Privacy Policy
1. This notification has been drawn up by Info Draft S.n.c., with offices in Milan, via Orti 7 (“Info Draft”) in accordance with Section 13 of Legislative Decree no. 196 dated 30 June 2003 regarding the protection of personal data (“Data Protection Code”), with the purpose of describing the methods employed to run the website at the address “www.sfilate.co.uk” (“the Website”) and the services made available both through the said Website and by means of shows, initiatives, events, etc. organised by Info Draft (“the Services”) in relation to the processing of the personal data of the users who consult the Website and/or use the Services (“the Users”).
COLLECTION OF PERSONAL DATA
Registration with the Website
2. In some sections of the Website, or when
using the Services, Users are offered the opportunity to join the Sfilate
community (“the Community”)
thereby benefiting from a series of exclusive advantages reserved for
registered Users.
The Community is run by Info Draft by means of the newsletter,
periodically sent by e-mail to the User’s e-mail address, by which
Users registered with the Community will be informed of exclusive initiatives
that Info Draft will make available to its registered Users. The Newsletter
may also contain publicity banners, adverts and promotional offers on
behalf of both Info Draft and third parties.
When registering with the Website,
Users will be asked to enter their personal data, some of which – each time expressly identified as such – it
will be compulsory and indispensable to supply in order to register as members
of the Community (e.g. e-mail address at which the Newsletter can be received).
Supply of other data is optional, at the User’s discretion, and failure
to supply it is not in any way prejudicial to membership of the Community,
but such failure may make it impossible for the User to take part in
any contests or initiatives, or in any case permit him/her to make only
partial use of some Services.
Users may change their profile at any time
and, in cases where Info Draft permits it, enter data previously not
supplied in order to take part in initiatives from which they would otherwise
have been excluded.
Browsing the Website and cookies
3. The Website server, using cookies too,
automatically records some information on the computer and the sections
visited by the User, for example: the name of his/her Internet access
provider, the website from which he/she accessed the Website, pages hit,
date and length of the hit, etc. This information will be recorded in
anonymous form, and used only to permit access to the Website and/or
make use of some Services, and then cancelled, or used in aggregate form
for Website statistics purposes and to monitor, again in aggregate and never
individual form, which Website pages and Services are most appreciated
by Users.
Opinions and preferences expressed by Users as part of a contest,
survey or similar initiative will also be used by Info Draft only in
aggregate and never in individual form, or for User profiling.
Cookies
4. The cookies used by Info Draft are text files that the Website
transfers to the User’s computer to facilitate browsing. Thanks to
cookies, recognition of registered Users by the Website can be facilitated,
thus avoiding the need for authentication (by logging in and entering
a password)each time they access the Website. Cookies, additionally, may
permit Users to personalise the way in which they make use of the Website
by saving their favourite settings.
As stated above, cookies also record
information regarding User browsing; this information is not however recorded
individually, and does not therefore interfere with Users’ privacy
and confidentiality.
Each user has the right to disable cookies using the
Internet browser software. Many browsers are designed to accept cookies
unless the User disables this option. Info Draft asks its Users to check
the settings of their browser with regard to cookies, and to ensure that
they comply with their wishes, bearing in mind that it may be necessary
to enable receipt of cookies in order to make use of some services (in
such cases, Users will be duly informed).
METHOD AND PURPOSE OF PROCESSING
Saving and processing of data
5. As Data Controller, Info Draft will save
the Users’ personal data,
either directly or by means of possible Data Processors stated on the Website,
in the servers located on the premises of TWT in Viale Jenner, 37 - 20100
Milan and to carry out all the processing operations using the staff – of
the Data Controller or the Data Processor – specifically designated
as persons appointed to process the data, or using external personnel
when maintenance operations are performed.
The data base can be accessed
only by the parties who are authorised to do so using methods that
guarantee its protection and confidentiality, thanks to the use of security
measures to prevent loss of data, unlawful or improper use and unauthorised
access to the data.
Each person appointed to process the data shall be given
specific instructions on how to handle the data, which the appointee must
obey in order to avoid incurring disciplinary action and/or legal proceedings.
The
data shall be kept only for the time strictly necessary to complete the
processing performed in relation to the data of each User, according to his/her
choices, preferences and instructions.
Processing in general
6. Info Draft uses the Users’ data according to the choices which
the Users’ have freely made when giving their informed consent either
when the data was collected or at a later date. Some data is used without
requesting consent – in accordance with Section 24 of the Data Protection
Code – to fulfil specific requests made by the User and within the
limits of the request itself. For example, the telephone number of a
User who has taken part in a prize contest may be used to notify him/her
of the result of the contest.
In accordance with what is set forth in the
Data Protection Code, by Section 58 paragraph 2 of Legislative Decree no.
206 of 6 September 2005 and by Section 19bis of Legislative Decree no. 273
of 30 December 2005 – as
modified when converted – the User’s data is used, until otherwise
indicated by the User, by remote communication techniques that permit
individual notification for the sending of advertising material, and
for performance of direct sales business, market research or sales communications.
Processing operations subject to consent, disclosure and circulation of data
7. Only when expressly authorised by the User, will Info Draft use his/her data for the activities stated in the paragraph hereinabove using automatic tools without the intervention of an operator and/or for other purposes authorised each time by the User. Similarly, Info Draft may share the data with or disclose itto its commercial partners – stated or listed each time on the Website – for the purpose of permitting such partners to separately process the data, as Data Controllers, using the same methods and with the same limits as those for which Info Draft has been authorised, only if expressly authorised by the User.Users’ data is never disclosed, with the exception of data voluntarily made available by the Users in any common areas of the Website which are freely accessible. Info Draft invites Users not to supply their personal data in common areas of the Website that are freely accessible, reserving the right to cancel such data or make it anonymous where such data is classed as sensitive according to the definitions set forth in Section 4, paragraph 1, letter d) of the Data Protection Code. Lastly, the data may be disclosed to public authorities in response to a legitimate order given by such authorities.
USERS’ RIGHTS
8. In compliance with what is set forth in Section of
7 of the Data Protection Code, Info Draft gives Users the right to
change their preferences with regard to the processing of the personal
data that refers to them at any time, and to obtain confirmation of whether
or not such data exists, to be informed of where the data was obtained,
the contents, the purpose and the method of processing, to request that
it is updated, rectified, integrated or to demand erasure or blocking of
data processed unlawfully.
Users, moreover, have the right to object to the
processing of their data, as well as demanding at any time that processing
of their data for the purposes of market research, sending of advertising
material, direct sales and sales communications be halted.
The rights
listed hereinbefore may be exercised by writing to Info Draft at the
e-mail address info@sfilate.co.uk
UNDERAGE USERS
9. Info Draft is aware that the Website and Services may
be of interest to minors.
Info Draft encourages parents to monitor the
use of the Internet by their children, for safer and more supervised
use of its contents, including the use of parental control tools. Besides
guaranteeing an on-line environment suited to minors, such tools can prevent
disclosure of personal data by children or young people who have not obtained
the consent of their parents.
With regard to the collection and processing
of personal data, Info Draft does not perform any processing of the personal
data of minors without the consent of their parents.
Only adult Users
or Users over the age of 14 years whose parents have given their consent
are therefore permitted to register as members of the Community.
Info
Draft, moreover, encourages parents of underage registered Users to become
Community members themselves: in this way parents can make use of the
Services and always be aware of the initiatives which Info Draft makes
available to their children, and thus check that they conform to their
expectations and that they are not in contrast with their educational
beliefs and methods.
In relation to delivery of some Services, Info Draft
does not require Users to state their age, and/or is not able to otherwise
get to know the age of Users. Info Draft therefore invites all Users
who are under the age of 18 not to communicate their personal data in any
circumstance without the consent of one of their parents, reserving the
right to prevent access to the Services and/or exclude from Community membership
any User who has concealed the fact that he/she is underage or who in
any case has communicated his/her personal data without the consent of
his/her parents even though he/she is under 18 years of age.
LINKS TO THIRD PARTY WEBSITES AND SERVICES
10. The Website and/or other messages and/or
notifications that Info Draft sends to Users as part of the Services,
may contain banners, publicity and/or adverts by third parties, advertisers
or Info Draft’s commercial
partners.
Info Draft informs Users that by accepting the offers made by
the aforesaid third parties, Users may purchase goods or services and access
multimedia pages that are the exclusive competence of such third parties,
which are beyond Info Draft’s control and which are not in any way
bound to respect what is set down in this notification.
Info Draft, therefore,
invites Users to supply their personal data in return for suitable guarantees
of confidentiality, and to take the greatest care before accepting services
offered by such parties, in relation to which Info Draft cannot exercise
any control, nor shall it be in any other way involved or held responsible.
CHANGES TO THE INFORMATION CONTAINED IN THIS NOTIFICATION
11. It being understood
that Info Draft does not in any case perform any processing operation
other than those expressly authorised and/or requested by each User, the
information contained in this notification may be subject to changes required
to comply with new legal regulations or to changes in Info Draft’s
data processing policy.
Each updated version of this notification shall be
made available on the Website in the appropriate section: Info Draft
therefore invites all Users to periodically consult the Website in order
to remain constantly informed of the latest version in force.
LAST UPDATE: September 4, 2009