MENU PRIVACY POLICY Pursuant to article 13 of legislative decree no. 196 of 30 June 2003 Personal data protection code. With this note, S.G.L. s.r.l., with registered office in via Trani, 342 - 76121 Barletta (BT) - Italy - (hereinafter “S.G.L. s.r.l.,”), intends to inform users visiting the website "www.circolo1901.it" (hereinafter the "Website") of the Policy adopted regarding Personal Data Protection, emphasizing its commitment and focus on protecting the privacy of the visitors to the Website. Visitors may browse the Website freely and are not obliged to register, except in certain areas of the same, in which the user can freely and expressly provide a series of personal data in order to access specific services. Therefore, where the user intends to provide his personal data in order to access those additional services, he will be expressly informed (pursuant to Article 13 of Legislative Decree no. 196 of 30 June 2003, Personal data protection code), of the purposes and methods for and with which the data will be used by S.G.L. s.r.l.as well as of the right to request, at any time, that the data provided are erased or updated. Information on personal data protection S.G.L. s.r.l.hereby provides the following information, pursuant to the Legislative Decree no.196/2003 "Personal data protection code" (hereinafter the “Code”). 1. Data Controller and Data Processor The Data Controller of the personal data is S.G.L. s.r.l.. The Data Processor with regard to the Site management is the pro-tempore Chairman of the Board of Directors. The name of the Data Processor and the list of the persons in charge of the processing may be requested by writing to the addresses indicated at point 7. 2. Types of personal data processed You do not need to be registered to access the Website. However, some sections in the Website do require you to register, or use a username and password (e.g. to complete the on-line purchasing process). There are also certain services for which you must provide your data should you wish to use them (e.g. your data may be required if you wish to access the Newsletter services, contact us, share your “Wish List” with a friend, etc.). Should S.G.L. s.r.l.collect information and personal data about users, it will inform the same in advance, pursuant to Art.13 of Legislative Decree 196/2003, of the purposes for which said data are required and of the means of the processing. If necessary, S.G.L. s.r.l.will require the user’s specific consent for the relative processing of the data (for example, personal data - such as the user’s name and surname, telephone number, email address and other information that the user consents to provide - may be requested to enable the user to access the services of the Website) S.G.L. s.r.l.will only use the personal data collected on-line for the purposes indicated during the registration process. The data related to the user’s connections and browsing on the Website (such as the URI-Uniform Resource Identifier addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user’s operating system and IT environment) are only collected for the purpose of gathering anonymous statistical information about the use of the Website and its correct functioning; such data are erased immediately after the processing. Data may be used to verify any responsibility in the case of alleged IT crimes damaging the Website: with the exclusion of such hypothesis, data are erased after the period of time required to provide the services of the Website. With reference to the data related to the user’s browsing within the Website, please see also point 6 below regarding the Profiling tools used by the Website. 3. Optional nature of the user’s decision to provide personal data The user can provide the personal data at his/her own discretion. Only in certain cases, failure to confer the data can prevent the user from accessing specific services and obtaining what requested (e.g. registration is required to proceed and purchase products online). 4. Data processing procedures and communication of data The data can be processed both electronically and on hard copy. S.G.L. s.r.l.guarantees that the personal data provided will be processed lawfully and correctly, in full compliance with the legislation in force, and will maintain the utmost confidentiality. All the information collected is sent via a protected connection to prevent it from being intercepted by third parties. The safety of the Website is guaranteed and certified by a leading company in the provision of services regarding Internet security. Data will not be communicated or disseminated to third parties except within the limits and under the conditions expressly indicated in the information notices provided to the user from time to time on the Website, and only upon receipt of authorization from the same. 5. Links to other sites This Privacy Policy is only applicable to the S.G.L. s.r.l.’s Website and is not valid for any other websites that may be consulted by the user via links originating thereof. S.G.L. s.r.l.cannot be held responsible for the personal data provided by the users to third parties or to any other website that may be linked to the Website. 6. “Profiling” and/or customization tools S.G.L. s.r.l.does not carry out any promotional communication and/or advertising activities without the user’s prior explicit consent. The Website uses “Cookies”: these are text files which are sent from a web server (which is the computer on which the Website visited is running) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and memorized on the hard disk of the user’s computer when visiting the Website. The cookie allows the Website to identify the user’s PC (by way of the information memorized therein) each time that the user reconnects to the Website using the same PC. By using cookies we can make it easier for the user to browse the Website. Cookies do not collect information that directly identify the user. Indeed, S.G.L. s.r.l.cannot track any personal information that directly identifies the user using the cookies (e.g. name, surname) unless such data are directly provided by the user. Moreover, another website cannot use a cookie sent by the S.G.L. s.r.l.’s Website to access information contained in the user’s computer. Once saved in the computer, cookies can only be read by the Website that created them (and therefore, in our case, by (www.circolo1901.it). What type of cookies does S.G.L. s.r.l.use? Technical cookies These are the cookies used with the aim of enabling browsing and therefore the electronic transmission of data on the net, or strictly necessary to provide the services granted by the Website. These are generally temporary cookies, the so-called "session cookies." They are issued by the Website on the user’s computer during browsing but are only memorized for the duration of the browsing session. This means that when the user closes the browser, the cookies are erased automatically and disappear, and do not remain memorized on the computer. They are formed by random numbers generated by the server and are used to help ensure that the Website can be browsed safely and efficiently. This kind of cookies make it easier for the user to browse the Website, for example by remembering the data the user has provided when filling in forms on the Website (so-called “user input cookies”), recognizing the user after logging into the Website (so-called “authentication cookies”), customizing the interface of the Website on the basis of the preferences indicated by the user, to gather bulk information on the number of visitors to the Website and on the most visited pages (“cookies analytics”), etc. These cookies do not require the user’s prior explicit consent as they are strictly necessary for the purposes of supplying the service requested by the user of the Website (ex art. 122, section 1, of the Code). Profiling cookies These are the cookies aimed at creating users’ profiles, for example for the purpose of sending advertising that are consistent/customized on the basis of the users’ preferences: these cookies are issued by the Website on the user’s computer during browsing, and are also memorized beyond the duration of the browsing session, until they expire or are erased by the user (so called “permanent cookies”). The use of this kind of cookies requires the explicit and informed consent of the user (ex art. 122, section 1, of the Code). When the user visits the Home Page (or any other page) of the Website, by viewing and acknowledging the banner containing the cookies’ information statement, and proceeding with browsing the Website – the user specifically authorizes the use of such cookies. If the user has set the Internet Browser (e.g. Explorer, Firefox, Chrome) to accept the use of cookies, this is also valid as a form of user consent (ex art. 122, section 2, of the Code). Please note that the user’s consent shall be requested only upon the first access to the Website: thereafter, thanks to the use of a technical cookie, we shall memorize the consent to allow the access to the pages of the Website directly when returning to the site. In any case the user has the right to enable/disable cookies or to erase them at any time (see point 6.2): in such case, when returning to the Website, the site will ask for a new consent). No other profiling tools are used on this Website (e.g. spyware). Moreover, should the user register on the Website and specifically authorize the monitoring of his/her browsing, the data related to the browsing sessions on the Website may be associated with his/her personal data. 6.1 Information on cookies released by Website We are pleased to provide the following information regarding the cookies used in the Website: 1) The domain name from which the Website server transmits the cookies is: www.circolo1901.it. 2) Purpose of data collection: the cookies are used to (i) make browsing on the Website easier and quicker and make anonymous statistical analysis on the use of the Website (technical cookies); (ii) improve the browsing experience by suggesting the best products and promotions based on the user’s browsing history (profiling cookies). 3) Data collected: the following information is memorized: the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relative to the user’s operating system and IT environment). Under a technical profile the following information is contained in the cookies (transmitted by the domain www.circolo1901.it): a numerical ID identifying S.G.L. s.r.l.and a numerical ID identifying the user (browsing the Website), both memorized in our database; a numerical ID identifying the browsing (so called “record”) of the user within our database; a pseudo-random alphanumerical session ID automatically erased by the browser upon its closing (session cookie). 4) Validity of the cookies: the Website uses session cookies (i.e. cookies that are automatically erased when the browser is closed), and permanent cookies (i.e. cookies that are kept until they are erased by the user, if applicable), which do not in any case last more than six months. 5) Requirement to accept cookies: accepting cookies is not mandatory but some contents and functions may be blocked if they are deactivated, although it will still be possible for the user to browse the Website. 6) Deactivation and erasure of cookies: cookies can be deactivated or erased at any time. In order to help you make a free and informed choice, please find hereafter information on (i) cookie identifier, (ii) cookie characteristics and aim, (iii) possibility to disable/enable individual cookies or to disable/enable them all. In any case you can disable/enable or erase cookies at any time by using the settings of your web browser. In particular, if you prefer not to receive cookies you can set your browser to warn you when a cookie is present so that you can decide whether to accept it or not; it is also possible to automatically refuse all cookies, by activating the appropriate option in the browser. To do this, you must consult the information reported in your browser’s User Manual (Help Page). 7) Data communication: the information collected via cookies is confidential and is not communicated to third parties. 6.2 Third-party cookies Third-party cookies are not used. 7. Location of data processing The data related to the services provided by the Website are processed at S.G.L. s.r.l.’s principal place of business in via Trani, 342 - 76121 Barletta (BT) - Italy by the persons in charge of processing appointed by the Chairman of the Board of Directors. 8. Rights of the parties concerned Pursuant to Article 7 of Legislative Decree 196/2003 you have the right to request information on how your data is processed including 1) to obtain confirmation, without delay, as to whether or not personal data concerning you exists; 2) to be informed of the source of the personal data, of the purposes and methods of the processing, of the logic applied to the processing, if the processing is carried out with the help of electronic means, of the identification data concerning the data controller, data processors and the designated representatives, of the entities or categories of entities to whom or which the personal data may be communicated or who or which may get to know said data in their capacity as data processors or persons in charge of the processing; the updating, rectification or, where interested therein, integration of the data; b) the erasure, anonymization or blocking of data that has been processed unlawfully; 3) to object, in whole or in part, to the processing of personal data concerning you, where it is carried out for the purpose of sending sales or advertising materials or direct selling, or else for the performance of market or commercial communication. You can exercise your rights at any time by contacting S.G.L. s.r.l.using the form available in the Customer Service section of the Website. 9. Applicable Law This Privacy Policy is regulated by the Italian Law and in particular by Legislative Decree 196/2003 Personal Data Protection Code, regulating the processing of personal data – also retained abroad – made by anyone based in Italy or by means of instruments located in Italy. The Code guarantees that the processing of personal data is made in full respect of fundamental rights and freedom, as well as of the dignity of the person involved with particular reference to privacy, personal identity and the right to personal data protection. 10. Right to review S.G.L. s.r.l.reserves the right to review, amend or simply update, totally or in part, its current "Privacy Policy" at its exclusive discretion, in any way and/or at any time, without any need to submit advance notice, even in view of changes in the law or regulations concerning Personal Data Protection. Users shall be notified of any amendment or updating of the Privacy Policy in the Home Page of the Website as soon as adopted; the new version of the Privacy Policy shall be binding upon its publishing n the Website in this section. Please access this section regularly to verify the latest Privacy Policy. The integral text of Legislative Decree no. 196 of 30 June 2003 Personal Data Protection Code can be consulted on the Website of the Italian Data Protection Authority www.garanteprivacy.it. 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