14 Via Pontaccio, 20121 Milan, Italy
Tax code and VAT number: IT13212040151
INFORMATION TO DATA SUBJECTS
(Privacy Law - Italian Legislative Decree N° 196, 30 June 2003)
10993 s.r.l. (hereinafter 10993) hereby undertakes to protect the personal data of its users online constantly.
In the various sections of the 10993 websites (hereinafter “site”) where we collect personal data, specific information to data subjects is provided pursuant to section 13 of the Italian Privacy Law, which you must read before providing the data required.
The information and data you provide or which we otherwise collect during registration to the various 10993 services will be processed in compliance with the provisions laid down in the Italian Privacy Law, Recommendation N° 2 of the European Data Protection Authorities Group of 17 May 2001, and the obligations of confidentiality which are intrinsic to 10993's business. The whole text of the Italian Privacy Law may be read on the Italian data protection authority website
Personal data processing is taken to mean any operation or series of operations performed, even without the help of electronic instruments, concerning the collection, recording, organization, retention, consultation, processing, editing, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion and destruction of data, even if not held in a database.
The personal data processed may consist of various elements which also depend on the way you decide to use the service, including text, photographs, videos, audio data, telephone numbers or any other type of information which identifies users or makes them identifiable according to the type of services requested.
As established in the provisions laid down in the Italian Privacy Law, 10993 shall process this data according to principles of fair play, lawfulness, frankness and protection of your confidentiality and rights.
Purpose of the processing.
We intend to process data in order to provide the services users request when they register and create an account. This processing includes collecting, retaining and processing data in order to establish business relations and subsequently manage them (along with the account created by the user) from an operative, technical and administrative point of view. This is done in order to provide our services and issue communications relating to developments in the relations established.
The data will also be processed in order to comply with legal, accounting and tax obligations.
Personal data may also be processed in order to allow navigation and consultation of 10993 websites.
Furthermore your personal data may also be collected, retained and processed for statistical analyses in anonymous and/or aggregate form, without the user being identifiable, so that we may check the quality of the services offered.
Lastly, the data may be processed – only if users give their consent – for marketing, advertising and promotional purposes in a broad sense to provide information and/or put together offers on products, services or initiatives offered or promoted by 10993, companies belonging to the 10993 Group and/or subsidiaries and associated companies, as well as commercial partners and outsourcers. This however does not entail any personal data being transferred to Third Parties.
Your personal data will mainly be processed using electronic instruments or automated means.
Communication and dissemination of non-sensitive personal data.
Your non-sensitive personal data may be communicated to:
1. people, companies or professional offices that provide assistance and advice to 10993 regarding the services supplied on the subjects of accountancy, administration, laws, taxes and finance;
2. subjects, entities and authorities to whom communication of your personal data is mandatory by law or in accordance with orders from the authorities;
3. subjects delegated and/or appointed by 10993 to perform business strictly related to providing the services and technical maintenance (including maintenance of network equipment and electronic communication networks);
4. commercial partners only if you have given your consent to your personal data being processed for advertising purposes;
5. commercial partners who offer services in cooperation with 10993 that you have requested and with regard to which 10993 is a simple content provider, in their capacity as independent data controllers for the relevant personal data.
In this case, any communications from 10993 to its partners are exclusively aimed at and necessary merely for technical management and customer care as part of an independent service relationship which the customer has with the partner that provides that service.
Furthermore, the subjects or categories of subjects to which your data may be communicated or to whom they may become known in their capacity as data supervisors (if appointed) or persons in charge of processing are:
companies in the 10993 Group, in Italy or abroad, 10993 Group staff in charge of service administration or technical management, and managers of the information technology platform through which the services are provided.
With reference to the scope of dissemination of your personal data, we hereby inform you that the personal data needed to activate the services will not be disseminated.
It is understood that, if you decide to use the services to disseminate particular information that regards you knowingly on the Internet (e.g. to publish photos and videos), this dissemination cannot be considered dissemination by the data controller.
Optional or mandatory consent.
As regards everything concerning service activation(registration, technical account maintenance, etc.) all personal data provided are optional, but any failure to provide these data would make it impossible to activate the services requested.
Consent to data processing for the following purposes is also completely optional and not mandatory: market and statistical research and studies;
sending advertising material and information;
performing direct sales or product or service placement;
sending sales information; performing interactive commercial communications, also pursuant to section 58 of Italian Legislative Decree 206/2005, in which the supplier uses the telephone, email, automated calling systems without operator, or fax.
Consent to receive unsolicited commercial communications pursuant to section 9 of Italian legislative decree N° 70 of 9 April 2003, which implements the so-called Directive on Electronic Commerce 2000/31/EEC is also optional. The law states that unsolicited commercial communications must immediately and unequivocally be identified as such and indicate that the recipient can object to receiving such communications in the future.
If you decide not to give your separate consent to processing for the commercial purposes specified here above when requested in particular site sections, this refusal will not have consequences of any kind.
If you give the optional consent described above, you may take part in competitions and prize draws that may be organized by 10993 or by its commercial partners for promotional purposes.
Processing of sensitive data.
When using the services for which you have asked to be registered (for example the options to publish photos, videos or audio data), the personal data which needs processing may be considered "sensitive" as defined in section 4, subsections 1 and 26 of the Italian Privacy Law. In particular such data may allow identification of racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of political parties, trade unions, associations or organizations of a religious, philosophical, political or trade-union nature, state of health and sex life.
We invite you not to publish sensitive data unless strictly necessary and if you choose not to use services which may entail such processing.
In any case, besides the hypothetical exception referred to in section 26, subsection 4 of the Italian Privacy Law, such data may only be processed with the written or equivalent consent of the person concerned. “Equivalent consent” also includes showing willfulness online through procedures such as clicking web page buttons marked “Accept”, “Send”, etc or selecting boxes next to the word “Accept”, etc. Such data shall furthermore only be processed in compliance with the general authorizations granted by the Italian Data Protection Authority to process sensitive data and upon authorization from the Italian Data Protection Authority, which may authorize particular categories of processing in general beforehand without prejudice to the written consent of the person concerned.
By virtue of the above, remember that if you do not give specific consent to process your sensitive data (which in any case obviously allows you to register) and you intend to use services which may entail this type of processing in the future, you will have to alter your registration data and give this consent.
If you do not give consent to sensitive data processing for any reason and later use services for which this processing is in any case required (for example if you publish photos which provide sensitive information), we hereby inform you that no group company may be held liable for any reason, nor may it receive any intimations whatsoever, since such publication of sensitive data (including dissemination over the Internet) occurs during your exclusive independent management of the webspace you are provided with by the group company when you register and use the services.
As stated above, it is important for you to alter the registration data already provided and give specific consent to processing sensitive data if you should decide to use services which necessarily entail the use of such information.
Sensitive data - especially information which may reveal sexual tastes and habits – will not be communicated or disseminated by Group companies unless they are obliged to do so by law.
It is understood that if you decide to use the services to communicate or disseminate your sensitive data knowingly on the Internet, this does not constitute communication or dissemination by Group companies, since these operations are independently performed by you when managing the webspace reserved to you or in any case during your normal use of the services.
Processing of third-party personal data provided by you.
When using the services for which you have asked to be registered (for example the options to publish photos, videos or audio data), it may be necessary to process third-party personal data (even sensitive data) which you have published or sent to the administrator and service.
In this case, you act as an independent data controller, and assume all the consequent legal obligations and liabilities.
You shall accordingly exonerate the 10993 group company data controller entirely from all intimations, demands, requests for compensation for damages from the processing, etc. which it may receive from third parties whose personal data has been published through the use of the services in violation of the applicable laws regarding the protection of personal data.
In any case, if you provide or process in any other way third-party personal data when using the service, you guarantee in advance that this particular processing is based on you having acquired the consent of the third party to process the information which regards them and consequently assume all connected liability.
The computer systems and software procedures which manage the operation of the 10993 site acquire certain personal data during their normal operation whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to identify the users concerned, but owing to its nature it could allow users to be identified through processing and association with data held by third parties.
This data category includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time at which the request is made, the method used to make the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and user's computing environment.
These data are only used to obtain anonymous statistical information regarding the use of the site and to make sure the site is operating correctly. Consequently they are deleted immediately after processing.
These data could be used to ascertain liability in the event of any computer crimes committed against the site or third parties.
With the exception of this, at present the web contact data is not retained permanently, unless the user requests so (e.g. the user's personal pages on the 10993 site which summarize the services used, the information published, etc).
Pursuant to section 122 of the Italian Privacy Law, we hereby inform you that it is necessary to send non-persistent cookies so that certain parts of the service that depend on identifying the path the user takes through the various site pages work.
The following information is recorded regardless of the presence of cookies:
type of browser (e.g. Internet Explorer, Netscape, etc.), operating system (e.g. Windows, Macintosh, etc.), the host and URL the visitor arrives from, and the data on the page requested.
These data may be used in an anonymous aggregate form for statistical analysis of site use.
Lastly, the use of so-called session cookies (which are not permanently stored on the user's system and deleted when the browser is closed) is strictly limited to the transmission of the session identification number (a random number generated by the server) needed to allow safe and efficient site navigation.
You can always disable cookies by simply configuring the browser you use.
Personal data processing by 10993 partners – data controllership and data supervisors
In the case of services and content provided directly by 10993, 10993 acts as data controller for the relevant data.
The details of the data controller mentioned above are as follows:
10993 s.r.l. with registered offices in 14 Via Pontaccio, 20121 Milan, Italy
An updated list of data supervisors (if appointed) is available on request from 10993 s.r.l., 14 Via Pontaccio, 20121 Milan, Italy
You may reach the data supervisors pursuant to section 29 of the Italian Privacy Law at any time to exercise the rights laid down in section 7 of that law by contacting the data controller's offices (10993).
PROMOTIONAL OPERATIONS: Lastly, we hereby inform you that the processing described in this section must be considered separately from the processing for advertising and marketing purposes, which is based on explicit prior consent from the person concerned acquired each time by the data controller considered, whether it be 10993 or its commercial partners/third parties. This is because the services mentioned here are covered by service contracts between independent commercial partner/third party data controllers and their customers.
The cases of communication of customers' personal data between 10993 and commercial partners for advertising or marketing purposes in a broad sense do not therefore fall within this category.
Data retention and security measures.
Data shall be retained on 10993 servers located in specific dedicated parts of the 10993 offices for the time laid down in the applicable laws.
In any case, data will only be retained for as long as it is needed to pursue the purposes described above. This time is equal to the duration of the service contract between you and the data controller.
If you delete your account and cease to use the services, your data will be deleted, unless it is needed for contract, administrative, tax, accounting or legal requirements after you cease to use the services.
As soon as the above mentioned requirements cease, your data will in any case be deleted.
We likewise inform you that these data will be collected, processed and stored in full compliance with the provisions in sections 31 et sequitur of the Italian Privacy Law and the technical specifications for security measures (Annexe B to the Law).
The data will also be processed in full compliance with the self-regulatory code on the subject of personal data processing laid down in the sector codes of ethics in force.
Section 7 (Right to Access Personal Data and Other Rights)
You may contact the data controller or data supervisors at any time, without any mandatory formalities or using the specific form provided by the Italian personal data protection authority (available free of charge from www.garanteprivacy.it), to exercise your rights as laid down in section 7 of the Italian Privacy Law, which we quote in its entirety here below:
Section 7 of Italian legislative decree N° 196 of 30 June 2003
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain:
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
The Italian version of this information to data subjects is binding; any translations in other languages are provided purely for your convenience.
For any information and to exercise the rights referred to in section 7 of Italian legislative decree 196/2003 shown above, you may write to:
14 Via Pontaccio, 20121 Milan, Italy
The person concerned may also send their request by email to