(Art. 13 Leg. Decree 196/2003)
In compliance with art. 13 of Legislative Decree no. 196 dated 30 June, 2003 (“Privacy Code”) the fol-lowing information is made available to the Users of the Website www.dotandcross.com, hereinafter “Website”, managed by the company Dogtrot s.r.l. unipersonale, Taxpayer and VAT number 04300580265, with registered office at 31030 Carbonera (TV), Via Brigata Marche no. 30, email firstname.lastname@example.org, Certified email email@example.com, the Data controller. Such information refers solely to the Website itself and not to any other websites visited via links from this one, for which we suggest reading the relevant in-formation provided by the individual Data Controllers respectively.
This information relates to processing in relation to the gathering and subsequent operations performed on the personal data of Website Users by browsing its pages and, above all, by means of the tools for requesting information and for providing personal data by email, contact forms, any procedures for registration/accessing reserved area, newsletter subscription, use of services and/or applications, the performance of similar and identical operations.
The processing of personal data will be based on principles of correctness, lawfulness, transparency and protection of confidentiality and rights of freedom of the Users involved in processing.
Data Controller and Supervisor
The controller of the processing of the personal data of the Users of this Website is the company Dogtrot s.r.l. uni-personale, Taxpayer and VAT number 04300580265, with registered office at 31030 Carbonera (TV), Via Brigata Marche n. 30, email firstname.lastname@example.org, certified email email@example.com
The Data Controller and Supervisor process the Users’ data also thanks to their own internal Data Pro-cessors, appointed by them and provided with instructions for the correct processing of personal data, including orally, by virtue of the Simplification Measure of the Italian Data Protection Authority dated 27 November 2008 as amended and supplemented.
Purpose of data processing
The personal data of the Users of the Website, as described above, will be processed in the manner and form prescribed by the Privacy Code, for the performance of the functions of the Website, with particular – but not sole – reference to the procedures described therein for data gathering, contact forms, any registration/reserved area access procedure, newsletter subscription, use of services and the like.
In particular, the personal data provided to the Data Controller will be processed for the following pur-poses:
– for purposes relating to the use/usufruct by the User of the services made available by the Website;
– to comply with the specific requests made by the User to the Data Controller through the Web-site and their communication tools (contact forms, information request forms and the like);
– for any subscription to the newsletter and the consequent receipt of various informative notices concerning the sector in which the Data Controller operates;
– for informative notices concerning the services and products provided by the Website, also fol-lowing requests for information by email or filling in the contact forms and entering data and other communication tools;
– for other accessory purposes or which are related to those indicated above and in any case falling within the scope of the activities of the Website;
– to carry out marketing activities with its express consent, by sending through digital media (e.g. WHATSAPP messages) and non-digital media (e.g. mail, fax and the like) information and no-tices of a promotional and advertising nature and, in general, any commercial communication relating to the services offered by the Website, including, for example, special offers, initiatives,
sponsorships, and other similar operations; the party involved shall always be entitled to refuse and oppose such processing, both initially and subsequently, easily and free of charge.
Without prejudice in any case to the further faculty of using the data for the purposes regulated by art. 130 sub-section 4 of the Privacy Code in relation to the processing of email coordinates, provided by the party involved in the context of the sale of a service, aimed at sending communications for the subsequent direct sale of services similar to those forming the subject of the sale itself; the party in-volved shall always be entitled to express its refusal and oppose such processing, both initially and sub-sequently, easily and free of charge.
The processing of data provided in general (so-called browsing data, such as, by way of example, anonymous data on visits) will be carried out, following automatic gathering, solely for the purpose of ascertaining and controlling access to the Website.
The sending of such email messages to the email addresses, both generic or not, indicated on the Website, the filling in of the fields of the contact forms and data entry, of any registration/reserved area access procedure, subscription to the newsletter, of filling in of forms, as well as the autonomous and voluntary entering of data and information in the appropriate free fields of same, will imply the acquisi-tion of the conferred data. This will allow the Website to process the requests and render the specific information and to complete the online process undertaken by the user.
Users are requested not to provide in general judicial data (i.e. data revealing pending criminal or judi-cial proceedings) and sensitive data (i.e. data revealing racial or ethnic origin, religious beliefs, philo-sophic beliefs or other beliefs, political opinions, membership of any political party, trade union, associ-ation or organisation of a religious, philosophical, political or union nature, as well as any data such as to reveal their state of health and sex life. Failure to do so shall result in such data not being taken into consideration and the Data Controllers shall not be answerable for such data
The personal identification data provided by the Users will be transferred to the database of the Web-site and will be processed by means of computer procedures by the operators, collaborators and part-ners of the Data Controller, in such a way as to ensure confidentiality and security and according to a logic strictly related to the purposes mentioned above.
All the data will be processed in full compliance with the Privacy Code and will be kept for the time strictly necessary to achieve the purposes mentioned above.
The data may be processed in automated or manual mode.
Data notification and dissemination
No personal data provided in general by Users will be notified to third parties (except for the procedure of notification to the competent Authorities, in the event of ascertainment of the performance of illegal activities) nor disseminated in any way. The above shall not apply to browsing data and the like (for which reference is made to the above), nor to third party profiling cookies (Notice on the use of Cook-ies which you can read here, which will be notified to the respective third parties involved, if they do not manage them directly as data Controllers.
According to the purposes and logic of the specific processing, as described above, the personal data specifically provided by Users may instead be subject to notification to collaborators or partners of the Data Controller, as well as to the Supervisor, for purposes closely related to the relationship, as such:
– companies and other partner companies (e.g. carriers and couriers and insurance companies) for purposes related and connected to those stated on the Website;
– various professionals, including lawyers, accountants and the like, for the protection of rights and/or for their commercial and fiscal management and/or for similar purposes;
No data will in any case be disseminated.
As for the circulation of data within the Data Controller’s organization, this will be carried out only through processors and/or specifically appointed and trained Supervisors, with regard to whom refer-ence is made to the specific preceding paragraph.
Nature of the processed data and consequences of any refusal
The provision of generic data relating to browsing by Users, for the above purposes, depends on the degree of privacy enabled or disabled by the user through its browser. In some cases, disabling may affect browsing this Website. For determinate modules of this Website, the provision of browsing data and/or the use of technical cookies is mandatory for the correct functioning of the Website itself.
The provision of some personal data is in any case necessary for the very structure of the Website and its procedures. For example, for sending messages via contact forms or for subscribing to the newsletter, the minimum data required therein are in any case mandatory, such as the USERNAME and/or the name/surname and/or the email address and/or other identification data of the sender;
The provision of personal data for marketing purposes is optional and failure to provide such data does not have consequences for the provision of services by the Data Controller, but prevents it from receiv-ing updates on commercial initiatives.
Any request for other optional data will be preceded by a specific approval check. Failure to provide such data may prejudice the provision of the service by the Data Controller and its partners.
Rights of the party involved
Finally, the Users of the Site are informed that they are entitled to exercise the rights set forth in art. 7 of the Law for the protection of personal data, which is reproduced below, by sending a request ad-dressed to the Data Controller as described above and identified, in paper form to the above address or to the email address firstname.lastname@example.org
The above rights may be exercised personally or by proxy or written power of attorney to individuals or associations, in the manner prescribed by law.
Art. 7. Right of access to personal data and other rights
1. The party involved is entitled to obtain confirmation of the existence or otherwise of personal data concerning it, even if not yet recorded, and their communication in intelligible form.
2. The party involved is entitled to know:
(a) the origin of the personal data;
b) the processing purposes and methods;
c) the logic applied in case of processing carried out using electronic media;
d) the identification details of the controller, supervisors and appointed representative in accordance with article 5, sub-section 2;
e) the entities or categories of entities to whom the personal data may be communicated or who can become acquainted with them as designated representative in the State territory, supervisors or per-sons in charge.
3. The party involved is entitled to obtain:
a) updating, amendment or, when so required, supplementing of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, in-cluding data whose storage is unnecessary for the purposes for which the data were gathered or sub-sequently processed;
c) certification that the operations as per letters a) and b) have been notified, also as regards their content, to those to whom the data were notified or disseminated, except in the case where this re-quirement proves impossible or involves the use of means manifestly disproportionate to the protected right.
4. The party involved is entitled to object, in whole or in part:
a) for legitimate reasons to the processing of personal data concerning it, even if pertinent to the pur-pose of data gathering;
b) to the processing of personal data concerning it for the purpose of sending advertising or direct sales material or for carrying out market or commercial communication surveys.