Privacy policy

Version 1.0 (valid from 25/05/2018)

PLOSE SKI S.p.A. (henceforth “Plose” or “Data Controller”) has always implemented measures to guarantee the privacy of its online users. This policy statement has been written in compliance with art. 13 of EU Regulation 2016/679 (“Regulation”) in order to inform you about our privacy policy, allow you to see how your personal data are handled when you use our website (http://divibox.dd37.firma5.com; henceforth “Website”), and, if necessary and/or appropriate, give your express consent to your personal data being processed. The information and details you provide or whichare otherwise acquired through your use of the Website (henceforth “Inquiries”) will be processed in compliance with the stipulations of the Regulation and the confidentiality practices already in force which guide our actions at the Plose.

In compliance with the applicable Norms, data shall be handled by Pose in accordance with the principles of lawfulness, fairness, transparency, purpose and retention time limitation, data minimization, accuracy, integrity and confidentiality.

CONTENTS

1. Data Controller
2. The personal data processed
   1. Web navigation data
   2. Data provided voluntarily by the subject
   3. Cookie
3. Purpose of processing the data
4. Legal basis and compulsory or optional provision of personal data
5. Who may receive your Personal Data
6. Movement of personal data
7. Data retention times
8. Rights of data subjects
9. Amendments

1.Data Controller

The Data Controller entrusted with processing data through the use of the Website is Plose, as given above. For any information on how your personal data are being processed by Plose – including a list of the appointed data processors – you can write to us at the following address: info@plose.org

2.The personal data processed

Following access to the Website, we inform you that Plose will process personal data, which may comprise identifying data such as your name, an identification number, an online username or one or more elements distinguishing your physical, physiological, mental, financial, cultural or social identity, which may lead to the data subject being identified or made open to identification (“Personal Data”).

The Personal Data processed through the Website are as follows:

a. Webnavigation data

The IT systems and software used to run the Website automatically acquire certain Personal Data, astransmission of the same is implicit to the use of Internet communication protocols. This type ofinformation is not gathered for the purpose of linking it to identified subjects, but, by its nature, ifprocessed and linked to data held by third parties, could lead to the user being identified. This categorycomprises data such as IP addresses or the domain names of the computers used by the usersconnecting to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources,the time of the request, the method used to make the request of the server, the size of the file sent inresponse to the request, the numerical code indicating the state of the response made by the server(complete, error, etc.) and other parameters pertaining to the user’s operating system and type of devicebeing used. These data are used exclusively to obtain anonymous statistical information about Websiteuse and to ensure the site is working properly, as well as making it possible to pinpoint any anomalies orimproper use of the site; they are deleted immediately after processing. In the event of unlawful attacksagainst either the Website or related third parties, these data may be used to identify the guilty party/ies; excepting these cases, the data regarding web contact are deleted within a few days of creation.

b. Data provided voluntarily by the subject

The optional, explicit and voluntary sending of your Personal Data through the e-mail address (info@plose.org) are used by Plose for the sole purpose of responding to your Inquiries or other requests and are communicated to third parties only if this is necessary for the same purpose .

Otherwise, the optional, explicit and voluntary sending of your Personal Data by means of requests for availability or booking on the Website entails the subsequent acquisition of the data communicated by the sender through those parts of the Website, including his name, e-mail address, possibly the mobile phone number, notes, etc. The processing of such data by Plose, who acts as the external data processor, is limited to forwarding the same to the individual autonomous data controllers, so that they can respond to the requests of the data subjects.

The Personal Data thus provided are used by Plose for the sole purpose of executing the Services, as well as for satisfying the requests transmitted and are communicated to third parties only if it is necessary for that purpose.

While using the Website, it may happen that you forward third-party data to the Plose. In this event, you act as independent data controller, and shall be responsible for all the duties and liabilities foreseen by law. As such, on this point you grant us the fullest possible exemption from any protest, claim, request for damages from data processing, etc. that may be made against Plose by third parties whose Personal Data have been processed through your using the Website functions in violation of the applicable legislation on personal data protection. Notwithstanding this, in the event of you providing or otherwise processing the Personal Data of any third party when using the Website, you hereby declare – and take full legal responsibility for the declaration – that there is a sound legal basis for doing so, in accordance with art. 6 of the Regulation legitimizing processing of the information in question.

It is specified that our Website provides links to other websites owned by third parties, which typically act as independent data controllers of the data processed through their websites. Therefore, when you are redirected to these websites, Plose is an external subject and cannot in any way be held responsible for any processing of your personal data that will be performed on those websits.

a.Cookies

Definitions, characteristics and application of the legislation

Cookies are small text files that the websites visited by the user send and record on their computer/mobiledevice, so that they can be resent to the same sites the next time the user logs on. It’s precisely thanks tocookies that a website can remember the user’s actions and preferences (such as login details, preferredlanguage, font size, other visual settings, etc.) so that the user doesn’t have to set these preferencesagain the next time they visit the website, or even when they move to a different page on the samewebsite. Therefore, cookies are used for authentication purposes, to monitor sessions and to memorize the data regarding user activities when browsing a website. They may contain a personal identificationcode that makes it possible to track the user’s activities within the website for statistical or advertising purposes. While navigating on a website, the user’s computer may receive cookies from websites or web servers other than those used by the website being visited (so-called “third-party cookies”). Some operations may be impossible to perform without the use of cookies, as in some cases they are vital to the technical functioning of the website.

Various types of cookie exist, with different characteristics and functions, and they may remain on the user’s device for varying lengths of time: “session cookies”, which are automatically deleted as soon asthe browser window is closed, and “persistent cookies”, which stay on the user’s computer until a previously established length of time has elapsed.

According to Italian legislation, for cookies to be used, it is not always necessary for the website user to give their express consent. In particular, “technical cookies” i.e. those used for the sole purpose of completing the transmission of information on an electronic communication network, or to the extent that is strictly necessary to respond to Inquiries explicitly made by the user – are used without express consent.

In other words, technical cookies are those which are vital to allow the website to function or in order to carry out the user’s requests.

Among the technical cookies that do not require express consent in order for websites to make use of them, the Italian Personal Data Protection Authority (see the edict ‘Individuazione delle modalità semplificate per l’informativa e l’acquisizione del consenso per l’uso dei cookie“’ published on May 2014 and the subsequent clarifications regarding the same; henceforth simply “Edict”) lists:

• “analytics cookies”, when they are used directly by the website administrator to gather aggregated statistical information about the number of hits and how users browse the site;
• navigation or session cookies (for authenticating users);
• technical cookies, which allow the user to navigate on the site according to a series of selected

criteria (e.g. language, products selected for purchase) in order to improve the Website.

For “profiling cookies” on the other hand – i.e. cookies designed to create a profile of the user that are used in order to send commercial messages in line with the preferences shown by said user when surfing the web in general – the express consent of the user must previously be obtained.

Types of cookies used by the Website and option to (de)select

The Website uses the following cookies that may be deselected, except for the third-party cookies: for these you will have to refer directly to the relative methods of selection and deselection for each cookie, for which we provide the relevant links:

• Navigation or session technical cookies which are strictly necessary either to allow the Website to function or to allow you to access content and receive answers to the inqueries you made.
• Functional cookies, i.e. those used to activate specific Website functions as well as a series of selected criteria (for example, language) in order to enhance the Website.
  N.B.: by turning off technical and/or functional cookies, you may render the Website unusable, or certain services or functions provided by the Website may become unavailable or fail to function correctly,therefore forcing you to modify or manually insert certain information or preferences each time you visit the Website.
• x Third-party cookies, i.e. cookies from websites and web servers other than Plose’s, used for the purposes of those third parties. We would like to point out that these third parties, listed below with the respective links to their privacy policies, are generally independent data controllers for the data gathered through the cookies they serve; therefore, you will have to refer to their data processing policies, notices and consent forms (selection and deselection of their respective cookies), as stipulated in the aforementioned Edict. We furthermore inform you that Plose does everything in its power to trace cookies on its own Website.

These cookies are regularly updated on the table below, where we state with total transparency which cookies are sent directly by Plose and what their respective purposes are. As for the third parties who send cookies through our Website, we have provided links to their respective privacy statements below: as mentioned before, the responsibility to inform users and obtain their consent is theirs, as foreseen by the Edict. This responsibility is not only for the cookies sent directly by the third parties, but also to any cookies sent through our Website during its utilization, of which said third parties avail of. Regarding these cookies, which are sent by service providers to the aforementioned third parties, Plose has no control over them, and does not know either their characteristics or purposes.

Below are the links to the relevant information on third-party cookies:

Google: www.google.com/policies/privacy/partners/

A detailed table of the cookies sent by Plose through the Website is presented below:

Cookies found on the Website

Website

WordPress

Google Analytics

Type 1: Functional cookies: created by the same website.
Type 2: Technical cookies: automatically generated by the server of the application to manage the session.
Type 3: Analytical cookies: cookies created with a measure code, like Google Analytics cookies.

Cookie settings

You can block or remove technical and functional cookies (either wholly or partially) by using specific functions provided by your browser. Nevertheless, we inform you that, if you do not authorise the use of technical cookies, it may be impossible for you to utilize the Website, view all the contents and make use of the available functions of the Website. Blocking technical cookies could lead to certain services or functions provided by the Website being unavailable or failing to work correctly, and you may be forced to amend or manually insert either information or preferences every time you visit the Website.

The choices you make regarding the cookies used by the Website will in turn be recorded on a specially designated cookie. In certain circumstances, however, this cookie may not work correctly; if this happens, we recommend that you delete or block the unwanted cookies through your browser.

If you subsequently use a different device or browser to access the Website, you will have to reset your cookie preferences.

How to view and make changes to cookies using a browser

Every browser has functions allowing you to authorize, block or remove cookies (either wholly or partially). For more information on how to set your cookie preferences through your preferred browser, you can consult the relevant instructions below:

Internet Explorer

• Firefox
• Chrome
• Safari
• Edge

3. Purpose of processing the data

The reasons for processing your data, with your express consent where necessary, are as follows:

a. to allow us to answer your Inquieris;

b. to comply with any legal, accounting or taxation obligations.

4.Legal basis and compulsory or optional provision of personal data

The legal basis for processing your Personal Data for the purposes stated in section 3.a is art. 6 (1)(b) of the Regulation, inasmuch as it is necessary to process your data in order to provide our Services and/or to reply to your queries. Providing personal details for these purposes is optional, but failure to do so will make it impossible for us to provide answers to your Inquiries.

The purposes stated in section 3.b constitutes a legitimate processing of Personal Data under the terms of art. 6(1)(c) of the Regulation. Once you have given your Personal Data, Plose must process them in order to comply with a legal obligation it is subject to.

5. Who may receive your Personal Data

For the purposes stated in section 3 above, our Personal Data may be shared with:

a. subjects who normally act as data controllers, or in other words: i) companies or firms of professionals which provide assistance and consultancy services to Plose to the extent they pertain to the use of the Website; ii) subjects we necessarily have to interact with in order to provide the Website (for example hosting providers) or to provide ancillary services regarding accounting, administration, labour law matters,; iii) subjects appointed to perform technical maintenance tasks (including maintenance of Internet connection apparatus and electronic communication network apparatus);(collectively,“Recipients”);

b. natural persons, organizations or authorities to whom we must forward your Personal Data in order to

comply with the relevant legislation or with specific orders;

c. individuals authorized by Plose to process Personal Data when strictly necessary in order to provide answers to your Inquiries or other information requests; these individuals have previously committed to maintain confidentiality or have a legal obligation to maintain confidentiality (e.g. employees of Plose).

6.Movementof Personal Data

Your Personal Data will not be shared with any Recipients outside the European Economic Area.

7. Data retention times

The Personal Data processed for the purposes stated in section 3.a will be stored only for the strictly necessary time it takes to achieve said purposes. As the data processing concerns the provision of answers to Inquiries or other information requests, Plose will process your Personal Data for the time permitted under the Italian law to protect its own interests (art. 2946 Code of Civil Law).

The Personal Data handled for the purposes stated in section 3.b will be stored for the time permitted by the specific disposition or applicable law.

You can request further information on data retention times and the criteria adopted to establish these times by writing to the following address: info@plose.org

8.Rights of data subjects

Under the terms of articles 15 onwards of the Regulation, you have the right to ask Plose, at any time, to allow you to access your Personal Data, to make amendments to or delete them wholly or in part, object to their processing; also the right to request restrictions to their processing in the cases foreseen by art. 18 of the Regulation, and to obtain the data pertaining to you in a structured, commonly recognized and legible format from a device, as foreseen by art. 20 of the Regulation. At any time you can revoke the consent already given, pursuant to art. 7 of the Regulation, without prejudice to the lawfulness of the processing carried out prior to the revocation of said consent.

Requests of this kind should be made in writing and forwarded to the following address:

info@plose.org

In any case, you always have the right to file a claim with the relevant Supervisiory Authority (Garante per la Protezione dei Dati Personali), under the terms of art. 77 of the Regulation, if you believe your Personal Data has been processed in violation of the applicable legislation.

9.Facebook Pixel

To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third party countries too. This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyse the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns. For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data. The use of Facebook Pixel is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time. In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/. You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook. If you do not have a Facebook account, you can deactivate any user based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

10.Amendments

The Data Controller reserves the right to amend or simply update the contents of its privacy policy, either partially or entirely, for reasons which may include changes to the applicable legislation. You will be informed of any such changes through publication on the Website. Therefore, the Data Controller invites you to consult this section regularly in order to familiarize yourself with the most recent and up-to-date version of the privacy policy; this way you will always be adequately informed about the data gathered and how they are used.