THE PROCESSING OF PERSONAL DATA BY DIGITAL MAGICS S.P.A.

Information on data protection ex section 13 Legislative Decree No. 196/2003

This privacy policy (“Privacy Policy“), provided pursuant to section 13 of Legislative Decree. No. 196/2003 (Italian Data Protection Code – “PrivacyCode“) is addressed to those who communicate their personal data to Digital Magics S.p.A. (“Digital Magics“), including, without limitation, using the web services of Digital Magics accessible from this website (“Site“).

This Privacy Policy regulates the ways by which Digital Magics collects, stores, uses, communicates, or treats in any other way, the personal data collected from users of the Site (“Users“).

By the term “Personal Data“, is meant any information relating to an individual, that are or can be identified, even indirectly, by reference to any other information, including a personal identification number (art. 4, letter. b, Code) .

Digital Magics may change, amend or update this Privacy Policy periodically, in consideration of possible changes to the applicable regulations or orders of the Authority for the Protection of Personal Data (“Personal Data Authority“), or to the services offered on the Site. The changes and updates of this Privacy Policy are applied and brought to the attention of all parties involved, as soon as they are adopted, through publication on the Site. Consequently, each user is invited to access the Site regularly to check the Privacy Policy.

 

Links

In the Site links to other third-party sites may be present (“Link“), in case they are considered of interest to the User. By linking to such sites, the User will leave this Site on free choice and access to a site owned by third parties. The information contained in these sites are independent and outside the control of Digital Magics, which assumes no liability in this regard, not even in relation to any processing of Personal Data that may take place under these circumstances. Consequently: (i) Digital Magics assumes no liability, nor provides any guarantee as to the nature and content of any third party website linked to this Site through Links; (Ii) this Privacy Policy is not applicable or relevant to the processing of personal data from other websites, even if accessed via Links; (iii) the access to the Link to third party sites is under the sole liability of the Users.

 

Collection of Personal Data

The Personal Data of Users processed by Digital Magics (“Personal Data Processing“), stored on Digital Magics servers or Digital Magics partners, as further specified below, can be collected in various ways, namely:

i. provided directly by the User: all the Personal Data entered on the Site (to browse, register as a user, or, more generally, for any other reason), or disclosed in the course of events organized or participated by Digital Magics, or that are provided to Digital Magics in any manner directly by the User (such as, for example, filling out forms or correspondence).

ii. collected automatically: Personal Data collected automatically through, but not limited to, “cookies”, are – in general – the navigation data of the User. The computer systems and software procedures, used to operate the Site, acquire, during their normal operation, some Personal Data, whose transmission is implicit in the communication protocols of the Internet. These are information that are generally not collected to be associated with identified parties, but by their very nature could, through processing and association with data held by third parties, involve the identification of Users. This category of Personal Information includes IP addresses, or domain names of computers used by Users who connect to the Site, the URI (uniform resource identifier) of the resources requested, the time of the request, the method used in submitting the request, the size of the fileobtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and computer framework of the User. These Personal Data are mostly used for statistical information on the use of the Site and to check its correct functioning. The Personal Data may also be used to ascertain liability in case of computer crimes against the Site.

For further information about the cookies used on the Site and to the purposes for which Digital Magics uses cookies, the User may consult theCookies Policy.

Regardless of how we collect data, Digital Magics is fully aware of the importance regarding the processing of Personal Data of Users. Therefore, in the absence of specific consent of the User, Digital Magics does not collect any information that may allow identification of individual visitors to the Site, nor will make use of any technology aimed to identify an individual User.

 

Place, Methods of processing Data and subjects to which Data can be communicated

The Personal Data Processing usually takes place at the headquarter of Digital Magics. Within Digital Magics, Personal Data are known only by those persons specifically charged of personal data treatment.

Personal Data is processed by Digital Magics and/or third parties, carefully selected for their reliability and competence and to which Personal Data may be disclosed as necessary or opportune, in order to carry out the activities related to the purposes set out in this Privacy Policy (which as, for example, natural and/or legal persons in charge of developing application software and/or databases). In addition, the Personal Data may also be communicated to companies belonging to the group of companies of Digital Magics, which, in any case, have a privacy policy coherent and consistent with that of Digital Magics, provided they are in Italy or in a other  European Union members. In any other case, except as provided by law or the user’s express consent, Personal Data are not transferred and/or disclosed to third parties. The specific list of persons to whom Personal Data may be disclosed, from time to time updated, is available at the registered office of Digital Magics.

The Personal Data is treated in compliance with the obligations and guarantees provided by the Code, both in analogue form and with technological systems by the persons in charge of the Data Processing (employees or third party representatives), for the time necessary to achieve the purposes for which Personal data have been collected. Specific security measures are taken to prevent data loss, illicit or improper use. As soon as the Personal Data is no longer needed for the purposes referred to in this Privacy Policy, Digital Magics provides for their deletion, unless the law sets forth for storage duties or that the User has given his/her consent to the processing for a longer time or for the storage for other purposes.

 

Purpose of Data processing and nature of consensus

Digital Magics collects Personal Data exclusively for the following purposes:

i. purposes related to the use of services offered by Digital Magics and the fulfillment of any contractual undertakings agreed with the User, such as, for example, the management of the registration of the User to the Site or the collection of spontaneous applications presenting by the User;

ii. statistical purposes, market researches, sending information and advertising material, newsletters, informing about promotional and commercial offers and other information services on the activity of Digital Magics.

iii. prevoius acceptance by the User, identify the profile of its Users to customize and tailor the commercial offers.

The provision of Personal Data according to the purposes of point i) is required to enjoy the services of Digital Magics, while the provision of Personal Data for the purposes of points ii) and iii) is freewill and the refusal to such processing involves only the inability to receive certain news or updates on sales and promotional activities, offers or other promotional material and/or tailored offers. At the time of the transfer of Personal Data, in the relevant page of the Site, it will be provided the User’s right to exclude the processing of points ii) and iii).

 

Communication

All communications and/or materials freely submitted from Users to Digital Magics by electronic mail or otherwise, including any data, questions, comments, suggestions or other, will be treated as non-confidential and not protected, unless otherwise indicated or unless the confidentiality of the data is obvious in reason of the nature of the same data. Subject only to the limits of the applicable rules, any document submitted or sent will be owned by Digital Magics and may be used for any purpose, including (but not limited to) reproduction, disclosure, transmission, publication and posting.

 

Rights of the Users

Under Section 7 of the Privacy Code, each User has the right to obtain confirmation by Digital Magics of the storage of Personal Data concerning him, and their communication in intelligible form. In particular, each User has the right to obtain information about:

i) the source of the Personal Data;

ii) the purposes and methods of processing;

iii) the ways in which electronic devices and computer process Personal Data;

iv) the identification data of the data controller, data processor, and representatives appointed under section 5, paragraph 2, of the Privacy Code);

v) the entities or categories of entities to whom Personal Data may be communicated and who or which may get to know Personal data in their capacity as appointed representative(s) in the State, data processor or person in charge of the processing.

In addition, each User has the right to obtain:

i) updating, rectification or, when interested, integration of data;

ii) erasure, anonymisation or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

iii) certification to the effect that the operations in points i) and ii) have been notified, as also related to their contents, to the entities to whom the data were communicated or disseminated, except where such compliance is impossible or involves the use of means manifestly disproportionate to the protected right.

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

i) on legitimate grounds, to the processing of Personal Data concerning him, even tough they are relevant to the scope of the collection;

ii) to the processing of Personal Data, where it is carried out for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial surveys.

Requests under the preceding paragraphs shall be addressed to the Data Controller (as indicated in the following paragraph) by e-mail, postal mail, or registered mail.

In particular, if the User wishes to be removed from the storage of the Users registered on the Site, Digital Magics invites him/her to send an e-mail to the following address: remove@digitalmagics.com including full name and e-mail address and writing in the email subject “Delete Name”.

 

Data Controller

The data controller is Digital Magics S.p.A., with registered office in Via Bernardo Quaranta, 40, 20139, Milan (MI), CF, VAT and Milan Company Register n. 04066730963.

The updated list of all the data processors (if any) and other data controllers (if any) is available at the registered office of Digital Magics above mentioned.