Atlantyca S.p.A. (hereinafter, "Atlantyca", the "Company" and/or the "Data Controller") hereby undertakes to protect the privacy of its own users.

The policy adopted in this respect, the information activity developed in connection with the processing of data of any visitors and clients of the SITE__HTTP Internet Website (hereinafter, the "Website"), and the arrangement of technological measures aimed at preventing the spread of data, clearly prove the commitment and reliability of our Company as regards the processing of personal data.

As foreseen under Italian Legislative Decree No. 196 dated 30 June 2003 (hereinafter, the "Data Protection Code"), which has replaced Italian Law No. 675 dated 31 December 1996, Atlantyca, in the capacity as data controller, in the person of its legal representative, hereby wishes to inform users of the following: the processing of personal data by the Data Controller (or by the persons in charge of the processing or by the data processors specified hereunder) complies with the provisions set forth by the laws and regulations in force on the subject-matter.

Data collection and on-line registration

In this information notice we explain how we collect your personal data on-line, as well as how we protect and use same.

Atlantyca S.p.A., having registered office in Milan, Corso Magenta, 60/62, Fiscal Code 05426990965, and the further persons in charge of the processing or data processors specified hereunder, control and use, either jointly and/or severally, all personal data you may enter on-line on our Website, both through a computer and through a mobile phone, unless otherwise indicated on the www.geronimostilton.com Website, pursuant to and to the extent of Italian Legislative Decree No. 196/2003 on Data Protection.

Types of collected information

Atlantyca does not collect any personal data without having obtained the specific data subject’s express consent to said extent.  Solely exceptionally in the event that the collection is aimed at sending advertising material, will we collect the user’s address.  Some Website functionalities do not request the user’s registration, whilst other activities or services request the user to register and/or open his/her own account and, should that be the case, the respective particulars (name, address and e-mail address) shall be requested.

In particular, we shall collect your particulars in different ways, even throughout your registration on the aforesaid Website and upon enrolment to competitions, when using some applications, purchasing our products and/or services, upon any call for tenders or competitions, upon the forwarding of letters or comments, while surfing our Internet Website and whenever you answer to our messages.

This information notice explains to you the way in which our Company and/or the other persons specified hereunder collect, file, use and manage your data and the choices you may make in connection with the collection and use of your personal data, also with respect to under-age persons.  It is hereby acknowledged that the use of the supplied data is made in compliance with the provisions of this information notice and as provided for or requested by applicable law.

Use and processing of the user’s personal data

Collected data may be used for statistical and marketing activities, in view of fulfilling the information and commercial promotion aims of the products distributed by the Company and by third party companies as specified hereunder, for market research purposes, in order to analyse the activities and choices of consumers, to provide and customise our services, for commercial proposals concerning products and/or services, and to manage the consequent contractual obligations and to allow users to take part in the activities on the Website, and to inform them on any further activity such as competitions, prizes, to send birthday wishes and/or newsletters and information on other interesting events or promotions regarding the Stilton world.

By registering himself/herself on the Website, the user shall be able to receive marketing information.  By providing his/her consent, he/she shall authorise us to use the supplied data within the aforesaid scope.  It is hereby acknowledged that the aforesaid registration is optional and may be changed and/or revoked at any time.  Nonetheless, upon the data subject’s rejection to said extent, it shall be impossible for the Data Controller to follow up any requests and to perform the requested services.

In order to be sure that the proposed marketing activities are interesting for you, we shall use your collected data through (i) different technical procedures such as, for instance, cookies (for further information in this respect, please refer to "Use of cookies"); (ii) data collected through census; (iii) your answers to our messages; (iv) consumer surveys.

The Data Controller may use the aforesaid information worldwide.  We hereby guarantee that our Company shall process your data with the adequate protection.  In particular, the Data Controller hereby undertakes to process the data in compliance with the relevant regulatory obligations, ensuring full compliance with the relevant law and contractual provisions and with the relevant regulations.  Data registration and processing shall take place on paper and electronically, with logics which are strictly related to the aforesaid purposes and, in any event, in such a way as to ensure the security and confidentiality of data.  The Data Controller shall process the relevant personal data and shall develop same both directly and having recourse to the work of other persons, who shall act in the capacity as Data Processors, either inside or outside the Data Controller’s structure, or in the capacity as persons in charge of the processing.

Security of data

Collected and processed data are protected by physical and logical methodologies such as to reduce any risks of unauthorised access, together with the spread, loss and destruction of data to the minimum extent, pursuant to Italian Legislative Decree No. 196/2003 and to the ‘Technical Specifications’ Enclosure.

We shall transfer your data to third parties in the following cases:

• If you have given your unequivocal consent upon collection or registration;
• If we have entrusted said task to other companies acting on our behalf.  Should this be the case, the companies entrusted to said extent may solely use your personal data for the declared purpose;
• If we carry out a merger and/or any corporate activity of interest for users;
• If there is a reason for us to believe that the transfer of your data is necessary in the event of legal proceedings or in the event of any order of the public authorities (to the extent permitted by law).  Furthermore, we shall be entitled to transfer the data of all persons registered, should we deem – in good faith – that the foregoing is requested by the laws and/or regulations in force, or that disclosure thereof may prevent the perpetration of an offence, expedite an investigation procedure by the police, protect the security of whomever uses our Websites (in particular, children), or protect the security or integrity of our Websites, to the extent permitted by law;
• If we use external data processors to process and develop any and all supplied data pursuant to the aims foreseen and communicated under this information notice, for instance, hosting activities related to the use of our Internet Websites.  Furthermore, some data may be shared with third parties (such as, for instance, auditors or legal advisors) in order to obtain their respective professional opinion.  Said processing shall be governed by an agreement pursuant to the relevant law provisions, in compliance with the rights to personal data protection.

Transfer abroad

The Data Controller acts worldwide and this may make the transfer of data to Europe, at an international level, to third party service suppliers and to persons in charge of the processing on the Data Controller’s behalf necessary, in order to manage and process same, for the purposes indicated under this information notice including, by way of example but without any limitation whatsoever, the maintenance and assistance of/to our Databases and of/to the Website.  Transferred data shall solely and exclusively be those which are fundamental to reach the result for which we have been authorised and subject to an express confidentiality obligation for partners.

The aforesaid transfer shall solely take place if the entity receiving the information complies with European legislation on personal data protection, abides by the ‘Safe Harbour Principles’ which, as stated by the European Commission, guarantee an adequate level of protection or, in any event, provides an adequate level of personal data protection in compliance with European legislation (for instance, provides adequate contractual warranties with respect to personal data protection), or if you have given your consent to the transfer of your personal data.

In particular, your data may be transferred and registered for maintenance and support purposes on servers available to eBit Consulting s.r.l., a company having a sole quotaholder, having registered office in Milan, Via Borromei 11, Fiscal Code and VAT No.: 06279460965 and to IM*MEDIA s.r.l., having registered office in Palermo, Via Generale Magliocco 27, Fiscal Code and VAT No. 04286410826, who shall be under the obligation to protect them from any unlawful access and unauthorised use, whereby we have entrusted the respective data processors with the processing of the data existing on the servers.

Your participation in the ‘community’ section of our Website, for instance, the comments you send to the blog, may be processed by the aforesaid persons or by third parties, in order to allow research functionalities and other Website functionalities.  Nonetheless, we hereby inform you that the personnel in charge of the processing are also authorised to have access thereto in order to cancel any messages deemed not adequate and/or unlawful, and in order to monitor and protect any under-age persons.  Insertion of messages shall take place under the protection of parents, who have given the respective consent and the foregoing shall release us from any liability as to the inserted content, which shall be the exclusive liability of the user having introduced the message into the system, both from a civil and criminal standpoint.  Any abuse in connection therewith shall be immediately reported to the Police.

The Data Controller abides by the Children's Online Privacy Protection Act (So called "COPPA") and by the ‘Safe Harbour Principles’ which, as stated by the European Commission, guarantee an adequate level of protection with respect to the legislation in force in the countries of the European Union, and we hereby guarantee that we shall take any and all necessary measures to ensure that your personal data are protected.

Guidelines for under-age persons

We hereby invite the parents and adults responsible for under-age persons to spend some time on-line with their own children and to take part in the interactive activities proposed by our Websites.  If the user is an under-age person (therefore, he/she has not reached the age to legally give his/her consent to the collection and processing of data) and wishes to register himself/herself on the Website, it shall be necessary to ask for the permission of the parents or of the guardian for registration purposes, therefore, to confirm to have obtained said permission and to provide their e-mail address.  Therefore, a message shall be sent to the parents, informing them of the occurred registration on the Website and, based on the user’s age, the parents may be requested to confirm the consent to the registration.  Do not send or forward any information by post to the Data Controller or to its subsidiaries without the consent of the parent or guardian.

Guidelines for registration.  How to remove or correct one’s own personal data

We hereby ask the parents and adults responsible for the under-age persons to spend some time on-line with their children and to take part in the interactive activities proposed on these Websites.  If you are not 18 yet and wish to register yourself on our Website, please ask your parents or your guardian for permission to register, confirming to have obtained their permission and providing us with their e-mail address (if your are registering through your computer).  At this stage, we shall send a message to your parents, informing them of the occurred registration on the Website and, depending on your age, we may ask them to confirm the authorisation to the registration.  If you have indicated to be willing to receive further material (solely available to certain age groups, as indicated upon registration), we shall furthermore ask you for your parents’ express consent.  Do not send or forward any information by post to the Data Controller or to its subsidiaries without the consent of your parents or guardians.

How to register oneself and how to remove or correct one’s own personal data

After having registered yourself on our Website, depending on the country in which you are, you shall be sent a confirmation message, or a message asking you to confirm your registration.  You may ask us to correct or remove your personal data from one or all of our mailing lists at any time, by clicking on the ‘Register yourself’ link or on other links indicated on the Website, under the ‘Contact us’ menu on the Website.  We shall solely send you e-mails if you have given your express consent to said extent.  Furthermore, you may cancel your registration from the e-mails by using the specific ‘Cancel registration’ links included in said e-mails.

You may provide us with the personal data of other persons willing to be informed about our products or services.  Before sending the aforesaid data to us, it is necessary for you to have obtained their authorisation to said extent.  Any collected data in connection with said other persons include: the recipient’s name and address, telephone number, address, e-mail address and personal interests.

Use of cookies and Google Analytics

Thanks to the help of technology, we collect information which allows us to make our Website more interesting and useful for our users.  For instance, when you visit our Website using your computer, we collect your IP address.  The IP address is often linked to the portal through which the user has accessed the Internet such as, for instance, his/her IP (Internet Service Provider) address, his/her company or university.  On its own, your IP address does not allow to go back to your personal identity.  We occasionally use IP addresses to collect information on the frequency with which our visitors visit the different sections of our Websites.  This information could be crossed with the personal identification data.  We use a similar identification system when you visit the Website through your mobile phone.

Our Website uses many different techniques to keep track of the visitors surfing it, amongst which, cookies.

Cookies are information which a Website sends to the computer of the user who is surfing its pages at that time.  We and other companies use cookies for different purposes.  For instance, when you come back to visit one of our Websites after having logged-in, cookies provide information to the Website which, in such a way, is capable of remembering your identity.  You may set your PC in such a way as to receive a notice each time you are sent a cookie, or you may deactivate all cookies by changing the settings of your browser (such as Netscape Navigator or Internet Explorer).  Since browsers are slightly different amongst them, to change cookies, we hereby recommend to consult your browser’s Guide, where you shall be able to find all necessary information to said extent.  By deactivating the cookies, you shall no longer have access to many different functionalities, such as those indicated above, which make Internet surfing easier; furthermore, some of our services may not work properly.

We could combine the data related to your visit sessions or other data collected through cookies, or other techniques, with personal identification data, in order to understand and increase your on-line experience and to ascertain which products, promotions and services are interesting for you.

The same techniques are used in the HTML e-mail messages that we send to our visitors, since they allow us to understand whether our visitors have opened the message and/or have followed one of the hypertextual links included in the e-mail.  The information included through these technologies is collected in a form which allows to go back to the user’s personal data.

Cookies and other techniques could include the transfer of data to us directly or to third parties authorised by us to collect said data on our behalf.  Data thus obtained could be collected in such a way as to allow the personal identification.

In so far as Google Analytics is concerned, we hereby clarify that said service, supplied by Google Inc (hereinafter, "Google") is used by our Website since, by using Cookies, same allows to analyse how users enjoy the Website itself.  The information generated from the Cookies with respect to the use of the Website (including the relevant IP addresses) shall be forwarded to Google and filed by the latter on a server located in the USA.  Google shall use the aforesaid information in order to assess the use of the Website, to draw up reports having as purpose the activity of the Website and to provide services related to the activity of the Website and to the use of Internet.  Finally, Google may transfer said information to third parties in compliance with the provisions of the applicable regulations, as described on the following Webpage in detail: https://www.google.com/privacypolicy.html.  By using our Website, you allow Google to process your data pursuant to the terms and conditions described in detail under Google’s policy therein.

Links to other Websites

We hereby inform you that while you are surfing our Website, you could be sent again to other Websites on which the collection of personal data takes place beyond Atlantyca’s control.  Should this be the case, Atlantyca and the persons related thereto shall not supply your personal identification data without your consent.  Should you decide to have access to these third party Websites, we hereby ask you to carefully look at the policy implemented by same with respect to the processing of personal data.

Security Procedures

The security and confidentiality of the information supplied by you are extremely important for our Company – for said purpose, we have implemented technical, administrative and physical security measures in order to protect the aforesaid information from any unauthorised access and unlawful use.  To obviate said risks, which are unfortunately strictly related to the use of Internet, our Company hereby undertakes to:

• a) Always request the use of usernames and passwords to access the respective personal identification data;
• b) Use firewalls to protect the information included in the respective servers;
• c) Limit the number of own employees and operators having access to said information and monitor same;
• d) Keep in place back up procedures and protection systems in view of the integrity of the supplied information;
• e) Dedicated staff in charge of surveillance.

Amendments to this Information Notice

This information notice may be subject to changes and the terms and conditions thereof could be amended.  We shall publish the last updated version of the information notice on the Website from time to time.  Should we wish to use your personal data in a way which is incompatible with this information notice, we shall request your consent again.

Queries

Should you have any query on the use of your personal data, please send an e-mail to info.gs-website@atlantyca.com