Privacy Policy

In accordance with the Legislative Decree no. 196 of June 30th, 2003, concerning the Code on the protection of personal data, Fabio Ciofini, Data Controller, guarantees the compliance with the legislation on the protection of personal data. Any personal data provided will be used exclusively to establish relationships with the customer, according to contractual agreements, and will not be transferred to third parties. Additional information (such as domain names, IP addresses and browser types) collected by our website, is used to track traffic statistics and for control requirements concerning service use modes by the competent authorities and they are not accompanied by any additional personal information. Fabio Ciofini also reserves the right to send to its customers offers, news or updates via e-mail, to the extent required by law, provided that the person concerned has, at any time, the right to object to that particular treatment. The data are processed only by duly authorized and responsible people, appointed by the Data Controller to manage relationships with customers. It is excluded in any case the disclosure to third parties or the dissemination of data. Objection to data processing or request for cancellation, modification or update of any personal information in our possession is possible at any time, by sending an email to:

Legislative Decree of June 30th, 2003 no. 196 - Title II: Rights of the interested party

Art. 7. Right to access to personal data and other rights

1. The interested party has the right to obtain confirmation as to the existence or otherwise of personal data referring to them, even if such data has not yet been registered, and to obtain communication of such data in an intelligible form.

2. The interested party has the right to obtain information on:

  1. the origin of the personal data;
  2. the purpose and method of processing;
  3. the logic applied in the event of processing by means of electronic devices;
  4. the identity of the Data Controller, the manager and the representative designated pursuant to article 5, par 2;
  5. the parties or categories of parties to whom the personal data may be communicated or who may learn of such data in their capacity as the designated representative in the State of managers or nominees.

3. The interested party has the right to obtain:

  1. the update, amendment or, when relevant, integration of data;
  2. the cancellation, transformation into anonymous form or block of data processed in violation of the law, including data whose retention is not necessary for the purposes for which the data has been collected or subsequently processed;
  3. a statement attesting that the operations as per letters a) and b) have been made known, also in terms of their content, to the parties to whom the data has been communicated or circulated, except in cases where compliance is impossible or requires use of means that is manifestly disproportionate to the right being safeguarded.

3. The interested party has the right to object, in whole, or in part:

  1. for legitimate reasons, the processing of personal data referring to them, even if such data is pertinent to the purpose for which it has been collected;
  2. the processing of personal data referring to them for the purpose of forwarding advertising or direct sales material or for market surveys or marketing communications.

Art. 8. Exercise of rights

1. The rights referred to in Article 7 are exercised through a request made without formalities to the Data Controller or manager, directly or through a nominee, and an appropriate response is provided without delay.

2. The rights referred to in Article 7 may not be exercised with a request to the Data Controller or the manager or with recourse pursuant to article 145, if the personal data is processed:

  1. pursuant to decree law no. 143 of 3 May 1991, converted, with amendments, by law no. 197 of July 1991 and subsequent amendments, regarding money laundering;
  2. pursuant to decree law no. 419 of 31 December 1991, converted, with amendments, by law no. 172 of 18 February 1992 and subsequent amendments, regarding support for the victims of attempted extortion;
  3. by parliamentary inquiry commissions set up pursuant to article 82 of the Italian Constitution;
  4. by a public party other than public economic entities, on the basis of specific provisions of law, exclusively for purposes relating to monetary and currency policy, the system of payments, the control of banking and financial brokers and markets, and also to safeguard their stability;
  5. pursuant to article 24, par 1, letter f), limited to the period during which they could effectively and concretely prejudice defence investigations or the exercise of rights in judicial hearings;
  6. by providers of electronic communication services accessible to the public relating to incoming telephone calls, unless this could effectively and concretely prejudice defence investigations as per law no. 397 of 7 December 2000;
  7. for reasons of justice, at judicial offices of any order and degree or the Consiglio superiore della magistratura or other self-governing bodies or the Ministry of Justice;
  8. pursuant to article 53, without prejudice to law no. 121 of 1 April 1981.

3. The Guarantor, also in response to instances from the interested party, in cases as per par 2, letters a), b), d), e) and f) acts in accordance with articles 157, 158 and 159 and, in cases as per letters c), g) and h) of par 2, acts in accordance with article 160.

4. Exercise of rights referred to in Article 7, when not relating to data of objective nature, may take place unless it concerns the rectification or integration of personal data of an evaluative nature, referring to judgements, opinions or other forms of subjective valuation, and the indication of conduct to be assumed or decisions to be taken by the processing owner.

Art. 9. Method for the exercise of rights

1. The request to the Data Controller or manager may also be sent via registered letter, fax or email. The Guarantor may identify another suitable system in reference to new technological solutions. With regard to the exercise of the rights referred to in article 7, paragraphs 1 and 2, the request can also be made verbally and in this case, written down briefly by the officer or manager.

2. When exercising the rights as per article 7, the interested party may appoint, in writing or by proxy/power of attorney, other individuals, institutions, associations or bodies. The interested party may also be assisted by a trusted individual.

3. The rights referred to in article 7 that refer to personal data for a deceased individual can be exercised by someone with a personal interest, or who acts to protect the interested party or for family reasons worthy of protection.

4. The identity of the interested person is checked based on suitable elements of evaluation, also using available documents or by exhibiting or attaching a copy of an identification document. A person acting on behalf of an interested party shall exhibit or attach a copy of the power of attorney or proxy signed in the presence of an official or signed and presented together with an unauthenticated photocopy of the identification document of the interested party. If the interested party is a legal entity, institution or association, the request shall be presented by an individual who is legitimated based on the respective articles of association or regulations.

5. The request referred to in article 7, paragraphs 1 and 2 shall be formulated freely and without constrictions, and can be represented, unless there are justified reasons, after a minimum period of 90 days has elapsed.

Art. 10. Response to the interested party

1. In order to guarantee the effective exercising of the rights referred to in article 7, the Data Controller is required to adopt suitable measures targeted towards the following, in particular:

  1. facilitating access to personal data by the interested party, also by using suitable computer programs targeted towards an accurate selection of the data that concern the individual interested parties that are identified or identifiable;
  2. simplifying the methods and reducing the times for responding to the requesting party, also with offices or services used for contact with the public.

2. The data are extracted by the manager or officers and can also be communicated verbally to the requesting party, or can be provided in visual form using electronic tools, as long as the data can be comprehended, also considering the quality and quantity of the information. If requested, the data will be transferred to paper or a data carrier, or transmitted telematically.

3. Unless the request refers to a particular processing of data or specific personal data or category of personal data, the response to the interested party will include all the personal data that concern the interested party or in any case processed by the data controller. If the request is directed towards a health care provider or a health care facility, the provisions specified in article 84, paragraph 1 shall apply.

4. If the extraction of the data is particularly difficult, the response to the request of the interested party can also take place by exhibiting or delivering copies of documents that contain the requested personal data.

5. The right to obtain the communication of the data in an intelligible form does not concern the personal data of third parties, unless the breakdown of the processed data or the deprivation of some elements would make the personal data relative to the interested party incomprehensible.

6. The data can also be communicated in an intelligible form using comprehensible handwriting. If communicating codes or abbreviations, also the parameters for understanding their meaning shall be provided, also by the officers.

7. If, following a request specified in article 7, paragraphs 1 and 2, letters a), b) and c) the existence of data concerning the interested party is not confirmed, a fee may be requested that does not exceed the costs that were actually incurred for the search carried out in the specific case.

8. The fee specified in paragraph 7 may not exceed the amount determined by the Guarantor with measures of a general nature, who can identify them on a flat rate basis in the case in which the data are processed electronically and the response is provided verbally. The Guarantor can also make provisions for requesting the fee if the personal data are located on a special support that must be specifically reproduced or when one or more data controllers determine a considerable use of means in relation to the complexity or extent of the requests and the existence of data concerning the interested party is confirmed.

9. The fee specified in paragraphs 7 and 8 can be paid via a postal payment or bank transfer, or using a payment or credit card, if possible upon receiving the response and in any case within 15 days from receiving the response.