Data processing policy statement (art. 13 Lgs. Decree 196/2003)

Data subjects: Web customers
GAMA SRL, in the capacity as Owner of the processing of your personal data, pursuant to Lgs. Decree no. 196 of 30 June 2003 (Data Protection Code), hereby informs you that this regulation includes the safeguarding of persons and other data subjects with regard to the processing of their personal data and that the data will be processed correctly, lawfully and transparently, protecting your rights and privacy.
Your personal data will be processed according to the provisions of the above legislative decree and the privacy obligations contained therein.

Purposes of processing: your data will be processed for the purposes connected to the following requirements regarding legislative or contractual obligations:
- to provide the services and/or products you have purchased;
- with regard to contractual, pre-contractual or legal obligations, exclusively for administrative and accounting purposes, including disputes;
- to implement user transactions;
- to meet legal requirements;
- for operational, legal, fiscal and management requirements;
- customer care
- Marketing activities inherent to services already purchased. The Data Protection Authority states that for these purposes, no consent is required. We remind you that at any time, it is possible to withhold consent for these purposes, according to the procedure stated in Art. 7.

The processing of data required to meet these obligations is necessary for the correct management of the relationship, and the provision of said data is obligatory for the purposes stated above. The Owner also makes it known that any failure to communicate or to provide correct information of any obligatory nature may make it impossible for the Owner to guarantee the suitability of the processing itself.

After your consent, your personal data may be used for the following purposes:
- Direct marketing, newsletters, market research or other sample surveys and direct sales; to receive, via automated means, email, and MMS or SMS or messages of other types, as well as messages by telephone, via operator, or standard mail; information materials to gauge satisfaction; promotional, commercial and advertising material, or material inherent to events and initiatives, including by entry of same in the company CRM of the Owner. Data will be used until such time as the data subject opposes it.
The provision of data for this purpose is optional and any refusal to processing will not affect the continuation of the relationship or the adequacy of the processing itself.

Processing operations:
The processing of your data will be carried out using tools and procedures that are sufficiently secure, and data will be handled using manual, electronic and/or telematic procedures, including cookies (for more information, see the website and cookie policy available on the website), and automated call systems, as identified in art. 130 of the Code, as per articles 11, 31 and successive of the Data Protection Act, by implementing the minimum security requirements envisaged in Technical specification Annex B. To compare and improve the results of communication, the Owner will use systems to send newsletters and promotional notices with reports. Via reports, the Owner will be able to know, for example: the number of readers, the openings, the unique “clickers” and the clicks; the devices (iPhone, Blackberry, Nokia...) and OS (Windows, Apple, Linux, Android...) used to read messages; details on the activities of individual users; the number of users yet to confirm registration; details of the emails sent according to date/hour/minunte; details of delivered and undelivered emails, and of forwarded emails; a list of people who cancelled registration for the newsletter; those who opened an email or clicked on a single link; users with message viewing problems; link tracking (i.e., the number of clicks on the links in a message); tracking clicks (the links that have been clicked and by whom).  All these data are used to compare and if possible, improve communication results.

Communication: Data will be stored at the Owner’s headquarters, at the headquarters of the external provider (appointed supervisor) and on the platform used to send out commercial information (Mailchimp); only duly authorised persons will process the data, which will only be communicated to other parties to implement the services necessary for the correct management of relations, guaranteeing the safeguarding of the data subject’s rights. Specifically, your data will be communicated to:
- Public and/or private subjects for which communication of data is obligatory or necessary to comply with legal requirements or which are in any case functional for administration of the relationship;
- Forwarding agents, Transporters, Couriers, Postal services, Logistics companies; -
- Subjects providing services for the management of the information system used by the Owner and telecoms networks (including email);
Consultants and self-employed persons, including associates;
- Banks and credit institutes.
Your data may also be viewed by company managing the website, limited to technical engineer access for reasons of web server maintenance and management.  

Disclosure: Your data will not be disseminated.