Privacy Policy

 January, 2011

We hereby inform you that Italian Legislative Decree No. 196 of 30 June 2003 (the Italian Data Protection Act) sets out the measures to safeguard individuals and other parties in relation to the processing of their personal details. As per the aforementioned legislation, our processing operations shall be carried out in line with the principles of fairness, legitimacy and transparency, in such a way as to protect your privacy and your other rights.

In accordance with the terms of Article 13 of Italian Legislative Decree No. 196/2003, we hereby provide you with the following information:

PURPOSES AND METHODS OF THE DATA-PROCESSING OPERATIONS

The personal details you supply will be subject to computerised and manual processing by our company for the following purposes:
- proper management of the contractual relationship and the relevant obligations (where applicable)
- fulfilment of legal, accounting and tax obligations
The details will be processed in the main using automated electronic and IT equipment, in ways that comply with the minimum security measures set out in the Technical Rules on Security, Appendix B of Italian Legislative Decree No. 196/2003.

GRANTING OF ACCESS TO YOUR DETAILS
The granting of access to your details is compulsory; if you refuse to grant access, this may make it wholly or partially impossible to fulfil the accounting obligations and/or the obligations set out by the specific regulations governing the data-processing operations. If you decide not to supply your details, or you make a mistake when supplying the compulsory information, it will be impossible for the party responsible for the data-processing operations to guarantee the correspondence of the data-processing operations with the contractual agreement to which the operations relate; moreover, the results of the data-processing operations may not meet the obligations set out by the relevant fiscal, administrative or other regulations.

EXTENT OF DISCLOSURE
The following parties may become aware of your personal details:
• parties carrying out technical or organisational tasks (mailing the information or transmitting it electronically, etc.)
• companies that provide software support

In relation to the transfer of your personal details outside of Italy, RCCONSULTING Srl guarantees that your details will be protected and processed in the same way overseas as they are under Italian law.

The party responsible for the processing operations is:
CONTECO SpA
Via Sansovino, 4
20133 MILAN
ITALY

All of the company documentation has been delivered to the chartered accountant, who has been delegated to process the company data for the following purposes:

Administrative and accounting purposes
Fulfilment of accounting and tax obligations
Client management (administration of client base; management of contracts, orders, shipments, invoicing, solvency checks)
Supplier management (administration of supplier base; management of contracts, orders, arrivals, invoices; selection of suppliers on the basis of company requirements)

Purposes relating to the banking, credit, insurance, brokerage and consulting
Consulting

At any time, you can exercise your rights as enshrined in Article 7 of Italian Legislative Decree No. 196/2003, which is shown below in its entirety:

Article 7 of Italian Legislative Decree No. 196/2003
Right of access to personal details and other rights

1. The data subject has the right to be provided with confirmation as to whether or not personal details concerning him or her are being held, even if said details have not as yet been registered, and to receive a copy of said details in an intelligible form.

2. The data subject has the right to be provided with information on:
a) the source of the personal details
b) the purposes of, and methods used for, the processing operations
c) the logic applied in the instance of processing operations carried out using IT tools
d) the identity of the data controller, its managers and its designated representative as per the terms of Paragraph 2, Article 5
e) the subjects or categories of subjects to which the personal details may be disclosed or which may become party to the details as designated local State representatives, managers or persons responsible.

3. The data subject has the right to demand:

a) the updating, correction or (when in the interest of the data subject) completion of the details
b) the cancellation, making anonymous or blocking of access to any details processed illegitimately, including those details that do not require to be stored in relation to the purpose(s) for which they were originally collected or subsequently processed
c) confirmation that the form and content of the operations referred to at letters a) and b) have been communicated to any individuals to whom the details have been disclosed, unless doing so would be impossible or would require the allocation of resources that are clearly disproportionate to the right being protected.

4. The data subject has the right to oppose, wholly or partially:
a) for legitimate reasons, the processing of the personal details in question, even if still relevant to the purpose(s) for which they were collected
b) the processing of the relevant personal details if said operation is being carried out with a view to sending the data subject advertising, direct sales, market research or commercial material.