PRIVACY POLICY

Think Simple SpA applies the current Italian data protection laws to guarantee the safeguarding and security of the personal data supplied by users, irrespective of the country from which they access the website www.vitrum.com

This Privacy Policy applies to all personal information collected and describes the procedures used to manage it in as provided for by Legislative Decree 196/03 (Italy’s Personal Data Protection Law). Its purpose is to define the data processing limits and procedures for each service so that customers and visitors to the site may freely provide their consent and authorize the processing of his or her personal data and its subsequent use.

1. The purpose of the data processing procedure
The user’s personal data, provided when registering at our site www.vitrum.com (hereinafter the “Site”) and utilized in the procedures that are required for accessing and using the services offered by the Site, are necessary in order to:

provide the services offered by the Site;
provide information and/or transmit details concerning the service;
carry out all legally-required accounting and tax procedures;
carry out those activities that are strictly linked to and instrumental in managing the company’s relations with its customers;
if the user has expressed his or her consent: supply information and/or offers regarding the services offered; verify the quality of the services offered; send advertising material and information relative to the products and the company’s initiatives or those of third parties; conduct statistical and market surveys and marketing/product preference surveys.

2. Data processing procedure
The user’s personal data will be processed by employees specifically assigned to this task, mainly using electronic and IT instruments, and will be stored on IT devices, in printed form and/or on any other suitable type of support.
The personal data will be conserved in a form that allows for the identification of the user only for the time strictly necessary for the purpose for which the data have been collected and subsequently processed, and in any case no longer than provided for by current legislation.
Pursuant to and in accordance with [Italian] Legislative Decree 196/2003, customers are informed that the data supplied to our company will be conserved in our archives subject to measures that guarantee the maximum level of security and confidentiality.

3. Type of data processed

Data voluntarily supplied by the customer/visitor
The personal data that the user is requested to provide consists of two categories: obligatory and optional.

Obligatory data fields are marked by an asterisk (*). Processing of this information for the purposes referred to above is strictly linked to the effective functional requirements of the services for which the information is requested. If the user should prefer not to provide this information, or not consent to its processing by our company, then he or she will not be permitted to register on the Site and utilize the services offered.
Optional data fields are those which the user may prefer not to complete. This will not affect the possibility of registering on the Site and utilizing the services offered.

Users are invited to check the data entered on the Site to ensure that the personal information is accurate, complete and up-to-date.

Navigation data
No personal data is required from the customer/visitor to access this website. During normal operation, however, the IT systems and software procedures used to run this website collect personal data, implicitly transmitted through the use of Internet communication protocols.
This information is not collected in order to be associated with other persons, but if processed and integrated with other third-party data it may allow users to be identified.
This category includes: the user’s IP address, the URL of the resource requested, the time of the request, the size of the files retrieved etc.
Navigation data are only used to obtain anonymous statistical information concerning the use of the Site and to control/improve the quality of service; they are deleted after processing.
This procedure does not process data that might provide direct identification.

Cookies
The site does not intentionally collect any of the users' personal data.
No cookies or tracing systems of any sort are used in the transmission of personal information (permanent cookies).
The use of “temporary or session cookies” (which are not permanently saved on the computer's hard disk and are automatically deleted when the browser is closed) is strictly limited to the transmission of information concerning thesession (comprising random numbers generated by the server) and necessary for secure and efficient navigation of the site.
Session cookies used by this Site avoid the use of other means of information technology which might potentially compromise the privacy of the user when navigating the site, and do not allow the collection of personal data that might identify the user.
The customer/visitor may set his or her browser to accept all cookies, some cookies, or to refuse them entirely. Note that failure to accept cookies may prevent us from providing the service requested when accessing areas requiring authentication.
In addition, at the end of each navigation session, the customer/visitor may delete the navigation cache memory and any cookies from his or her hard disk.

4. Communication of data
The user’s personal data will be utilized for organizational and functional procedures by employees assigned specifically to this task and solely as required for the provision of the services offered. Said employees have received adequate training in the security and confidentiality of personal data, and in particular are aware that they are strictly prohibited from divulging or distributing personal data to third parties except as required for the provision of the services.
The user’s personal data will not be divulged; however, in order to permit the provision of the services, the data may be communicated – always within the limits laid down by law and for the purposes envisaged in paragraph 1 above – to the third parties listed below:

persons engaged in the shipping, delivery and return of the products purchased;
banks for the collection and payment of monies, including the suppliers of remote electronic payment services;
accountants engaged in book-keeping and tax procedures;
consultants and other professional figures who provide related services.

5. User’s rights
Pursuant to and in accordance with article 7 of [Italian] Legislative Decree 196/2003, and in relation to the processing of personal data, the user may at any time exercise his or her rights, including the right to request and obtain confirmation of the existence or non-existence of personal data relating to him or herself, even if such data have not yet been recorded, and communication of the same in intelligible form.

The user retains the right to request and obtain information concerning:

the origin of the personal data.
the purposes and methods of its processing.
the logic used in the case of processing using electronic instruments.
the name and title of the data controller and the data processor.
the persons or categories of persons to whom the data may be communicated or who may become aware of such data in their capacity as designated representatives, officials or officers of the State.

The user also retains the right to request and obtain:

the updating, correction or integration of said data.
the cancellation, transformation into anonymous form or block of any data processed in breach of the law, including data whose conservation is necessary in relation to the purposes for which the data were collected or subsequently processed.
a declaration stating that the operations described in the first two points above have also been forwarded to those whose data have been communicated or distributed, if such provision is possible and requires the use of resources proportional to the user’s protected right.

The user may object in whole or in part:

for legitimate motives to the processing of personal data regarding him or herself, even if pertinent to the purpose of their collection.
to the use of personal data regarding him or herself for the purpose of the sending of advertising material or direct sales material or market research campaigns or marketing material.

To exercise your rights as a user, please write to Think Simple SpA Viale Lino Zanussi 3 - 33170 Pordenone
or e-mail us at info@thinksimple.it

6. Data controller – Data processor
The Controller and Processor of the personal data is: Think Simple SpA with registered offices in Viale Lino Zanussi 3 - 33170 Pordenone.