Clitber light srl

Clitber Light Policy for the treatment of personal data

This declaration contains the indication of norms and directives followed by Clitber Light as regards the treatment of personal data for web site www.Clitber.com visitors. 
As the website is hosted in the Italian territory, the information and the data concerning the users will be treated by Clitber Light in conformity to the italian norms following the directives 95/46/CE and 2005/58/CE of European Parliament and European Council, that is the legislative decree dated 30 june 2003 n. 196 and following modifications and integrations.

1. Aim and formality of data treatment

Clitber Light informs the users that the collected data will be exclusely processed for the reasons listed below and to keep the users updated on news, promotions, competitions and the general business of Clitber Light.
Being steady the communications and diffusion in law terms, the data can be communicated in Italy or abroad to:
- our agents and distributors net
- factoring companies 
- credit institutes
- debt collection companies
- credit insurance companies
- commercial information companies
- professionals and consultants
- transport companies
- insurance companies
- private and public labs entitled by Clitber Light to carry out tests and analysis
- to activate sales contracts
- for direct marketing, also through newsletters, Mms messages or Text (Sms) messages or any other kind 
- for information programms
- to create professional profiles concerning clients and consumers
- for marketing researches or other analysis useful to improve the proposed products or services
The gathered data could be treated in electronic form, magnetic, telematics or paper format, and, anyhow, they will be protected by the suitable safety systems and constantly updated and stored in a safe and controlled environment.

2. Data conferring and consequences of a possibile denial

The data conferring is not compulsory, except for the cases in which the collected data should be used to activate a contract or a service requested by the user. In this case, the data conferring denial of the interested user's implies the impossibility for Clitber Light will imply the impossibility to execute the received task.

3. People in charge of the treatment and spread limitations

The personal data filled in by the user will be known and used by Clitber Light and/or its branches at the aim to give execution to the activities object of the data gathering ( for example, to give execution to contracts of sale or service performance or for the newsletter delivery). The data could be communicated to other controlling, controlled and/or connected companies to Clitber Light in Italy, in the European Union or towards countries not belonging to the European Union, provided the Country regulations assure an adequate level of protection to people. The adequacy will be estimated comparing the systems of the foreign Country to the Italian ones. 
The data could also be communicated to suppliers of electronic communication, financial brokers, credit institutes and other financial organizations, managers of central informatics systems (risk, anti-fraud, etc.), insurances, consultants and professionals,  who assist Clitber Light on the credit collection and in the lawsuit management, companies entitled to pack, ship and deliver the purchases or that deliver the mail and the commercial newsletters, organizations or research companies, associations of no profit organization.

4. Rights of the interested user

Owner and responsible of gathered data treatment is Clitber Light located in Italy, Via A.Carpenè, 1 - Z.I. 33070 Maron di Brugnera (PN), where the interested users can addressed in writing for the exercise of the sanctioned rights on art. 7 D. Lgt. 196/2003, that is for: 
1) to obtain the indication of personal data origin, the purposes and modalities of the treatment, the logic applied in case of treatment carried out with the aid of electronic instruments; the references of treatment holder, of the subjects or categories to which the data might be communicated or might come to acquaintance.
2) to obtain the update, the correction or the integration of the data, the cancellation, the transformation in anonymous form or the freeze of treated data due to the violation of the law, included those in which the conservation is not necessary with respect to the objectives for which they have been gathered or consequently treated, the declaration that the requested operations have been brought to the attention, also as regards their content, of those who have received, by communication or spreading, except for the case in which such implementation is impossible or implies the employment of  disproportionate means if compared to the defended right; 
3) to oppose for legitimate reasons against the treatment of personal data, even if  pertinent to the aim of the gathering, or to the treatment of personal data which imply the mailing of advertisement or direct sale or for the fulfilment of marketing researches or commercial communication.

Art. 7. The access right to personal data and other rights (D.Lgs 196/2003)

1.The interested user has the right to obtain the personal confirmation of the existence of  personal data, even if not yet registered, and their communication in intelligible form. 
2. The interested user has the right to obtain all the indications on:
a) origin of personal data;
b) the purposes and modalities of the treatment;
c) the logic applied in case of treatment effected by means of electronic tools;
d) the identification data of the owner, of the responsible persons and of the representative designed in accordance to art. 5, subsection 2;
e) the subjects or the categories of subjects to which the personal data can be communicated or which can learn them as legal representative in the State territory, or entitled representatives.
3. The interested user has the right to obtain:
a) the update, the correction, or, when it shows interest, the data integration;
b) the cancellation, the anonymous transformation or the block of the treated data in violation of the law, included those for which it is not necessary the conservation in accordance to the aims for which the data themselves have been gathered or consequently treated;
c) the confirmation that the operations indicated at letters a) and b) have been brought to cognizance, also for their content, of those who have communicated and diffused the data, except for the case in which such implementation is revealed impossible or it involves the employment of enormous means with respect to the protected right.
4. The interested user has the right to oppose totally or partially:
a) for legitimate reasons concerning his own personal data treatment, and also if connected to the aim of the gathering;
b) the treatment of his own personal data, with the aim to send advertisements or direct sales information or to fulfil the marketing researches or commercial communication.

Art. 13. Circular Letter (D.Lgs 196/2003)

1. The interested user or the person where the data have been gathered are previously orally or in writing about the following:
a) the purposes and the modalities of data treatment;
b) the obligatory or optional nature of data conferring;
c) the consequences of a possible refuse to answer;
d) the subjects or the categories of subjects to which the personal data can be communicated or which can learn them as legal representative in the State territory, or entitled representatives, and the diffusion environment of the data themselves;
e) the rights in Art. 7;
f) identification data of the owner, and if named, of the legal representative in the State territory in accordance to Art. 5 and of the responsible person. If the owner designed more representatives, at least one of them has to be indicated, giving instructions in the web site the communication net or the way to easily find the updated list of all the responsible representatives. If a responsible representative is designed for replying to the interested user in case of rights claim in accordance to Art. 7, such responsible representative is indicated.

2. The circular letter indicated at subsection 1 also contains the elements foreseen by the specific disposition of this code and might not include the elements known to the person who provides the data or whose knowledge can concretely obstacle the execution, for a public subject, of inspections or checkings with the aim to defend or safeguard the State or to prevent, to control or to repress crimes. 
3. The Garantor can invalidate by an issued official measure the simplified modality for the provided informative, in particular from telephone services regarding assistance and custom information.
4. If the personal data are gathered at the interested user's address,  the informative at subarticle 1, including the categories of treated data, is given by the interest user itself at the data registration, or, if the communication is foreseen, not beyond the first communication.
5. The disposition at subarticle 4 can not be applied when:
a) the data are treated according to a law obligation, a rule or the community norms;
b) the data are treated with the aim to develop the defensive investigations expressed on law 7 december 2000, nr. 397, or, however, to assert or defend a right in court, provided the data are treated solely for these aims and only for the period needed for their achievement;
c) the informative to the interested users implies the use of means that the Garantor, assigning possible suitable measures, clearly declares as disproportionate with respect to the protected right, or it reveals itself, at Garantor's judgment, impossible.