Personal data protection disclosure

in accordance with Art. 13 of Italian Legislative Decree no. 196 of 30 June 2003

This disclosure is given, in compliance with Art. 13 of Italian Legislative Decree no. 196/2003 (the “Personal Data Protection Code”), to users (hereinafter the “Users” or the “User”) of the website, in its desktop and mobile versions (hereinafter the “Website”) owned by Edizioni Morelli srl (hereinafter the “Data Controller”) and aims to describe how the Website is managed with regards to personal data processing and to allow Website Users to understand the purpose and methods of personal data processing carried out by the Data Controller, if such is conferred.

The Data Controller sees the privacy of its users as an essential element to be safeguarded under the scope of its activities. The Data Controller is assiduously committed to searching for the best possible protection of personal data, including information on the data processing of Website Users and the preparation of technological measures aimed at avoiding any data loss, so as to guarantee that the processing of the personal data of the User takes place in compliance with personal rights, fundamental freedoms and dignity, with specific reference to confidentiality and personal identity.

Collection of browsing data

During normal operation, the computer systems and the technical and software procedures underlying the Website function, acquire certain personal data, the transmission of which is implicit in the mechanisms used for the access and function of internet protocols.

Each time the User connects to a website and each time it recalls or requests any contents, the access data is saved in our systems in the form of tabular or linear files.

This category of data includes, for example, the IP addresses or domain names of the computers used by the users connecting to the website, the request made by the User’s browser in the form of the URI (Uniform Resource Identifier) addresses, the date and time of the request made to the server, the method used to submit the request to the server, the quantity of data transmitted, the numerical code indicating the status of the response given by the server and other parameters relating to the operating system and computer environment of the User.

This data may be used by the Data Controller solely in order to obtain anonymous statistical data on the use of the website in order to identify the pages preferred by Users and therefore supply ever more appropriate contents, and to ensure that it is all functioning correctly. At the request of the Authority, data may be used to ascertain liability in the event of hypothetical computer crimes to the detriment of the website or its Users.

Type of users

According to website use, Users can be divided up into two types: Private Users and Professional Operator Users (such as estate agents, construction companies, other professionals and companies operating in the sector).

Private Users can access certain services (e.g. property search) anonymously.

Professional Operator Users access the services intended for them after registration.

Purpose of processing

The data collected via the website will be processed lawfully and according to principles of correctness; it will be used to provide the services envisaged by the website.

In addition to the collection of browsing data, which takes place automatically (as per the paragraph above), the User may voluntarily supply personal data that is collected by the Data Controller exclusively through the completion of certain fields requiring data entry (hereinafter “Forms”) offered on-line on the Website. There are different types of Forms according to the type of service the User wishes to use.

With Professional Operator Users, the Data Controller collects data on-line on the Website, by means of direct contact and the stipulation of contracts.

On various pages and screens of the Website, the User has the possibility of sending personal data (e.g. e-mail address, name and surname, telephone number, postcode, other personal and other data). The sending of this data is optional, specific and voluntary and entails the subsequent acquisition of the sender’s e-mail, which is necessary to respond to the requests as well as of any other personal data as may have been entered for the specific service requested.

The personal data that the User supplies will be recorded and stored on protected electronic storage devices and processed using suitable security measures, also associating it and integrating it with other electronic files or databases.

More specifically, for the contact service with estate agencies, construction companies, private users and other subjects publishing property advertisements (hereinafter the “Advertisers”) with regards to the property advertisements published (hereinafter the “Advertisers Contact” service) and for the service of forwarding on the User’s searches to the estate agencies and other companies and professionals competent in the search zone (hereinafter referred to as the “Search Forwarding” service), in order to fulfil the requests for information, the data will need to be disclosed to the Advertisers on the Website, thereby authorising them to process it accordingly.

The nature of these services requires the disclosure by the User on the Website and the consequent processing of data and information about the User’s approaches and preferences as regards location, type and characteristics of properties and any financing; this data and information and the related processing are, in fact, essential in order to satisfy and answer the User’s requests.

The data collected may be used to supply services connected with the obtaining of commercial proposals and to apply for loans offered by banks or financial companies.

The sending of e-mails to any addresses as may be given on the Website shall entail the acquisition by the Data Controller of the sender’s e-mail address. This e-mail address, together with any other personal data as may be collected, is necessary in order to be able to respond to the requests sent and supply the services specifically requested.

Data will be processed electronically and/or as hard copies, mainly using automated, computerised procedures and will be carried out directly by the Data Controller's organisation or by external subjects to said organisation, as data supervisors and/or persons in charge of the processing as well as service companies, as data supervisors and/or persons in charge of the processing.

Suitable security measures are envisaged to avoid any incorrect or unlawful use of data, access by unauthorised subjects and loss of data.

No data collected on the Website is disseminated except in order to supply the service envisaged by the Website.

Data processing under the scope of the Advertisers Contact service

Need for specific consent

Under the scope of the Advertisers Contact service, data may be disclosed to the estate agency that publishes the property advertisement (the contact details and references relative to the agency are published in the advertisement), to any property group with which the estate agency is affiliated, the construction company and other companies publishing property advertisements that will therefore also become data controllers of the data processing.

Said data controllers shall process the User’s data in order to answer his/her requests for information about the property or properties he/she has chosen, or for consultancy on financing and will proceed in accordance with Article 13, paragraph 4 of Italian Legislative Decree no. 196/2003 to provide the User with a complete disclosure relative to the processing of his/her personal data.

At any time, the User may exercise his/her rights pursuant to Article 7 of Italian Legislative Decree 196/2003 by sending written notice to the estate agency, construction companies or any other company publishing a property proposal, to the potential property group with which the estate agency is affiliated and the credit intermediary.

In compliance with current legislation, with reference to the processing of said personal data, specific (compulsory) consent will be requested for the processing and communication of this data by selecting the “Accept” box on the specific form.

Nature of data conferral

Data conferral is optional but any refusal by the User will make it impossible for the Data Controller to follow up on the requests and provide the services requested pursuant to the paragraph above.

Processing method

The Data Controller will process data in compliance with legislative obligations, guaranteeing complete compliance with provisions of law, contracts and regulations. The recording and processing of data shall take place both as hard copies and electronic ones, with logics that are closely related to the above-described purposes and, in any case, in such a way as to guarantee the security and confidentiality of said data. The Data Controller will process the personal data both directly and through other subjects acting as Supervisors, who may be internal or external to the Data Controller’s structure, or act as appointed persons.

In compliance with applicable legislation, an anti-spam checking system is in place on communications made through the Form used for replying to advertisements made available to Users. The data entered there may be verified purely in order to identify any unlawful activities or contents that are not compliant with the General Conditions of the Service, but will not be processed or disclosed for commercial or promotional purposes.

Data security

The data collected and processed will be protected using physical and logical methods so as to minimise the risks of unauthorised access, dissemination, loss and destruction of data, in accordance with Italian Legislative Decree no. 196/2003 and the “Technical Specification” annex.

Scope of disclosure and dissemination of data

The data supplied by the User will be disclosed and used only by the Data Controller and any companies as may be appointed as data supervisors.

As specified, for some services, the data will be disclosed to companies collaborating with or using the services of the Data Controller (for example the individual sellers for information on properties; banks or credit intermediaries for the disbursement of loans and mortgages and other financial services connected with the purchase and sale of property) with the sole aim of supplying the services requested by the User. In these cases, the companies are independent data controllers and the Data Controller is not responsible for their processing of the data. The Data Controller also refuses all liability for contents and compliance with Privacy law by websites that are not managed by the Data Controller.

Transfer of data abroad

The personal data collected via the Website may be transferred outside national territory only and exclusively in order to provide the services requested through the Website and in compliance with the specific provisions envisaged by the Privacy Code.

Information on cookies, search engines and data on position

Cookies aim to speed up the analysis of traffic on the internet, facilitate Users access to the services offered by the Website and provide advertising that is useful and pertinent to visitors. Using cookies does not transmit or acquire personal data, nor are any User tracking systems employed. If the User does not wish the information he/she has supplied to be collected through the use of cookies, he/she may implement a simple procedure present on the browser, which disables use of cookies.

Information relative to the property proposals included on the Website will be visible in the searches carried out on the internal search engine and may be made available to third party search engines insofar as the Website allows for the indexing of its contents by third party engines.

If the page relating to the advertisement has already been removed by the Website, it is possible that a cache copy may remain in the search results for a few days. The search results are not managed by the Website but the User may signal the removal of the page and request an update of the cached copy directly from the search engine.

For more information, visit the page: http://www.villeecasali.com/privacy-policy/

Duration of processing

Data processing shall last for no longer than necessary to fulfil the purpose of collection, i.e. to save search criteria, notification, publication of advertisements and contact details of professional operators.

Processing shall last until the data subject decides to delete the data entered, by notifying the Data Controller.

Rights of the data subject

Article 7 of said Italian Legislative Decree no. 196/2003 (the "Privacy Code") gives the User the faculty to exercise specific rights.

More specifically, the User shall have the right to obtain confirmation as to whether or not personal data concerning him/her exists, regardless of whether or not it has been recorded, and to communication of such data in intelligible form.

He/She may also ask to know the source of the data, the logic, purpose and method of processing and the details identifying the Data Controller, the Data Supervisor and the subjects/categories to whom and which data may be disclosed or who/which may become aware of such in their capacity of designated representative in the State, of Supervisors or Processors.

He/She may obtain the erasure, transformation into anonymous form or block of any data processed in breach of the law, and the update, correction or, where interested therein, the supplementation of said data; he/she may also oppose processing on legitimate grounds.

All rights of the User have been brought to the attention, also with regards to its content, of those to whom the data has been communicated or disclosed.

To exercise the rights pursuant to Art. 7 of Italian Legislative Decree no. 196/2003, the User may contact:

Edizioni Morelli srl, Via Grancini 8 20145 Milan

Data Controller, supervisors and persons appointed for processing

The Data Controller is Edizioni Morelli srl, in the person of its pro tempore legal representative, which uses Data Supervisors to achieve the purposes specified above. The Data Controller has also appointed its employees and collaborators as persons in charge of the processing.

The data subject may also contact the Data Controller, Edizioni Morelli srl at any time:

Address: Via Grancini 8 20145 Milan

E-mail: edizionimorellisrl@gmail.com

in order to:

• obtain an updated list of supervisors
• have clarification of the operations described
• exercise the rights pursuant to Art. 7 of Italian Legislative Decree no. 196/2003

Amendments

This disclosure may be subject to amendment. If substantial amendments are made to the use of data relative to the User by Edizioni Morelli srl, it will notify the User publishing it as clearly as possible on its pages.