PRIVACY POLICY

Daniela Dallavalle Spa, a company with its Registered Office in Viale J.A. Fleming 9-11 – 41012 Carpi (Mo) set up and operating in conformity with Italian law, recognises the importance of the privacy of the users of its site and undertakes to respect it.

The information provided to users and contained in this privacy policy (to be called the “Privacy Policy“) refers to the site www.danieladallavalle.com. It includes details of the Data Controller of the processing, the personal data collected through the site, the purposes and procedures for the processing of such data, the third parties involved in the processing, the possible transfer of the data abroad, the safety measures adopted in order to protect the data collected and the procedures available to the user to check the processing of the data relating to him or her and exercise the rights imparted by Legislative Decree no. 196 of 30 June 2003 (hereinafter to be called “D.Lgs. 196/2003“).

This Privacy Policy has been drawn up in compliance with Recommendation no. 2/2001, adopted on 17 May 2001 by the Article 29 Personal Data Protection Working Group in relation to minimum requirements for the online collection of data in the European Union and also represents the information provided to data subjects pursuant to Article 13 of Legislative Decree 196/2003, set out below to provide adequate information for the user:

Article 13. Legislative Decree 196/2003 Information

1. The data subject or the person from whom the personal data are collected must be informed in advance, orally or in writing, of the following:

a) the manner and purpose of the intended processing of the data;

b) whether the provision of the data is obligatory or discretionary;

c) the consequences of a refusal to reply;

d) those parties or categories of parties to whom the personal data may be communicated or which may obtain knowledge of the same in the capacity of Data Processor or processing staff and the ambit of the communication of such data;

e) the rights described in Article 7;

f) the identifying details of the Data Controller or, if appointed, the Representative in State Territory pursuant to Article 5 and of the Data Processor. When the Data Controller has appointed more than one Data Processor, at least one of these must be indicated, also indicating the communication network site or the manner by which the updated list of the data processors can be easily identified. When a Data Processor has been designated to reply to the data subject in the case of the exercise of rights pursuant to Article 7, the details of such data processor must be provided to the data subject.

2. The information set out in paragraph 1 must also contain the elements required by specific provisions of this code. It will not have to contain elements already known to the person providing the data or knowledge of which might impede the conduct by a public body of functions in the form of inspection or checking carried out for purposes of defence or security of the state or the prevention, investigation or suppression of offences.

3. The Regulatory Authority may issue instructions defining simplified procedures for the information provided by telephone assistance and public information services in particular.

4. If the personal data have not been collected directly from the data subject, the information described in paragraph 1, including the categories of data processed, must be given to the data subject at the moment the data are recorded or, if their communication is envisaged, no later than the making of the first such communication.

5. The provision set out in paragraph 4 will not apply when:

a) data are processed pursuant to an obligation laid down by law, regulations or Community law;

b) the data are processed for the purpose of the conduct of defensive investigative operations pursuant to Law no. 397 of 7 December 2000 or, in any case, to enforce or defend a right in judicial proceedings so long as the data are processed exclusively for such purposes and for the period strictly necessary for their pursuit;

c) the provision of the information to the data subject entails the use of means which the Regulatory Authority, by the provision of appropriate measures, declares to be manifestly disproportionate with respect to the right to be defended, or is shown, in the view of the Regulatory Authority, to be impossible.

5-bis. The information described under paragraph 1 is not required in the event of receipt of curriculum vitae sent spontaneously by data subjects for the purposes of the possible initiation of employment relations. At the moment of the first contact subsequent to the sending of the curriculum, the Data Controller will be required to provide the data subject with succinct information, including orally, containing at least the elements set out in paragraph 1, a), d) and f). (1)

This Privacy Policy has been drawn up for this site alone and not for any other web-sites that the user may visit by means of the links on the site, to which the party drafting this policy declares itself to be entirely unconnected for all effects and purposes.

TYPE OF PERSONAL DATA COLLECTED AND PROCESSED

Navigation data

If a user visits and views the site www.danieladallavalle.com, the site does not generally collect the personal data of the user apart from so-called “Navigation Data”. The technological platform by which the site is made available to users records some navigation data automatically whose transmission is implicit in the use of internet communication protocols such as the name of the internet access provider, the site of origin, the pages visited, the date and duration of the visit, etc. The above information is required for access to the site and the use of some services and may be analysed in anonymous and aggregate form for statistical purposes and to check the correct functioning of the site.

www.danieladallavalle.com does not collect these data to associate them with other information regarding users in order to be able to identify a particular user subsequently. Nonetheless, these data, by their very nature, could permit the identification of users following processing and association with other information. Navigation data may thus be used by www.danieladallavalle.com for the identification of possible liability for the commission of computer offences causing damage to the site or through the site. Save for the above possibility, the navigation data described are stored only temporarily in compliance with the applicable law.

Data provided voluntarily by the user

www.danieladallavalle.com collects and processes personal data provided voluntarily by the user when interacting with site functionality and services, for example, when registering to receive news relating to the world of Daniela Dallavalle and the newsletter and other commercial communications, and sending spontaneous job applications as also in the case of requests for information or that information be sent to third parties. Those sections of the site where the user’s personal data are collected display the information required pursuant to Article 13 of Legislative Decree 196/2003 and specific consent is requested for the processing of the data provided in such sections in compliance with the above Decree.

PURPOSES OF THE PROCESSING

Daniela Dallavalle Spa processes user data for the following purposes:

• The management of the registration on the site and operational management of site navigation;

• Management of the site’s security;

• Market research and statistical surveys;

• Recruitment and selection of staff;

• Compliance with obligations imposed by laws and regulations;

• The exercise of its rights in judicial proceedings.

Following the user’s consent, the Data Controller will be entitled to process the data for the purposes of identifying individual and group profiles (profiling activities) as also for marketing purposes such as communication by means of newsletters, electronic mail and sms, of information and/or updates on Daniela Dallavalle Spa products together with the initiatives and events organised by Daniela Dallavalle Spa including possible invitations to such initiatives and events.

The user may in any case indicate his or her opposition to the sending of promotional e-mails (newsletters) at any time. An explanation will be provided for each communication of how to oppose the related processing and not to receive further e-mails.

NATURE OF THE PROVISION

Apart from navigation data (collected automatically by the system), the provision of data by the user for the purposes indicated above will be discretionary. Any failure to provide data for marketing will have no consequence on his or her ability to gain access to the functionality offered by the site apart from the inability to use the services strictly connected to registration. Any failure to provide data for profiling purposes will have no consequence in relation to his or her ability to gain access to the functionality offered by the site.

MANNER OF PROCESSING

The personal data provided by the user will be processed using computerised and online procedures, prevalently through the use of automated electronic means and (this being limited to specific operations) by means of paper-based media.

In compliance with Legislative Decree 196/2003, specific security measures are employed to prevent the loss, unlawful and improper use, of the data and unauthorised access to the same.

PARTIES INVOLVED IN THE PROCESSING

The user’s personal data will be processed by persons identified as data processors or processing staff pursuant to the provisions of Articles 29 and 30 of Legislative Decree 196/2003.

Such data may be made known to the other companies which collaborate with Daniela Dallavalle Spa. Furthermore, such data may be transferred outside Italian territory with the user’s consent, to other parties collaborating with Daniela Dallavalle Spa.

In addition to the above, the data may be made known to other third parties such as professionals, consultants and, more generally, third parties co-operating with Daniela Dallavalle Spa in the achievement of the purposes described above, that is, third parties entrusted with activities on the basis of outsourcing arrangements.

In any case, Daniela Dallavalle Spa hereby undertakes only to provide the data to such third parties necessary for the completion of the functions and activities entrusted to them. It also undertakes to take all possible steps to ensure that the third parties use the data received only for the purposes indicated by Daniela Dallavalle Spa and in compliance with the applicable law concerned with personal data processing.

The user’s personal data may also be made known to third party companies in the case of merger or company division, of purchase or assignment of the business or business division or in the case of other company operations of an extraordinary nature.

The user’s personal data may also be made known to legitimate recipients pursuant to law or regulations, for example, in the case of requests by competent public or judicial authorities or, more generally, in the context of judicial proceedings as also in the protection and defence of the site and of the rights of Daniela Dallavalle Spa

The above parties will process the data in the capacity of autonomous Data Controllers or Data Processors as the case may be

The updated list of all Data Processors may be requested of the Data Controller identified below at the e-mail address infotrattamentoprivacy@danieladallavalle.com or by use of the fax number +39 059-6323571

The data will not be subject to dissemination.

CONNECTIONS WITH THIRD PARTY SERVICES AND SITES

The site or other messages or communications sent to users by Daniela Dallavalle Spa may contain banners, advertising messages and advertisements of third parties or commercial partners of the Data Controller.

If users follow up the proposals made by the above-cited third parties, they may gain access to multi-media pages appertaining exclusively to such third parties, which, being out of the control of the Data Controller, are in no way bound to comply with the provisions of this Privacy Policy.

Daniela Dallavalle Spa thus invites users to take care in following up services offered by third parties and to read the information provided by such third parties in relation to the personal data processing effected by the latter. The Data Controller is unable to exercise control over the same and may not be held liable in that regard.

AMENDMENTS TO THIS DOCUMENT

This Privacy Policy may be amended to comply with new legal requirements, with changes in data processing effected by Daniela Dallavalle Spa or because of changes relating to the operation of the site or the provision of services rendered through the same.

Daniela Dallavalle Spa will communicate any updating immediately by publishing the same in this section and thus invites users to check the Privacy Policy on a periodical basis to be sure that they have read the latest version to be published.

DATA CONTROLLER

The Data Controller is Giuliano Cavaletti based at Daniela Dallavalle Spa, with its Registered Office in Via Fleming 9-11 – 41012 Carpi (Mo)

THE USER’S RIGHTS

Users of the site may exercise the rights laid down in Article 7 of Legislative Decree 196/2003, which has been set out in its entirety below. Such rights may be exercised without formality by simple request to the Data Controller identified above to the e-mail address indicated or the fax number +39 059-6323571

Article 7 of Legislative Decree 196/2003
Right of Access to Personal Data and other Rights

1. 1. The Data Subject will have the right to obtain confirmation of the existence or otherwise of personal data regarding him, even if not yet recorded, and the communication of the same in intelligible form.

2. The Data Subject will have the right to obtain indications on the following:

a. the origin of the personal data;

b. the purpose and procedures used in the processing of the same;

c. the logic applied in the case of processing effected using electronic means;

d. the identifying details of the Data Controller, the Data Processors and the Designated Representative pursuant to Article 5, paragraph 2;

e. the parties or categories of parties to which the personal data may be communicated or which may come to know of the same in their capacity as designated representative within the territory of the state, Data Controller or Data Processor.

3. The Data Subject will have the right to obtain the following:

a. the updating, correction, or, where this is in his interests, supplementing of the data;

b. the deletion, conversion into anonymous form or blocking of any data processed in breach of the law, including those which do not have to be preserved in relation to the purposes for which the data were collected or subsequently processed;

c. receipt of confirmation that the parties to whom the data have been communicated or disclosed have been informed of the operations referred to under letters a) and b) above, including with regard to their content, save in circumstances where such compliance is shown to be impossible or entails the use of resources manifestly disproportionate to the right to be protected.

4. The Data Subject will have the right to oppose, in whole or in part:

a. on legitimate grounds, the processing of personal data concerning him even though pertinent to the purpose for which it was collected;

b. the processing of personal data regarding him for the purposes of the sending of advertising materials, direct sales, the conduct of market research or commercial communications.

PRIVACY POLICY

Daniela Dallavalle Spa, a company with its Registered Office in Viale J.A. Fleming 9-11 – 41012 Carpi (Mo) set up and operating in conformity with Italian law, recognises the importance of the privacy of the users of its site and undertakes to respect it.

The information provided to users and contained in this privacy policy (to be called the “Privacy Policy“) refers to the site www.danieladallavalle.com. It includes details of the Data Controller of the processing, the personal data collected through the site, the purposes and procedures for the processing of such data, the third parties involved in the processing, the possible transfer of the data abroad, the safety measures adopted in order to protect the data collected and the procedures available to the user to check the processing of the data relating to him or her and exercise the rights imparted by Legislative Decree no. 196 of 30 June 2003 (hereinafter to be called “D.Lgs. 196/2003“).

This Privacy Policy has been drawn up in compliance with Recommendation no. 2/2001, adopted on 17 May 2001 by the Article 29 Personal Data Protection Working Group in relation to minimum requirements for the online collection of data in the European Union and also represents the information provided to data subjects pursuant to Article 13 of Legislative Decree 196/2003, set out below to provide adequate information for the user:

Article 13. Legislative Decree 196/2003 Information

1. The data subject or the person from whom the personal data are collected must be informed in advance, orally or in writing, of the following:

a) the manner and purpose of the intended processing of the data;

b) whether the provision of the data is obligatory or discretionary;

c) the consequences of a refusal to reply;

d) those parties or categories of parties to whom the personal data may be communicated or which may obtain knowledge of the same in the capacity of Data Processor or processing staff and the ambit of the communication of such data;

e) the rights described in Article 7;

f) the identifying details of the Data Controller or, if appointed, the Representative in State Territory pursuant to Article 5 and of the Data Processor. When the Data Controller has appointed more than one Data Processor, at least one of these must be indicated, also indicating the communication network site or the manner by which the updated list of the data processors can be easily identified. When a Data Processor has been designated to reply to the data subject in the case of the exercise of rights pursuant to Article 7, the details of such data processor must be provided to the data subject.

2. The information set out in paragraph 1 must also contain the elements required by specific provisions of this code. It will not have to contain elements already known to the person providing the data or knowledge of which might impede the conduct by a public body of functions in the form of inspection or checking carried out for purposes of defence or security of the state or the prevention, investigation or suppression of offences.

3. The Regulatory Authority may issue instructions defining simplified procedures for the information provided by telephone assistance and public information services in particular.

4. If the personal data have not been collected directly from the data subject, the information described in paragraph 1, including the categories of data processed, must be given to the data subject at the moment the data are recorded or, if their communication is envisaged, no later than the making of the first such communication.

5. The provision set out in paragraph 4 will not apply when:

a) data are processed pursuant to an obligation laid down by law, regulations or Community law;

b) the data are processed for the purpose of the conduct of defensive investigative operations pursuant to Law no. 397 of 7 December 2000 or, in any case, to enforce or defend a right in judicial proceedings so long as the data are processed exclusively for such purposes and for the period strictly necessary for their pursuit;

c) the provision of the information to the data subject entails the use of means which the Regulatory Authority, by the provision of appropriate measures, declares to be manifestly disproportionate with respect to the right to be defended, or is shown, in the view of the Regulatory Authority, to be impossible.

5-bis. The information described under paragraph 1 is not required in the event of receipt of curriculum vitae sent spontaneously by data subjects for the purposes of the possible initiation of employment relations. At the moment of the first contact subsequent to the sending of the curriculum, the Data Controller will be required to provide the data subject with succinct information, including orally, containing at least the elements set out in paragraph 1, a), d) and f). (1)

This Privacy Policy has been drawn up for this site alone and not for any other web-sites that the user may visit by means of the links on the site, to which the party drafting this policy declares itself to be entirely unconnected for all effects and purposes.

TYPE OF PERSONAL DATA COLLECTED AND PROCESSED

Navigation data

If a user visits and views the site www.danieladallavalle.com, the site does not generally collect the personal data of the user apart from so-called “Navigation Data”. The technological platform by which the site is made available to users records some navigation data automatically whose transmission is implicit in the use of internet communication protocols such as the name of the internet access provider, the site of origin, the pages visited, the date and duration of the visit, etc. The above information is required for access to the site and the use of some services and may be analysed in anonymous and aggregate form for statistical purposes and to check the correct functioning of the site.

www.danieladallavalle.com does not collect these data to associate them with other information regarding users in order to be able to identify a particular user subsequently. Nonetheless, these data, by their very nature, could permit the identification of users following processing and association with other information. Navigation data may thus be used by www.danieladallavalle.com for the identification of possible liability for the commission of computer offences causing damage to the site or through the site. Save for the above possibility, the navigation data described are stored only temporarily in compliance with the applicable law.

Data provided voluntarily by the user

www.danieladallavalle.com collects and processes personal data provided voluntarily by the user when interacting with site functionality and services, for example, when registering to receive news relating to the world of Daniela Dallavalle and the newsletter and other commercial communications, and sending spontaneous job applications as also in the case of requests for information or that information be sent to third parties. Those sections of the site where the user’s personal data are collected display the information required pursuant to Article 13 of Legislative Decree 196/2003 and specific consent is requested for the processing of the data provided in such sections in compliance with the above Decree.

PURPOSES OF THE PROCESSING

Daniela Dallavalle Spa processes user data for the following purposes:

• The management of the registration on the site and operational management of site navigation;

• Management of the site’s security;

• Market research and statistical surveys;

• Recruitment and selection of staff;

• Compliance with obligations imposed by laws and regulations;

• The exercise of its rights in judicial proceedings.

Following the user’s consent, the Data Controller will be entitled to process the data for the purposes of identifying individual and group profiles (profiling activities) as also for marketing purposes such as communication by means of newsletters, electronic mail and sms, of information and/or updates on Daniela Dallavalle Spa products together with the initiatives and events organised by Daniela Dallavalle Spa including possible invitations to such initiatives and events.

The user may in any case indicate his or her opposition to the sending of promotional e-mails (newsletters) at any time. An explanation will be provided for each communication of how to oppose the related processing and not to receive further e-mails.

NATURE OF THE PROVISION

Apart from navigation data (collected automatically by the system), the provision of data by the user for the purposes indicated above will be discretionary. Any failure to provide data for marketing will have no consequence on his or her ability to gain access to the functionality offered by the site apart from the inability to use the services strictly connected to registration. Any failure to provide data for profiling purposes will have no consequence in relation to his or her ability to gain access to the functionality offered by the site.

MANNER OF PROCESSING

The personal data provided by the user will be processed using computerised and online procedures, prevalently through the use of automated electronic means and (this being limited to specific operations) by means of paper-based media.

In compliance with Legislative Decree 196/2003, specific security measures are employed to prevent the loss, unlawful and improper use, of the data and unauthorised access to the same.

PARTIES INVOLVED IN THE PROCESSING

The user’s personal data will be processed by persons identified as data processors or processing staff pursuant to the provisions of Articles 29 and 30 of Legislative Decree 196/2003.

Such data may be made known to the other companies which collaborate with Daniela Dallavalle Spa. Furthermore, such data may be transferred outside Italian territory with the user’s consent, to other parties collaborating with Daniela Dallavalle Spa.

In addition to the above, the data may be made known to other third parties such as professionals, consultants and, more generally, third parties co-operating with Daniela Dallavalle Spa in the achievement of the purposes described above, that is, third parties entrusted with activities on the basis of outsourcing arrangements.

In any case, Daniela Dallavalle Spa hereby undertakes only to provide the data to such third parties necessary for the completion of the functions and activities entrusted to them. It also undertakes to take all possible steps to ensure that the third parties use the data received only for the purposes indicated by Daniela Dallavalle Spa and in compliance with the applicable law concerned with personal data processing.

The user’s personal data may also be made known to third party companies in the case of merger or company division, of purchase or assignment of the business or business division or in the case of other company operations of an extraordinary nature.

The user’s personal data may also be made known to legitimate recipients pursuant to law or regulations, for example, in the case of requests by competent public or judicial authorities or, more generally, in the context of judicial proceedings as also in the protection and defence of the site and of the rights of Daniela Dallavalle Spa

The above parties will process the data in the capacity of autonomous Data Controllers or Data Processors as the case may be

The updated list of all Data Processors may be requested of the Data Controller identified below at the e-mail address infotrattamentoprivacy@danieladallavalle.com or by use of the fax number +39 059-6323571

The data will not be subject to dissemination.

CONNECTIONS WITH THIRD PARTY SERVICES AND SITES

The site or other messages or communications sent to users by Daniela Dallavalle Spa may contain banners, advertising messages and advertisements of third parties or commercial partners of the Data Controller.

If users follow up the proposals made by the above-cited third parties, they may gain access to multi-media pages appertaining exclusively to such third parties, which, being out of the control of the Data Controller, are in no way bound to comply with the provisions of this Privacy Policy.

Daniela Dallavalle Spa thus invites users to take care in following up services offered by third parties and to read the information provided by such third parties in relation to the personal data processing effected by the latter. The Data Controller is unable to exercise control over the same and may not be held liable in that regard.

AMENDMENTS TO THIS DOCUMENT

This Privacy Policy may be amended to comply with new legal requirements, with changes in data processing effected by Daniela Dallavalle Spa or because of changes relating to the operation of the site or the provision of services rendered through the same.

Daniela Dallavalle Spa will communicate any updating immediately by publishing the same in this section and thus invites users to check the Privacy Policy on a periodical basis to be sure that they have read the latest version to be published.

DATA CONTROLLER

The Data Controller is Giuliano Cavaletti based at Daniela Dallavalle Spa, with its Registered Office in Via Fleming 9-11 – 41012 Carpi (Mo)

THE USER’S RIGHTS

Users of the site may exercise the rights laid down in Article 7 of Legislative Decree 196/2003, which has been set out in its entirety below. Such rights may be exercised without formality by simple request to the Data Controller identified above to the e-mail address indicated or the fax number +39 059-6323571

Article 7 of Legislative Decree 196/2003
Right of Access to Personal Data and other Rights

1. 1. The Data Subject will have the right to obtain confirmation of the existence or otherwise of personal data regarding him, even if not yet recorded, and the communication of the same in intelligible form.

2. The Data Subject will have the right to obtain indications on the following:

a. the origin of the personal data;

b. the purpose and procedures used in the processing of the same;

c. the logic applied in the case of processing effected using electronic means;

d. the identifying details of the Data Controller, the Data Processors and the Designated Representative pursuant to Article 5, paragraph 2;

e. the parties or categories of parties to which the personal data may be communicated or which may come to know of the same in their capacity as designated representative within the territory of the state, Data Controller or Data Processor.

3. The Data Subject will have the right to obtain the following:

a. the updating, correction, or, where this is in his interests, supplementing of the data;

b. the deletion, conversion into anonymous form or blocking of any data processed in breach of the law, including those which do not have to be preserved in relation to the purposes for which the data were collected or subsequently processed;

c. receipt of confirmation that the parties to whom the data have been communicated or disclosed have been informed of the operations referred to under letters a) and b) above, including with regard to their content, save in circumstances where such compliance is shown to be impossible or entails the use of resources manifestly disproportionate to the right to be protected.

4. The Data Subject will have the right to oppose, in whole or in part:

a. on legitimate grounds, the processing of personal data concerning him even though pertinent to the purpose for which it was collected;

b. the processing of personal data regarding him for the purposes of the sending of advertising materials, direct sales, the conduct of market research or commercial communications.