Privacy Policy

Privacy Policy Article 13, Italian Legislative Decree 196/2003

This statement (“Policy”), made pursuant to the provisions of article 13 of Italian Legislative Decree 196/2003 (Code regarding the protection of personal data – “Privacy Code”) is aimed at those who communicate their personal data to GUT Edizioni S.p.A. (“GUT”),including, but not limiting to, the use of GUT web services accessible through the website www.gutedizioni.com (“website”).

This Policy governs the procedures by which GUT collects, stores, uses, communicates, or – in any other way – treats personal data collected from the users (“Users”)of its Website.

The term “Personal Data” refers to any information related to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number (Privacy Code: article 4, letter b).

GUT may periodically amend, supplement or update this Policy, in consideration of possible changes to the applicable regulations or of provisions of the Italian Data Protection Authority (“DPA/Authprity”) or of services offered on the Website. Through their publication on this Website, changes and updates to this Policy are brought to the attention of the Users and go into effect as soon as they are adopted.Consequently, every User is invited to access the Website from time to time to check if the Policy has possibly been revised.

Hyperlinks

The Website may contain links to third-party websites (“Links“), which may be considered of interest to the User. By clicking on such external links, you leave the GUT Website of your own free choice and access to websites owned by third parties. All information contained in these websites is independent and outside the control of GUT, which assumes no responsibility in this regard, even concerning the possible treatment of Personal Data that may take place in these circumstances. Consequently: (I) GUT assumes no responsibility nor provides any guarantee as to the nature and content of any third-party website linked to this Website via Links; (II) this Policy is not applicable or relevant to the processing of data by other websites, even if the latter are accessed by the User via Links; (III) connection to third-party websites is the sole responsibility of the Users.

Personal Data Collection

Users’ Personal Data processed by GUT (“Personal Data Processing“) may be collected in different ways, namely:

I. they may be provided directly by the User: all Personal Data entered in this Website (to surf the Internet, to register as a User, or, more generally, for any other reason), or communicated in the course of events organized or participated by GUT, or provided in any way to GUT directly by the User (e.g. by filling out forms or correspondence);

II. they may be automatically collected: all Personal Data automatically collected through, but not limited to, the so-called “cookies“, are – as a general rule – data related to the User’s use of the Web. The computer systems and software procedures used to operate this Website acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet Communication protocols. For more information about the cookies used on this Website and the purposes for which GUT uses cookies, the User may consult the Cookies Statement.

Through this Website, GUT neither requests nor collects Sensitive Personal Data (such as information that could reveal racial or ethnic origin; political, philosophical or religious beliefs; sexual habits or health data). Otherwise, GUT commits to seek prior consent of the User.

Place, Mode of Personal Data Processing and persons to whom the information may be disclosed

Personal Data Processing takes place – as a general rule – at the headquarters of GUT and/or at the headquarters of the electronic communication service providers of the company. Such Data are known only by appointed technical personnel or by some employees during occasional maintenance operations.

Personal Data are processed by GUT and/or by third parties: the latter are carefully selected for their reliability and competence and to them it may be disclosed what is necessary or appropriate in order to carry out the activities related to the purposes referred to in this Policy (such third parties can be, for example, natural and/or legal persons responsible for developing application software and/or databases). Personal Data may also be communicated to corporations belonging to the group of companies of which GUT is part. Such corporations, in any case, have a privacy policy coherent and consistent with that of GUT, provided they are located in Italy or in a European Union country. In any other case, except as provided by law or by the User’s express consent, Personal Data are not transferred and / or disclosed to third parties. The precise list of persons to whom Personal Data may be disclosed is available, updated from time to time, at the registered office of GUT.

Personal Data are treated by our employees (personnel or third party representatives) – in compliance with the obligations and guarantees provided by the Privacy Code – both in analog form and with information technology systems, for the time strictly necessary to achieve the purposes for which they are collected. Specific security measures are observed to prevent the loss, or the illegal or otherwise improper/not correct use, of such data. As soon as Personal Data are no longer required for the purposes referred to in this Policy, GUT provides for their cancellation, unless the law does not provide for storage obligations or unless the User has not consented to their treatment for a longer time or to their archiving for other purposes

Purposes of the processing and nature of consent

GUT processes Personal Data solely for the following purposes:

I. the purposes related to the use of services offered by GUT and fulfillment of any contractual obligations established with the User, especially if the User intends to make use of the opportunity to communicate with GUT through the “Contacts” section;

II. subject to User’s consent: statistical purposes; market research; mailing of information, advertising materials and newsletters; notification of promotions and marketing offers and other information services concerning GUT’s activities;

III. subject to User’s consent: definition of the profile of its Users in order to customize and individualize offers.

II.  the provision of data for the purposes referred to at point i) is required to deliver GUT services, while that for points ii) and iii) is voluntary and any refusal to such treatment only involves the inability to receive news or updates of sales and promotional activities, offers or other promotional materials and / or customized offers. When User’s Personal Data are granted, in the relevant page of this Website the User is given the option to exclude the uses referred to at points II) and III). In the event that the User does not wish to receive any advertising message from GUT, the User is invited to contact GUT at the address listed in the “Data Controller” section.

Comunication

All communications and/or materials transmitted voluntarily to GUT from Users by electronic mail or otherwise, including any data, questions, comments, suggestions or other, will be treated as non-confidential and unprotected unless otherwise indicated or unless the confidential nature of the data is evident in view of the nature of the same. Subject only to the limits of the applicable rules, any forwarded or submitted document will become property of GUT and may be used for any purpose, including (but not limited to) reprint, disclosure, transmission, publication and posting.

Users’ Rights

According to Article 7 of the Privacy Code, each User has the right to obtain from GUT the confirmation of saving his or her Personal Data as well as communicating of such Data in an intelligible form. More precisely, each User has the right to obtain information concerning:

I. the origin of Personal Data;

II. the purposes and methods of the processing

III. the manner in which electronic and information technology instruments process Personal Data;

IV. the identity of the owner, of managers (or of the designated representative under Article 5, paragraph 2, of the Privacy Code);

V. the recipients or categories of recipients to whom the Personal Data may be communicated or who can learn about acting as appointed representatives in the State territory, or acting as managers or agents.

In addition, each User has the right to obtain

I. the updating, rectification or, when interested, integration of data;

II. the cancellation, anonymization or block of unlawfully processed data, including data whose retention is unnecessary for the purposes for which such data were collected or subsequently processed;

III. the certification that the operations referred to at points i) and ii) above have been notified, also regarding their content, to those to whom the data were communicated or disclosed, except where such compliance It proves impossible or involves a use of resources manifestly disproportionate to the protected right.

The User also has the right to object, in whole or in part:

I. for legitimate reasons, to the processing of Personal Data concerning her- or himself, even if relevant to the purpose of the collection;

II. to the processing of Personal Data concerning her- or himself, for mailing of advertising or direct sale material or for carrying out market research or commercial communication.

Requests referred to in the previous points should be addressed to the Data Controller (as indicated in the following paragraph) by e-mail, regular mail or registered mail.

Data Controller

The Data Controller is GUT Edizioni S.p.A., based in Milan, Italy, IT 20139 -Viale Ortles, 52/54. E-mail: info@gutedizioni.com

The updated list of all Data Controllers (if appointed) and of other Controllers (if any) can be obtained at the above-mentioned registered office of GUT.