Private data and privacy safeguard

ProgetPlus srl Disclosure

Dear Customer,

We would like to inform you that your personal data will be used by ProgetPlus srl (“Components Engine”) and communicated to other companies, in full compliance with the fundamental principles, dictated:

• by the Directive 95/46/CE and by Italian Law 675/96 for the protection of personal data;
• by the Directive 97/66/CE and by Italian Legislative Decree 171/98 for the protection of privacy in telecommunications;
• by the Directive 97/7/CE and by Italian Legislative Decree 185/99 for the protection of consumers in remote contracts;
• by the CE Directive of 4 May 2000 for electronic commerce.

DATA CONTROLLER AND DATA PROCESSOR
The personal data controller is ProgetPlus srl (“Components Engine”) having its registered office in via Sarno, 116 – 47020 Cesena (FC) – Email:
 . The personal data processor is Mr. Flavio Rondini.

PERSONAL DATA PROCESSING OPERATIONS AND THEIR PURPOSES
Hereafter, we shall summarize all the operations performed by us which entail the collection, preservation or elaboration of your personal data, and the purposes we pursue with each of them.

a.       collection, preservation and elaboration of your personal data for the provision of the newsletter service and to provide Judicial Authorities with required information. Specifically, the purposes are:

1.       to conclude, manage and perform the contract for the delivery of the required service;

2.       to organize, manage and carry out the delivery of the service (sending the newsletter);

3.       to comply with legal obligations or with the other provisions required by cognizant Authorities;

4.       to send informational notices strictly connected with the service delivered to you;

5.       to send notices about new services offered, organized events and special offers which ProgetPlus srl (“Components Engine”) deems to be of interest for its users;

b.       elaboration of the personal data provided by you and of those resulting from your Web browsing in order to define your commercial profile;

c.       use of your commercial profile by ProgetPlus srl (“Components Engine”) for marketing and promotional aims pursued by ProgetPlus srl (“Components Engine”);

d.       use of your commercial profile by ProgetPlus srl (“Components Engine”) for marketing and promotional aims pursued by third parties;

METHOD OF PROCESSING
Processing operations shall take place in fully automated fashion by means of a process that allows to determine the customer’s commercial habits as they are manifested by Web browsing.
Personal data shall be processed solely with electronic means whose access is reserved to personnel in charge of the processing. ProgetPlus srl (“Components Engine”) has provided all IT security measures necessary to minimize the risk of infringement of its users’ privacy by third parties. It is ready at all times to adopt all other security measure that should be found indispensable. We would like to remind you that the transmission of personal data to ProgetPlus srl (“Components Engine”) always takes place under the user’s responsibility. Providing us with additional personal data is an option available to you, and it may assist ProgetPlus srl (“Components Engine”) assure that the service you receive is ever more accurate and suited to your expectations (proposals for new services, commercial offers, etc.).
ProgetPlus srl (“Components Engine”) excludes a priori any processing which may directly or indirectly involve sensitive data.

FREEDOM TO PROVIDE CONSENT AND CONSEQUENCES OF A DENIAL
Providing us with your data is optional. However, if you deny your consent for all purposes (a), (b), (c), (d), we will not be able to deliver the services to you.

SERVICE TASKED WITH REPLYING TO ANY QUESTIONS ABOUT DATA PROTECTION
For information or questions about the protection of personal data, please write the “Personal Data Protection Service” - ProgetPlus srl (“Components Engine”), via Sarno, 116 - 47020 Cesena (FC) Italy, email: .

Data subject’s rights

We further inform you that ever data subject may exercise his/her rights as per Art. 13 of Law 675/96, which we summarize below:

a.       to know, through free access to the content of the Record as per Art. 31 of Law 675/96, the existence of the processing of data which may involve him/her;

b.       to be informed about:

1.       name, denomination, corporate name, domicile, residence and registered office of the data controller

2.       aims and method of the processing

3.       name, denomination, corporate name, domicile, residence and registered office of the data processor;

c.       to obtain from the data controller:  

1.       Confirmation of the existence of personal data that involve him/her and notification of such data. Information about the logic and the purposes of the processing.

2.       Erasure, 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 and processed.

3.       Updating, rectification or integration of the data.

4.       Certification to the effect that the operations as per numbers 1 and 2 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.

d.       to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;

e.       to object, in whole or in part, to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or interactive commercial communication surveys and to be informed by the data controller, no later than the time when the data are communicated or disseminated, of the possibility of exercising said right free of charge.

For each request as per Paragraph 1, Letter c) no. 1), the data subject may be required, if the existence of data concerning him/her is not confirmed, to reimburse expenses for an amount not to exceed the costs actually incurred, in the manners and within the limits set out by the regulations as per Article 33, Paragraph 3.

The rights as per Paragraph 1 referred to personal data concerning deceased persons may be exercised by anyone who has an interest therein.

In exercising the rights as per Paragraph 1, the data subject may provide, in writing, a power of attorney to natural persons or associations.
The professional privilege rules for those exercising the profession of journalist, limited to the source of the information, shall apply.

To exercise the rights set out by Article 13 of Law 675/96 and summarized above, the Customer shall address a written request to: