Privacy Policy

This page describes the website management methods of www.trm.to.it (hereinafter: the “Site”) as regards the processing of users’ personal data.
This policy refers to all those who interact with the online services accessible by telematic means at the website www.trm.to.it pursuant to Article 13 of Italian Legislative Decree no. 196/2003 (Data Protection Code) and Recommendation no. 2/2001 of the Working Group pursuant to Article 29 of Directive 95/46/CE. By visiting the Site, users implicitly approve the practices described in this Privacy Policy.

Collection and processing of personal data
Browsing data
In the course of their regular operation, the computer systems and software procedures used to operate the Site collect certain personal data whose transmission is integral to online communication protocols. This information is not collected in order to identify users but may, by its very nature, be processed and associated with data held by third parties in such a way that enables the identification of users.
Such information includes IP addresses, domain names of the computers used by users to connect to the Site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, 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 response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s electronic environment.
This data is used exclusively for the purposes of obtaining anonymous statistical data regarding the use of the Site and to verify its correct operation, and is deleted immediately after use. Data may be used to ascertain responsibility in the case of computer crimes affecting the Site.
Voluntarily provided data
The non-compulsory, explicit or voluntary sending of emails to the addresses provided on this Site entails the subsequent acquisition of the sender’s address, which is required to respond to requests, as well as any other personal data included in the message.
Specific information will be progressively reported or displayed on the pages of the Site designed to offer particular services upon request.

Purposes of the data processing
The personal data provided by and/or referring to users is collected and processed for the technical administration of the Site. In the case of users who request the receipt of informative material, data will be collected and processed only for the purposes of carrying out the requested service.
This data may be used by TRM to carry out its own regular activities and, in particular, for the following purposes:
• To guarantee the correct operation of the Site;
• To manage relations with the user;
• To carry out its own activities and interests in regard to the services offered.
The data will be collected and processed by TRM employees or collaborators appointed as data processors and data processing managers.
This data may also be collected and/or processed by third-party companies entrusted by TRM to carry out technical or organisational activities on behalf of TRM. These companies are direct collaborators of TRM and are appointed as external data processing managers. The list of data processors is continually updated and is available upon written request sent to the address indicated in the “Data Processing Manager” section.
Data is not disclosed to third parties, nor is it transferred abroad or disseminated.
Data processing methods
Data is processed using automatic tools for the period strictly necessary to achieve the purposes for which it was collected.
Links to other websites. The TRM S.p.A. web pages may contain hyperlinks to other websites whose domain does not belong to TRM. TRM S.p.A. may not be held in any way liable for the content of websites which users may access through links on its Site. The existence of a link to another website does not imply the approval of, nor acceptance of liability by, TRM S.p.A. as regards the content to the new site, including in relation to the data processing and usage policy adopted by said site.

Disclosure of data
Except as specified in regards to browsing data, the disclosure of data for other processing purposes is optional. Failure to provide such optional data may make it impossible to pursue these additional purposes.

Rights of data owners
At any time, data owners may carry out the deletion, transformation into an anonymous format, copy, updating, correction, integration or blocking of any data processed unlawfully pursuant to Article 7 of Italian Legislative Decree no. 196/2003, provided in detail at the end of this policy.
To exercise these rights, users can send written notification to the email address provided in the “Data Processing Manager” section.
For more information and to exercise the rights described above, send an email to the following address: privacy@trm.to.it or write to TRM S.p.A. – Via Paolo Gorini n. 50, Turin (TO), Italy, 10137.

DATA CONTROLLER AND DATA PROCESSING MANAGER
The Data Controller is: TRM S.p.A., with registered offices in Via Paolo Gorini n. 50, Turin (TO), Italy, 10137.
The Internal Data Processing Manager is: Gianluca Sarto.
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This privacy policy may be amended periodically and the use of the information collected is subject to the privacy policy in effect at the time of use.
This document, published on the website www.trm.to.it, constitutes the “Privacy Policy” of this Site and is subject to amendment.

ARTICLE 7 OF ITALIAN LEGISLATIVE DECREE NO. 196 OF 30 JUNE 2003
(Right to access personal data and other rights)
1. The data owner has the right to confirm the existence or otherwise of their personal data, even if this has not yet been recorded, and receive notification of the same in an intelligible format.
2. The data owner has the right to obtain information regarding:
a) the origin of the personal data;
b) the purposes and methods of the data processing;
c) the logic applied in the case of electronic data processing methods;
d) the details of the data controller, data processing managers and appointed representatives pursuant to Article 5, paragraph 2;
e) the entities or categories of entities to whom the personal data may be disclosed or become known in their capacity as appointed regional representatives, data processing managers or data processors.
3. The data owner has the right to obtain:
a) the updating, correction or, if requested, the integration of the data;
b) the deletion, transformation into anonymous form or blocking of unlawfully processed data, including data whose retention is unnecessary for the purposes for which the data was collected or subsequently processed;
c) the attestation that the activities referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data has been communicated or disclosed, except in the case that this proves impossible or involves the use of means manifestly disproportionate to the protected right.
4. The data owner has the right to oppose, in all or in part:
a) for legitimate grounds, the processing of personal data concerning the data owner, even if such data is relevant to the purpose of the collection;
b) the processing of personal data concerning the data owner for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication.