Privacy Policy This privacy policy (hereafter, “Privacy Policy”) refers to the Website www.gasparucci.it, including the areas dedicated and reserved for registered users (hereafter, the “Website”) and outlines the personal data handling conducted by Gasparucci (hereafter, “Gasparucci”,) through the Website, which is the property of Gasparucci and is registered to the same and currently managed by it. Gasparucci acknowledges the importance of the privacy of its users, and is committed to respecting it. Gasparucci handles the user’s personal data when the user visits the Website and uses the services and functions on the Website. The Privacy Policy has been drafted in compliance with Recommendation no. 2/2001, adopted on 17 May 2001 by the Working Group on Data Protection – Art. 29, in relation to the minimum requirements for online data gathering within the European Union. In addition, it represents the policy for all those involved, in accordance with Article 13 of the Legislative Decree dated 30 June 2003, no. 196 and subsequent amendments and integrations (hereafter the “Privacy Code”). The Privacy Policy specifies who the data controller is, who controls and manages the personal data gathered and handled through the Website, which personal information is gathered, for which purposes it is gathered and the methods used to handle the personal data. It also defines the sphere of their communication to third parties and any transferral abroad, the security measures adopted to protect and safeguard said data, and the means by which users can verify the handling of the data which regard them, and to exercise the rights acknowledged by the Privacy Policy. This privacy policy is only made available for the Website, and the activities conducted and services provided by Gasparucci , including through its handling managers, and not for any other websites which can be consulted by the user through links and/or activities implemented by third parties. 1. TYPES OF DATA HANDLED 1.1 Navigation data During their normal functioning, the computer systems and programmes needed to run the Website record certain data acquired automatically and inevitably. These could, when combined with other data, allow users to be identified. This data can only be used to obtain statistical information on the use of the Website and to ensure it is operating properly. Where expressly requested, this data may be used by the Public Authority to ascertain responsibility where computer offences are committed against the Website and/or third parties, in compliance with the procedures applied by the competent Authorities. 1.2 Data supplied voluntarily by individual users The personal data supplied voluntarily by individual users consist of the data gathered by sending emails, interacting with the Website’s functions, requesting services offered by the Website and by filling out specific formats to access reserved sections of the Website. 2. METHOD AND PURPOSES OF THE HANDLING The data will be handled manually as well as with the help of electronic instruments for the following purposes: managing registration to the Website, the newsletter, SMSs and mailing lists, managing purchases of products through the Website (including all activities geared towards sales and services for sales and after-sales, such as administrative activities, accounting, managing returned goods and guarantees, fraud prevention, managing customer relations), handling participation in promotions and other initiatives organised via the Website, responding to and handling requests for information, questions, communications or feedback from users. Gasparucci also handles the personal data of users in compliance with legal requirements, regulations and laws on a European level (including laws governing anti-money laundering) and for exercising rights in judicial proceedings. The user shall have the possibility of opposing the handling of data for commercial purposes at any moment, and to no longer receive materials and promotional and/or commercial information. 3. COMMUNICATION OF DATA The data can be communicated by INDUSTRIES, in its capacity as data handler, to service companies and/or third parties, professionals and independent collaborators who work with INDUSTRIES to pursue the above purposes. The data may, with the express consent of the user, be transferred beyond the national territory, including to countries which do not belong to the European Union. In any case, when the personal data is transferred to a country outside of the European Union, the principles outlined by the Privacy Code shall be applied. Parties receiving the personal data of the user may handle it in their capacity as Handler, Supervisor and/or person appointed to handle the data, depending on the case in question. The complete and up-to-date list of Data Supervisors will be supplied on request, which must be made to Gasparucci at the address info@gasparucci.it. To find out more about personal rights and to keep up-to-date with regulations governing the protection of persons with regard to the handling of personal data, users can visit the Website of the Privacy Guarantor for protection of personal data (Garante) at http://www.garanteprivacy.it/ Under no circumstances will the data be subject to distribution. 4. AUTOMATIC MECHANISMS FOR COLLECTING DATA – COOKIES The Website might send cookies to the user’s computer. A cookie is a fragment of text transferred to the hard drive of the user’s computer from the server of the web page. A cookie can contain information (such as the exclusive user ID), used to work back to the pages of the websites visited by the user. Gasparucci uses cookies exclusively for assessing activity on its Website, in order to determine which areas and contents of the Website are visited most. This information allows Gasparucci to make constant improvements and updates to the benefit of its users. Cookies are not used to store passwords, information regarding credit cards or other information which can enable any kind of personal identification of the user. The Website uses “session” and “permanent” cookies. The session cookies are temporary, and are automatically eliminated every time the Website is left. Permanent cookies, on the other hand, remain on the user’s hard disk until removed. Cookies are used to allow the Website to be used in full, and/or to track the visit to the different pages/sections of the Website. In any case, cookies are not and will not be used to collect personal data, or to detect information regarding the user’s navigation on other websites. Most browsers are initially set to accept cookies. Users may, however, reset their browsers to deactivate operativity of cookies. This decision may, however, prevent certain functions of the Website from being used, or the possibility of interacting with the Website itself. 5. DATA PROVISION With the exception of data regarding navigation (gathered automatically by the system), provision of data by the user is necessary for registering on the Website and accessing the services and functions offered by the Website and reserved areas. Failure to provide the data will make it impossible for the user to access and use said services and functions. The provision of data for marketing purposes is always free and optional. Any failure to provide data for the above activities will not have any consequence on the user’s possibility to use the services and functions offered by the Website 6. RIGHTS OF THOSE INVOLVED The user may, at any time, exercise the rights acknowledged under Art. 7 of the Privacy Code, including by way of example, the right to obtain confirmation of the existence or otherwise of personal data regarding him/her, verify its content, origin and precision, ask for it to be integrated, updated, rectified, cancelled and transformed in anonymous form, as well as to block any data handled in violation of the law. The user may oppose the handling of data for legitimate reasons. For any demands or requests regarding the handling of one’s personal data and to exercise the rights acknowledged by the Privacy Code, the user can contact Gasparucci as indicated below. The Privacy Policy is subject to amendments and updates, and the version currently in force is the one published on the Website. Amendments made to the Privacy Policy are published on the Website. You are asked to check the Privacy Policy periodically in order to remain up-to-date regarding any changes made. 7. CONTROLLER AND SUPERVISOR OF THE HANDLING The personal data gathered will be stored and handled using an electronic system managed by Gasparucci , based Via La Villa, 5 – 61034 – Fossombrone (PU) – Italy in its capacity as Controller and Supervisor of the data handling. Any communications must be sent to the following e-mail: info@gasparucci.it. APPLICABLE LAW AND JURISDICTION These Terms and Conditions of Use are governed by Italian law and must be interpreted in accordance with the same. The Court of Milan (Italy) will have exclusive jurisdiction for all controversies arising from, or in any way linked to, the use of the Website and/or the relative Terms and Conditions of Use, notwithstanding all rights which might be attributed by the law for taking legal proceedings in the place of residence or usual home address of the user. In the event that any of the provisions contained in the Terms and Conditions of Use should be deemed unlawful, invalid or inapplicable, every necessary part of said provision shall be amended in order to render it lawful, valid or applicable and the remaining provisions shall retain full validity and applicability. These Terms and Conditions of Use constitute the overall agreement between the user and Gasparucci regarding the object of the same. All the provisions of these Terms and Conditions of Use are applied to the utmost extent consented by the applicable laws It remains understood that, with regard to the correct interpretation of these Terms and Conditions of Use, in the event of any discrepancy between the original wording in English and the translation into any other language, the original wording in English shall be deemed the binding version. Privacy Policy