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Information on the processing of personal data pursuant to art. 13 of Legislative Decree no. 196/2003 and following the entry into force of the EU Regulation no. 679/2016.

Last update: 24 May 2018

Access to certain sections of the Website/App (hereafter, the "Website") and/or any requests for information or services by users of the Website/App may be subject to the entering of personal data.

Pursuant to art. 13 of Regulation EU no. 679/2016 (General Data Protection Regulation or "GDPR"), every party that enters into contact with our Company by communicating or providing his or her own personal data (the "Data Subject") must be informed as to the possession and processing of the personal data by Voxfarm S.r.l., with main office in Rome (RM), Via dei Monti di Pietralata, 16, 00157 as Data Controller (the "Controller").

Therefore, the Data Subject – before providing his or her own personal data when registering on the Website/App – must view this disclosure.

1 – Source of personal data:
The personal data are collected by the Controller directly from the Data Subjects, or provided by the Data Subjects voluntarily in relation to the services they request, for example when registering in the reserved web area set up by the Controller, by completing an on-line form in order to take part in initiatives or to acquire additional information on the Controller's activity.

2 – Purposes of the processing:
According to the needs expressed from time to time by the user accessing the various sections of the Website/App (and without prejudice to the particular disclosures and regulations for individual operations involving the provision of specific personal data, published from time to time on the Website/App), the following are the purposes of the processing of the personal data, which is to say those provided directly by the users by completing on-line forms, or through the use of social networks (see following section "Nature and mode of provision of the users' Personal Data"), which is to say those acquired automatically (see following section "Categories of Personal Data subject to processing").
Therefore, the Controller announces that the processing of the personal data shall be done with the following purposes:
1 – to allow registration on the Website/App, which is necessary for accessing particular sections of the Website/App and to deliver and manage the various services offered by the Controller, and to allow users to publish Contributions directly on the Website/App, or on websites managed autonomously by third parties with which Voxfarm has, where applicable, made agreements to this effect, such as, merely by way of example and not limitation, social networks like Facebook, Twitter, Instagram etc. (hereafter, "Social Networks"); the publication of the Contributions may also take place along with a nickname chosen by the user while registering on the Website/App, and, where applicable, with the image associated by the user with his or her own nickname, for which: i) the user shall bear sole liability for any choice that should harm the interests of third parties; ii) the user is not required to use personal data allowing third parties other than Voxfarm to identify him or herself, but the user, through Voxfarm, might also disseminate his or her own personal data should he or she have inserted them into the nickname, as well as any photo that he or she has associated with his or her profile.
2 – fulfilment of obligations of law or regulations, or as provided for by EC rules, including provisions imparted by Authorities legitimated for this by law and/or by Supervisory and Control Bodies;
3 – fulfilment and performance of precontractual relations (for example, to respond to users' needs with regard to Voxfarm products, advertising, or the Website/App – "Contacts" section of the Website/App, or to take part in initiatives organized by the Controller) and contractual relations (for example for the performance of e-commerce purchases on the website, also for relations with suppliers of instrumental goods and services and business partners for purposes connected to the performance of the activities aimed at the fulfilment of services and at the delivery of services or goods by the Controller;
4 – fulfilment of administrative, management, and accounting activities;
5 – development of commercial, advertising, and marketing activities, also via direct marketing practices, such as market research, commercial information, surveying of customer satisfaction, telemarketing, automated calling systems without operator intervention, post and e-mail, faxes, and MMS (Multimedia Message Service) and SMS (Short Message Service) messages, IT applications (Apps), in the reserved area of the internet site, or via social networks;
6 – disclosure to third parties, such as a suppliers and business partners, of personal data for marketing purposes, also through direct and commercial marketing practices;
7 –user profiling on the internet site, in order to customize the users' experience on the Website/App and to improve services and products offered by Voxfarm to its customers, and to survey the users' preferences and send them information, including that of a commercial nature, that corresponds more with their interests, using the information provided by them when registering or when completing questionnaires. or on the basis of actions performed or information provided during navigation on the Website/App

3 – Legal basis for the processing and provision of data. Withdrawal of consent to processing:
For the purpose described above, the legal basis for processing is the Data Subject's consent pursuant to art. 6, paragraph 1, letter "a" of the GDPR, documented in written form. For some types of processing, the legal basis for processing may consist of the need to fulfil and to perform a contract that the Data Subject is party to, or precontractual measures adopted at the Data Subject's request (art. 6, paragraph 1, letter "b" of the GDPR), or the fulfilment of legal obligations to which the Controller is subject (art. 6, co. 1, letter "c" GDPR).

The provision of the data, when they are acquired on the basis of a legal obligation or because they are strictly functional to the performance of the precontractual or contractual relationship, is necessary, and any refusal to provide them shall result in the impossibility of performing the activities required to carry out the contract and the services provided by the Controller, even via third parties.

Consequently, the Data Subject, by signing the bottom of this disclosure and/or with the express acceptance of this disclosure via the Controller's web service, expresses his or her consent to the processing of the data for the aforementioned purposes (cf. paragraph 2, no. 1-4).

In this regard, it is mandatory to provide data whose fields are marked with an asterisk, so that Voxfarm might meet the user's needs in the context of the functionalities of the Website/App. The partial or inexact provision of or failure to provide the Personal Data marked by an asterisk as necessary for the performance of the requested service shall make this performance impossible.

For the sole purposes of marketing (cf. paragraph 2, no. 5), disclosure to third parties for marketing and commercial purposes (cf. paragraph 2, no. 6) and profiling (cf. paragraph 2, no. 7), the consent to processing is not mandatory but optional, and subject to the Data Subject's express and specific consent. Therefore, any refusal to provide same shall not impair the legal obligations and the precontractual and contractual services with the Controller.

The provision of Personal Data may take place: a) by completing the fields in the various sections of the Website/App; or b) by autofill, thanks to the Data Subject's request to a Social Network with which it is registered to disclose to Voxfarm some of the data that the Data Subject has already provided to the Social Network; in this latter case, Voxfarm recommends paying attention to the following:
i) when selecting the link that permits registration through a Social Network, present on the Website/App or on one of the Voxfarm pages on the Social Network, a window will appear containing a box to accept the disclosure of the Personal Data by the Social Network to Voxfarm, and three links, to be selected:
a) for the reading of this disclosure;
b) for the list of personal data that are from time to time mandatory or optional, in accordance with the specific purpose of processing;
c) for the list of data that the Social Network is about to disclose to Voxfarm;
ii) once he or she has read the disclosure, the user, having selected the box with which he or she declares being an adult and having learned which data are mandatorily to be provided, may select the link as per point c) above, in order to de-select those data that he or she does not wish to provide to Voxfarm through their disclosure by the Social Network. Both in the case of provision of Personal Data with the completion of fields, and with autofill thanks to the Social Network, should the user have neglected to provide one or more of the mandatory data, a Voxfarm error message will appear, with the list of missing mandatory Personal Data.

Withdrawal of consent to processing
The Data Subject has the right to withdraw his or her consent to the processing of the data, if the legal basis for the processing consists exclusively of the Data Subject's consent (for example, for the purposes of marketing (cf. paragraph 2, no. 5), disclosure to third parties for marketing and commercial purposes (cf. paragraph 2, no. 6), and profiling purposes – cf. paragraph 2, no. 7).

This right does not exist if the processing takes place in fulfilment of legal obligations or for the fulfilment of precontractual or contractual obligations, or relations aimed at the supply of services by the Controller to the Data Subject (paragraph 2, no. 1-4).

In any event, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

4 - Categories of processed data:
The categories of processed data consist of shared data, identification data (such as name, surname, mailing address, e-mail address, password, age, date of birth, sex, image, profession, marital status, etc.), contained in forms and in on-line forms, or in the communications sent by the Data Subjects during their relations with the Controller and for the performance of said relations, which is to say for the use of the related services.
In addition to Personal Data provided directly by the users while connecting to the Website, the IT systems and software procedures tasked with the Website's function administer and/or automatically and indirectly acquire certain information that might constitute personal data, whose transmission is implicit in the use of Internet communication protocols (such as, merely by way of example but not limitation, "cookies" (as better specified below), IP addresses, domain names of the computers employed by the users connecting to the Website, addresses in URL notation of the requested resources, time of the request to the server).

The information on the collection and use of cookies ("Cookie policy") is reported below.

5 – Processing procedures: The data will be processed with respect for the necessary safety and confidentiality, for determined, explicit, and legitimate purposes, they shall be pertinent, updated, and not exceeding the purposes listed above for which they were collected, and may be used in additional processing operations in terms compatible with these purposes. The processing shall take place manually and with the aid of electronic and automated tools (including the collection of data electronically, directly from the Data Subject).

6 – Categories of recipients to which the personal data may be disclosed:
The personal data may be disclosed to the following categories of parties, which shall process them as autonomous Controllers, or Processers tasked with the processing operations under their purview, appointed by the Controller:
1 – suppliers of services and commercial partners chosen by the Controller, which, in that case, shall deal with the processing thereof, without seeing to the dissemination of the data;
2 – specifically hired parties, such as consultants, employees, and other collaborators qualified for the processing operations necessary for or connected to the performance of precontractual and contractual activities and to the services rendered by the Controller, also via third parties;
3 – third parties that perform or provide specific services strictly functional to the precontractual and contractual relationship (e.g. for sale via e-commerce), or services rendered by the Controller (also through ongoing processing operations) with regard to the Data Subject, such as IT services and cloud computing companies; banks and companies performing payment services; agents; companies carrying out deliveries and performing logistics services, professional offices that provide assistance services and tax, legal, or administrative consulting services; credit recovery companies and lawyers hired to follow the credit recovery procedures or litigation; correspondence mailing and printing companies; auditors, if any.
4 – inspection bodies tasked with checks and verifications relating to fulfilment of legal obligations, to which the data may be disclosed following inspections, verifications, and checks. The data are not subject to dissemination or transfer to third countries or international organizations.

7 – Storage periods:
The personal data, including sensitive or judicial data, shall be stored for 10 (ten) years after the termination of the contractual relationship with the Data Subject. If the Data Subject has provided the data for the purpose of taking part in promotional or commercial or charitable initiatives that do not involve the execution of a contractual relationship, the data shall be stored for the lesser duration of 5 years after the data are provided. In any event, this is without prejudice to the possibility of their additional storage in fulfilment of possible legal obligations or for the protection of rights in judicial settings. The personal data may be erased even prior to that period if they are no longer needed for the fulfilment of contractual, administrative, tax, accounting, or legal obligations.

8 – Existence of an automated decision-making process:
There is no automated decision-making process.

9 – Rights of the Data Subject The Data Subject may at any time exercise his or her rights, and in particular the following:
− the right to obtain from the Controller access to the personal data (art. 15 GDPR);
− the right to rectification and completion of the personal data (art. 16 GDPR);
− the right to erasure of the personal data ("right to be forgotten"), in the cases provided for by art. 17 GDPR;
− the right to obtain restriction of processing of the personal data, in the cases and with the procedures established by art. 18 GDPR;
− the right to data portability, in accordance with the provisions of art. 20 GDPR;
− the right to object to the processing of personal data in the cases provided for by law;
− the right to withdraw consent to processing (cf. paragraph 3);
− the right to lodge a complaint with a supervisory authority and in particular with Italy's Garante per la Protezione dei dati personali.

All the rights to which the Data Subject is entitled may be exercised by writing to the Controller's address at: Voxfarm S.r.l., with main office in Rome (RM), Via dei Monti di Pietralata, 16, 00157 – certified e-mail: - - Fax: 0696681333

At the Data Subject's request, the Controller shall provide a copy of the personal data subject to processing. In the event of additional copies requested by the Data Subject, the Controller may charge a reasonable fee based on administrative costs. If the Data Subject submits the request via electronic media, and unless otherwise indicated by the Data Subject, the information is provided in a commonly used electronic format.

10 - Controller, Processor, and DPO (Data Protection Officer)
The Controller is: Voxfarm S.r.l., with main office in Rome (RM), Via dei Monti di Pietralata, 16, 00157, tax code no. 11659621004, in the person of its pro tempore Legal Representative, Mr. Attilio Salinetti
Controller's contact data:

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