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INFORMATION ON THE PROCESSING OF PERSONAL DATA EX ART. 13 D.LGS. 196/2003 AND CONSENTS EX ARTICLES. 23, 122, 130 D.LGS. 196/2003

Dear interested party, we would like to inform you about the relevant elements concerning the processing of your personal data within the GlooboBusiness services provided by 10993 s.r.l. also, but not only, through the site www.gloobobusiness.com (hereinafter also referred to as "Site"). This document will allow you to know our privacy policy in order to understand how your personal information is handled when you use our services and to allow you to consent to the processing of your data expressed and aware. We remind you that in the various sections of the Site where we collect your data, specific information may be published pursuant to art. 13 of the Privacy Code for you to read before providing the requested data. By data processing we mean any operation or set of operations, carried out even without the use of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database.

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

Subjects who may process personal data: The processing will be carried out by natural persons, designated by the Owner as persons in charge or possibly responsible for the processing, belonging to the categories of administrative, accounting, legal, IT technicians, commercial, communicators, persons in charge of the processing of traffic data according to the purposes pursued.
Other data processors, natural or legal persons, to whom your data would be transmitted for specific purposes (e.g. to provide parts of the communication service or to manage administrative-accounting aspects) may be designated and the updated list of such persons may also be requested from the Data Controller by email at info@gloobobusiness.com. Your data may also be transmitted to other subjects, entities or authorities, if the communication of your personal data is obligatory under the provisions of the law or orders of the authorities.

Types of data processed, in compliance with the principles ex art. 3 and 11 D.Lgs. 196/2003: Personal data such as name and surname, tax code and other identification data (eg. gender, date and place of birth); address and contact data (such as physical addresses, e-mail, telephone or fax numbers); payment data (bank details, credit card numbers); log data relating to the events of insertion, modification, cancellation of all the above mentioned data; data on consumption habits and choices; data on navigation choices on the Site; telephone and telematic traffic data stored for a maximum of six months for the purposes of managing and billing services, and for 24 months (telephone) or 12 months (telematic) for the exclusive purpose of ascertaining and prosecuting crimes in compliance with art. 132 Legislative Decree 196/2003. The types of traffic data that may be processed are as follows, depending on the service provided to the contractor:
Telephone traffic data (including those relating to unanswered calls) necessary to identify:
the origin of the communication (calling telephone number, possible name of the registered user);
the destination of the communication (the telephone number or numbers called and, in the case of additional services such as call forwarding or call transfer, the number or numbers to which the call is forwarded);
the time reference of the communication (date and time of beginning and end of the communication);

Telematic traffic data
Internet access, data necessary to identify:
* the origin of the communication, i.e. the identification information of the access point: name and address of the registered user to whom, at the time of communication, one or more IP protocol addresses, a user identifier or a telephone number were assigned;
Telephony, sending faxes, sms and mms via Internet, data necessary to identify:
* the source of the communication: IP address and any registered user identification; any telephone number and personal data of the registered user;
* the destination of the communication: number called and, in the case of additional services such as call forwarding or transfer, the number or numbers to which the call is transmitted;
* the date, time and duration of the communication: date and time of beginning and end of the communication;
Sensitive data are not processed pursuant to art. 4 of Legislative Decree no. 196/2003, the contracting party is therefore required not to provide data revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade union nature, as well as personal data disclosing health and sex life.
The computer systems and software procedures used to operate the Site also acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This is information that by its very nature could, through processing and association with data held by third parties, allow users to be identified.
This category of data (which we call "Browsing Data") includes IP addresses or domain names of the computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit 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 (successful, error, etc..) and other parameters relating to the operating system and computer environment of the user.

Purpose of processing: The processing of personal data is that necessary to manage the contractual relationship connected to the use of GlooboBusiness services, requested by the contracting party concerned, as well as that essential to perform the services themselves, as regulated by the attached contract and accepted by the contracting party concerned, with the registration and creation of his account: this includes the collection, storage and processing of data for the purposes of establishing and subsequent operational, technical and administrative management of the relationship (and of the account created by the user) connected to the provision of services and the performance of technical and legal communications relating to the performance of the relationship established. The purposes therefore include aspects of an administrative-accounting nature (management of deadlines, payments, membership data), defensive aspects where it is necessary to assert or defend in court a right of the Data Controller also against abuse of use of the services or non-payment, executive aspects of contractual obligations or in any case in response to requests by the data subject. GlooboBusiness services do not include Mobile Payment tools for its users, i.e. services that allow to make payments or money transfers by phone.
Data will also be processed to fulfil legal, civil, administrative, accounting and fiscal obligations.
Personal data may also be processed for the purpose of allowing navigation and consultation of 10993's websites. In addition, we specify that the purposes of processing also concern the collection, storage and processing of your data to perform statistical analysis in anonymous form, without the possibility of identifying the user, aimed at verifying the quality of services offered.
The data of the contracting party concerned may be processed for the sending of promotional emails relating to services similar to those subject to the sale of this service, pursuant to Article 130, paragraph 4 of Legislative Decree 196/2003, it being understood that the contracting party concerned has the right to object to the receipt of such communications immediately by contacting the Data Controller at: info@gloobobusiness.com or by post, at 10993 s.r.l., Via Pontaccio, 14 - 20121 Milan.
With the free consent of the contracting party concerned, the data may be processed for the sending of emails, sms, mms, faxes, self-responders, telephone calls with operator or paper mail with promotional content, pursuant to and for the purposes of Articles 23 and 130 of Legislative Decree no. 196/2003. With the free consent of the interested party, commercial profiling relating to consumer preferences and habits or other parameters, such as gender, age, territory of residence, etc., may be carried out.
The Navigation Data are used in order to obtain anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing, unless there is express consent from the contracting party/user concerned. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: apart from this possibility, data on web contacts are not currently permanently stored, unless requested or consented to by the contractor/user (e.g. access to the user's personal pages within 10993 that summarise the services used, the information published, etc.).
With the free consent of the contractor and/or user, pursuant to and for the purposes of article 122 D.Lgs. 196/2003, information may be stored (e.g. via cookies) in the terminal equipment of the contractor or user or access to information already stored, for purposes of behavioural advertising or otherwise not necessary to technically perform the service requested by the contractor or user or not merely statistics on aggregate data. The following cookies are used, subject to the consent of the Provider and/or the user, on the website www.gloobobusiness.com:

Google
* SID and HSID: contain digitally signed and encrypted records for a user's Google account ID and most recent access date. 
* NID: stores information to help personalise ads in Google properties, such as the Google search network.
* Pref: This cookie issued by Google allows you to store information that changes the behavior or appearance of the sites themselves, such as your preferred language or geographical area.
* __utmz: Keep track of where visitors come from, what search engine they used, what link they clicked on, what keyword they used, and the country they are in when they visit the website.
* utmc: Record the exact moment when a visitor leaves the website.
* _utmb: Records the exact moment when a visitor first accesses the website.
* _utma: Keeps track of the number of visits made by a visitor, when his first visit occurred and when his last visit took place. PRIVACY POLICY GOOGLE: http://www.google.com/policies/privacy/                                                                            
Optimizely     
* optimizelySegments: Keeps track of user information such as browser, campaign, traffic source and any other data defined in Optimizely. 
* optimizelyEngUserId: Contains a unique end-user identifier, used by Optimizely to track information by user. This cookie has a lifetime of 10 years to ensure that the user is properly identified and thus prevent duplication of data over the long term.
* OptimizelyBuckets: Records experiments and web page variations. With this cookie a user will always see the same page variation. This cookie also has a duration of 10 years. 
PRIVACY POLICY OPTIMIZELY https://www.optimizely.com/privacy                                                                         
Times, methods and means used for processing: The processing of personal data will last the time strictly necessary for the execution of the contractual relationship and/or the other purposes indicated above and for compliance with legal or regulatory obligations. At the end of the treatment the data no longer necessary will be deleted and destroyed. The processing may take place either in paper format (for example with reference to the contractual form if filled in and signed on paper) or in electronic format and with the use of telematic tools. E-mail, fax, telephone with operator, sms, mms, automatic answering machines could be used. The data are normally processed at the offices of the Data Controller indicated above and at the operational headquarters in Via Pietro Calvi 18 in Milan. Your data are not normally transferred outside the European Union, except to carry out an explicit request to route a telephone call outside the European Union. If you accept the processing of data through advertising cookies, in this case we remind you that the servers that manage Optimizely's cookies are located outside the European Union, for this reason we invite you to consult the respective privacy policies as indicated in the paragraph on Purposes.
The use of so-called technical or session cookies (which are not permanently stored on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site. The so-called technical or session cookies that may be used on the site http://www.gloobobusiness.com/ avoid the use of other IT techniques that could potentially compromise the confidentiality of the user's navigation and do not allow the acquisition of the user's personal identification data. 
Obligations and consequences in case of failure to provide data: If data strictly necessary for the performance of the contracted services are not provided, it may be impossible to provide the services in question. Traffic data are collected by the Data Controller, provider of electronic communication services for express legal obligation (art. 132 D.Lgs. 196/2003). Failure to consent to the processing of data for promotional purposes or in any case not strictly necessary for the performance of the services contracted or requested by the user/contractor has no effect on the provision of such services.

Rights of the data subject: The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or non-existence of such data and to know the content and origin, verify its accuracy or request its integration or updating, or correction (Article 7 of the Code on the protection of personal data). Pursuant to the same article, the data subject has the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and to oppose in any case, for legitimate reasons, their processing. For example, you may oppose the receipt of messages of a promotional nature, also by selecting which means to accept and which not (e.g. email, sms, mms, fax, autoresponders, telephone with operator, paper mail). Requests should be sent by e-mail to: info@gloobobusiness.com or by post to 10993 s.r.l., Via Pontaccio, 14 20121 Milan.

I acknowledge and declare that I have understood the information on the processing of personal data pursuant to art. 13 Dl.Lgs 196/2003, in the terms set out above.

GlooboBusiness instructions for use (optional). Having taken note of what specified in the above information, I agree to receive from 10993 srl communications by e-mail and sms, being able to oppose at any time to receive messages of this type.

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