Privacy Policy


This privacy policy (the "Privacy Policy") applies to site (the "Site") and refers to the processing of personal data SEA MANAGEMENT SRL (hereinafter "SM" ) performs as the owner and operator of the site. SM will treat the personal information that is collected when they visit the site and interact with the features and services offered on the same. This Privacy Policy has been drafted in accordance with the Recommendation. 2/2001, adopted on 17 May 2001 by the Working Group for Data Protection Article 29, concerning minimum requirements for the online collection of data within the European Union. This Privacy Policy is also on the processing of personal data intended to stakeholders in accordance with art. 9 of the Law December 8, 1992 on the Protection of Personal Data, as amended on 11 December 1998 and added to by the Royal Decree of 13 February 2001 (segufito "Privacy Act"). This Privacy Policy specifies the identity of the data controller who is the owner and manager of personal data collected and processed through the Site; specifies which personal data are processed, the purposes and conditions of the processing; specifies limits the disclosure of personal data to third parties; indicates what are the security measures taken to protect and safeguard data; and specifies the ways in which users can check the processing of their data and to enforce their rights under the Privacy Act.


The Data Controller is: SEA MANAGEMENT srl Corso Europa, 14 20122 Milano - Italy tel / fax. 02 7395 2348 Email: - P / VAT IT 08544610960, current list of the data processors, if appointed, and the recipients of the communications data are available to users at SM.In the operations of the data processing performed through the Website may be involved other companies in the MS group (eg accounting tasks in case of purchase of products or for reasons of personnel selection, etc.), As specified below . These companies will act in compliance with applicable privacy laws for the purposes set forth herein.


The visit and consultation of the Site, in general, do not involve the collection and processing of personal data of users. The processing of personal data of users that visit and consult the Site is limited to the so-called navigation data and, more specifically, the data whose transmission to the Site is implicit in the operation of the computer system that manages the site and use of protocols typical communication of the internet. Navigation data include, for example, the IP addresses or domain names of the computers that you use to connect to the site and the information about the type of operating system user. The navigation data such as those specified above, such as, for example, the number of visits and the time taken for visits to the Site, are collected and processed by SM exclusively for statistical purposes and in anonymous form in relation to the access and use Site in order to check the proper functioning of the Site and to improve its content and operation. In view of their specific nature, the navigation data may allow the identification of users if associated with data held by third parties. SM, however, does not collect surfing data to associate them with the identification data of users. Navigation data are canceled after being processed anonymously. These data can be used to determine the liability arising from cyber crimes committed against the Site or through it. Except as set forth above, SM retains data users' browsing only for the period of time necessary established by applicable law and then turns them into anonymous data. SM also collects and processes personal data provided voluntarily by users when they interact with the functionality of the Site and the services offered on the same, for example when registering to the Site; User registration to the newsletter or mailing list; purchase of products on the Site, the latter operation that includes all other activities related to it such as, for example, delivery of products, sending the invoice, return and replacement product, return of refunds, purchase and use of gift certificates, also in electronic format, activities relating to payments including prevention of fraud; use of the service to clients and interaction with our call center; user participation in promotions or other initiatives on the Site such as, for example, races and competitions;requests for information from the user or sending questions to SM, sending communications or feedback through regular mail or through the Site;for purposes of recruitment when users submit their curriculum vitae (CV) and other information. SM will treat personal information when required to meet the provisions of the law, regulation or Community legislation, and to defend their rights. SM will also process personal data of users when they contact the customer service and call center, which can communicate with users and therefore treat their personal information through e-mail, chat and telephone. For information on the processing of personal data carried out when a user purchases of products on the site, users are invited to read the relevant privacy statement .The call center will also record the user's phone number to call you and perform back-office services in order to provide you with services and information requested. The call center, with the permission of the user, will also undertake marketing, business statistics and profiling. In some cases, for purposes of internal training, quality control and verification, the conversations can be recorded and saved e-mail to the extent permitted by applicable law. Users will always be notified in advance of the possibility that their communications can be recorded and will have the opportunity to object to this unless it is made necessary by the purpose of verification in connection with a purchase or for other reasons, as allowed by applicable law. With your consent, which is optional, SM shall handle the personal data of users for purposes of verification and for marketing purposes. This activity is to send to the user via e-mail or other electronic communication, such as SMS or MMS, fax, etc., Promotional messages and information material on products and services offered by the MS group, on special initiatives on prices and promotions group SM and other initiatives such as events, exhibitions or fairs organized by the group or the group SM SM takes part; as well as for the purposes of profiling. Users are given the opportunity, free of charge and at any time, to object to the processing of personal data for the sending of information and promotional material; in each communication there will be a special section in which you specify the mode (easy to follow and at no additional cost) to withdraw his consent. The personal data that SM collects and processes include the name and contact information such as address, phone number, email address and any additional information. In each section of the site where we collect personal data is published a specific information prepared in accordance with the Privacy Act. When required by the Privacy Act, SM asks the user consent before proceeding to the processing of personal data. When you do provide personal information of third parties (for example, using the function of sending e-mail to a friend, the functions related to the use of gift certificates or other purposes) the user confirms, to the extent permitted by applicable law that such communication as well as all correspondence and subsequent treatment provided in this Privacy Policy, complies with applicable privacy laws. Thus, for example, the user must have informed the third person of the processing of personal data and have obtained his consent as provided in this Privacy Policy.


The personal data collected through the Website is stored and processed through a computer system operated by SM located at its offices listed above. The updated list of the data processors, if appointed, and the recipients of the communications data are available to users at SM. Personal data are processed by personnel specifically authorized intermediary to access and process the data, including the personnel who carry out extraordinary maintenance operations of the Site. Other companies in the MS group also may be involved in the operations of the data in relation to the functionality of the Site and the services offered on the same, for example in relation to the purchase of products, the provision of support services to the customers and the service call center. Users are encouraged to read the section of this Privacy Policy on the Limits of the communication of personal data. All data processors acting on behalf of MS and according to the guidance given dala same.


Cookies are small data files stored in the user's computer. The Web site uses cookies for specific and limited purposes and, in particular, to offer the user easier navigation on the site, to facilitate the operations log-in (for example by storing the name and password), for purposes of internal security , system administration and analysis of trends. Cookies used by MS can not run a program on your computer or download a virus and does not consent to SM any control on your computer. SM does not use cookies to access information stored on the user's computer, to save information to the same or to monitor its operations. This section of the Privacy Policy applies to cookies and any other technology used by MS that lets you track the user and apply to any instrument is used by the user to browse the Site, whether his computer or other instrument. The so-called "session cookies" are stored in a temporary memory and are deleted when the user closes their browser of Internet. The "session cookies" do not collect any information from the user's computer. The cookies used when registering on the Site collect personal information that allow MS to recognize you on subsequent visits and are used to facilitate navigation and log in to the site, to allow MS to identify which sections of the site the user is more interested in order to provide a custom navigation and customization of information published, and for purposes of management and security as specified above. The Site may contain links to other sites. SM does not have any type of access or control over cookies, web bacon or other technologies that allow you to trace the user present on third-party sites accessible from the Site; the availability, content or materials posted or through such sites and the conditions applied to the processing of personal data by such third-party sites. SM expressly disclaims any liability related to such third-party sites. SM invites users to learn about the privacy policy applied by the third-party sites to which users can access through the Site in order to obtain information concerning the collection and processing of their data. This Privacy Policy applies only to the Site as defined above. Many Internet browsers automatically accept cookies. Users usually can modify and disable this setting. The "Help" section of the toolbar present on the majority of browsers explains how to block the storage of cookies, web bacon and other technologies that allow you to trace the user, how to get the browser notifications relate to the storage of such items or as disable them entirely. Completely block the storage of cookies may limit the possibility for the user to browse the Site and may prevent the use of certain features on the Site or the services offered on the same.


Personal data collected by MS are treated mainly with electronic and computerized instruments as well as by manual (paper processing) according to the logic and procedures meeting the processing purposes specified herein. The personal data are treated according to the applicable privacy laws, including the aspects of security and confidentiality, and are kept for the time necessary to achieve the specific purpose from time to time and prosecuted in accordance with applicable privacy laws.


SM is committed to ensuring the security of personal information. SM processes personal data in accordance with the provisions relating to the security established by the applicable laws in order to prevent the loss and destruction, even accidental, of data, unauthorized access, as well as illegal or illegitimate data themselves. The information systems and computer programs are also configured to use personal information only when necessary to achieve the specific goal of treatment from time to time pursued. SM uses a number of advanced security technologies and procedures to help protect personal information against the risks identified above. For example, the personal information provided by users are stored on secure servers located in areas under surveillance. Furthermore, for some data transmissions over the Internet, encryption techniques are used such as the Secure Socket Layer (SSL). Users can help MS to update and maintain accurate their data by communicating to SM to any changes regarding your address, title, phone number or email address. Users who have registered can do so online by following the instructions in the relevant pages of the Site.


SM communicate the personal data of users within the limits and under the conditions specified in this Privacy Policy and in the published in the respective sections of the Site where data is collected. However the data is disclosed in full compliance with the consent given by the user at the time of harvest, when required by the Privacy Act. The users' personal data will be accessible within the SM by the internal and external personnel that need to access them in the execution of their job responsibilities in relation to the purposes specified herein. The personal data of users will also be accessible from the data processors, if appointed. The updated list of the data processors and the persons to whom the data may be communicated remains free of charge to users who may request it to MS. Personal Data may be disclosed to authorities, authorities, public institutions, banks, lending institutions, professionals, independent consultants also organized as an association, business partners and third party service providers. SM may apply to such persons for the provision of services of technical and organizational relating to the management of the site and the activities carried out by it such as, for example, the sale of products and execution of related services, management functionality provided on the Site and initiatives and services to which users can subscribe or request through the Site, as well as to perform other services strictly functional to achieve the purposes of processing specified herein. For purposes necessary to provide the Site and the services related to it such as, for example, the purchase of products through the Site or by phone at our call center. The personal information may also be disclosed to other companies within the group SM European Economic Area (except SM International Sagl located in Switzerland to which data transfers are possible because the European Commission has recognized privacy law Switzerland an adequate level of data protection) that will process the data in compliance with applicable privacy laws to achieve the purposes of processing specified herein. With specific reference to the sale of the data will be processed by the company of SM in the country where the product delivery must take place, which will act as owner of user data according to applicable privacy laws for the following purposes: issue of invoices , product delivery, refund or replacement product, return of refunds, purchase and use of gift certificates in electronic format, activities relating to payments including prevention of fraud. Personal data may be shared with other companies in the MS group when treatment has the marketing and profiling, as defined above. Moreover, for the execution of transactions and the processing of payments SM turns to third party service providers for the management and support of the information platform.These service providers are bound by contractual obligations to take appropriate security measures to protect the security and confidentiality of personal information and details of the relevant credit card. Third parties that receive personal information, as specified above, use the data as Holders of the treatment (for the purposes of sales and marketing companies will be present locally) or data processors, as appropriate, in compliance with applicable privacy laws and for the purposes set forth herein. Personal information may also be disclosed to third parties in case of mergers, acquisitions, disposal of any business unit, product, site or operation. Will be provided to such persons only the information needed to perform their functions. Such third parties agree to use the information only for the purposes of treatment specified above, to keep them confidential and secure and to comply with applicable law and the instructions given by SM. Except as provided above the users' personal data will not be shared with third parties, persons or companies that are not related to MS or that do not run on its behalf functions commercial, professional or technical. The personal information may be disclosed to any third party it is a legitimate recipient under the laws or regulations, for example in the case of legal proceedings, claims courts and other competent authorities or due to additional obligations, court, to defend the site and the rights and assets of SM. The personal information will not be disclosed to third parties other than group companies SM for their marketing purposes and will not be disclosed in any case.


Except as described above regarding the navigation data (see "Data Treaties and Purposes of Treatment"), consent to the processing of personal data is necessary to the execution of the functions and the provision of services offered on the Site, and requested by the user such as the registration with the Site, to newsletter or mailing list, the management of purchases of products made on the Site and related activities, the management of user participation to promotions and other initiatives on the Site such as, for example, race and contests, sending information to users or sending to SM other communications or feedback, management of the selection of candidates who have submitted their curriculum vitae (CV) and other information. The consent to the processing of personal data is required for the execution of the activities required to meet the provisions of the law. In the above circumstances the lack of consent to the processing of personal data by the user makes it impossible for SM perform its contractual obligations or provide the services, products or information requested as specified above.


Users hannoil right to enforce at any time the rights under Art. 10 of the Privacy Act or other applicable privacy laws, as applicable, including without limitation the right to obtain confirmation of the existence of personal data concerning him, to verify their content, origin and accuracy, ask for their integration , update, change or delete and object to the processing for legitimate reasons (including the ability to object, free of charge and at any time, the processing for marketing purposes). For any questions regarding the processing of personal data carried out by MS and to enforce rights under the Privacy Act, users can contact SEA MANAGEMENT srl Corso Europa, 14 20122 Milano - Italy tel / fax. 02 7395 2348 - P / VAT IT 08544610960, This Privacy Policy is subject to updating. The version published on the Site is the one currently in force. If SM modify this Privacy Policy, will notify by posting a link on the home page of the Site that refers to the amended privacy policy entitled "New Privacy Policy". SM invites users to view the Privacy Policy periodically in order to be updated with any changes. The date of entry into force of this Privacy Policy is September 9, 2010