This agreement consists of the translation of an Italian agreement and is thus entirely governed by Italian law.
(Privacy Code - Legislative Decree 196 of 30 June 2003).
Romanelli Project (hereinafter eastitaly.com) has a constant commitment to protecting the online privacy of its users.
Remember that the various sections of the eastitaly.com web sites (hereinafter, "Site") where we collect your personal data publish specific disclosures pursuant to Article 13 of the Privacy Code. You must read these disclosures before providing the requested data.
The information and data that are provided by you or otherwise acquired during registration for the various services of eastitaly.com (e.g. registration of domain names, provision of e-mail accounts, provision of web space, provision of hosting services, provision of other accessory services, jointly referred to hereinafter as the "Services"), will be processed in compliance with the Privacy Code (whose complete text can be downloaded from the website of the Garante Privacy [Privacy Authority]
), Recommendation no. 2 of 17 May 2001 of the Group of European Supervisory Authorities ("Garanti"), and the privacy obligations that govern the activity of eastitaly.com. www.garanteprivacy.it
Processing of personal data shall mean any operation, or set of operations, carried out with or without the help of electronic or automated means, concerning the collection, recording, organization, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasure, and destruction of data, whether the latter are contained in a database or not. The personal data subject to processing can consist - partly in consequence of how you decide to use the Services - of text information, photographic or video images, audio tracks, telephone lines, and any other information that can be used to identify the data subject, according to the type of Services requested.
In accordance with Code regulations, the processing carried out by eastitaly.com will comply with the principles of fairness, lawfulness and transparency, and protection of your privacy and rights.
Purposes of processing.
The purpose of the processing that we intend to carry out is to permit provision of the Services requested by the user, and then independent management of the toolbar. The user will access the toolbar by registering and creating his own user profile when the Services are provided, including the collection, keeping, and processing of the data for establishment and subsequent operating, technical, and administrative management of the relationship connected with provision of the Services and exchanging messages in regard to management of the established relationship. The data will also be processed in order to comply with statutory, accounting, and tax obligations.
Furthermore, the purposes of processing also regard the collection, keeping, and elaboration of your data as part of statistical analysis in anonymous and/or aggregate form. Such analysis does not permit identification of the user, and is designed to audit the quality of the services we offer.
Finally, the data can be processed - but only when the user has granted his or her specific consent - for marketing and general advertising promotion, to provide information and/or make bids on products, services, or initiatives that are offered or promoted by eastitaly.com, companies belonging to the Romanelli Project and/or affiliated companies and/or subsidiaries thereof, in addition to commercial partners and outsourcers, without this causing the transfer of personal data to third parties.
Your personal data will normally be processed by means of electronic or automated tools.
Communication and dissemination of common personal data.
Your common personal data may be communicated to:
persons, companies, or professional firms that provide accounting, legal, tax, and financial support and consulting services to eastitaly.com in regard to provision of the Services;
parties, entities, or authorities to which your personal data must be communicated pursuant to statutory obligations or orders by authorities;
parties delegated and/or engaged by eastitaly.com to perform activities that are strictly connected with provision of the Services or with which eastitaly.com must interact for provision of the Services (e.g. the national and foreign registration Authorities to which the technical and administrative documentation and forms of the Maintainer must be sent, the authorities that manage the WHOIS database that contains the personal data of the assignees of domain names, etc); the parties that are delegated and/or engaged by eastitaly.com to perform technical maintenance (including maintenance of the network devices and electronic communication networks);
commercial partners, but only if you have granted your specific consent in this regard.
Furthermore, the parties or classes of parties to which your personal data may be communicated or that might acquire them in their capacity as data processors (if designated) or persons in charge of the processing are: Romanelli Project companies inside or outside Italy, Romanelli Project personnel engaged to provide administrative and/or technical maintenance of the Services, and managers of the information technology platform used to provide the Services.
Your personal data that are necessary to activate the Services will not be disseminated. It is implied that if you decide to use certain Services without availing yourself of the right to prevent dissemination of your personal data when you request use of those Services (e.g. when requesting the assignment of domain names, you do not explicitly deny your consent when asked in regard to publication of your personal data on the WHOIS database), responsibility for such dissemination of your personal data can never be attributed to eastitaly.com.
Optional or mandatory consent.
Providing your personal data is optional for all procedures connected with activation of the Services (registration, technical maintenance of the account, etc.), but if you do not provide your personal data, the requested Services cannot be activated.
Your consent is also optional and not mandatory for the processing of personal data for conducting market surveys, research, and statistics; for sending advertising and informative material; for direct sales activities or placement of products or services; for sending commercial information; for effecting interactive commercial communications pursuant to Article 58 of Legislative Decree 206/2005, inter alia, through the use by the telephone service provider of electronic mail or automated calling systems without use of an operator, or by fax. Your consent is also optional for receiving unsolicited commercial messages pursuant to Article 9 of Legislative Decree 70 of 9 April 2003, which received the Electronic Commerce Decree 2000/31/EEC. This statute envisages that unsolicited commercial messages must be immediately and unequivocally identifiable as such and indicate that the recipient of the message may refuse receipt of such messages in future.
If you decide not to grant your distinct consent to processing for commercial purposes - when requested in specific sections of the Site - such refusal will have no consequences. If you grant your optional consent as envisaged hereinabove, you may be allowed to participate in promotional prize games that might be organized by the Romanelli Project or its commercial partners.
Processing of sensitive data.
When you use the Services, certain of your data classified as "sensitive" data pursuant to Articles 4(1) and 26 of the Code might be processed, particularly in regard to data that can reveal your racial and ethnic origin, religious, philosophical, or other convictions, political opinions, membership in parties, trade unions, associations, or religious, philosophical, political, or labor organizations, and in regard to personal data that can reveal your health status and sexual life.
We suggest that you do not publish sensitive data unless this is strictly necessary or if you decide not to use particular Services that might involve such processing. In any event, aside from the waivers and exceptions envisaged in Article 26(4) of the Code, these data may be processed only with written or equivalent consent ("equivalent consent" also consists of a manifestation of desire online through procedures such as clicking such buttons as "Accept," "Enter," etc. on web pages or checking boxes next to the term "Accept," etc) of the data subject in compliance with the General Authorizations granted by the "Garante" for processing of sensitive data and after authorization by the Garante for protection of personal data, which may grant general or preliminary authorization - without prejudice to the written consent of the data subject - to particular types of processing.
In addition to requesting your written or equivalent consent, our activities are authorized in advance by General Authorizations 2, 4, and 5 of 2007.
On the basis of the foregoing, we remind you that if you do not specifically consent to processing of your sensitive data (although you could obviously still register in this case), if you wish to use Services in future that might entail such processing, you will have to modify your registration form by granting specific consent. If you do not grant your consent for processing of sensitive data for any reason, and subsequently use those Services that require such processing (e.g. if you publish photos that contain sensitive information), we inform you that no Group company can be held liable for any reason whatsoever, and cannot receive complaints in this regard, since the sensitive data (including dissemination over the web) will be published in consequence of your exclusive, independent management of the web space that will be provided to you by the Group companies upon registration and use of the Services by you. However, we must emphasize the importance, as previously mentioned - of modifying your registration form by giving your express consent to the processing of sensitive data if you decide to use Services that necessarily entail use of this information.
The sensitive data - particularly those that can reveal sexual tastes or habits - will not be communicated (unless mandated by law) or disseminated by Group companies. It is implied that if your decide to use the Services intentionally to communicate or disseminate your sensitive data on the internet, this will not represent communication or dissemination by Group companies, insofar as you carry out these operations independently in managing your reserved web space or otherwise within the ambit of your normal use of the Services.
Eventual processing of the personal data of third parties provided by the data subject.
When you use particular Services (e.g. the eastitaly.com promotions that that allow you to request assignment of domain names in favour of third parties), the personal data of third parties that you send to the Service operator might be processed. In this case, you will assume the role of independent data controller, assuming all consequent legal obligations and liability. You accordingly grant full indemnity against all complaints, claims, or requests for damages in consequence of the processing, etc. that the data controller might receive from the third parties whose personal data were processed through your use of the Services in violation of applicable laws and regulations governing the protection of personal data. In any event, if you provide or otherwise process the personal data of third parties while using the Service, you hereby guarantee - assuming all consequent liability - that this particular instance of processing is based on your first having received the third party's consent to processing of the information that regards him or her.
The information systems and software procedures used to operate the eastitaly.com site acquire certain personal data in the course of normal operations. The transmission of those data is an implicit part of use of the internet communication protocols.
This information is not collected for association with identified data subjects, but by their very nature, they might permit the identification of users through processing and association with the data held by third parties.
This class of data includes the IP addresses or domain names of the computers used by the persons that log onto the site, the URI (Uniform Resource Identifier) addresses of the requested resources, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the answer given by the server (successful, error, etc.), and other parameters regarding the operating system and the user's IT environment.
These data are used only in order to obtain anonymous statistical information on use of the site and to monitor its proper functioning. They are deleted immediately after they are processed. The data might be used to ascertain liability in the case of hypothetical computer crime committed against the Site or third parties. Except for this possibility, your web contact data are currently not stored on a permanent basis, unless requested by the user (e.g. access to the personal pages of the subscribed on the eastitaly.com site that list the services used, information published, etc.).
You can always deactivate the cookies simply and easily with the configuration options of the browser that you use.
Data Controller and Data Processors.
The data controller and data processors are as follows: Romanelli Project di Romanelli Francesco, with registered office in via Don Luigi D'Agostino 15 - 33030 Campoformido.
The updated list of data processors (if designated) can be obtained in the document at the end of this disclosure.
You may contact the data processors pursuant to Article 29 of the Code at any time by contacting the offices of the data controller Romanelli Project in order to exercise the rights envisaged in Article 7 of the Code.
Storage of data and security measures.
The data will be stored for the time defined by applicable laws and regulations on the servers of eastitaly.com, located in specific, dedicated spaces at the Romanelli Project server farm in Basaldella di Campoformido (UD), Strada dell'Artigiano 40, which is accordingly designated the external data processor. In any event, your data will be stored strictly for the amount of time necessary to realize the aims illustrated hereinabove, which shall be for as long as the service relationship between you and the data controller. If you should cancel your account, thereby ceasing to use the Services, your data will be deleted except as necessary comply with contractual, administrative, tax, accounting, or legal obligations after you terminate use of the service. As soon as these obligations are satisfied, your data will be deleted.
We also inform you that these data will be collected, processed, and kept in full compliance with the provisions of Articles 31 et seq. of the Privacy Code and the Technical Regulations - Annex B of the Code, regarding security measures.
The data will also be processed in full compliance with the personal data processing self-governance rules set out in the applicable professional codes of conduct.
Art. 7 (Right of access to personal data and other rights)
You may contact the data controllers or data processors at any time, without formal obligations, or by using the specific form prepared by the "Autorità Garante per la protezione dei dati personali" (the "Personal Data Protection Authority," available free of charge at
) in order to assert your rights as envisaged in Article 7 of the Code, which we reproduce here in full for your convenience: www.garanteprivacy.it
Article 7 of Legislative Decree 196 of 30 June 2003
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.
A data subject shall have the right to be informed:
of the source of the personal data;
of the purposes and methods of the processing;
of the logic applied to the processing, if the latter is carried out with the help of electronic means;
of the identification data concerning the data controller, data processors and the representative designated as per Article 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.
A data subject shall have the right to obtain:
updating, rectification or, where interested therein, integration of the data;
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;
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.
A data subject shall have the right to object, in whole or in part:
on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
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. Contact
For any information and in order to exercise the rights envisaged in Article 7 of Legislative Decree 196/2003 cited hereinabove, the data subject may write to:
Romanelli Project di Romanelli Francesco
via Don Luigi D'Agostino, 15
The data subject may also send his request via e-mail to the address firstname.lastname@example.org