Such data may be transferred to extra-EU countries in compliance with and within the limits set forth in L. Decree n. 196/2003, Sections 43 and 44 lett. b) aimed at the fulfillment of any contractual obligations and/or related purposes. Your data will be disclosed to third parties belonging to the following categories: – third-party companies providing IT and network services to Valtur S.p.A. (Sole-Shareholder Company), including e-mail services; – any third-party consultants; – any competent authorities as prescribed by the applicable law, as recognized/enforced by any decisions or upon request. Such third parties are appointed Data Processor themselves otherwise they may operate as independent Data Controller. Appointed Data Processors are enlisted in a document that is constantly updated and available at Valtur S.p.A. (Sole-Shareholder Company), based in Milan at Via Conservatorio 15, 20122.

6. NATURE OF THE CONSENT- REFUSAL
You may provide your personal data on an optional and discretionary basis although it may be necessary to receive any direct marketing information. However, failure to provide such data may affect your ability to receive such information.

7. DATA SUBJECT RIGHTS
You may freely exercise your rights at any time under Legislative Decree no. 196/2003, Sections 7, 8, 9 and 10 by contacting the Data Controller or Data Processor, at the following phone number 02 30099811, or by sending an e-mail privacy@valtur.it. You have the right, at any time, to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to personal data, verify their accuracy or request their rectification or erasure (please refer to D. Lgs. 196/2003, Section 7). For the purposes of such applicable law, you may demand the restriction of processing of personal data concerning the data subject, their pseudonymization or to object to such processing.
If you do not wish to receive anymore advertising and commercial direct marketing communications through e-mail, SMS, chat messages, you may unsubscribe, at anytime, by sending an e-mail to privacy@valtur.it with sub. “unsubscribe from automated direct marketing communications” or by clicking the link unsubscribe form newsletter, so that you will not be bothered anymore. If you do not wish to receive anymore marketing mails you may send an e-mail to privacy@valtur.it with sub. “unsubscribe from manual direct marketing communication” so that you will not be bothered anymore. If you do not wish to receive anymore communications at all you may send an e-mail to privacy@valtur.it with sub. “unsubscribe from marketing” at any time so that so that you will not receive any kind of advertising materials, direct sale materials, market surveys and commercial information.

8. AMENDMENTS
Data Controller reserves the right to amend, update, add or remove any part of the current privacy statement at his own discretion and at any time. Please refer to this privacy statement regularly to review the updated version. In order to make this review easier for you, our privacy statement will outline the last update. Your use of the website signifies and constitutes your assent to and acceptance of the revised privacy statement.

9. SOCIAL LOGIN
Social Login is a form of single sign-on using existing information from a social networking service to sign into a third party website by sharing basic social account information. For example, User may use social login to rapidly sign into a third-party website or to take part in a competition or to buy on-line. In short, with prior user’s consent, the social network will share user’s personal data needed to login into a third-party website, without filling the registration form.
For any further information according to L. Decree 196/2003, Section 13, please refer to Third-Party policies hereinbelow mentioned where you can find a link to the policies and, if provided, give you the option to either provide or refuse your consent:
Facebook social login: https://developers.facebook.com/docs/plugins
Twitter social login: https://support.twitter.com/articles/20170519#
Google account login: https://www.google.com/policies/privacy/

Last update: 20.02.2017

Data Controller Valtur S.p.A. (Sole-Shareholder Company).

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