In compliance with D.lgs no.196 of 30 June 2003 ("Personal Data Protection Code") which establishes the provisions for the protection of persons with regard to the handling of personal data, the Company "Alcantara Spa" (now on referred to as "Company") informs the subject party that the Company has to obtain or is already in possession of some data regarding the said party and then providing the relative information as well as the data and the relative handling of them and also the purpose and methods of the data handling for which they are intended; whether the data provided are obligatory or optional; the consequences to the refusal to allow the data handling; the parties or categories of parties to whom the data can be transmitted and the limits of circulation of the data; the rights of the subject party; the person in charge of the data handling.

The above information is provided to the subject party for the purpose of obtaining full consent in writing to the data handling, such written consent by the subject party constitutes the legal precondition with regard to the personal data provided to the Company by the said subject party or by third parties, who carry out transactions or provide information to the Company that concern the subject party, as an example, of a commercial, financial and professional nature.

In accordance with the above mentioned provisions, the handling of the data will conform to principles of accuracy, legality, transparency, safeguard of confidentiality and the rights of the subject party.

Pursuant to Art.13 of D.lgs no.196/2003 it is specified that:
a) the data handling to be put into effect by us with regard to the personal data of the subject party, will consist in their collection, recording, organisation, retention, consultation, processing, amendment, selection, extraction, comparison, usage, interconnection, control, communication, circulation, cancellation and destruction, as well as the combination of two or more of such operations; b) the personal data of the subject party handled by the Company are exclusively non sensitive data that enable direct identification; these data obtained from Public Registries and other sources are relative to the financial circumstances, assets and relationships of the said party with the Company; c) at the time the information is rendered: - the appointee for the data handling is Alcantara Spa with offices in Via Mecenate 86, 20138 Milan; - the person designated for the data handling verification of the requests in the exercising of the rights under Art.7 D.lgs No.196/2003 is the pro-tempore Director of Human Resources of the Company who is located at the same address as the Company. - The names of other personnel responsible for the data handling and the possible subsequent change of the appointee and other persons in charge, will be made known by means of a statement available at the abovementioned offices and can be easily obtained free of charge by the subject party, on request in writing to the person in charge at the above address; d) the handling of the personal data by the Company of the subject party has an inherent aim with the object of our Company, such as the execution of Contracts entered into by the subject party with the Company, the fulfilment of connected obligations such as fiscal matters, drafting of preliminary reports for the conclusion of Contracts and the preparation of studies, statistics and market research; the sales activity for products and services including the initiative to develop contacts for acquiring new clients and the dispatch of informative material, publicity and commercial material; e) the personal data of the subject party can be conveyed: - to the Company staff, as well as to agents, brokers or distributors appointed to market the products and services of the Company; - to Companies belonging to our Group but operating abroad; - to persons in charge of the data handling, as indicated in the present report; - to parties appointed for the recovery of debts due to us; - to business information Companies; - to insurers; - to parties also operating abroad, that perform functions, assignments or activities, for example of a technical, organisational or managerial nature or relevance, of which the Company avails itself or with which it is in relationship in the management of the business or organised to provide services which include the Contract articles that concern the subject party. It could for example cover organisations or consortiums of the sector in which the Company operates; parties managing private risk or debt recovery centres; parties that offer services instrumental to the management of the Company or Auditing and Balance Sheet Certification Firms; parties that offer consistent and uninterrupted management of complex payment systems or payment services; parties with massive workloads relative to payment, cheques, other instruments or bills and documents transmissions, insertions in envelopes, transport and sorting of communications; parties offering data processing and filing for example, of the documentation relative to the existing relationships with clients; parties that on appointment by the Company perform the activity of quality control of the services, client requirements or marketing; - to parties to whom the data of the subject party should be transmitted by the Company in discharge of legal obligation.

In regard to the data handling of the subject party, such parties could perform the function of appointee or of persons in charge for the data handling of the subject party on behalf of the Company or perform in total autonomy as separate appointees for the data handling of the subject party. In so far as it is limited to the communication, the handling of the personal data of the subject party could involve their transmission and their transfer within the European Community Member States as well as to non Community Members. The list of parties to whom the Company will communicate the data of the subject party will be constantly updated and the subject party will have free and easy access by applying to the person designated for the data handling verification of the requests by means of exercising the rights under Article 7 of D.lgs 196/03; The handling of the data will not consist under any circumstances in the circulation of the data of the subject party without the express consent of the said party. The data will not be communicated, nor circulated to other parties, if the consent of the subject party is not expressly requested, except in cases - in addition to those referred to above - in which the communication of the data does not require the consent of the subject party as referred to in Article 24 of D.lgs No.196/03; 
f) the data handling listed above will either be recorded on paper or information systems or automated systems, as well as through appropriate instruments for connecting third parties to our data banks and such instruments will be suitable to store, manage, transmit and process - based on quantity, quality and temporal and soon - the data of the subject party and interrelating them with the data of other parties; g) Each and every handling of data occurs through the use of appropriate instruments to guarantee its security and confidentiality, as well as avoid unauthorised access and exclude the collection of sensitive data on the person. As far as access to the on line service is concerned, the primary security systems are accessed by means of Passwords and Identification codes.

The communication of the data is optional, except for the personal and fiscal data of the subject party, necessary to comply with fiscal obligations related to contractual relationships maintained with the Company; only the absence of communication of such data can imply the non execution of Contracts by the Company with the subject party, as well as the suspension and annulment of any existing contractual relationships between the Company and the said party.

To the appointee of the data handling, the subject party can apply in the manner referred to in Articles 8 and 9 of D.lgs No.196/03 and the said party can exercise the rights as provided for in Art.7 of D.lgs No.196/03.


Alcantara S.p.A.
Registered Office - via Mecenate 86, 20138 - Milan
Share Capital: € 10,800,000 fully paid up
Fiscal Code, VAT Number and Milan Companies Register Number No. 00835580150
Milan R.E.A. No. 850982
Alcantara® is a registered trademark of Alcantara S.p.A.