PRIVACY POLICY

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INFORMATION PUSUANT TO ART. 13 OF LEGISLATIVE DECREE NO. 30.06.2003, N.196

DATA PROTECTION POLICY

1. INTRODUCTION
In compliance with the requirements of Article. 13 of Legislative Decree no. 30.6.2003, n. 196 (hereinafter "the Decree"), information for those who interact with the web services of APAM Esercizio S.p.A is accessible electronically from www.apam.it.

2. LINKS TO TERTIARY WEB SITES 
Links to other websites may be found on the web pages of APAM Esercizio S.p.A These links serve to provide a better service to APAM’s users; APAM Esercizio S.p.A cannot, however, be held responsible, in any way whatsoever, for the content of the web pages accessible via its site.
The existence of a link to another site does not, in any way whatsoever, imply APAM’s approval or acceptance of responsibility for the content of the site accessed. This also applies to the policy adopted for the processing of personal data and its use.

3. TYPE OF PERSONAL DATA PROCESSED AND THE PURPOSE OF PROCESSING
Navigation data and cookies
During normal operations, the IT systems and software procedures used to operate the web site www.apam.it acquire some personal data, the transmission of which is implicit in Internet communication protocols.
Although this information is not collected for identification purposes, through processing and association with data held by third parties, it may allow for user identification..
This category of data includes, for example, the time of request, the method used to submit the request to the server, the numeric code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and the user’s IT environment.
For the collection of such data and their preservation APAM Esercizio S.p.A makes use of Google Analytics, a service owned by Google Inc.

Navigational data is only used to obtain anonymous statistical information regarding the use of the site and to monitor its correct functioning.
Cd. cookies are not used for the transmission of personal information, nor are cd. persistent cookies, i.e. systems aimed at tracking users, of any kind used.
The use of cd. session cookies (which are not stored permanently on the user's computer and are deleted once the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to guarantee the user safe and efficient navigation on the site.
The cd session cookies used in the www.apam.it website ensure that other techniques that are potentially prejudicial to the privacy of the websites users are not necessary, and do not allow for the acquisition of personal identification data.

Data provided voluntarily by the user
The optional, explicit and voluntary forwarding of notices by post, fax, telephone, email or the use of the various menu options on the website www.apam.it (for example, send curriculum vitae), involve the acquisition of the sender’s address, which is necessary to respond to requests, and any other personal data included in the missive or in the communication or in the menu in question. Such data will be treated in accordance with the Decree and for the sole purposes for which it was disclosed.

The provision of personal data provided voluntarily is optional, however, lack of disclosure of such data makes it impossible for APAM Esercizio S.p.A. to provide the requested service and/or to forward the information or requests to the website.

4. PROCESSING METHODS - SAFETY MEASURES
Following consultation of the www.apam.it website, data relative to identified or identifiable persons may be processed.

Personal data is processed electronically and/or on paper, according to standards of correctness, lawfulness, transparency, confidentiality and in accordance with the provisions of art. 11 of the Decree as well as in accordance with any additional provisions of the Decree and other applicable regulations.

All personal data is only processed for the time that is strictly necessary to fulfil the purposes for which they were originally collected. In order to prevent the loss or destruction, even accidentally, of data, or the misuse or incorrect use of such data, as well as unauthorized access to such data, the specific technical and organizational security measures required by the current legislation have been put into place.

5. HOLDER, THOSE RESPONSIBLE AND IN CHARGE OF DATA
Pursuant to art. 28 of the Decree, the navigation processing data Controller, is APAM Esercizio S.p.A with registered offices in Via dei Toscani 3/c - 46100 Mantova.
In accordance with art. 28 of the Decree, the Controller of data voluntarily provided by users, is APAM Esercizio S.p.A, the  provider of the service requested.

The complete list of data controllers, pursuant to art. 29 of the Decree, and/or entities in charge of Data Processing, pursuant to art. 30 of the Decree, for each Group of the company can be obtained at the following e-mail address: apam@apam.it

6. COMMUNICATION AND DISCLOSURE OF INFORMATION
Personal information collected may be disclosed to third parties responsible for implementing the activities related and instrumental to the management of data as well as to the authorities competent in fulfilling legal obligations.

Under Article. 157 of the Decree, the Authority for the Protection of Personal Information may request provision of information and documentation, with the consequent obligation to respond.

7. PLACE OF DATA PROCESSING
The processing of personal data takes place at APAM Esercizio S.p.A’s offices - Via dei Toscani 3 / c - 46100 Mantova.

8. PERSONAL INFORMATION OF A MINOR
The disclosure of the personal information of a minor must be made by a parent or a person who exercises legal authority. Notice is hereby given that APAM Esercizio S.p.A. does not process the personal information of minors without the consent of a parent or the person who exercises parental authority.
Users who have not yet turned 18 are invited not to communicate their personal data under any circumstances without the consent of a parent or person exercising parental authority. APAM Esercizio S.p.A. reserves the right to deny access to services and does not guarantee the successful completion of activities/services requested to any user who has concealed his minor age or has disclosed their personal information without the consent of a parent or a person exercising parental authority.

9. RIGHTS OF THE INDIVIDUAL
Under Article. 7 of the Decree, the individual has the right, at any time, to obtain confirmation of the existence or otherwise of such personal data and to know its content and origin, verify its accuracy, request an update, correction or, when interested, an integration.
Under the same article. 7 of the Decree, the individual has the right, at any time, to request the cancellation of such data, the transformation into an anonymous form or the blocking of data handled unlawfully, including data that need not be kept for the purposes for which the data was collected and processed, and to object, in whole or in part, for legitimate reasons, to their processing..

Requests should be made, pursuant to art. 8 of the Decree, to the Data Controller or Data Processor:

  • by e-mail to dpo@apam.it;
  • by fax to 0376 230 330;
  • by post to APAM Esercizio S.p.A.  - Via dei Toscani 3/c – 46100 Mantova.

10. INFORMATION
For any information relevant to the terms and conditions of use and/or to report any violation of the site www.apam.it, the user can write to dpo@apam.it