Altaeco S.p.A.

PRIVACY POLICY

FOREWORD

With this document, Altaeco S.p.a., with registered office in Via Giovanni Pascoli 4/6, 20010 Vittuone, Milan (MI), data controller of the web sites of the Altaeco S.p.a. Group and specifically the following:

intends to provide information concerning the management of the websites with regard to the processing and protection of personal data of data subjects (users) that browse them, with direct access from the home page or from internal pages.

This document is a policy in compliance with the provisions of Article 13 of Legislative Decree no. 196 of 30 June 2003 (Code on the protection of personal data). This document is valid only and exclusively for the web sites mentioned above for which the company is data controller and not for other websites consulted by the user through links that may be activated in the aforementioned pages. By simply browsing the web site, data may be collected that refer to identified or identifiable persons.

DATA CONTROLLER, DATA PROCESSORS AND PRIVACY COMMUNICATION

The Data Controller is Altaeco S.p.A., with registered office in Via G. Pascoli 4/6, 20010 Vittuone, Milan (MI).

An updated list of data processors, appointed by the Data Controller pursuant to art. 29 of Lgs. D. 196/2003, is available in the registered office of the Data Controller. For any communication regarding articles 7 et seq of Lgs.D. no. 196/2003, as amended and supplemented, the Data Controller has provided the e-mail address privacy@altaeco.com

DATA PROCESSED.

Browsing data:
The information systems and the software procedures responsible for the functioning of the web site acquire, during their normal use, certain personal data, the transmission of which is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified data subjects but, because of its nature, it could be possible to identify the users through processing and association with data held by third parties.

This category of data includes IP addresses or domain names of computers used by the users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numeric code indicating the state of the reply given by the server (completed, error, etc.) and other parameters related to the user's IT environment and operating system.

The data collected in this manner could be used to establish responsibility in the event of any IT crimes that damage the web site.

DATA SUPPLIED DIRECTLY BY THE USER

The optional, explicit and voluntary sending of data as required by various sections of the above mentioned web site are used in order to carry out the user's requests (for example, but not limited to: when information or clarification is requested by writing to the e-mail addresses on the web site on the home page or on the internal pages or when CVs are spontaneously sent for the purpose of submitting one's candidacy, or when direct calls are made or faxes are sent to the numbers in the "contacts" section. With particular regard to the data entered by companies and professionals in the pages dedicated to the corresponding registration required for the application and candidacy for training.

Specific policies for particular services requested by the user are present on the above mentioned web site.

NATURE OF DATA PROVISION.

Browsing data is processed since necessary to carry out IT and telematic protocols; the provision of personal data by users is free and optional.

PROCESSING METHODS.

The data collected through the above mentioned web site is processed through IT and telematic procedures. Technical data is stored on the company's servers, to which are subject to all the security measures provided for by Lgs.D. 196/2003 and attached.

COOKIES

The Data Controller uses certain cookies as indicated in detail in the specific cookie policy present on the company's web site.

RIGHTS OF THE DATA SUBJECT

The data subject may exercise his/her rights as provided for by articles 7, 8, 9 and 10 of Lgs. Decree no. 196. issued on 30 June 2003 by contacting the Data Controller. In particular, according to art. 7, the data subject has the right to obtain confirmation of the existence or otherwise of personal data related to him/her, including data that has not yet been recorded and to obtain that data in a clearly understandable form. The data subject has the right to obtain information regarding: a) the source of any personal data; b) the purposes and methods of processing; c) the logic applied in the event of electronic processing; d) identification details relating to the Data Controller, the data processors and the representative designated in compliance with article 5, paragraph 2; e) the subjects and categories of subjects to whom the personal data may be communicated or who may become acquainted with said data, in their capacity as data processors, persons in charge of data processing and appointed representatives in Italy. The data subject has the right to obtain: a) that said data is updated, amended and, if in the interest of the data subject, completed; b) that any data processed in violation of the law be cancelled, made anonymous or blocked, including any information that does not need to be held for the purposes for which it was collected or subsequently processed; c) receive confirmation that the operations in a) and b) have been made known, also as regards their content, to the parties to whom the data has been communicated or disclosed, except in cases where this is impossible or requires the use of means that are clearly disproportionate with the protected right. The data subject has the right to oppose, either in full or in part a), for legitimate reasons, to the processing of personal data relating to him/her even if relevant to the purposes it was collected for; b) to the processing of personal data relating to him/her for the purposes of delivering advertising material, direct sales, market surveys or for marketing communications.

DISCLOSURE AND DISSEMINATION.

The data collected will not be disseminated, sold or exchanged with third parties without the express consent of the data subject, except for any disclosures to authorised third parties - committed to confidentiality or in the case of appointed data processors pursuant to art. 29 of Lgs.D no. 196/2003 - (such as IT support companies and hosting companies) where necessary for the purposes of this policy. The data may be disclosed to the competent authorities in accordance with the law.

PLACE OF PROCESSING OF PERSONAL DATA.

Personal data acquired through web services offered by Altaeco S.p.a. will be kept at the registered office in Via G. Pascoli 4/6, 20010 Vittuone (MI).

The data is handled only by technical personnel in charge of processing or by those appointed for occasional maintenance work.