Privacy

These programming conduct guidelines governing confidentiality and privacy (“Privacy Policy”) relate to the website www.stc-it.com (the “Website”) and the processing of personal data performed by S.T.C. Servizio Trasporti Combinati S.p.a. on the occasion of a visit to its Website and interaction by a user with the services and facilities offered by the Website, pursuant to and for the purposes of the relevant Italian legislation.

We have based this Privacy Policy on Recommendation No. 2/2001 which was adopted on 17 May 2001 by the European Data Protection Authorities in a workgroup established by Article 29 of Directive No. 95/46/EC, to identify minimum requirements for the collection of personal data on-line and, in particular, the methods, timescales and type of information that the Data Controller must provide to the user when that user connects to a web page, regardless of the purpose for which the connection is made, in order to guarantee fairness and lawfulness in the data collection practices.

We are aware of the significant importance of safeguarding confidentiality of personal data and we undertake, with the utmost care and attention, to respect the principles designed to ensure secure, protected and orderly browsing on the Internet, bearing in the mind that every time personal data is provided on the Internet, the risk exists that those data may be intercepted and used wrongfully by third parties, so that it is not possible to guarantee full security and protection of the personal data supplied.

This Website may contain links to other websites to which this Privacy Policy does not apply.

This Privacy Policy is updated periodically; the version presently published on the Website is updated to 4 December 2010.

We would recommend the user to check the Privacy Policy periodically in order to remain informed regarding any amendments.

PERSONAL DATA PROCESSING NOTICE PURSUANT TO LEGISLATIVE DECREE NO. 196/2003

This Privacy Policy is valid also as notice to the Data Subjects pursuant to Article 13 of Legislative Decree 30 June 2003 No. 196 (“Italian Data Protection Code”) which identifies the Data Controller who controls and manages the data collected on the Website, describes and specifies the type of personal data collected, the methods of collection of the personal data when the user browses the Website, the purposes of the processing performed on the personal data collected, the purpose of the communication of the personal data to third parties, the measures which we implement to protect and manage the data, the methods by which the user can verify the processing of the personal data collected which relate to them, the methods of exercise of the rights granted to the Data Subject by the Privacy Code.

The Data Controller is the company S.T.C. Servizio Trasporti Combinati S.p.a., having its registered office in at Via Francesco Rolla, Genova, n. 29/C, Tax Code No. 02196090928.

TYPE OF DATA – COLLECTION AND PURPOSES OF PROCESSING

Connection data

The collection and treatment of the personal data of the users of the Website is generally limited to only the connection data, that is to say the data which the computer systems and software processes which run the Website acquire in the course of their normal operation and whose transmission is implicit in the use of Internet communication protocols. Into this category of data fall the IP addresses or domain names of the computers used by users who connect to the Website, the addresses in URI (Uniform Resource Identifier) annotation of the resources requested, the time of the request, the method of use in submitting the request to the server, the size of the file obtained in reply, the code number indicating the status of the reply given by the server (success, error, etc.) and other parameters relative to the user’s operating system. This information is not collected in order to be associated to identified users and parties, but it could, by its very nature, by way of formulations and association with other data held by third parties, permit identification of users. The connection data are collected and processed for the sole purpose of extracting anonymous statistical information regarding access and use of the Website in order to check on correct functioning and to improve the content and said functioning. The connection data are deleted immediately following the analysis in anonymous form; they could be used for the ascertainment of liability in the event of any criminal acts performed to the detriment of the Website or through the Website: without prejudice to that possibility, in general the user’s connection data are not preserved for more than seven days or in compliance with the term established by the applicable law.

Data provided voluntarily by the user

We also collect and process personal data (e.g. contact details such as first name, last name, telephone number, email address; corporate details such as head office address, telephone number, email addresses, information regarding business activities; information regarding goods or transport; third party data only where strictly necessary for the purposes of the services required and exclusively for that purpose) provided voluntarily by the user (and with the specific consent of the latter, where required) when the user uses the Website, or at the request of the user for the services offered by the website – and for the fulfilment of reciprocal contractual obligations deriving from the relationship established by the user or the provision of services strictly connected thereto or necessary for that reason  – such as log in or registration on the website, request for a quote, tracking of goods, on-line invoicing, participation in a programme or other initiative offered on the Website, or to control access to areas protected by password or management of requests for information received from the user; or, with the voluntary and optional consent of the user, in the event of a request for sending of information or informational, promotional or advertising materials, newsletters or even employment applications or curriculum vitae sent in by the user.

Again with the specific voluntary and optional consent of the user, we collect and process personal data (such as, in addition to those indicated above, information relative to habits, interests, preferences, consumption propensities, user’s profile, especially with reference to transport of goods) for profiling, surveys of the level of satisfaction, compilation of internal statistics, customer loyalty schemes and marketing purposes, such as sending to the user – also by way of automatic calling systems without human intervention, newsletters, emails, text messages –information and updating on products, services and promotional and commercial offers.

Usually we do not collect or process sensitive data (personal data capable of revealing racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of political parties or trade unions, associations or organisations of a religious, philosophic, political or trade union nature or personal data capable of revealing the state of health or sex life), unless the sensitive data can influence the provision of the service requested or the performance of the contract; in those cases, we can collect and process the sensitive data only with the express consent of the user.

Further specific purposes, regarding individual processing, are set out in detail in the sections of the Website relative to the services provided. In correspondence with the individual sections, the user will find specific notices about personal data processing, pursuant to Article 13 of the Privacy Code.

Unless specific consent is required for the processing of the personal data connected to specific purposes (in that case the user shall be requested to express the relative consent using the methods indicated), by continuing to use this Website, the user is consenting to the processing of personal data as established in this Privacy Policy. 

We can also process the user’s personal data without consent in the instance listed in the Privacy Code (inter alia: to fulfil contractual obligations or to fulfil obligations prescribed by national legislation or regulations or European Community law.

OPTIONAL NATURE OF THE SUPPLY OF DATA

In addition to that specified in relation to connection data, and without prejudice to that provided in some sections of the Website with reference to specific purposes of the processing, the user is free to provide the personal data in order to request the services which we offer such as registration or log in to the Website (e.g. in order to receive newsletters)  sending of informational, promotional or advertising material, profiling, surveys of the level of satisfaction, compilation of internal statistics or direct marketing. Failure to supply personal data, however, may render it impossible for us to send informational, promotional or advertising material or to perform for profiling or satisfaction questionnaires.

The personal data required for the provision of the services requested by the user (including request for a quote, tracking of goods, on-line invoicing), to perform reciprocal contractual obligations deriving from the contractual relationships established with the user, for the provision of services strictly connected or necessary to same, are strictly necessary for the specific purpose of the processing. The failure to supply data may render it impossible for us to provide the service or facilities requested or to perform contractual relationships for which the processing is intended, without prejudice to the fact that the consent of the user is not required for the collection and processing of personal data necessary for those purposes, pursuant to Article 24 Privacy Code.

COOKIES

Cookies are small text files stored on the hard disk of the user’s computer which the server sends to the user’s browser when a web page is visited. Cookies therefore allow a connection between the user’s computer and the browsing on the Website, permitting the server to download the web pages faster on subsequent visits and allow recognition of the profile which may have been created by the user.

The Website uses session cookies for specific and limited purposes. The Website uses cookies to offer the user easier browsing on the Website to allow logged in/registered users easier access. The session cookies, strictly limited to the transmission of session identifiers (or random numbers generated by the server) in order to allow secure and efficient surfing of the Website, can be deleted manually by the user browser functions. The cookies, which are used following log in or registration by the user by way of the collection of personal data, are used to provide the user with easier access to the area restricted to logged in or registered users, in addition to  personalized browsing on the Website.

The cookies used do not permit any control over the user’s computer nor any sending of programmes or downloading of viruses; furthermore, the cookies do not permit access to the user’s computer nor any information stored there.

Browsers are set up so that they can accept cookies automatically; users can change the set up of their own browser to disable that function (using the Help section on the tool bar which shows how to avoid reception of cookies and other technologies used to track users or, usually, selecting the items “Tools – Internet Options – Privacy” and select the preferred set up). Disabling cookies in any event permits browsing on the Website but may limit the possibilities for use of the Website functions.

We do not have any kind of access and/or control over cookies used by other sites whose links appear on our Website and therefore we do not assume any responsibility in that respect; accordingly would invite the user to read the Privacy Policy on any third party sites.

PLACE AND METHOD OF PROCESSING

The personal data collected on our Website, physically hosted by the company Cap S.p.A. – Fastweb Server Farm – having its administrative headquarters at Via Lungobisagno Dalmazia 71, 16141 Genova, are processed and preserved by an electronic system at the headquarters of the Data Controller Company and are handled only by that company’s employees, contractors or appointed parties, or by persons appointed to perform occasional maintenance operations.

The server which makes the Website available is located in Italy care of the company Cap S.p.A. – Fastweb Server Farm - Data Controller for its own independent data processing.

The personal data collected are prevalently processed by computers and in any event automatically but also at times without the aid of electronic instruments i.e. manually. In any event the data are preserved only for the time necessary to pursue the purposes for which they are intended on each occasion and in compliance with current law. We collect and process the personal data in compliance with current provisions in order to safeguard their confidentiality, integrity, completeness and availability and to reduce to a minimum any risks of deletion, destruction, loss, tampering (including unintentional), unauthorized access, processing without consent or not in compliance with the purposes of data collection, unlawful or improper use of the data, or unlawful disclosure.

We cannot in any event be held liable for any untruthful or inaccurate information supplied by the user nor for information regarding the user which may be supplied by third parties, including fraudulently, nor in any event can we be held liable for any consequences which may ensue for that party.

Similarly, we cannot be held liable for any damages of any nature caused directly or indirectly by the access to and/or browsing on the Website.

COMMUNICATION OF PERSONAL DATA

We communicate the user’s personal data within the limits and using the methods specified in this Privacy Policy. The personal data provided by the user are used for the sole purpose of providing the service or facilities requested and are accessible by our internal and external personnel authorized to perform the processing.

The user’s personal data can be communicated to third parties who perform services or functions connected with or instrumental to the activities which we perform, and for purposes connected to the provision of the services requested by the user, to our consultants, parent and/or subsidiary and/or affiliated companies, to parties who perform insurance, banking, para-banking services and to parties appointed for the maintenance of the computer system or the software in use.

The personal data may be communicated to any party who appears as legitimate recipient by legal or regulatory obligations, for example but not limited to, the legal authorities, police, Inland Revenue, the States and Authorities of the States of the European Union or third parties with respect to the European Union for reasons of security (the collection and processing of personal data pursues, in that case, that objective), in accordance with the applicable law.

In compliance with the purposes shown above, the user’s personal data can be transferred to third party commercial partners, including companies having their headquarters outside the European Union who guarantee a different or lower level of protection for the personal data than that offered by this Privacy Code or within the European Union, with the consent of the voluntary and optional consent of the user.

The third parties to whom the data can be communicated in terms to the foregoing, act as independent Data Controllers.

RIGHTS OF THE DATA SUBJECTS

The rights of the data subject
The Data Subject has the right to obtain confirmation of the existence or otherwise of personal data which relate to him, even if not yet recorded, and their communication in an intelligible form.

The Data Subject has the right to obtain details of:

1. the source of the personal data;
2. the purposes and the methods of processing;
3. the logic applied in the event of processing performed with the assistance of computers;
4. the details of the Data controller, Data Supervisor, persons in charge of the processing and the designated representative pursuant to Article 5(2);
5. the parties or categories of data subjects to whom the personal data can be communicated or who can have access to said data in their capacity as designated representative of the government on the territory, data supervisors or persons in charge of data processing.

The Data Subject has the right to obtain:

1. the updating, correction or, where there is a legitimate interest, the supplementation of the data;
2. the deletion, transformation into an anonymous form or blocking of the data processed in breach of the law, including those whose preservation is not necessary in relation to the purposes for which the data were collected or subsequently processed;
3. the attestation that the operations referred to at subparagraphs a) and b) have been made known, also as regards their content, to those to whom the data have been communicated or disclosed, with the exception of the case in which that performance is impossible or requires the use of resources greatly disproportionate to the right protected.

The Data Subject has the right to challenge, in whole or in part:

1. for legitimate reasons, the processing of their personal data, even if pertinent to the purpose of the collection;
2. to the processing of their personal data for the purposes of sending of publicity material or direct sales or for market research or commercial communication.

In order to exercise your rights or if you have any questions or requests in relation to personal data, please contact Mr. Fabrizio Bertacchi, details below:

S.T.C. Servizio Trasporti Combinati S.p.A. Via Rolla 29 C 16152 Genova – Italia
email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it
Tel: 010.65.75.210