Version 1.0 of 03.08.2015
1. Type of personal data and purposes of the processing
The IT systems and software procedures, that have been set up to operate this Website, collect personal data as part of their ordinary functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects; however, in consideration of its nature, such information might allow the identification of the Users, through processing and matching with data held by third parties. This category of data includes IP addresses and/or the domain names of the computers used by the Users connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the User's operating system and computer environment. These data are only used to obtain anonymous statistical information on Website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to assess liability in case computer crimes are committed against the Website.
Data supplied by the Users on a voluntary basis
The voluntary, explicit and optional sending of e-mail messages to the addresses indicated on this Website implies the collection of the sender's address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s). Save as specified for the browsing data, the User does not have an obligation to provide the data requested in the contacts forms on the Website. However, failure to provide such data may result in the impossibility to obtain what has been requested.
2. Processing means
Personal data are processed with electronic and non-electronic means, duly taking into account the relevant processing purposes, and in any case by ensuring the security and the confidentially of the data.
3. Persons to whom the data may be communicated and data dissemination
ALDâ€™s employees or collaborators entitled to manage the Website may have access to the Users' personal data. Such individuals, who have been formally appointed by ALD as persons in charge of the processing, will process the Users' personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code.
Furthermore, third parties appointed by ALD as external data processors, such as, by way of example, IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies sending marketing communications, which process the Users' personal data on behalf of ALD, may have access to the Users' personal data. One of the data processor appointed by ALD is Interactive Thinking S.r.l., having its registered office in Via Flaminia Vecchia 495, 00191, Rome, who manages the Website on behalf of ALD. Users have the right to obtain a list of the possible data processors appointed by ALD, by submitting to the latter a written request by certified mail, email or fax.
The Usersâ€™ personal data will not be communicated to third-party data controllers nor disseminated.
5. Data subjects' rights
Pursuant to Section 7 of the Italian Privacy Code, ALD hereby informs that the Users have the right to be informed (i) of the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may have access to the said data in their capacity as data processor(s) or person(s) in charge of the processing. Furthermore, Users have the right to obtain a) updating, rectification or, where they have an implied interest, integration of the data; b) deletion, 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. Users have the right to object, in whole or in part, a) on legitimate grounds, to the processing of their personal data, even though they are relevant to the purpose of the collection; b) to the processing of their personal data, 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 above-mentioned rights can be exercised by contacting ALD by (i) registered mail to its registered office (to the attention of the Compliance Department), (ii) by email to the email address firstname.lastname@example.org.