Privacy

Under Legislative Decree n. 196/2003, the laws for the protection of personal information (Privacy Code), any processing of the user’s data will be based on the principles of correctness, lawfulness and transparency as well as protection of the user’s confidentiality and rights.

Data Controller

The DATA CONTROLLER is “Esplora S.r.l.” with registered office in Rome (Italy) - Largo Leo Longanesi, 9 - Scala B.
Postal code: 00142 - Tax Code and VAT number: 12778961008 - E-mail: legal@esplora.it

Purpose of the Data Processing

Pursuant to art. 13 of the Privacy Code (Legislative Decree n. 196/2003 of the Republic of Italy), “Esplora S.r.l.” informs the user that the personal data will be processed to allow access to the services provided by the portal and reserved for registered users and that, under article 24, paragraph 1 of Legislative Decree n. 196/2003, the express consent of the user is not required.
Furthermore, “Esplora S.r.l.” will utilize the personal data for administrative, tax or accounting purposes to fulfill contractual obligations.
However, “Esplora S.r.l.” may process personal data in aggregate form, in compliance with the measures provided by the Privacy Authorities and the specific exemption from consent provided by the same Authorities, for analysis and electronic processing purposes (for example, the classification of clients in homogeneous categories such as service levels, consumption, costs, etc.), to periodically monitor the development and economic progress of the activities of “Esplora S.r.l.”, steer the relative industrial and commercial processes, improve services, plan and realize commercial communication campaigns.

The Data Processing Procedure

In relation to the abovementioned purposes, individual and collective personal data shall be processed by preserving it on paper, computer and electronic support, in compliance with the laws in force at present and in the future of the Republic of Italy and the European Union, with criteria that are strictly connected to the purposes described and by adopting suitable safety measures to reduce the risk of destruction or accidental loss of the data, of non-authorized login or unauthorized processing or not compliant with the purpose of the actual collection of the data. Personal data shall be processed for a period that does not exceed the aforesaid purposes for which the data was collected.

Sharing the User’s Data

Within the structure of “Esplora S.r.l.”, as DATA CONTROLLER, processing may be carried out by all its employees, within the limits of their respective competences, duties and assignments, as well as by natural or legal persons connected with the DATA CONTROLLER with a continuous collaboration, even if in outsourcing.
Outside the structure of “Esplora S.r.l.”, the data may be communicated to:

a.

professionals and consultants for legal, tax and administrative matters;

b.

a. legal and administrative authorities in relation to all legal obligations in force at present and in the future.

Rights of the Data Subject

The user, as DATA SUBJECT of the data processing, may exercise the rights indicated in art. 7 of the Privacy Code of the Republic of Italy, and in particular:

1

the DATA SUBJECT has the right to obtain confirmation of the existence of his/her personal data, also if it has not yet been registered and to receive communication of the same in an intelligible form;

2

the DATA SUBJECT has the right to obtain indications regarding:

a.

the origin of the personal data;

b.

the purpose and processing method;

c.

the logic applied in case of processing performed with the aid of electronic tools;

d.

the identification information of the DATA CONTROLLER and of any managers/supervisors under paragraph 2 of article 5 of Legislative Decree n. 196/2003, the laws for the protection of personal information (Privacy Code), of persons or categories of persons to whom the personal data may be communicated or divulged;

3

the DATA SUBJECT has the right to obtain:

a.

an update, rectification or, when required, integration of the data;

b.

cancellation, transformation in anonymous form or block of data processed in violation of the laws in force at present or in the future, including data that does not require saving, for the purposes for which it was gathered and subsequently processed;

c.

a declaration that the operations in letters a. and b. above have been disclosed, also for their content, to those persons to whom the data was communicated or disclosed, except in cases where such fulfillment is impossible or implies the use of means which are disproportionate to the right being protected;

4

the DATA SUBJECT has the right to challenge all or part of:

a.

the processing of his/her personal data for legitimate reasons even if pertinent to the purpose of the collection process;

b.

the processing of his/her personal data for the transmission of advertising material or direct sale or to perform market research or commercial communications.

To exercise such rights, the user may write to “Esplora S.r.l.” at the following e-mail address: legal@esplora.it

Changes to the Privacy Policy

“Esplora S.r.l.” reserves the right to change or update the present Privacy Policy; therefore, the user should examine said Privacy Policy from time to time for any changes that may have taken place.
The uninterrupted use of the platform shall constitute acceptance by the user of such changes.

Minors

“Esplora S.r.l.” does not process nor consciously request the data of users who are minors (under 18 years old) and/or who are not legally and mentally competent according to the Country of origin or residence, nor consciously allow such users to register on the Platform.