Processing of personal data under art. 13 Legislative decree n° 196 dated 30/06/2003. (PRIVACY CODE)

Personal data submitted or collected within our activity may be subject to processing based on the principles of accuracy, legality and transparency protecting the Customer’s privacy and rights.

The data processing activity in question is required for:
1. providing the services available at our website;
2. meeting law obligations;
as well as, upon consent,
3. for profiling our users. The term profiling is used to indicate the process through which the commercial propensity of the user, observable through his internet surfing activity, may be established. VR|46 shall use a system for profiling the users based on the analysis of the accesses to services provided on the website. VR|46 guarantees that – during the profiling process –confidential data as defined by art. 22 of the law shall not be processed directly or indirectly in any manner whatsoever, same case also applying to disclosure of personal data subject to processing by VR46 srl to third parties;
4. for sending advertisement e-mails. Sending advertisement e-mails shall not create grounds for disclosure of personal data to third parties for any reason whatsoever;
5. for submitting commercial information regarding new offers of products and services, to check the customer satisfaction level regarding products and services provided by VR46 srl or Companies with which VR46 srl has commercial agreements.

We would like to specify that processing data for the purposes under points 1 and 2 is compulsory to gain access to our services while processing data for the purposes under points 3,4 and 5 is optional and shall be performed by VR46 srl only upon the Customer’s consent.

Data processing shall be carried out by specifically appointed personnel and be performed through means suitable to guarantee security as well as privacy. Such processing may also be carried out through automated means suitable to store, manage and transmit the data in question.

Lastly, the personal data subject of processing shall not be disclosed to third parties or transferred abroad in any manner whatsoever, except for the disclosure, always within the limits of the law and for the purposes provided for by point 1, to: persons in charge of packaging, shipping, delivering and returning products, banks, people or professional offices providing consultancy and assistance services regarding law, accounting, levy, administrative, taxation and financial requirements as well as consultants and other persons providing related services or persons who disclosure thereto is required for proper fulfilment of the obligations regarding the supply contract; to Public Administrations.

Personal data submitted or to be submitted by the Customer during the relation shall be processed with the aim of meeting obligations derived from the sales and purchase contract of which it forms part, as well as meeting the ensuing obligations provided for by the laws, regulations or European Council directives and always in compliance with the minimum security requirements provided for by the PRIVACY POLICY. The Customer’s personal data shall be processed for promotional and advertisement purposes only if expressly and previously allowed by the Customer. Article 7 of the regulation, outlined hereinafter, establishes the rights of the Customer regarding processing the submitted personal data.

Art. 7 of the legislative decree n° 126 dated 30th June 2003 – Right of access to personal data and other rights

1. The person in question has the right to obtain confirmation of the existence or absence of personal data regarding him, even though not yet recorded, and disclosure thereof in an intelligible manner;
2. The person in question has the right to request information regarding: a) the origin of the personal data; b) the purpose and method of processing; c) the logic applied in case of processing carried out using electronic means; d) the identification data regarding the person in charge of processing the data and the designated representative according to art. 5, paragraph 2); e) persons or categories of persons to whom personal data may be disclosed or who may be aware of such personal data as the designated representative or persons in charge in the country;
3. The person in charge has the right to request: a) updating, correction or, when deemed necessary, integration of the data; b) deletion, transformation into anonymous form or blocking of data processed against the law, including data not required to be stored as regards with the purposes for which the data in question was collected or subsequently processed; c) ascertaining that the operations under letters a) and b) were revealed, even regarding contents thereof, to those whose data was disclosed, except for cases wherein meeting such requirements is impossible or requires means overtly unjustifiable with respect to the protected right;
4. The person in question has the right to object, wholly or partly: a) to processing personal data regarding him, though concerning the purpose of collection, due to legitimate reasons; b) to processing personal data regarding him with the aim of sending advertisement material or for carrying out market survey or commercial communication.

Data treatment shall not exceed the period required for the purposes for which such data collected.

Personal data shall be processed by VR|46 Sr.l. a single member limited liability company, with headquarters in Via Rosselli n° 46, 61100 Pesaro, Italy. In compliance with art. 8 of the law, Gruppo Pritelli srl with registered office in via Respighi 54 int. 4 – 47841 Cattolica (RN) Italy, was appointed to manage processing personal data

Furthermore, Gruppo Pritelli srl with registered office in via Respighi 54 int. 4 – 47841 Cattolica (RN) Italy may be contacted at any time to request personal data and request integration, variation or deletion due to infringement of the law thereof, or object to processing thereto.