Information to Data Subjects Pursuant to Section 13 of Italian Legislative Decree N° 196/2003


Michael Patrick Andrew Farrell (hereinafter referred to as Mr Farrell), in his capacity as data controller pursuant to and by effect of Italian legislative decree N°196 of 30 June 2003 (act concerning the protection of personal data, hereinafter referred to as the “Italian Privacy Act”), hereby informs you that the aforementioned act provides for the protection of individuals and other entities as regards the processing of their personal data and that this processing shall take place according to principles of fairness, lawfulness and transparency and protection of your confidentiality and rights.
Your personal data, concerning and connected with your business relationship with Mr Farrell, will be processed in accordance with the provisions in the act mentioned above and the confidentiality obligations laid down therein.

Processing purposes
Your data will be processed exclusively to provide the information and services you have requested. The data controller also informs you that if you fail to provide the required information or if that information is incorrect, he may not be able to ensure adequate processing.

Processing methods
Your personal data may be processed in the following ways:
• automatic processing by computer;
• manual processing on hardcopy records.All processing will take place in compliance with the methods referred to in sections 11 and 31 et seq. of the Italian Privacy Act and by adopting the minimum security measures laid down in the technical specifications (schedule B).

Your data may be processed in Mr Farrell’s offices and/or remotely on the servers of Internet service providers. Your data will be communicated exclusively to entities qualified to carry out the services required for correct management of the business relationship, and your rights shall be guaranteed.
Your data may be communicated outside Mr Farrell’s offices, in particular:
• to public and/or private entities for which communication of the data is compulsory or necessary owing to legal obligation, or in any case indispensable in order to manage the business relationship;
• to data processing centres and Internet service providers.

Your personal data will not be disseminated in any way.You have the right to demand that the data controller deletes, communicates, updates, corrects and supplements your personal data. You may also assert the rights laid down in section 7 of the Italian Privacy Act, reproduced here below.

Legislative decree N° 196/2003: Section 7 – Right to Access Personal Data and Other Rights (official Italian government translation)
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him 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.