Information on personal data processing - Information on Privacy

This document supplies, according to Italian Legislative Decree nr. 196/2003 (hereinafter, the “Code”), information on personal data processing provided by the user (hereinafter, the “User”), through the website www.ovo.com (hereinafter, the “Website”) to OVO Italia S.r.l. (hereinafter, “OVO™ Italia”), in its quality of Data Controller and Data Processor, and, in particular, about the typology of data, the modalities and the purposes of the personal data processing. This document supplies also explanation about how to contact the Data Controller and the Data Processor in order to formulate questions or to receive any information about the personal data.

The access and the registration on the Website and on the services and applications provided by it (hereinafter, the “Services”) presupposes the consent to the personal data collection and processing, pursuant to the modalities described in this Information on Privacy. This Information on Privacy applies also in case of personal data collected by commercial partners of OVO™ Italia and shared with OVO™ Italia. This Information on Privacy does not apply with reference to the personal data processing carried out by companies not directly controlled by OVO™ Italia or not owned by the latter, or by the staff which is not subordinate employer or not directly managed by OVO™ Italia. The Information on Privacy applies only with reference to this Website and not to other websites in case consulted and/or consultable by the User through links.

Data provided by the User on registration
Generally, the collected and processed data are whatsoever information allowing the User to be directly identified or contacted. As an example, the User can be requested to provide personal data like name, surname, fiscal code, VAT number, email address, date of birth, sex, employment, activity field and, in case, personal interests. The data providing is voluntary; nevertheless, the contingent refusal to supply the data, identified as obligatory by the asterisk, implies the non-acceptance of the registration and the consequent impossibility for OVO™ Italia to provide some Services.
In addiction to the personal data provided by the User, the Website may use technologies which permit to collect some technical information such as, as an example, the Internet protocol address, the operative system used and the typology of browser and of traffic.

Use of data
The personal data provided to OVO™ Italia by the User are used exclusively for the following purposes:

• purposes directly connected and instrumental to the execution and management of the Services, pursuant to the Term and Conditions of the Website;
• statistical purposes, previous achieving of specific consent by the User;
• marketing, commercial information and market survey purposes, included the shot mailing related to item and Services provided by OVO™ Italia or third parties, previous achieving of specific consent by the User;
• purposes concerning the survey about the quality of the Services and the satisfaction of the User, carried out directly and/or in cooperation with other qualified companies, previous achieving of specific consent by the User.

In particular, in the ambit of the abovementioned purposes, OVO™ Italia, previous achieving of specific consent by the User, shall carry out an activity of automatic monitoring of the User navigation profile by means of cookies and other technologies, in order to:

• improve the quality of the Services according to the requirements expressed by the User, in general;
• identify personalized Services and commercial information more suitable for the preferences of each User;
• avoid the indiscriminate display of advertising messages regarding items and/or services extraneous to User’s personal interests.

Divulgation of personal data
OVO™ Italia, in its quality of Data Controller and Data Processor, shall not divulgate to third parties the personal data of the User, except for (a) the communication to the persons in charge of the processing and to the System Administrators; (b) should OVO™ Italia, persons in charge of the processing and System Administrators have to communicate the personal data to third parties in order to fulfill duties set forth by the laws governing them; (c) previous specific consent of the User, OVO™ Italia shall communicate to third companies offering their items and/or services on Internet platform, who with OVO™ Italia entered into commercial or partnership agreement in order to promote the diffusion and distribution of the Services or the offer of new services, and (d) previous specific consent of the User, the communication to third companies, qualified in surveys, concerning the quality of the Services and the satisfaction of the Users, as well as statistical surveys.

Modalities of data processing and security
The personal data processing shall carried out also by means of computerizes or telecommunication tools able to memorize, manage and transmit the data, however by the use of tools able to guarantee their security and confidentiality. In particular, taking into account the risks related to the disclosure of personal data, no system is totally secure or tamper or hacker proof. For this purpose, pursuant to Article 33 ss. of the Code, all the security measures reasonably needed have been implemented in order to avoid and minimize the risks due to any non authorized access, processing, alteration or disruption or contrary to any applicable law.

Cookies and web beacons
The Website uses a technology called “cookies”. The cookies are little data files which are memorized in the computer of the Users when they page to the Website or to part of it. The cookies help OVO™ Italia to realize which part of the Website is more patronized, which are the web pages displayed by the Users in the Website and how long they visit the Website.
OVO™ Italia uses the cookies only to study the traffic of the Website in order to improve the performance of it and satisfy the interests and the preferences of the Users.
The use of the cookies is also in favor of the User; for example, at the subsequent visit on the Website, the cookies may permit the User not to insert again the registration data.
Should the User prefer not to receive the cookies, these latter may be disabled following the directions provided by the browser producer. The Users are requested to follow the directions supplied by the browser in order to receive more information related to these functions.
The “web beacons”, also known as “single pixel” or “clear gif technology” or “action tags”, can be used on the Website. This technology allows OVO™ Italia to check which User has clicked on element (such as links or charts) of a webpage of the Website or of an e-mail of it. As an example, OVO™ Italia may use web beacons in order to know which email addresses of the Users are actually open and working. This information is used by OVO™ Italia in order to optimize and improve the performance of the Website and the Services provided by it.
The web beacons are usually used together with the cookies. Shouldn’t the User wish that the information relevant to its cookie are associated to the visits at the pages of the Website, he shall set up the browser in order to disable the cookies.  

Modification of the Information on Privacy
OVO™ Italia shall modify the contents of the Information on Privacy or modify the access to the Website or its content at any moment, with or without any notice, however publishing the relevant Information on Privacy.

Access to personal data
OVO™ Italia represents and warrants to process personal data in the most obvious way. The User, in its quality of data subject, may: (a) gain access to his personal data, (b) request information, (c) exercise the rights set forth by Article 7 of the Code, such as the right to obtain by the Data Controller confirmation as to whether or not personal data concerning him exist and communication of such data in intelligible form, (d) to be informed about the source of personal data, of the purpose, method processing, the logic applied to the processing, the entities or categories of entity to whom or which the personal data may be communicated, the Data Controller, Data Processor, persons in charge of the processing (e) to obtain the updating, rectification or, where interested herein, integration of the data, erasure, anonymization or blocking of data processed unlawfully, and (f) to object on legitimate grounds, to the processing of personal data, or object to the processing of personal data carried out for marketing, commercial information and statistical purpose. The rights above may be exercised contacting OVO™ Italia at the following e-mail address: legal@ovo.com.

Procedure in order to modify and/or delete data
OVO™ Italia offers to the User the possibility to rectify, modify or delete the information and preferences relevant to his account.
The User can ask the erasure of his account by entering the section of the Website “My OVO” menu “My Profile”.
Should the User make use of some payment Services that OVO™ Italia may offer, directly and/or in collaboration with other commercial partners, the User is aware that OVO™ Italia may have to conserve some personal data, for the time indicated by specific law disposals, even if the User does not use anymore such payment Services or asks the cancellation of his OVO™ Italia’s account.
OVO™ Italia allows the User to revoke/modify the consent to the data processing in any moment pursuant the modalities described by this Information on Privacy.

Data Controller and Data Processor
The Data Controller and Data Processor is OVO Italia S.r.l., with registered office in Via Fratelli Ruffini 10, 20123 - Milano. In order to formulate any question or receive any clarification with reference to personal data, or to exercise the rights set forth by art. 7 of the Code, the User shall contact the Data Controller and Data Processor also via e-mail at the following address: legal@ovo.com.