Laws on privacy

Laws on privacy
Last edit: 10/02/2012

OLOS is the managing Organization of the websites that you can reach at the URLs: www.tregua.org; www.olosfondazione.org; www.olos.net; www.bike4truce.org.

Reason for this notification
In this page are described the management modalities for the website regarding the treatment of the personal data for the consulting users.

OLOS is subject to European laws and, being constituted in Italy, in particular to the Legislative Decree of 30th June 2003, n.196 security code for personal data (follows as: Code) and, for some particular aspects, to the Directive 2002/58/CE of the European Parliament and Council of 12th July 2002 regarding the private life and electronic communications.

According to this Decree (Art. 33 – 36) and to the connected technical Disciplinary on the subject of minimal security measures – Enclosure B – OLOS applies its own Programmed Document on Security (PDS) that recovers and connects, for the operative aspects, to the one deposited by the technical partners.

OLOS, within the activities included in managing the Contest is entitled to secure all rights, conditions of use and the guarantees that satisfy the exclusive property of the producer for computer technologies and data transmissions that it uses, according to the contract stipulated with its technical partners.

OLOS recognizes the importance of security for the personal data and commits to not collect or utilize personal data for purposes different than those described in the present Privacy Laws and/or in the supplementary informative on privacy for certain services without the express authorization of the user.
This informative on the security for personal data (privacy) describes the way in which OLOS and its associates treat the personal information when you use the services available on the website www.tregua.org. To comprehend the way we treat the information you give us when you use OLOS, we invite you to read these norms.

For possible questions regarding the application of the existing Norms on privacy, contact OLOS through the website or send an email to: privacy@tregua.org.

The informative is available only for the website: www.tregua.org and not for any other websites possibly consulted by the user through the link, of which the Foundation is not responsible.

This informative is also inspired by the Recommendation n.2/2001 which the european authorities for the protection of personal data, united by the Group instituted by art.29 of the directive n.95/46/CE, have adopted on the 17th May 2001 to find some minimal prerequisites for the collection of personal data online, and, in particular, the modalities, the time frame and the nature of the information that the head of data management must supply the users when they connect to the web pages, regardless of the purpose of the connection.

Head of data management
Following the consultation of this website data relative to identified or identifiable people can be treated. The OLOS Foundation, according to art.4 comma1 letter f), defines itself responsible for the treatment of the data

Place for data management
The treatments connected to web services of this website are carried out in the center of the company I.D.E.A. srl and are followed exclusively by the personnel in charge of the treatment, or by possible people in charge of occasional maintenance operations.

Modalities for data management
Personal data are treated with automated instruments only for the strictly necessary time frame to achieve the objectives for which they were assigned.
Specific security measures are observed to prevent the loss of data, illicit or wrongful use and non authorized access.

Rights for the implicated
The subjects whose personal data is implicated have the right at any moment to obtain the confirmation of the existence or not of the data and to know the content about it and the origins, verify whether it is correct and ask for a possible integration or update, or else the rectification (art.7 D.Law 196/2003).
According to the same article, they have the right to ask for the cancellation, the transformation into anonymous form of the data treated for violation of the law, let alone to oppose one self in any case, for legitimate reasons, to their treatment.
The demands regarding art.7 D.Law 196/2003 have to be directed to the OLOS Foundation, to the email address: privacy@tregua.org.

P3P
The present informative is consultable in automatic form by the most recent browsers that implement the standard P3P (“Platform for Privacy Preferences Project”) proposed by the World Wide Web Consortium (www.w3c.org).
Every effort will be made to make this site’s functionalities the most interoperable possible with the automatic control mechanisms of privacy available in some products utilized by the users.
Considering that the improvement state of the automatic control mechanisms doesn’t leave them exempt form errors or dysfunctions, we specify that the present document, published to the address www.tregua.org, constitutes the “Privacy Policy” of this website that will be subject to updating (various versions are consultable at the same address).

Quick note on Security
It’s better that some things remain private
The publication of user Contributions that talk about you, your friends or your family, can be fun and exciting. You can never know you will find it: it could even show up in the front page or end up in the most viewed list! If your user Contribution is personal, ponder the idea to mark it as private so that it can be viewed only by your friends and those who you choose to share it with.

Protect your secret identity!
If you insert some public user Contribution, verify that they do not have any elements that can let a stranger know who you are or where you live. Personal information like your telephone number or your private address should NEVER be shared with other users. Be careful for elements such as license plates, images from the exterior of your home that could accidentally appear on the background of a user Contribution and allow a stranger to track you.
The only information known to the system are the ones you will have introduced personally while compiling your user profile. If you think that your personal email address is not the most appropriate for your OLOS Account (OLA) through which you will carry out various activities within the Contest, register another one for this purpose. Even this is a useful precaution to avoid annoyances.
The partners of OLOSteam will never ask you for your password, or other information on your OLA. Don’t be fooled by someone who contacts you pretending to interact as an OLOSteam!
The Contest’s website expects to have many visitors every day and, exactly as in reality, most of them are proper, but unfortunately not everyone. Therefore you should protect yourself and your friends keeping your personal user Contributions private and not revealing your identity. Use the comments in a loyal way and expose the improper behavior by marking the user Contribution.

Contents downloaded to the website
Any kind of personal information or user Content that you voluntarily share online (in messages, in your channel page for video reproduction, or in your profile page, etc.) becomes publicly available and it can be gathered and utilized by others.

Use of the data gathered by OLOS
We offer different services, for example the navigation of the contents and the Research function within the website, that do not require the registration of an OLA or the inclusion of any personal data. In order to offer the complete package of our services, we request to collect the following information, and to utilize the following instruments:

Activity not tied with OLA
You can view the user Content on the website without needing an OLA. You can also contact us for issues associated to a particular user Content without having an OLA.

Activity associated with OLA
For other activities on the website, like, for example, the downloading of a Video or its voting you need an OLA. This allows you to access our various services that require a registration.

Data supplied by the user
When a user completes an OLA registration, we request personal data such as name, last name, email address and OLA password. For some services, like for example sending a Video, we also request a few added data. All the data that we record are cryptographied on a protected server of our storage provider. We allow ourselves the right to organize the data that the user sends us through his OLA with information from other services operating on the website or of third parties with the purpose to make an easier navigation and better the quality of our service. Some services allow you to exclude the combination of such information.
If you provide information that allows you to be identified at a personal level on the website, these will be utilized to manage, maintain and provide you the general and personalized functions of the websites, and to manage the indications on the user contents or the messages that you send us.
When you upload or download user Content or you send messages through the website, your OLA user name (not your email address) will be viewed by other users, who will be able to contact you with messages and comments. Any Content you send to the website could be redistributed through internet and other channels, and could be viewed by all users.
OLOS does not utilize the email address or other personal data to send commercial or marketing messages without your consent, if not within its functions or specified programs in which there will be options available to opt-in or opt-out. It can, however, utilize the email address without further consent for non marketing or administrative purposes (for example for automatic communications regarding depositing and/or modifying a Video, to announce important changes to the website, or to provide technical assistance).
We can also utilize both the information that allow for your personal identification and those that do not (like anonymous data utilized by the users, cookie, IP address, browser type, click stream data, etc.), to better the quality and the website’s structure and create new characteristics, functionalities, promotions, and services memorizing, monitoring and analyzing all the preferences and tendencies of the users, just like the activities and communications of the same users.
Beyond the responsibility that we assume for the respect of your rights in the application of the privacy code, if you should receive in your email address that you provided for the registration of your OLA, any undesired message – that you think could be traced to an improper use of the address – we solicit you let the OLOSteam know immediately through a communication to: privacy@tregua.org.

Available options for the personal data
In case we should decide to use personal data provided by the user for a different purpose than the original one, we will preventively request authorization from the user.
In the eventuality OLOS offers the user a use of the personal data for a different purpose than that described in the present Privacy Laws and/or in the informative on the privacy for a specific service, it will also offer the user a useful way to negate his/her own consent to the use of the personal data for the purposes in question. The user can refuse to provide his/her own personal data for any kind of service, but in such case OLOS will not be able to distribute the specific requested service.

Cookie
When the user visits the website, we send to his/her computer one or more “cookie” (a small file containing a series of characters) that identify in a univocal way the user’s browser. We utilize cookie to better the quality of our service memorizing the preferences of the user and monitoring his habits of navigation, for example his/hers research modalities.
We use cookie, GIF transparent and information on registrar files to:

a) To memorize the information introduced so that they won’t be inserted again during the visualization of the website or the next time you visit the website;
b) Provide contents and personalized information;
c) To verify the effectiveness of our communication campaigns;
d) To control global elements like the total number of visitors, the viewed pages and so forth;
e) To keep a trace on the data you insert, on the user contents that you send and the state of promotions, lotteries and contest’s.

The website also uses cookie in its communication services to help the adviser and publisher sponsors to publish and manage commercials on the web. We can set up a cookie in the browser when the user visits a website and visualizes or clicks on an announcement supported by the commercial services managed by OLOS.
Almost all browsers accept cookie as a predefined structure, but it is possible to reconfigure the browser to block or alert the user when the browser is about to send a cookie. However, some functions and some services on the website could also not work correctly if the cookie is deactivated.
The user has the ability to deactivate the cookie for the publication of announcements at any moment.

Access information
When a user accesses the services of the website, our servers automatically register the information sent from the user’s browser every time he/she visits the website. These server logs can include information such as web requests, IP address, type and language of the browser, date and time of the request and one or more cookie that identify in the same way the user’s browser.

User communications
When the user sends emails or other analogous communications to the website, OLOS bestows upon itself the right to memorize such communications in order to elaborate and satisfy the user’s requests and better its own services.

Affiliated websites
We offer some of our services in collaboration with other websites. It is possible that the personal data provided to such sites are sent by the website to allow the distribution of the service. Such information is elaborated in compliance with the present privacy laws. It is possible that the affiliated websites apply a different policy for privacy; therefore the user is invited to consult the relative privacy laws.

Link
The website can present links in such format that allows monitoring of the links if they have been clicked. We use this information to better the quality in our technological research, of our personalized contents and of commercials.

Other websites
The present privacy laws are valid only for the services managed directly by OLOS. We do not have any control on the websites viewed as a result of a search or links within our services. These other websites can insert their own cookie or other files on the user’s computer, collect data or ask the user for personal data.
OLOS elaborates the personal data only for the purposes described in the present laws on privacy and/or in the supplementary informative on privacy valid for specific services. Other than those already mentioned above, such purposes include:
a) To offer our services to the users, including the publication of personalized contents and publicity:
b) To execute activities that verify, research and analyze with the aim to manage, protect and better our services;
c) To verify the technical operations of our network;
d) To develop new services.

OLOS elaborates the personal data on its own servers, located in Italy. We bestow upon ourselves the right to elaborate the personal data in order to distribute our services. In some cases, we allow ourselves the right to elaborate the anonymous personal data on behalf of third party and complying with the instructions provided to us, for example our partners in communications.

Sharing of the data
OLOS shares the personal data with other companies or private individuals foreign to OLOS only in the following cases:
The user has provided his/her own consent, mandatory for the sharing of private personal data.
We provide such information to our technical partners, other companies or trusting individuals for which we demand the task to elaborate the personal data on our behalf. We ask them to elaborate the personal data based on our instructions and in compliance with the present laws on security for your personal data, let alone other appropriate measures for security and confidentiality.
We have good reason to believe that the access, the use, the conservation or the spreading of such data is to be held reasonably necessary in order to
a) To comply with any law, normative, legal procedure or request of agencies and current governmental organisms;
b) To apply security laws for personal data when carrying out the Services, including for these, the verification of potential violation;
c) To identify, prevent or hinder in other way frauds or other illegal behaviors of technical nature or relative to security;
d) To protect the rights, the property or the security of the website, of its users and of the public in the required measure allowed by the law.

We allow ourselves the right to share with third parties some additional data of non personal nature, for example, the number of users that have searched for a specific term or the number of users that have clicked on a particular announcement. This type of information does not allow to personally identify the user.

Protection of the information
We adopt and we make our providers adopt as well, appropriate security measures to impede the non authorized access or the modification, the spreading, the destruction of non authorized data, of which internal exams from our collecting procedures, memorization and elaboration of the data and our security measures, let alone physical protection measures to impede the non authorized access to the systems where the personal data is memorized.
The access to the personal data is restricted to the workers, external associates and OLOS agents that need such information in order to manage develop or better our services. These people are bound by confidentiality obligations and are subject to possible disciplinary provisions, like immediate dismissal and penal sanctions, in case they do not oblige to such obligations.

Data integrity
We constantly control our collection, memorization and elaboration procedures of the data in order to guarantee that only the necessary personal data is collected, memorized and elaborated to provide or better our services. Where possible we try to guarantee that the personal data that is elaborated is accurate, complete and up-to-date, but it is the users’ responsibility to update or correct his/her own personal data, where necessary.

Access and keeping personal data up-to-date
When the user utilizes the website’s services, we try to provide the him/her access to his/her own personal data, we encourage him/her to correct it, in case there are errors or not up-to-date, or we allow him/her to eliminate the data, on specific request from the user, where it does not result necessary by law or by legitimate business purposes to keep that data. We ask all users to identify themselves and the data that can be accessed or that you would like to be corrected, or removed before elaborating this type of request. We also reserve ourselves the alternative to not elaborate requests unjustifiably repetitive or systematic, that require excessive technical work, that put at risk other’s privacy, are not practical (for example, requests that involve memorized data on backup tapes) or do not allow a mandatory access. In all cases in which we provide access to the data or offer the correction, we give this service for free, except for the occurrence where excessive work is demanded. Some of our services have different access, correction or elimination procedures for the personal data. Information for these procedures is available in the section of frequently asked questions (FAQ).

Application of the laws
OLOS verifies regularly its own respect of the current laws on privacy. For possible questions or doubts in merit on the current laws on privacy or the treatment of the personal data on behalf of OLOS, contact OLOS through this website or send an email to the address privacy@tregua.org.
It is procedure for OLOS to answer users who send formal complaints, written to this address, to verify the indicated problem. We try to work together with the according authorities, among them local authorities looking after the security of the data, to answer possible claims regarding the transfer of personal data that are not resolved directly between OLOS and the single users.

Modifications of the present laws for the security of the personal data
The current laws for the security of the personal data are subject to modifications in time. We try to not reduce the rights of the users expected by the current laws on privacy without their explicit consent and we expect that such modifications will be of small entity. In any case, we will publish every eventual change to the current laws on security of the personal data in this page and, if the variations are significant, we will send a notice clearly visible (for certain services we will send a notice of the changes via email). Each version of the current laws on security of the personal data will be identified in the top section of the page where the validity date is and the preceding versions of the laws will be stored to allow consultation.
For any possible questions or doubts on the current laws for privacy, it is possible to contact OLOS at any moment through this website or by sending an email to the address: privacy@tregua.org.

Our postal address for problems regarding the security of your personal data is the following:

Fondazione OLOS
7, Via Ruggero Settimo
65123 Pescara (PE)
Italy