Thank you for visiting www.newvision.it and www.4me.it web sites of New Vision S.r.l. (hereinafter, “New Vision”).
This privacy policy (the “Privacy Policy”) applies to the web sites http://www.newvision.it and http://www.4me.it (the “Sites”) and refers to the personal data processing activities performed by New Vision upon the user visit to the Sites and the user interaction with the services and functionalities offered by the Sites. The Privacy Policy has been drafted in accordance with the Recommendation n. 2/2001, adopted on May 17, 2001 by Article 29 Data Protection Working Party in relation to the minimum requirements for the collection of data on-line within the European Union and also represents information statement to the data subjects according to section 13 of Legislative Decree June 30, 2003 n. 196 consolidated (the “Privacy Code”). The Privacy Policy specifies the identity of the data Controller that controls and manages the personal data collected and processed through the Sites, specifies what is the personal information collected, the data processing purposes and conditions, the extent of personal data communication to third parties, the data security measures adopted in order to protect and safeguard data and the ways in which the user may verify the processing of data relating to the user and enforce the user’s rights as acknowledged under the Privacy Code.
The Controller of the personal data processing is New Vision S.r.l., with registered offices at via Giacomelli 16, 35010 Limena (PD); e-mail: info@newvision.it. The data Processor for enforcement of the privacy rights under art. 7 of the Privacy Code currently is the Information Systems Manager at New Vision S.r.l., domiciled for this duty at the data Controller’s offices as above specified.
In general, the visit and consultation of the Sites does not imply collection and processing of personal data of the user.
The processing of personal data of users that visit and consult the Sites is limited to the so named surfing data, namely the data whose transmission to the Sites is implicit in the functioning of the information systems in charge of the managing of the Sites and in the use of communications protocols proper of the Internet. Surfing data are, for example, the IP addresses or the domain names of the computers employed by the users who connect to the Sites and other parameters relating to the type and the information operating system employed by the user. Surfing data are not collected by New Vision in order to be associated with to users or identified persons, however surfing data for their own nature may allow the identification of the user if they are processed and associated with other data owned by third parties. Surfing data are collected and processed by New Vision exclusively for statistical purposes and in anonymous form in relation to the access and use of the Sites and for purposes of monitoring the correct functioning of the Sites and of enhancing the Sites functioning and content. Surfing data are deleted immediately after the processing in anonymous form; said data may be used for purposes of assessing possible responsibilities in case of information crimes realized against the Sites or through the Sites. With the exception of the aforementioned circumstance, New Vision keeps the users’ surfing data only temporarily for a maximum period of seven days or otherwise required under applicable law.
Furthermore, New Vision collects and processes personal data voluntarily provided by user or collected, also from third parties, in the course of its activity. Personal data may be voluntarily provided by user for example upon interaction of the user with the Sites functionalities and request of the services offered by the Sites, for example upon user subscription to the Sites, to other initiatives offered through the Sites, upon user request of information or informative material to New Vision or user sending to New Vision of a communication through traditional mail or through the Sites. New Vision will also process user’s personal data to assess or defend a legal claim and to comply with laws, regulations and Community legislation.
With the user’s consent, that is free and optional, New Vision may also process user’s personal data for purposes of defining of individual and group profiles (profiling), and for marketing purposes, notably to send to user, also through newsletter, e-mails, sms and mms, information and updates on our products, offers, promotional campaigns and on events and similar initiatives organized by New Vision or to which New Vision takes part to, including possible invitations to said events. User will always have the opportunity to object the processing of his/her personal data for the sending of promotional information through e-mail; in each communication there will be a specific section in which are specified the conditions for revoking the consent and not receiving anymore promotional material and information.
Personal data will be collected and processed through an electronic system managed by New Vision that is located at the offices of New Vision as above specified. Moreover, other companies of the New Vision group are involved in the data processing in relation to managing of the Sites and relevant services and functionalities and the processing purposes above reported. User is invited to look at the section of the Privacy Policy relating to the extent of data communication for further information on data communication and on details on personal data transfer out of the European Union.
Cookies are small data files stored on the hard disk of the user’s computer. The Sites deploys cookies for specific and limited purposes, notably in order to offer to user an easier surfing on the Sites, for internal security purposes, for statistic analysis (for example in relation to the Site traffic) and system management.
The so called ‘session cookies’ are stored in a temporary memory and are deleted when user closes the browser.
New Vision does not use cookies to access information stored on the user’s computer, to store therein information and to monitor user’s activities. The foregoing applies to user’s computer and any other kind of device used by user to connect to the Site.
Personal data collected by New Vision are processed mainly with electronic, information and telematic means, according to logics and procedures strictly related to the purpose of processing above reported. Data may also be processed without electronic means through manual means; in any case data are kept only for the time necessary to achieve the specific processing purpose from time to time sought and according to applicable legislation on data protection, including security and confidentiality principles that inspire our activity. We will process data according to applicable security requirements to minimize the risks of data destruction and loss, even accidental, of unauthorized access, unlawful processing or processing that does not comply with the purposes of data collection and of illicit or not correct use of data, with specific but not limited reference to Annex B to the Privacy Code (Technical Specifications on Minimum Data Security Measures). Moreover, information system and programs are configured so as to minimize the use of personal and identification data so that said data are used only when necessary to the specific processing purpose from time to time sought.
New Vision communicates user’s personal data within the limits and under the circumstances specified in this Privacy Policy and in the information statement published upon providing of data by user, in any case in full compliance with the consent given by the user upon collection of data, when required by the Privacy Code.
User personal data will be accessible within New Vision organization by the internal and external personnel that need to access them because of their duties in relation to the processing purposes pursued as persons charged with data processing operations, and by the Processor above specified. The complete and updated list of Processors and of the subjects to which data may be communicated will remain at user disposal upon request at New Vision or at the Processor.
User personal data may be communicated to professionals, independent consultants, also in associate form, third parties to which New Vision may revert to in relation to performance of technical and organizational services for the purposes above reported, third parties in case of mergers, acquisitions, sale of business or part of business and other extraordinary operations, and to the legitimate addresses of communications under laws or regulations. For pursuing of the processing purposes above specified user’s personal data may be communicated to other companies of the New Vision group, that will process data under applicable privacy law and that are established within the European Union.
The aforementioned subjects that receive user’s personal data will process them as Controllers, Processors or persons in charge of processing, as the case may be, for the same purposes above specified and according to applicable data protection law; they are provided only with the information necessary to the relevant functions. It is understood that user’s personal data will not be communicated to third parties for their own marketing purposes and will not be spread.
Except for the foregoing description in relation to the surfing data, providing of personal data by user is necessary for performance of the services and functionalities offered by the Sites and required by user, such as for example user subscription to the Sites, the New Vision program or other initiatives offered through the Sites and relevant management, replying to user’s questions, and sending of information and informative material requested by user. Providing of personal data by user is mandatory to assess and defend legal claims and to comply with applicable legislation; denial of providing personal data by user in the above reported circumstances would make it impossible for user to subscribe to the Sites, the New Vision program or other initiatives offered through the Sites, to receive the services, functionalities, replies, information and informative material requested to New Vision.
Providing of personal data by user for profiling and marketing purposes as above specified is free and optional; denial of providing personal data by user for profiling and marketing purposes will have no consequence, for example said denial will have no consequence on the possibility for user to subscribe to the Sites, the New Vision program or other initiatives offered through the Sites, to receive the services, functionalities, replies, information and informative material requested to New Vision.
User is entitled at any moment to enforce his/her rights as provided under Section 7 of the Privacy Code, for example the right to obtain confirmation that user’s personal data exist or do not exist, verify their content, origin and accuracy, ask for their integration, updating, amendment, deletion, transformation in anonymous form, block for breach of laws and regulations, and user may oppose for legitimate reason the data processing.
To enforce user’s rights and for any query or request relating to the personal data processing by New Vision, user may contact the data Processor, currently the Information Systems Manager at New Vision S.r.l., who is domiciled for this duty at the offices of New Vision as follows: New Vision S.r.l., via Giacomelli 16, 35010 Limena (PD); e-mail: info@newvision.it.
This Privacy Policy is subject to updating by New Vision. The version published on the Sites is the version actually in force. If New Vision change this Privacy Policy, it will notify user of such changes by posting a revised link on the home page of the Sites for 30 days that reads “Newly Revised Privacy Policy” and that links to this page where the revised Privacy Policy will be posted. New Vision will also, where required by applicable law, obtain user’s consent for any such changes. New Vision invites user to periodically verify the Privacy Policy to be informed on any change to the same.
The Effective Date of this Privacy Policy is 2011, April 4th.