SUBJECT: DATA PROTECTION CODE – ITALIAN LEGISLATIVE DECREE 196/2003

We hereby inform you that Italian Legislative Decree n. 196 dated 30th June 2003 (the “Personal Data Protection Code”) provides for the safeguarding of persons and other parties as regards processing of their personal data.
Under the above-mentioned Code, your personal data will be processed in a manner which is accurate, lawful and transparent and protects your privacy and rights.
Pursuant to Section 13 of the Code, please find below information regarding the treatment of your data.

Purpose and methods of data processing operations
We have received your personal data, which will be processed exclusively for purposes strictly connected to and necessary for the fulfilment of contractual obligations and your relations with our company, in particular for:
- entry of your data into our company databases;
- accounting purposes;
- management of payables and receivables;
- compliance with the provisions of civil and tax laws, regulations and European Community provisions.
Processing of your personal data will take place in hard copy and electronic form by the data controller, data processor or agents thereof, with observance of protection measures to ensure security and privacy. 

Nature of data collection and consequences for failure to provide data
Provision of your personal data is compulsory for fulfilment of contractual obligations and, more generally, for compliance with the law.

Communication and publication of data
In order to perform the contract and for the above purposes, your personal data may be communicated to:
- all physical and legal persons (law firms, administration and tax consultants, auditors, transport companies, data processing centres, etc.), if necessary for the above purposes;
- banking institutions for management of payables and receivables;
- factoring and debt recovery companies;
- our employees and consultants who have been specifically appointed and within the scope of their role.
If necessary, and for the above-mentioned purposes, your data may be communicated abroad.
The data collected will not be published.

Data Subject’s Rights
Under Section 7 of the Code, you may at any time exercise your rights vis-à-vis the data controller, which are set  forth below for your ease of reference.

1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him/her exist, regardless of their being already recorded, and communication of such data in intelligible form.

2. A data subject shall have the right to be informed
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.

3. A data subject shall have the right to obtain
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

4. A data subject shall have the right to object, in whole or in part,
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

The rights referred to in Section 7 may be exercised by making a request to the data controller or processor without formalities, also by the agency of a person in charge of the processing. A suitable response shall be provided to said request without delay. Requests may be sent to the data controller via registered letter, fax or e-mail.

5. Data Controller
The data controller is Teko Telecom S.p.A. with registered offices in Via Meucci 24/a, 40024 Castel San Pietro Terme (BO), Italy.