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TREATMENT OF PERSONAL DATA IN ACCORDANCE WITH LAW N. 196/2003

To whom it may concern,
We would like to inform you about the significant elements concerning the use of your personal information by GlooboVoip, a  service provided by 19003 s.r.l. also, but not only, through the www.gloobovoip.com website (hereinafter called "Website").  This Privacy Policy is designed to assist you in understanding how your private information is used when you use our service and to allow you to choose how to authorize us to use your personal data.  We remind you that in various parts of our Website, your personal data may be used  in accordance with Article 13 of the Privacy Law that that must be read and agreed to before we can provide the information requested.  By treatment of personal data we mean any activity or series of activities done in digital form or not, regarding the collection, registration, organizing, storage, consulting, processing, modifying, selecting, extracting data , comparing, using, interconnecting, blocking, communicating, diffusing, deleting and destroying data, even if not entered in a database.

Data controller: 10993 s.r.l., Via Pontaccio, 14 - 20121 Milan, Italy. Fiscal code and VAT 13212040151

Who is authorized to use your personal information: Your information will be used by individuals, selected by the Controller by appointment or responsible for its use, belonging to the administrative, accounting, legal, IT, commercial, communication categories authorized to use the traffic data depending on the objective to be reached. 
Others can be authorized to be responsible for its use, individual or legal entity , who will receive the data to be used for specific objectives (for example to supply parts of the communication service or to manage admin-accounting aspects) and the updated list of these subjects can be requested to the Controller by e-mail at info@gloobovoip.com. Your data may be given to third parties, entities or authorities, if they are requested by law or authority provisions.

Type of data used, in accordance with ex Article 3 and 11 legislative decree 196/2003:  Personal data such as first name, last name, fiscal code and other identifying information (i.e. postal addresses, e-mails, phone and fax numbers, payment data (bank information, credit card numbers; log data to enter, modify and cancel of all the above data; data on consumer habits and choices; Website navigation data; phone or online traffic data retained for six months at most to fulfill the management and invoicing of the services, and for 24 months (phone) or 12 months (Internet communication)   to comply with applicable legislation, regulatory requests and relevant orders from competent courts ( art. 132 D.Lgs. 196/2003). The type of information retained depends on the following, depending on the type of service provided:
Phone traffic data (including  unanswered calls) necessary to determine:
- origin of the call (phone number of person calling, possibly the user's registration information);
- destination of call (number or numbers called, and, with extra services like call forward or transfer, the number or numbers the call is made to);
- time reference of call (date and time call began and ended);
Internet communication 
Access to the Internet network, necessary to determine:
- origin of the call, in other words information that identifies the point of access: name and address: name and address of registered user who, at the time of the call had one or more IP protocol addresses assigned, user or phone number identification;
Telphony, fax, sms, mms sent by Internet, necessary to determine:
- source of the call: Ip address and possibly the   user's registration information); possibly the registered user's phone number and personal details;
- destination of the call: number called and, with extra services like call forward or transfer, the number or numbers the call is made to);
- date, time and length of call: date and time call began and ended;
We do not deal with sensitive information ex. art 4 D.lgs. 196/2003, therefore the contracting party does not have to provide information regarding racial and ethnic origins, religious, philosophical or other beliefs, political opinions, membership to political parties or unions, religious, philosophical, political or union associations or organizations, as well as personal information regarding health and sex life. 
During their ordinary operations, information platforms and software procedures used to make the Website function, acquire some personal information> This information is implicitly transferred when using Internet communication protocols.  
This information, by its own nature could, through processing and association with data retained by third parties, allow the users to be identified. 
This category of data (we will call "Navigation Data") includes IP addresses or domain names of the computers used by the users that log into the website, URI (Uniform Resource Identifier) addresses of the resources requested, the time of request, method used when submitting the request to the server, the size of the file received as answer, numeric code indicating the status of the answer provided by the server ( successful, error, etc.) and other parameters relative to the user's operating system and computer environment.

Purpose of collecting personal data:   Your personal data is collected and used, as permitted or necessary in condition of the contract to make use of GlooboVoIP's service , as well as necessary for GlooboVoip to provide this service, as regulated by the contract attached and accepted by the interested party, by registering and creating an account: information includes the collection, storage and processing of the information to provide operational, technical and administrative management of the relationship ( and the account created by the user) connected to the services offered  and technical and legal notices regarding the relationship established. The purposes, therefore,  include administrative and accounting activities ( management of deadlines, payments, registration information), defensive aspects if it's necessary to take into account or defend the Controller's rights  in court, even against abuses  when the service is used or for failure to pay, executive aspects about contractual obligations or in any case to answer any requests from the user. GlooboVoIP's service does not offer its customers instruments such as Mobile Payment, in other words services that allow you to pay or transfer money by phone. The information will be used to fulfill the law, civil, administrative, accounting and fiscal obligations. 
Personal information may be used also to allow Web navigation in general and the navigation of 10093 specifically. Furthermore, we declare that the purpose of collecting information include collection, storage and processing of this information for statistics in anonymous form, with no possibility to identify the user, in order to offer a more effective service.  Your personal data may be used to send you information with promotions regarding other services similar to the ones already provided in accordance to art. 130 comma 4 D.Lgs. 196/2003 it being understood that the  user has the right to request not to be contacted by Controller by  writing to info@gloobovoip.com or by mail to 10093 s.r.l., Via Pontaccio, 14 - 20121 Milan, Italy.

With the contracting party's free consent, the information may be used to send e-mails, sms, mms, faxes, answering services, phone calls with operators or paper mail to provide offers, pursuant to and by effect of artt. 23 and 130 D.lgs. 196/2003. With the contracting party's free consent, this information may be used to determine consumer preferences and habits or other parameters, such as gender, age, place of residence, etc.
Site navigation data is used to obtain statistics in an anonymous form regarding how the site is used and to check it's proper operating conditions and they are deleted immediately after being processed, unless otherwise expressly agreed to by the user. The data might be used to  assess responsibility in cases of hypothetical computer crime with regards to the Website or to third parties: save this exception: data regarding web contacts aren't permanently stored, unless there are requests or approvals on part of the contracting party/user(i.e.: access to the user's personal pages within 10093 that summarize services used, information published, etc.) .
With the contracting party and/or user's free consent, pursuant to and by effect of art. 122 D.Lgs. 196/2003, information(i.e. with cookie) might be stored in the contracting party or user's device or access to information previously stored., for behavioral advertising purposes or, in any case, not necessary to technically provide the service requested by the contracting party/user or not only for statistics on aggregate data. The following cookies are used, subject to the contracting party and/or user's prior agreement, on the www.gloobovoip.com website: 
•	Google
         - SID and HSID :  contain digitally signed and encrypted records of a user’s Google account ID and most recent sign-in time.
         - NID remembers information to allow the personalization of the adverts owned by Google, as the Google search network.
         - Pref :  provided by Google, remembers information that changes the way the site behaves or looks, such as preferred language or the region you are in. 
         - _utmz: keeps track of where the visitors come from, what search engine is used, what link is clicked, what key word was entered, the country where the user is when the website was visited.
         - _utmc: checks exactly when a visit to the website ends.
         - _utmb: checks exactly when a visitor visits a website for the first time
         - _utma: keeps track of  the number times a visitor visits the website, when the first and last visit were.
           PRIVATE POLICY GOOGLE: http://www.google.com/policies/privacy/
•	Optimizely
         - optimizelySegments: stores the visitor'segment information such as browser, campaign, source type or any other information defined in Optimizely.
         - optimizelyEngUserID: contains the end user's unique identifier used by Optimizely to track information on a per user basis.  This cookie has an expiration time of ten years to ensure that an end user will continue to be properly identified and thus prevent duplicated data even over long periods. 
         -optimizelyBuckets: stores the experiments and variations that a user has been bucketed into. Therefore, the user will continually see the same variation for every experiment on this page. This cookie also has an expiration time of ten years.
          - PRIVACY POLICY OPTIMIZELY http://www.optimizely.com/privacy

•	TradeDoubler
         - Cuvid: is typicaly written to the browser upon the first visit to the website and is updated every time the page is visited. 
         - TradeDouble: tracks links  you hit on a Tradedouble affliliates
•	GlooboVoIP
          - IdFirstPage:identifies the first page visited by the user during the web search
          - ASP.NET.SessionId: used by framework.net for it's internal operations
          - Language: identifies that last language used by the user to surf the web
          -IdUnicoUser: provides a unique identifier for the user logged in
          -GtpUserSaved: records encrypted data regarding the user's log data when "Remember" is flagged in the Login window
          -PRIVACY POLICY GLOOBOVOIP http://www.gloobovoip.com/InfoPrivacy/InfoPrivacy.aspx

For how long and how  do we use your personal information? Your personal information will be retained for as long as it is necessary to fulfill all of the purposes stated in the contract and/or to comply with applicable laws and regulatory requests.
After this period, your personal information will be deleted and destroyed. The information can be in paper form (for example a contract that has been filled in and signed) or in electronic form by using electronic methods. Electronic mail, fax, telephone with operator assistance, sms, mms, voice mails may be used.  The data is usually processed at our registered office and  at our operating office in via Pietro Calvi, 18 in Milan, Italy. GlooboVoip transfers your data out of the EC only when the phone is transferred out of the EC territory. If you give your consent to the use of advertising cookies, we here remind you that the servers that  manage the Optimizely cookies all operate out of the EC, therefore we suggest you check their privacy policies links that can be found  under Purpose.
The use of the above mentioned persistent and session cookies (temporary cookies, or unique identifiers associated with your browser for the duration of your visit to our website. Once you close your browser, the session cookie ID will disappear and information about your visit is not retained.) is exclusively to recognize you when you sign in and understand how you arrived at our website, so we can make sure that we provide you with relevant customer content and information. The use of the above mentioned persistent and session cookies used in our website http://www.glooobovoip.com/ protect you against fraud and phishing.

Obligatoriness and consequences of lack of data submission: If the minimum data necessary is not submitted, we cannot guarantee we will be able to provide our service. The Controller that provides electronic communication service collects traffic data as per  law (art. 132 D.Lgs. 196/2003).  If you opt-out from receiving advertising or any Internet based activity that doesn't impede our functionality to provide our service or otherwise requested  by the user/contracting party, we will still provide you with our service.

Rights: Subjects have the right to request the confirmation of the existence of the information supplied and to know the content and origin, verify the exactness or ask to add , update or rectify it at all times (article 7 of the Codice that regulates the protection of private information).  Pursuant to this article, the user can request that any data being illegally used be deleted, changed into an anonymous form or blocked; as well as object in any case, for legitimate reasons, they be used. For example, you can choose not to receive any promotional  information and /or also select how to receive it (i.e. e-mail, sms, mms, fax, voice mail, operator, paper mail). Your requests may be sent to: info@gloobovoip.com or, by post, to 10993 s.r.l., Via Pontaccio, 14 - 20121 Milan, Italy.

The contracting party has taken note and agreed to art. 13 D.Lgs. 196/2003 in conformity with the above-mentioned terms and conditions.

PROMOTIONAL OFFERS (optional). Consent pursuant to and in accordance with art. 130 D.Lgs. 196/2003 - The person concerned , having taken note of the above-mentioned terms and conditions, agrees to receive promotional material and personalizzed offers by e-mail and sms from 10993. It si possible to opt-out at any moment.

CUSTOM OFFERS (optional). Consent in accordance with art. 23 D.Lgs. 196/2003 regarding profiling - The person concerned, having taken note of the above-mentioned terms and conditions, agrees to profiling activities regarding use preferences of the service.