Privacy policy

The following provisions concerning the processing of personal data are addressed to all users of the site http://www.tamtamy.com ("Site"), that have followed the on-line registering procedure as indicated in the TamTamy General Term and Conditions ("Managers/Users") and are compliant with all applicable Italian laws and, in particular, with the provisions set forth by the Legislative Decree 30 June 2003, no. 196, Italian Data Protection Code ("Data Protection Code").

It is strongly recommended to the Managers/Users to frequently review this document in order to know any possible modifications or amendments to the same mainly due to changes in law provisions.

By accessing to the Site the Manager/User declares and acknowledges to be informed about the terms and conditions of this Data Protection Policy ("Policy") and of the possible subsequent amendments to the same.

The Policy is intended to explain to the Manager/User the kind of information that Reply S.p.A., with registered office in Turin (Italy), Corso Francia 110 (http://www.reply.eu), in its quality as data processor, collects and how such information are used by the same REPLY.

It is strongly recommended to the Manager/User to carefully read this Policy. In addition, please note that third parties' web sites made available by specific links of the Site are governed by separate privacy policy different from this Policy.

Information - Cookies

During the accessing and the surfing on the Site, non-personal information regarding Manager/User's computer will be collected. Such information concern, for example:

• the kind of browser used (Netscape Navigator, Internet Explorer or Mozilla Firefox);
• the domain name used by the Manager/User in order to access to Internet;
• the web site from which the Manager/User linked the Site;
• the date and hour of access;
• the visited web pages.

The above mentioned information are collected by Manager/User's computer browser by means of the so called cookies. Cookies are small text files, often containing an anonymous identifying code, that may be sent to Manager/User's browser from a web server and that are subsequently recorded on the hard disk of Manager/User's computer. Cookies are read again and recognized by the web site from which they have been sent each time the Manager/User visits or connects to the same. Cookies contain information which allow the web site to record Manager/User's surfing preferences and, therefore, to customise a site according to Manager/User's requirements. Most part of the browsers is set up in order to accept cookies, but it is possible to reset the browser in order to allow the Manager/User to refuse cookies or to notify the Manager/User if he/she/it receives a cookie.

The Manager/User can decide to refuse Site's cookies, whether the browser allows such option, but in such case some pages of the Site could not be accessible and/or could not correctly run.

For example, refusing cookies, the Manager/User shall make the log in each time he/she/it will access to the restricted access areas of the Site. On the contrary, accepting cookies, the Site will keep in memory Manager/User's log in and his/her/its preferences thus automatically customising the Site according to Manager/User's requirements.

REPLY informs the Manager/User that the access to the Site and the use of the services provided by means of the same allow the web server to automatically record the so called "system's log", which are the information sent by Manager/User's browser during the surfing on the Site. Such information consist in web pages requested by the Manager/User, read, modified or created documents, address of the internet protocol, kind of browser used, browser's language, date and hour of a request and they can be aggregated in order to develop statistics concerning the use of the Site which will be made available to REPLY's authorized personnel only.

Linking and framing

REPLY informs the Manager/User that he/she/it can create a link to the home page of the Site http://www.tamtamy.com ("Home Page"). To this purpose it will be necessary that the Manager/User sends a specific request by e-mail to tamtamy@reply.it in which shall be indicated: (a) the data of the person responsible for managing the technical aspects of the linking activity (including e-mail and phone number); (b) the data of the requiring subject; (c) the indication of the web address of the site to which the link to the Home Page will be created; (d) any further information necessary and/or useful in order to obtain REPLY's relevant authorization.

Whether authorized by REPLY, the creation of the link to the Site grants a non exclusive and non transferable license for the use of the name "TamTamy" for the sole and exclusive purpose consisting in creating a hyper link to the site owned by the third party to http://www.tamtamy.com, being expressly excluded any other use.

In any case, REPLY exclusively acknowledges the possibility to link the Home Page and not the internal pages of the Site.

Without the prior written authorization of REPLY, it will not be permitted to create links to the Home Page of the Site, nor to internal and/or related pages of the Site, thus creating a so called "deep link". It will not be permitted to hook up the Site or present the content of the same in another web Site, thus performing a so called "framing".

To this regard, please be informed that the infringement of the provisions set forth above will constitute an act of unfair competition according to Italian law provisions in force.

Personal data

According to article 4, paragraph 1 lett. b) of Data Protection Code, personal data mean "any information relating to natural or legal persons, bodies or associations, identified or identifiable, even indirectly, by reference to any other information including a personal identification number".

By registering to the Site and, in particular, by filling in specific registration forms, the user will be required to give his/her/its personal data, among which, by way of example:

• business name;
• registered office of the company or legal person;
• e-mail.

REPLY informs that registration forms published on the Site contain both non-mandatory fields and mandatory fields (indicated with an asterisk [*]) and that, in relation to these latter, in case of Manager/User's refusal to confer his/her/its personal data, REPLY may not be able to respond to Manager/User's request or activate Manager/User's option choices.

Collection of personal data

Personal data provided by the Manager/User by registering to sections of the Site or by creating or updating his/her/its profile ("Account") will be used by REPLY in order to respond to Manager/User's requests as well as to allow the Manager/User to use specific services provided by the Site, to receive e-mail and information, even regarding possible amendments to this Policy.

In particular:

• Newsletter and e-mail

  Registered Managers/Users can receive information and newsletters by e-mail. In order to access to this service the Manager/User, by filling in the specific registration forms published on the Site, will be requested to necessarily give the following information: name and e-mail. The Manager/User can, at any time, decide not to receive information and newsletter. To this purpose, it will be necessary that the Manager/User modify profile's properties or that he/she/it follow the instruction indicated at the bottom of each newsletter.

  In such manner, the Manager/User will be promptly cancelled from information and newsletter's mailing list.

  If the Manager/User meets problems during the cancellation procedure, the same Manager/User can, at any time, contact REPLY at the following address: tamtamy@reply.it.

• Correspondence sent by the Manager/User

  REPLY informs the Manager/User that the information sent by this latter by e-mail or by any other mean to the addresses indicated in the Site can be stored by REPLY for the time necessary in order to respond to Manager/User's requests and questions and to improve the services offered by the Site.

• Interactive communication's means (TamTamy Social Network)

  Without prejudice to the above, REPLY informs that the Manager/User will be free to add contents to and to customise, at his/her/its own discretion, his/her/its Account, making available to all or part of the other Site's Manager/User his/her/its personal data as well as other information such as, by way of example, photos, preferences, etc.

  With regard to the above, the Manager/User shall comply with and fulfil the rules provided by REPLY and indicated in the TamTamy General Term and Conditions (/tamtamy/web/terms-of-service.action;jsessionid=800D4DF1A7FC1BCAA332B64663120BCC.jvm0b).

  It is suggested to the Manager/User to carefully evaluate whether or not it is opportune to disclose and make available his/her/its personal data, even sensitive (please note that sensitive data shall mean, according to article 4, paragraph 1, lett. d of Data Protection Code "personal data allowing the disclosure of racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade-unionist character, as well as personal data disclosing health and sex life"), to other Managers/Users on the TamTamy Social Network. In fact the TamTamy Social Network, being open to all Managers/Users and visible by non-registered users of the Site in general, can not be considered neither private nor secure.

  In fact, the information sent by the Manager/User can be collected by third parties and used according to modalities and for purposes which REPLY can not control or verify. As a consequence, REPLY can not be considered liable for any damage of whatever kind which the Manager/User or third parties may suffer due to the wrong, unfair or unlawful use by a third party of their personal data made available by the Manager/User in the TamTamy Social Network.

REPLY will not use Manager/User's personal data for purposes other than as stated above, and, in particular, in order to send unsolicited communications or information in respect to which the Manager/User does not give his/her/it consent. In addition, REPLY does not sell, rent or otherwise make available any personal data submitted to it by the Manager/User to any third parties, save for the subjects indicated in the Privacy Statement and unless it is to REPLY's legal advisors or where so required by law or by a court decision.

Processing of personal data

As already specified in the Privacy Statement according to article 13 of the Privacy Code, Manager/User's personal data collected and/or provided by means of the Site or by means of the correspondence sent by the Manager/User according to the provision set forth in paragraph 5 above, will be used by REPLY, in its quality as data processor, in order to allow the Manager/User to use the requested or authorized services and, in some cases, in order to carry out market research and for sending newsletter or advertising material.

The personal data collected and/or provided by the Manager/User will be communicated, for the purposes indicated above and in the Privacy Statement (/tamtamy/web/privacy-statement.action;jsessionid=800D4DF1A7FC1BCAA332B64663120BCC.jvm0b), to third parties having contractual relationships with REPLY among which, by way of example, suppliers which perform technical support activities and companies of the group to which REPLY belongs.

REPLY also informs that Manager/User's personal data will be communicated to third parties providing on behalf of REPLY specific services requested by the Manager/User such as, by way of example, programs, products, information, assistance and technical support, management and maintenance of the Site.In order to ensure the security of Manager/User's personal data, the third parties providing the above indicated services on behalf of REPLY will be appointed by this latter, depending on the case, as persons in charge of the processing or data controllers.

Whether required by the provisions of the Data Protection Code, REPLY will ask the Manager/User, by specific fields inserted in the pages of the Site or according to the modalities specified from time to time, to give his/her/its consent for the processing of the relevant personal data.

In any case Manager/User's personal data will not be disseminated.

Personal data of minor than 18 years old persons

The access to the services provided through this Site are available to companies and people major than 18 years old. Given the above, REPLY does not consciously collect information regarding minor than 18 years old people by means of the Site.

As a consequence, REPLY shall not be considered liable for the false data provided by minor than 18 years old people. Should REPLY acknowledge that personal data - duly modified - were provided by a minor person, Reply will immediately cancel the personal data already collected, with the consequent impossibility for the minor person to access to the services offered through the Site.

Personal data security

In relation to the above indicated purposes and as already outlined in the Privacy Statement (/tamtamy/web/privacy-statement.action;jsessionid=800D4DF1A7FC1BCAA332B64663120BCC.jvm0b), the processing of Manager/User's personal data is carried out by means of manual, information and data transmission means, applying principles strictly related to the mentioned purposes and, in any case, in such a manner to ensure security and confidentiality of personal data.

As anticipated above, the processing of personal data can be carried out, on behalf of REPLY, by third parties, in their quality as data controllers and/or persons in charge of the processing, which will provide services concerning data processing or which will perform activities related to or necessary in order to execute services and transactions requested by the Manager/User. In addition, whether it is necessary in order to respond to Manager/User's request, Manager/User's personal data can be communicated to REPLY's employees or offices or collaborators which will be appointed as persons in charge of the processing or data controller according to the provisions of the Privacy Code.

In any case, the personal data provided by the Manager/User will be processed in compliance with the provisions of the Privacy Code and, in particular, with the provisions concerning the protection and the security of personal data set forth by Part I, Title V, Data and System Security, of the same Privacy Code.

In particular, in order to ensure the security of Manager/User's personal data, REPLY carried out the following activities:

• all persons who access to personal data have personal userID and password which are periodically modified according to the terms provided by the law in order to avoid the risk of unauthorised access;
• servers are protected by a firewall which protect the data;
• employees/workers signed confidentiality agreements;
• backup systems have been implemented in order to ensure the integrity of user's personal data.

When Reply, in order to provide the Manager/User with specific services, transmits to third parties - over the Internet - highly confidential information (such as a credit card number), the same REPLY protects such data by using encryption, such as the Secure Socket Layer (SSL) protocol.

Finally, REPLY's databases are managed and located abroad outside the territory of the European Community.

This Policy is governed by the laws of Italy and any dispute arising in connection to the same Policy will be submitted to the exclusive jurisdiction of the competent Italian courts.