We describe below the procedures for processing the personal data of users (“Users”) who access the website (the “Website”) and who, after registering, use the services offered on it, including social networking services and the on-line purchase of digital coupons that give the Purchaser or the Beneficiary indicated by him the right to collect or receive one or more products (“Product(s)”) or to benefit from one or more services (“Service(s)”), offered on the Website. It is in the concrete interest of 4Gifters to offer services to Website Users based on ensuring the protection of their data and which provide each User with maximum control of their privacy at all stages of processing of their data on the Website: from the creation of their profile (with the User free to choose which information to insert) to the sharing of their data (with the User having maximum discretion regarding the choice of procedures for sharing or not sharing his or her profile and content generated by the same party using the services), to the cancellation of their data. This privacy policy, pursuant to Art. 13 of Legislative Decree No. 196/2003 (the Personal Data Protection Code), regarding the protection of personal data, relates exclusively to the processing of personal data associated with the Website. Any third party websites which may be consulted by the User via links shall remain subject to the privacy policy provided by the manager of the relevant third party website; similar considerations shall apply to any processing of personal data by the Partners of the Company, which shall remain subject to the privacy policy stipulated by the relevant Partner. Users are encouraged to read such documents before browsing third party websites or providing their personal information to the Company’s Partners. For the purposes of this document, the definitions contained in the General Conditions shall be valid. 1 Data controller The data controller is 4Gifters Italy Srl, (the “Company”) with registered office in Milan at Piazza Cavour, 7, Tax Code/VAT No.: 08438240965, Telephone: 0272021490, e-mail: 1 Type of data Navigation data In order to consult the public pages of the Website, no contribution of personal data by the User is required. However, any contacts with the Company, the optional, explicit and spontaneous sending of messages, e-mail or traditional mail to the contact addresses of the Company indicated on the Website shall entail the subsequent acquisition of the sender’s address, including e-mail or the associated telephone number, necessary for replying to requests, as well as any other personal data included in the relevant communications. These data shall only be used to follow-up the request of the User and may be disclosed to third parties only where this is necessary for that purpose). These data shall be kept for the time strictly necessary for providing the User with the requested service and shall not be circulated. Data provided during registration and during the use of the 4Gifters services For the purpose of use of the services, the User is obliged to register with the website. Processing will focus on operations or the set of operations (such as, merely by way of example: collection, registration, consultation, organisation, storage, processing, notification, modification, selection and use), relating predominantly to the data provided by the User during registration and/or when using the services: identifying and contact data of the User, acquired during the registration and management phase for the User, including: • several data items essential for the registration and use of services (e.g. username, password, e-mail, first name and surname, telephone number and place of residence); • several data items which are entirely optional and which serve exclusively for the management of the User’s account (e.g. telephone and electronic contacts, gender, date of birth, photo, and language); data relating to the User’s profile, provided voluntarily by the User for the creation of his profile, including: • nickname; • Favourite colour, Size, Birthday a) when the User decides to log in through social applications (such as Facebook Connect, Twitter), some data made public by the User on his own social network profile (such as, merely e.g.: name, surname, sex, city and e-mail address, language, photograph), processing shall be limited to the type of data required for traditional registration on the website and management of the User’s account. The use of this access method shall not entail any notification of data to any social networks by the Company. b) data on the habits and preferences of the User (e.g. purchasing history, type of Products and/or Services purchased or given, consumption preferences, interests). Such data do not include any sensitive data (e.g. data likely to reveal state of health, religious, philosophical or other convictions) that may be inferable from the type of Products and/or Services forming the object of the Digital Coupons, which shall be processed exclusively for the provision of the Services, subject to the written consent of the User and/or Beneficiary and, in any case, in observance of the indications contained in the General Authorisations of the Authority for the Protection of Personal Data; c) any data of third parties (Beneficiaries) not using the features of the Website, which may still be acquired by the Company insofar as they are inserted by the User in order to allow the Beneficiary to receive the Digital Codes. These data shall be processed by the Company solely for the purpose of allowing the Beneficiary to receive and make use of the relevant Digital Code, and shall be retained only for the time strictly related to the management of the Digital Codes of which he or she is the beneficiary. 1 Purposes of processing Personal data shall be collected and processed for the purposes and according to the procedures presented below: 1 in order to provide the services requested by the User (e.g.: management of registration and website access processes; management of the User’s account; management of orders and payments; shipment of Products, where applicable; user assistance and management of any complaints or disputes; any refunds; data processing for the provision of individual services requested by the User, content sharing and interaction in the community); 2 for compliance with legal and/or regulatory obligations (e.g. tax compliance); 3 for the protection of our rights, both judicial and extrajudicial; 4 with the consent of the User, for marketing purposes through the forwarding, via e-mail, traditional mail (paper), telephone, fax and/or SMS/MMS, of newsletters and commercial notifications relating to the services offered by the Company and/or its Partners. If the User has also agreed to the profiling activity described below, the Company may use the result of the analysis so conducted to send personalised commercial notifications, and for the promotion of its own products and/or services and/or those of its Partners, which may, in the opinion of the Company, be of interest to the User; 5 to perform statistical analyses, market surveys and investigations, including by telephone and on line, on services offered by the Company; 6 with the consent of the User, for profiling purposes, and specifically for the analysis of choices, preferences, interests and buying habits of the User acquired during the use of services. The data may also be used through the creation of individual profiles and/or aggregated in order to draw up market analyses and statistics for the identification of products and/or services of interest of its users. 1 Nature of the conferral of data With regard to the purposes set forth in paragraphs (1) - (3), the conferral of data marked as mandatory during the registration phase (or under other circumstances in which the User is required to provide data), is necessary in order to use the services offered by the Company and any refusal shall imply the objective impossibility of using the services. It is not necessary to obtain the User’s consent for such processing purposes, with the exception of the cases in which the Products and/or Service forming the object of the Digital Coupon involves the processing of sensitive data, in which case the company shall require the specific consent of the interested party. The provision of any data found to be functional for pursuing the aims set forth in paragraphs (4)-(6) is entirely optional and free of charge and the potential rejection shall in no way prejudice the possibility for the User to use the services. In this event, however, the Company may not be able, for example, to forward informative material to the User on the website services or on Products and/or Services of its Partners, including promotional material focused on products which may, in the opinion of the Company, be of interest to the User. It is in any case understood that the processing of data for such purposes shall only be made with the express and specific consent of the User. 1 Navigation data - Cookies - Social Functionalities Navigation data The computer systems and computer programmes used for the operation of the Website collect some personal data, the transmission of which is implicit in the use of Internet communication protocols (e.g. IP addresses or domain names of computers used by users who connect to the Website, URI – Uniform Resource Identifier - of requested resources, the time of request, the method used to submit the request to the server, the file size obtained in response, the numerical code for the state of the response provided by the server (successful, error, etc.) and other parameters regarding the User’s operating system and IT environment). Although this is information which is not collected, since it is associated with identified interested parties, by its nature, it could, through processing and association with data held by third parties, allow Users to be identified. These data are only usable for the purpose of obtaining statistical information, not associated with any given identification data of the User on the use of the Website and in order to check its correct functioning, being cancelled immediately after processing. The data could be used to determine responsibility in the event of hypothetical IT crimes against the Website: notwithstanding this possibility, at present, data on web contacts are not retained for more than 365 days. Cookies Our site uses cookies and collects technical and profiling cookies, including of third parties. For greater information or in order to deactivate all or some of the cookies used press here [LINK]. Social features If the User/Users (i) log in to services using the access credentials for a social network (such as Facebook or Twitter, “Social Network”) or (ii) associate the account their own account with an account of the same User on a Social Network, the Company may receive data from this Social Network relating to the User, in accordance with the conditions of use and with the provisions of the privacy policy of the Social Network itself. The Company may add this information to the User’s data already collected by its own services. If the User chooses to share information with such Social Networks, the Company shall share the data with these latter parties in accordance with the options expressed by the User. Any data notified to the Social Network shall be subject to the terms and conditions of use of the Social Network. The Website contains several functions typical of “Social Functions” social communication networks, such as the Facebook “I like” function, the Tweet button and other widgets or interactive mini-programmes executed on the Website. These Social Functions could detect the User’s IP address, which pages are visited on the Website and could activate a cookie in order to enable the proper functioning of the same social function. These features may be hosted by a third party or directly on the Website. The interactions between the User and such social features are governed by the conditions of use and the privacy policy of the companies which make these features available (e.g. Facebook or Twitter). 1 Notification and circulation of data For the proper performance of the above objectives, the Company’s staff allocated to the management and maintenance functions of the Website, assistance to Users and to the management, as well as the staff of third-party companies which, also in the capacity of data processing controllers, provide services to the Company (e.g. providers of IT services of hosting and maintenance of the platform, such as e=Commerce Outsourcing Srl, Via Sesia snc Rho (MI), Iva 08576060969, freight forwarders, providers of assistance services to customers) may have access to the collected data. Furthermore, because of the type of services provided, e.g., in the case of the “Gift Up” or “Team Gift” service, the data which the User has chosen to share with his own “friends”, or the participation of each member of a Team Gift, on reaching the figure of the gift, shall be shared by the User with the members of the circle of “friends” or Team. The data may only be accessible to all Users with reference to the type of information and within the limits of what is defined by the User through the setup of his own account. In no case shall the collected data be transferred to third parties for use for their own purposes; it is hereby understood that, in the event of extraordinary company transactions (e.g. the sale or leasing of a company), the data may be assigned or transferred to acquiring/leasing third parties or assignees. 1 Rights of the interested party Article 7 of Legislative Decree Number 196/2003 grants certain rights to the interested party (in this case, the User), as a subject to whom the personal data refer, including the right to obtain confirmation at any time as to whether or not such data exist and to know their content and origin, to verify their accuracy or request their inclusion, updating or correction. According to the same article, the interested party is also entitled to ask the Company for the cancellation, transformation into anonymous form or the blocking of data processed in infringement of the law, as well as to object in any event, on legitimate grounds, to their processing and to the processing of their own personal data for marketing purposes, through one or more channels, and/or of profiling, where previously allowed. The User may object and request the cancellation of his name, at any time. In order to exercise these rights, the User may apply to the Company, via the contacts indicated in point 1 above or by using the e-mail