This informative note was prepared by JL S.r.l., currently at Via Varese 10, Milan (“Company”) pursuant to Article 13 of Legislative Decree n. 196 of 30 June 2003 regarding the protection of personal data (“Privacy Law”), for the purpose of describing site management procedures at www.aldocoppola.com (“the Site”) and services made available through the Site by the Company (“the Services”) in relation to the processing of the personal data of people using the Site and/or Services (“Users”).
COLLECTION OF PERSONAL DATA
Joining the Community
In some sections of the Site, or during the use of the Services, the User is given the opportunity to register, enter in a specific area of the Site and therefore take advantage of a range of exclusive benefits reserved to registered users.
Everything is managed by the Company through the newsletter, which is sent periodically by email to the email address provided by the User, through which registered users will be informed of exclusive initiatives that the Company will make available to them such as contests with prizes, exclusive services, blogs, forums, discussion areas, invitations, etc. (“Newsletter”). The Newsletter may also contain advertising banners, advertisements and promotional offers of the Company and third parties.
Upon registration, the User will be asked to enter personal data, some of which – expressly identified as such each time – will be mandatory and indispensable for registration (for example, the e-mail address for receiving the Newsletter). Other data may or may not be provided, at the User’s discretion, and failure to provide them is in no way detrimental to the purpose of admission, but it may prevent the User from participating in some contests and initiatives or grant only partial use of services by the User. Where required, the Users who do not provide their mobile phone number or related consent cannot, for example, be contacted via text message to be invited to previews or events, and cannot participate in contests, games, and surveys conducted through text messages, video messages, or other mobile messaging. Moreover, they cannot receive ring tones, logos, wallpapers and other multimedia content designed for mobile phones, nor can they receive commercial offers, discounts, information on promotions from the Company and/or its partners sent through mobile phones and their networks.
Site Navigation and Cookies
3. The Site server, also through cookies, automatically registers some information about the User’s computer and browsing habits, such as: the name of the User’s providers for accessing the Internet, location, pages viewed, date and duration of the page view, etc. This information will be stored anonymously and only used to provide access to the Site and/or use of certain services, and then deleted, or used in aggregate form for statistical purposes of the Site and to track, always in the aggregate and never individual form, what pages and what services on the Site are most appreciated by Users.
Even the comments and preferences expressed by the User during a contest, survey or another similar initiative, where required, are only processed by the Company in aggregate form and never in individual form, and they are not used for User profiling purposes.
Information to Third Parties
4. In some areas of the Site, the User may be given the opportunity to send articles, messages, gadgets or gifts to third parties; in these sections, the User may be asked to indicate the address and/or name of the recipient. The Company uses this information only to comply with the User’s request and then immediately deletes the information from its database without further use.
5. The cookies used are text files that the Site transfers to the User’s computer to facilitate browsing. Cookies can help the Site recognize the registered User, thereby avoiding, for example, a need for authentication (via “login” and “password”) every time the User accesses the Site. Cookies can also allow Users to personalize their use of the Site by saving favorite settings.
As shown above, cookies also record certain information related to the User’s browsing habits; such information is not registered, however, in an individual form, and therefore does not interfere with the privacy and confidentiality of the Users.
Each User has the option to disable cookies through the software used for navigating the Internet (i.e., “Browser”). Most browsers are set so they accept cookies in the absence of any instructions from the User. The Company invites Users to check their browser settings for cookies and adjust them to suit their preferences, while bearing in mind that to take advantage of some Services they may need to enable the reception of cookies (in such cases, the User will duly informed).
PROCESSING METHOD AND PURPOSE
Data Storage and Access
6. In its capacity as owner of the processing procedure, the Company shall proceed, directly or through any persons responsible indicated on the Site, to save the personal data of Users on special servers and to perform all other processing tasks through the staff – of the owner and persons responsible – assigned with this task or through any external contractors during maintenance operations.
The database is accessible only by authorized persons using methods that guarantee data protection and confidentiality, with the adoption of security measures in place to prevent data loss, illicit or incorrect use and unauthorized access.
The data is kept for the time strictly necessary to execute those processing tasks carried out in relation to the data of each User based on his choices, preferences and indications.
Processing in General
7. The Company utilizes the data of Users in accordance with the choices that the User has freely made when giving his consent at the time of data collection or afterward, and to comply with obligations required by law, a regulation or an EU directive.
Some data is used without requesting consent – according to Article 24 of the Privacy Law – to fulfill a specific request made by the User and within the limits of the request.
Processing operations requiring consent, communication and dissemination of data
8. Only in the presence of explicit authorization by the User shall the Company proceed to use his/her data for the same activities referred to in the previous paragraph with the help of automated tools without the involvement of an operator and/or for other purposes authorized each time by the User. Similarly, only with the explicit consent of the User may the Company share or disclose his/her data to business partners – each time expressly indicated or listed on the Site – so they may proceed, as owners or persons responsible, with separate processing procedures having the same methods and same limits as the authorized processing operations of the Company. The data of Users, without the prior consent of the same, is never disclosed, except for data that the User voluntarily makes available in any public areas of the site that are publicly accessible. The Company invites Users not to provide their personal details in public areas of the publicly accessible Web site and reserves the right to delete such data or make it anonymous if it should include sensitive data as defined in Article 4 paragraph 1 letter d) of the Privacy Law. The data can ultimately be communicated to public authorities in the presence of a legitimate order from them.
RIGHTS OF USERS
In accordance with the provisions of Article 7 of the Privacy Law, the Company grants the User the right to modify, at any time, preferences regarding the processing of his/her personal data and to obtain confirmation of the possible existence of such data and to know the origin, content, purpose and methods of processing, and to request updating, modification, integration, or the deletion or blocking of data processed in violation of the law.
The User has the right to object to the processing of his/her data and to request, at any time, the termination of processing for the purposes of market research, sending advertising material, direct sales, and commercial communications.
The rights listed above may be exercised by writing to the person responsible for the data processing:
Aldo Ernesto Coppola, Fiscal Code CPPRST62C02F205R
USERS OF MINOR AGE
The Company is aware that the Site and Services may be of interest to minors.
Regarding the collection and processing of personal data, the Company does not process personal data from minors without the consent of their parents.
Registration is therefore only permitted to adult Users or to the Users who have turned 14 and have the consent of their parents.
The Company, however, also encourages registration of the parents of underage registered Users: in this way, parents have an opportunity to take advantage of the services and always be aware of the initiatives that the Company makes available to their children, and to verify if they meet their expectations and reflect their own educational models and approaches.
OWNER AND MANAGER OF THE DATA PROCESSING
The owner of the processing procedures of personal data is Aldo Ernesto Coppola, Fiscal Code CPPRST62C02F205R
The manager responsible for processing the personal data is:
– Aldo Ernesto Coppola, Fiscal Code CPPRST62C02F205R
In view of the global nature of the Company’s activities, the data can be transferred to computer servers located in other countries within the European Community. Any transfer of data takes place in accordance with the law on data protection in the United Kingdom and in the European Union.
MODIFICATIONS TO THIS INFORMATION
It being understood that Company, in any case, will not perform data processing operations other than the ones expressly authorized by each User, the present information may be modified to comply with new legal provisions or with the Company’s changed data processing policies.
Each updated version of this information will be made available in the specific section of the Web Site: the Company therefore invites all Users to periodically consult the Site to remain informed of the latest release.