This information is, considering the art. 13 – 196/2003 of the “Privacy Policy”, for those that will browse this internet web site (WEB SITE), property of Circle srl, with legal headquarter in Via Moncenisio 75 – 20089 Rozzano MI, C.F. / P. IVA 07869320965, registered to the Company Register in Milan.

The Privacy Policy has the aim of describing the treatment of the personal data of the users that browse the web site and/or use the features and the services available on the web site, as for example contests, initiatives, online purchasing of products and services, participation to forums and discussions etc.

The users are requested to read carefully this information sheet before sending any kind of personal and/or fill any electronic form in the Web Site.

1. TYPE OF DATA TREATED

Circle srl can collect some data, as for example consolidated information during the web site browsing  User ID and password, name, surname, address, location, date and place of birth, e-mail address and/or other personal data voluntary provided by the users during the registration or during the participation to contest or initiatives or during the request of product or services or other requests forwarded by the users through the web site.

The Web site is accessible to the users without the provision of their personal data. However some part of the web site are accessible only to registered users.

1.1 Browsing Data

The computer systems and the software procedures for the functioning of this web site acquire automatically, during their normal operations, some data coming from the browser used and these data are spread automatically during the use of the communication protocols of Internet.

Inside this category of data there are, for example, IP address, domain name of the computer used by the users that browse the web site, the URI address (Uniform Resource Identifier) of the resources requested, the timing of the request to the server,  the way used to make the request to the server, the size of the file got as answer, the code number for the answer status given by the server and other elements related to the operative system. These information, as default, are not collected to be associated to identified interests and they can be used by Circle to obtain statistic nameless information about the use of the web site and to control the correct operation.

These information should be moreover be used for the verification of the responsibility in case of computer crime to damage the web site.

1.3 Personal data provided by the users

Circle collects also the personal data filled by the users in the registration forms or voluntary provided by the users themselves for example to take part to contests or iniziatives organized by Circle or to request products or services offered through the web site.

2. AIMS OF THE DATA PROCESSING

The personal data of the users of the web site will be treated exclusively according to the aims and the manners described in this informative and in compliance with the disposition applicable in the Privacy Policy.  The treatment of the personal data consists in one or more of these following operations:collection, registration, organization, storage, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, communication to third parties, interruption, cancellation and/or destruction of the personal data. Accordingly to the will of the user, the treatment of the personal data will be done – concerning to the situation – for one or more of the following aims:

(a) registration, certification, customization of the access of the user to the different areas of the web site and to the different contents;

(b) provision of products and/or services required by the user and, specifically, the management and execution of the agreement settled by the user and the relative administrative, accounting, financial and legal, and the answer to the request of the user

(c) promotional and marketing activities in relation to the activities and product / services of Circle as for example sales and promotional communication, sending of promotional and advertising material, newsletter sending, brochure, event’s invites, direct sales, market researches, statistical analysis etc. These activities can be made with any manner and, concerning to the situation, through communication by phone or forwarding of mail or through electronic communications (i.e. fax, email. sms or mms) or automatic call systems without the use of an operator.
(d) targeting activities as collection, analysis and elaboration of information related to the user, to his preferences, habits, purchase choices and / or browsing experiences, made with the manners at the point c) – with the help of electronic tools for marketing or customized services supplying, as for example the customization of contents of the web site and of the features available through the web site itself;

(e) compliance to the law, to EU regulation and /or instructions or requirements of the public Authorities

3. DATA PROCESSING

The processing of the personal data will be done in respect to the principles of privacy, accuracy, requirement, relevance, and openness as for Privacy Policy. The treatment of the personal data will be done mostly through electronic tools, in compliance to the law. Suitable security requirements will be used to prevent the loss of personal data, illegal or not correct uses and not authorized accesses.

The personal data of the user will be stored for the timing useful for the aims for which they are collected, and for the safeguard of Circle in a legal procedure.

4. MADATORY OR OPTIONAL DATA ENTRY

The provision of the personal data by the user (as in the form with the field with the asterisk) is mandatory to have access to the reserved areas or to take part to contests/ initiatives to which the user is interested or to answer to the requests of the user or to provide to him/her the products or services requested. If the user doesn’t fill these fields he is not allowed to have access to the reserved areas of the web site or to take part to contests/initiatives to which he is interested in, to receive information, products or services required. The treatment of these data, being related to the answer to the requests of the user itself and / or to  give execution to agreements with the user, don’t require the consensus of  the user itself.

The provision of data by the user for marketing and targeting aims is instead optional and the treatment can be done only with the consensus of the user. If the user doesn’t fill the fields with the personal data can’t have access to the areas of the web site or the participation to contests / initiatives to which he/she is interested in or the reception of information and provision of products and services required.

5. COMMUNICATION AND SPREADING OF THE DATA

For the aims at the point 2 and only for those purposes, the personal data of the user can be shared with the workers, partners and/or sales of Circle, named as responsible of the treatment, concerning the reasons and the limits of the activities they have to do.

The personal data of the users may be shared also with the subjects that makes activities related to the Circle activities:

(i) managers and adiministrators of the computer system;

(ii) management or elaboration of Circle database;

(iii) collection of purchase orders of products and services by the users;

(iv) consulting activities for Circle as administration, accounting, financial, legal;

(v) logistics activities, forwarding and transport;
The personal data of the user will not be spread.

6. OWNER AND ENTITY IN CHARGE OF THE DATA PROCESS

Owner of the data treatment is Circle srl, with legal headquarter in Via Moncenisio 75 – 20089 Rozzano MI, C.F. / P. IVA 07869320965, registered to the Company Register in Milan.

The Sales, Digital and Marketing Department of Circle is in charge of the data treatment.

7. RIGHTS OF USERS

The users can  have the rights included in the article 7 of the privacy code. These rights can be used as indicated in the article 9. Specifically the user will have the right to:

(a) have the confirmation of the presence of the personal data about him/her, even if they are not registered yet, and their communication in a comprehensible way

(b) have indication of the origin of the data, the aims and the ways of treatment, the process applied when the treatment is made with the help of electronic tools; (iv) of the owner and the person in charge of the treatment; and (v) of the subject and the categories of subjects to which the data can be communicated or the indication of the third parties to which the personal data of the user are gave;

(c) have the updating and the integration of the data; the cancellation, the transformation to nameless and the interruption of the data treated against law; including  those for which is not necessary the conservation in relation to the aims for which the data are collected or treated; (iii) the declaration that the operation above are known, also regarding the contents, of those to whom the data are communicated and spread, except the situations in which this fulfillment is not possible.

(d) take position against for reasons related to the treatment of the data, even if are related to the purposes of collecting; and (ii) to the treatment of the data for the sending of the advertising materials or direct sales or for the market researches or sales communication made through traditional manners(by phone or mail) , or through electronic communications (as fax, email, sms or mms) or automated systems.

The right to be opposed can be done also in part, for example only for the sending of promotional communications made by automated tools.

The user has the right at the article 7 of the privacy policy, and the right to know the updated list of the persons in charge of the treatment, sending a mail through postal service to Circle srl, Via Bombrini 13/3 16149 Genoa.