Report and agreement for the use of personal data

Legislative Decree No.196, Article 13, of 30 June 2003

MoreToTrade Srl considers the privacy of its customers to be of fundamental importance and guarantees that the use of personal data by its website will be carried out in full respect of the fundamental rights, freedom and dignity of the person concerned, with particular reference to confidentiality, personal identity and the right to protection of personal details. To this end, MoreToTrade Srl has adopted and implemented a Privacy Policy for all that concerns the method of management of the website in reference to the use of the customer’s personal details. This is a report that is also covered by Article 13 of “The Code on the Subject of Personal Data Protection”, (Legislative Decree 196/2003)

We urge you to look at the following Privacy Policy and to check it well regularly, for eventual updates or revisions should they become necessary.

Definition of “Personal Details”
For the purpose of the present Policy, as specified more fully in Article 4 of the Code, by “Personal Details” we mean – “any information regarding any one individual person, board, corporation or association, identified or identifiable, even indirectly, by means of reference to any other information, including a personal identification number”.

Process Method
Users may access various sections of the website without having to give any personal information. MoreToTrade Srl collects and processes personal details on-line through its own website or other of its Company e-mail addresses. This processing is mostly automated in the following ways:

1.Details given voluntarily by the user
MoreToTrade Srl collects personal details and other data that is inserted into registration forms or module fields on the website, as well as details and data sent to the Company by e-mail.

2.Navigation data collected by means of electronic tools
The IT systems and software procedures used in MoreToTrade Srl’s website acquire, in the course of normal use, an amount of personal information, the transmission of which is implicit in the use of Internet Communication Protocol. For example, the user’s IP address or the domain name of the computer used to access the website, the URLof the requested sources, the time of the request or the session time, the method used for making the query to the server, the size of the files received in reply to the request, the code number concerning the status of the server’s reply and other types of information regarding the user’s operating system and technological environment.

Collection Aims
MoreToTrade Srl collects the personal details of its clients necessary for putting in place the authorization, qualification and personalization of operations for access to the various areas and relative content of the Company’s website. Furthermore, MoreToTrade Srl acquires the necessary data for carrying out its contractual obligations with its clients, deriving from reservation operations and ticket buying by passengers. The performing of these obligations necessarily entails that the data must be available to MoreToTrade Srl’s booking and commercial clerks as well as third party service-supply firms.

MoreToTrade Srl uses the personal details collected on-line with the aim of offering products and services, controlling the system of authorized access for monitoring the safety of data and evaluating work proposals sent in by candidates (CVs). Only on specific request, via the on-line registration form, does MoreToTrade Srl send commercial offers or marketing promotions by means of its own Newsletter.
MoreToTrade Srl, as the proprietor of these relevant procedures, states that the data in question will be processed and utilized exclusively for the ends set out in this Privacy Policy.

Communication and/or Dissemination of Personal Details
Personal details will be accessible to the employees of MoreToTrade Srl, formally named Process Representatives or Agents. The use and transmission of personal details on the part of external individuals and organizations that are working for MoreToTrade Srl are regulated by contracts that provide for adequate protection for the data. Users’ personal data will be used by and released exclusively to individuals and organizations that work for them, in conformity with this Privacy Policy and according to the specific provisions of the current regulations.
MoreToTrade Srl, moreover, manages the information contained in its own website in collaboration with other service providers and web agencies, from which it may receive personal details relative to the users of this data. These on-line collaborations are regulated by special contracts that presuppose an adequate protection level of the processed personal data.
MoreToTrade Srl is obliged, in ever-greater measure, to communicate to the various local authorities in all countries in the world, particularly to the Customs and Immigration Authorities, the personal and traveling details of its clients, acquired by the Company during its normal contractual dealings. This communication is necessary for carrying out the transport contract and comes about, above all, for security reasons. In some cases, MoreToTrade Srl may also be required to release its website users’ personal details, in carrying out contractual obligations, conforming to current regulations, or satisfying a service request on the part of the user. The release of data may come about in the following cases:

1. When on-line users have authorized the data release;
2. When MoreToTrade Srl needs to communicate information on users in order to offer services and satisfy an on-line user’s request;
3. When MoreToTrade Srl needs to communicate information to its partners, so that they can carry out services for on-line users;
4. When MoreToTrade Srl is obliged, by order of the judicial authorities, to release information regarding clients or conforming to a local or international law, regulation or warrant.
Furthermore, circumstances may arise whereby, for example, MoreToTrade Srl decides for commercial reasons to effect buying, selling or merger of capital. In the scope of such reorganization, the personal data may be shared with present or future buyers. In such circumstances, MoreToTrade Srl will obtain written guarantees that personal data will be treated with an adequate level of protection in accordance with existing regulations. Except in cases explicitly allowed by law, or covered by this Privacy Policy, personal details will not be communicated or shared without the agreement of the interested party.

MoreToTrade Srl will not sell or give away its website users’ personal details to unauthorized third parties.

Care of Personal Details
In conformity with the principle of necessity allowed by Art. 3 of Legislative Decree 196/03 MoreToTrade Srl guarantees that processing by electronic tools is carried out, limiting the use of personal details and identification data to a minimum of the cases where it is strictly necessary, in order to achieve the aims for which they were collected. MoreToTrade Srl also guarantees the adoption and observing of specific security measures to avoid loss of data, any unlawful or incorrect use of data, and unauthorized access.

Agreement to Personal Data Processing
MoreToTrade Srl carries out their user/clients’ data processing exclusively with the consent of the same. However, should a user not agree to his/her details being processed or request their cancellation, it will not be possible to access the reserved areas of the Company’s website.

The Processing Owner
The processing owner of your details is MoreToTrade Srl.

Processing Manager
The processing manager of your data is our Personnel and Organization Manager. Processing connected with MoreToTrade Srl’s website services is carried out at the Rome Fiumicino offices and is solely looked after by technical personnel of the processing office responsible (e.g. Internet Area), or by eventual outsourcers who carry out occasional or periodic technical operations (e.g. database maintenance).

Options for Data Contribution
Apart from what has been specified as regards navigation data, the user has the option to contribute – or not – personal details asked for in the request module and/or registration to the MoreToTrade Srl website.

Not contributing them may make it impossible to obtain what the user requires.

Finally, it must be remembered that in some cases – not the object of this site’s usual management – the Authorities may ask for news and information as allowed by Legislative Decree 196/03 Art. 15, so as to verify personal data processing. In these cases, the reply is obligatory under pain of a fine.

Your Rights
MoreToTrade Srl’s website users may always appeal to the Owner and/or Processing Manager (see above) to assert their rights as set out in Art. 7 of Legislative Decree 196/03, which states the following:

1. The interested party has the right to obtain confirmation of the existence, or not, of personal details that regard him/her, even if not yet registered, and the communication thereof in an intelligible form. 2. The interested party has the right to obtain evidence of:
a. the origin of the personal details;
b. the purpose and manner of processing;
c. the logic applied in case of processing effected with the aid of electronic tools;
d. the identity details of the owner, manager and agent designate as set out in Art. 5 clause 2;
e.the subjects and categories to which the data may be communicated or who might come to know of it in the role of designated national representative, manager or person in charge.
3. The interested party has the right to obtain:
a. the update, correction or, when necessary, completion of data;
b. the cancellation, transformation to anonymity or blocking of data processed in violation of the law, including that whose conservation is unnecessary in relation to the purpose for which the data was, or will be, subsequently processed;
c. the declaration that the operations set out in letters a) and b) above, also as regards their content, have been brought to the notice of those to whom the data was communicated or disseminated, excepting those cases in which this is impossible or would require a manifestly disproportionate use of resources with respect to the right being protected.
4. The interested party has the right to object, in whole or in part, to:
a. the processing of personal data that regards him/her, for legitimate motives, even though pertinent to the purpose of their collection;
b. the processing of personal data that regards him/her for the purpose of sending publicity material or direct selling, for carrying out market research or sending commercial messages.

In conformity with the present regulations and in addition to the other rights here specified, MoreToTrade Srl offers its website users the following options:
1. Non-collection of personal details:
The user can choose not to furnish personal details on-line to MoreToTrade Srl, deciding not to insert or release personal information in the registration forms or web module fields, or, in this case, not using any of the personalized services available on the Company’s site. Some of the contents and/or services on MoreToTrade Srl’s website are offered exclusively to users who release personal information or use personalized services.
2. Limitations of use and personal data communication for various purposes:
Access to certain content sections and/or services on MoreToTrade Srl’s website may require the user’s consent to the use and release of personal details with the aim of implementing a contact list and/or to identify and offer supplementary services and promotions considered interesting to the user. Users can limit further processing that may be done using this information by verifying or choosing their options when inserting the data.

Furthermore, the information given after the first registration may be modified or cancelled by changing the preceding options inserted in the MoreToTrade Srl registration form, accessing the section from the Home Page. Alternatively, the information may be modified by sending an e-mail to: privacy[ at ], with “cancellation/modification according to Art. 7, of L. D. 196/2003″ as its subject. Where allowed, it is also possible to update and alter personal data on line.

Modification of the Privacy Policy
MoreToTrade Srl ’s Privacy Policy may be updated and/or modified in order to implement and/or conform to National, EU or International laws, or to come into line with technological innovation. The updates and/or variations that may be made to this Privacy Policy will be reported on this web page and will always be available via a Hyperlink with the Company’s site, so that those interested can be fully informed about the use that is made of their personal details furnished to MoreToTrade Srl’s website.


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