| On personal data protection matters, the Italian Civil Code (hereafter called “the Code”), after adopting the legislative decree no. 196 dd. 30th June 2003, imposes to the subjects that define themselves as “holders” of the personal data, according to art. no. 4 of the above mentioned law, to supply all the concerned people with precise information regarding possible use of their personal data. Cyber Trade Srl, as holder of personal data, intends therefore to thoroughly specify the information requested as far as the personal data use is concerned (hereafter called “the Data”). The Data gathered by Cyber Trade Srl, both directly from the concerned person or through third persons or otherwise acquired in the framework of the activities carried out by the companies belonging to the network connected to Cyber Trade Srl, might become subject to use in compliance with above mentioned norm and of confidentiality obligations. 1. PURPOSES OF PERSONAL DATA USE The Data shall be used by Cyber Trade Srl, using computer and/or paper supports, for following purposes: a) gathering of preliminary information or of information following up the conclusion of a contract, including the evaluation of economic-financial risks connected or of the existing legal, non-patrimonial relationships; the execution of the obligations deriving from the contract; the correct management of the contract with relevant obligations; administrative and accounting management; correspondence management also via fax or e-mail; activities that are tightly connected and necessary to fulfill mutual obligations; b) fulfillment of obligations ruled by laws, regulations, EC norms or fulfillment of administrative practices. c) functional purposes for Cyber Trade Srl activity, such as satisfaction surveys among customers on service quality, carried out through personal or telephone interviews; questionnaires; studies or market researches; information, statistical or scientific activities; marketing; promotion and sale of products and services offered by Cyber Trade Srl, also quoting by name the person concerned for advertisement purposes; public relation activities carried out with various means and modes. The agreement for the use of Data for the purposes listed under point c) is optional and denying it does not imply any kind of consequence. However the refusal could affect the concerned person as not to be able to keep updated on events of various kind, new service or product presentations, etc., nor to receive publications or other information material that could be of interest for the person. The Data are accessible only to those people who, within Cyber Trade Srl, have the need to because of their activities and tasks such as, as an example, even though this does not cover all possibilities, staff in charge of external relations, of customer care, of market monitoring; accounting staff; secretaries; directors and managers. Those persons, whose number shall be kept to the minimum possible, use the personal data as "Data processors", they are appointed to this purpose and are appropriately instructed as to avoid losses, destruction, unauthorized access or data uses not allowed by the law. Holder of the personal data is Cyber Trade Srl, with Headquarters in Ravenna – Italy, represented by Mr Flavio Guerrini. Person in charge of the use of the Data for Cyber Trade Srl is Mr Roberto Ravaioli, who is in charge to answer any requests relating to the use of personal data. He also holds the updated list of the other people in charge inside the Organization. 2. COMMUNICATION OF THE DATA TO THIRD PERSONS Cyber Trade Srl may communicate the Data for the same purposes they have been gathered for, both within the Cyber Trade Srl network and to the following subjects: a) Authorities and Organs of Supervision/Control; other subjects indicated by the latter according to regulations promulgated by them or established by laws, including EC laws, by norms or by administrative practices. b) third subjects cooperating with Cyber Trade Srl, for purposes strictly bound and interrelated to the finality described in point 1., letter a) , and precisely: c) third subjects who perform tasks that are functional to Cyber Trade Srl activity, such as: - subjects that carry out customer satisfaction surveys on the quality of the services supplied; - subjects that carry out information, statistical or scientific activities; - subjects in charge of promoting and selling products and services; - subjects that elaborate studies and market researches; - subjects that carry out public relation activities; The agreement for the use of Data for the purposes listed under point c) is optional and denying it does not imply any kind of consequence. However the refusal could lead to the impossibility for Cyber Trade Srl, or for the other companies belonging to the network, to keep the concerned person updated on events of various kind, new service or product presentations, etc., and for the concerned person to receive publications or other information material that could be of interest. 3. TRANSFER OF THE DATA ABROAD The Data of the concerned person might moreover be transferred abroad, also outside the European Union, for the same purposes as stated in point 1 aforesaid, with or without the use of electronic or automated supports. The agreement for the use of Data for the purposes listed under point c) is optional and denying it does not imply any kind of consequence. However the refusal could lead to the impossibility for Cyber Trade Srl, or for the other companies belonging to the network, to keep the concerned person updated on events of various kind, new service or product presentations, etc., and for the concerned person to receive publications or other information material that could be of interest. 4. DATA USE MODE Cyber Trade Srl, uses the Data of the concerned persons lawfully and correctly, as to ensure their confidentiality and safety. The Data handling – including the gathering and any other operation described as “handling” according to art. 4 of the Civil Law Code (as for example, even though this does not cover all possibilities, the recording, the organization, the elaboration, the communication, the storing and canceling of the Data) – is carried out with manual and/or computer supports, with organizational methods and with a rationale closely related to the purposes described. The Data are kept during the necessary time in relation to the finality they have been gathered for, in full respect of the law and of possible provisions of the Granting Authority. 5. EXERCISE OF THE RIGHTS The Law provides that all concerned subjects must be informed of the rights they can exert according to the Law itself. The list of those rights is contained in art. 7 of the Law; it provides, among others, that the concerned person might require to access the own Data, thus getting a copy of the information at hand, and – whenever there are grounds to – to have it updated, corrected, integrated, cancelled or blocked; as well as to totally or partially oppose the use of the own Data for legitimate reasons. The concerned person may assert the own rights, according to the modality established by the Law, by addressing Cyber Trade Srl, using the Data Holder address, or the address of the person in charge of Data handling, as indicated above. This information has been updated on Nov. 17th 2010. Cyber Trade Srl Online from June 2011 |