Version 1.0 of 30 July 2015
1. Type of personal data and purposes of the processing
The IT systems and software procedures, that have been set up to operate this Website, collect personal data as part of their ordinary functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects; however, in consideration of its nature, such information might allow the identification of the Visitors, through processing and matching with data held by third parties. This category of data includes IP addresses and/or the domain names of the computers used by the Visitors connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the Visitor’s operating system and computer environment. These data are only used to obtain anonymous statistical information on Website use as well as to check its functioning; they are erased immediately after being processed. The data might be used to assess liability in case computer crimes are committed against the Website.
Data supplied by the Visitors on a voluntary basis
The voluntary, explicit and optional sending of e-mail messages to the addresses indicated on this Website implies the collection of the sender’s address, which is necessary in order to reply to any request, as well as of such additional personal data as is contained in the message(s). Save as specified for the browsing data, the Visitor does not have an obligation to provide the data requested in the contacts forms on the Website. However, failure to provide such data may result in the impossibility to obtain what has been requested.
2. Other processing purposes: marketing (sending advertising material, direct sale and commercial communication)
Subject to the Visitor’s consent, the personal date will be processed by U-First for marketing purposes (e.g. sending advertising material, direct sale, market research and commercial communication) in order to contact the Visitor by email and propose the purchase of products or services offered by U-First. By providing the email address and clicking on the button “Submit“, “Subscriber“, “Send“, “Register“, or other buttons with a similar label, the Visitor givers his/her consent to the processing of his/her email address for marketing purposes. The Visitor’s consent is optional and, failing to provide such consent, the Visitor will not experience any detrimental effect and his/her possibility to visit the Website and receive a reply or the requested material will not be jeopardized. The Visitor may in any case opt-out at any time from receiving further promotional communications, by contacting U-First as further below indicated.
3. Processing means
Personal data are processed with electronic and non-electronic means, duly taking into account the relevant processing purposes, and in any case by ensuring the security and the confidentially of the data.
4. Persons to whom the data may be communicated and data dissemination
U-First’s employees or collaborators entitled to manage the Website and reply to the Visitors’ requests or send the promotional communications may have access to the Visitors’ personal data. Such individuals, who have been formally appointed by U-First as persons in charge of the processing, will process the Visitors’ personal data exclusively for the purposes indicated in this policy and in accordance with the provisions of the Privacy Code.
Furthermore, third parties appointed by U-First as external data processors, such as, by way of example, IT and logistic service providers for the operation of the Website, outsourcing and cloud computing service providers, professionals and advisors, marketing companies sending marketing communications, which process the Visitors’ personal data on behalf of U-First, may have access to the Visitors’ personal data. Visitors have the right to obtain a list of the possible data processors appointed by U-First, by submitting to the latter a written request by certified mail, email or fax.
The Visitors’ personal data will not be communicated to third-party data controllers nor disseminated.
6. Data subjects’ rights
Pursuant to Section 7 of the Italian Privacy Code, U-First hereby informs the Visitors that they have the right to obtain confirmation as to whether or not personal data concerning them exist, regardless of their being already recorded, and communication of such data in intelligible form. Visitors also have the right to be informed (i) of the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may have access to said data in their capacity as data processor(s) or person(s) in charge of the processing. Furthermore, Visitors have the right to obtain a) updating, rectification or, where they have an implied interest, integration of the data; b) deletion, 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 or subsequently processed; c) certification to the effect that the operations as per letters a) and b) 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. Visitors have the right to object, in whole or in part, a) on legitimate grounds, to the processing of their personal data, even though they are relevant to the purpose of the collection; b) to the processing of their personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The above-mentioned rights can be exercised by contacting U-First by (i) registered mail to the address “Via Giovanni Amendola n. 46, 00185 Rome (Italy)”, (ii) fax to the number +39 06 87811673 or (iii) by email to the email address email@example.com.