USERS PRIVACY POLICY

Immagina 110 S.r.l. C.F./ P.I. 10077560968 Via Secondo Cremonesi Lodi LO (hereinafter, “IMMAGINA 110”), manager of the internet website http://www.clyck.it (hereinafter, the “Website”), hereby provides the privacy policy pursuant to Article 13 of the Legislative Decree No. 196/2003 (the “Privacy Code”), in its capacity as data controller in relation to personal data pertaining to the users registered to the Website (hereinafter, the “Users”). IMMAGINA 110 takes the outmost account to the privacy rights and to the protection of its Users’ personal data. Users may contact IMMAGINA 110 for any information in relation to this privacy policy at any time whatsoever using the contacts specified under the following paragraph 5.

1. Purposes of data processing

The Users’ personal data will be processed by IMMAGINA 110 for the following processing purposes: a) contractual obligations (Article 24, paragraph 1, letter b) of the Privacy Code), i.e. in order to give execution to the general terms and conditions published on the Website, being accepted by the User during the registration process; fulfil specific requests of the User. Subject to the User giving IMMAGINA 110 a specific and optional consent to its data processing for marketing purposes pursuant to the subsequent paragraph 2, any contact data (name, surname, electronic mail address) will be used by IMMAGINA 110 for the sole purpose of ascertaining the identity of the relevant User (also by means of validation of the electronic e-mail address), avoiding frauds or infringements, and contact the User only for services reasons. b) accounting-administrative purposes (Article 24, paragraph 1, letter 1-ter) of the Privacy Code), or in order to carry out organisational, administrative, financial and accounting activities, as internal organisational activities and activities aimed at fulfilling contractual and precontractual obligations; c) legal obligations (Article 24, paragraph 1, letter a) of the Privacy Code), or in order to fulfil obligations provided by the law or the European laws and regulations. Providing the personal data for the processing purposes specified above is optional but necessary, since failing to provide the same imply the impossibility to register to the Website. A star in the registration form on the Website identifies the personal data, which are necessary for purporting the processing purposes described under this paragraph 1.

2. Further purposes of processing: marketing (sending advertising material, direct sales and commercial communication)

With the free and optional User’s consent, some User’s personal data (name, surname, electronic mail address and phone number) may be processed by IMMAGINA 110 also for marketing purposes (direct sale, dispatch of marketing material and commercial communication) or in order for IMMAGINA 110 to contact the relevant User by means of electronic mail for proposing to the same to purchase products and/or services offered by IMMAGINA 110 and/or third parties companies, present offers, promotions and commercial opportunities on the Website. Giving consent to personal data processing for such purpose is free and optional and, in the event such consent is missing, the possibility to subscribe to the Website is not prevented in any manner whatsoever. In the event that such consent has been granted, the relevant User may revoke the same at any time whatsoever upon request to IMMAGINA 110 following the methods specified under the following paragraph 5. The relevant User may also easily oppose to the sending of further marketing communications (by e-mail) also clicking on the specific revocation link for revoking the consent, which is included in each marketing e-mail. Once revoked the consent, IMMAGINA 110 will send to the User an electronic mail message in order to confirm that the consent has been actually revoked. IMMAGINA 110 hereby informs that, following the exercise of the right to object to the sending of contact communications (already completed a little before the receipt by IMMAGINA 110 of the objection request) the relevant User continues receiving further marketing messages. In the event that the relevant User continues receiving marketing messages once elapsed 24 hours from the exercise of the objection right, please flag such issue to IMMAGINA 110, using the contacts specified under the following paragraph 5.

3. Processing methods

Users’ personal data processing will be carried out by manual and IT instruments, applying logics strictly connected to the purposes and, in any case, so that the safety and confidentiality of the relevant data is guaranteed.

4. Data disclosure and dissemination

IMMAGINA 110’s employees and/or workers appointed to manage personal data may become aware of any Users’ personal data. Such subjects, who are formally appointed by IMMAGINA 110 as “persons in charge for the processing”, will process the relevant User’s data exclusively for the purposes specified under this policy and in compliance with the provisions of the Privacy Code. Furthermore, third parties which may process personal data for the account of IMMAGINA 110 may become aware of any Users’ personal data in their capacity as “third parties data supervisors”, such as, including, but not limited to, providers of logistics and IT services functional for the Weboperational, outsourcing or cloud computing services providers, professionals and advisors, companies entrusted with the sending of marketing e-mails for the account of IMMAGINA 110. Any users have the right to obtain a list of the data supervisors (if any) appointed by IMMAGINA 110 upon a specific request to be made to IMMAGINA 110 following the modalities specified under the following paragraph 5.

5. Data subjects’ rights

Pursuant to Article 7 of the Privacy Code, IMMAGINA 110 hereby informs that any Users has the right to obtain the indication of (i) the source of the personal data; (ii) the purposes and methods of the processing; (iii) the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) the identification data concerning data controller and data processors; (v) the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated data processor(s) or person(s) in charge of the processing. Furthermore, data subjects have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, 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. Users have the right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, 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. Users may exercise such rights by contacting IMMAGINA 110 by sending an electronic mail message to info@clyck.it with as subject “Privacy”.