Privacy Policy

Registration with the Website

2. In some sections of the Website, or when using the Services, Users are offered the opportunity to join the Sfilate community (“the Community”) thereby benefiting from a series of exclusive advantages reserved for registered Users.
The Community is run by Info Draft by means of the newsletter, periodically sent by e-mail to the User’s e-mail address, by which Users registered with the Community will be informed of exclusive initiatives that Info Draft will make available to its registered Users. The Newsletter may also contain publicity banners, adverts and promotional offers on behalf of both Info Draft and third parties.
When registering with the Website, Users will be asked to enter their personal data, some of which – each time expressly identified as such – it will be compulsory and indispensable to supply in order to register as members of the Community (e.g. e-mail address at which the Newsletter can be received). Supply of other data is optional, at the User’s discretion, and failure to supply it is not in any way prejudicial to membership of the Community, but such failure may make it impossible for the User to take part in any contests or initiatives, or in any case permit him/her to make only partial use of some Services.
Users may change their profile at any time and, in cases where Info Draft permits it, enter data previously not supplied in order to take part in initiatives from which they would otherwise have been excluded.

Browsing the Website and cookies

3. The Website server, using cookies too, automatically records some information on the computer and the sections visited by the User, for example: the name of his/her Internet access provider, the website from which he/she accessed the Website, pages hit, date and length of the hit, etc. This information will be recorded in anonymous form, and used only to permit access to the Website and/or make use of some Services, and then cancelled, or used in aggregate form for Website statistics purposes and to monitor, again in aggregate and never individual form, which Website pages and Services are most appreciated by Users.
Opinions and preferences expressed by Users as part of a contest, survey or similar initiative will also be used by Info Draft only in aggregate and never in individual form, or for User profiling.


4. The cookies used by Info Draft are text files that the Website transfers to the User’s computer to facilitate browsing. Thanks to cookies, recognition of registered Users by the Website can be facilitated, thus avoiding the need for authentication (by logging in and entering a password)each time they access the Website. Cookies, additionally, may permit Users to personalise the way in which they make use of the Website by saving their favourite settings.
As stated above, cookies also record information regarding User browsing; this information is not however recorded individually, and does not therefore interfere with Users’ privacy and confidentiality.
Each user has the right to disable cookies using the Internet browser software. Many browsers are designed to accept cookies unless the User disables this option. Info Draft asks its Users to check the settings of their browser with regard to cookies, and to ensure that they comply with their wishes, bearing in mind that it may be necessary to enable receipt of cookies in order to make use of some services (in such cases, Users will be duly informed).


Saving and processing of data

5. As Data Controller, Info Draft will save the Users’ personal data, either directly or by means of possible Data Processors stated on the Website, in the servers located on the premises of TWT in Viale Jenner, 37 - 20100 Milan and to carry out all the processing operations using the staff – of the Data Controller or the Data Processor – specifically designated as persons appointed to process the data, or using external personnel when maintenance operations are performed.
The data base can be accessed only by the parties who are authorised to do so using methods that guarantee its protection and confidentiality, thanks to the use of security measures to prevent loss of data, unlawful or improper use and unauthorised access to the data.
Each person appointed to process the data shall be given specific instructions on how to handle the data, which the appointee must obey in order to avoid incurring disciplinary action and/or legal proceedings.
The data shall be kept only for the time strictly necessary to complete the processing performed in relation to the data of each User, according to his/her choices, preferences and instructions.

Processing in general

6. Info Draft uses the Users’ data according to the choices which the Users’ have freely made when giving their informed consent either when the data was collected or at a later date. Some data is used without requesting consent – in accordance with Section 24 of the Data Protection Code – to fulfil specific requests made by the User and within the limits of the request itself. For example, the telephone number of a User who has taken part in a prize contest may be used to notify him/her of the result of the contest.
In accordance with what is set forth in the Data Protection Code, by Section 58 paragraph 2 of Legislative Decree no. 206 of 6 September 2005 and by Section 19bis of Legislative Decree no. 273 of 30 December 2005 – as modified when converted – the User’s data is used, until otherwise indicated by the User, by remote communication techniques that permit individual notification for the sending of advertising material, and for performance of direct sales business, market research or sales communications.

Processing operations subject to consent, disclosure and circulation of data

7. Only when expressly authorised by the User, will Info Draft use his/her data for the activities stated in the paragraph hereinabove using automatic tools without the intervention of an operator and/or for other purposes authorised each time by the User. Similarly, Info Draft may share the data with or disclose itto its commercial partners – stated or listed each time on the Website – for the purpose of permitting such partners to separately process the data, as Data Controllers, using the same methods and with the same limits as those for which Info Draft has been authorised, only if expressly authorised by the User.Users’ data is never disclosed, with the exception of data voluntarily made available by the Users in any common areas of the Website which are freely accessible. Info Draft invites Users not to supply their personal data in common areas of the Website that are freely accessible, reserving the right to cancel such data or make it anonymous where such data is classed as sensitive according to the definitions set forth in Section 4, paragraph 1, letter d) of the Data Protection Code. Lastly, the data may be disclosed to public authorities in response to a legitimate order given by such authorities.


8. In compliance with what is set forth in Section of 7 of the Data Protection Code, Info Draft gives Users the right to change their preferences with regard to the processing of the personal data that refers to them at any time, and to obtain confirmation of whether or not such data exists, to be informed of where the data was obtained, the contents, the purpose and the method of processing, to request that it is updated, rectified, integrated or to demand erasure or blocking of data processed unlawfully.
Users, moreover, have the right to object to the processing of their data, as well as demanding at any time that processing of their data for the purposes of market research, sending of advertising material, direct sales and sales communications be halted.
The rights listed hereinbefore may be exercised by writing to Info Draft at the e-mail address


9. Info Draft is aware that the Website and Services may be of interest to minors.
Info Draft encourages parents to monitor the use of the Internet by their children, for safer and more supervised use of its contents, including the use of parental control tools. Besides guaranteeing an on-line environment suited to minors, such tools can prevent disclosure of personal data by children or young people who have not obtained the consent of their parents.
With regard to the collection and processing of personal data, Info Draft does not perform any processing of the personal data of minors without the consent of their parents.
Only adult Users or Users over the age of 14 years whose parents have given their consent are therefore permitted to register as members of the Community.
Info Draft, moreover, encourages parents of underage registered Users to become Community members themselves: in this way parents can make use of the Services and always be aware of the initiatives which Info Draft makes available to their children, and thus check that they conform to their expectations and that they are not in contrast with their educational beliefs and methods.
In relation to delivery of some Services, Info Draft does not require Users to state their age, and/or is not able to otherwise get to know the age of Users. Info Draft therefore invites all Users who are under the age of 18 not to communicate their personal data in any circumstance without the consent of one of their parents, reserving the right to prevent access to the Services and/or exclude from Community membership any User who has concealed the fact that he/she is underage or who in any case has communicated his/her personal data without the consent of his/her parents even though he/she is under 18 years of age.


10. The Website and/or other messages and/or notifications that Info Draft sends to Users as part of the Services, may contain banners, publicity and/or adverts by third parties, advertisers or Info Draft’s commercial partners.
Info Draft informs Users that by accepting the offers made by the aforesaid third parties, Users may purchase goods or services and access multimedia pages that are the exclusive competence of such third parties, which are beyond Info Draft’s control and which are not in any way bound to respect what is set down in this notification.
Info Draft, therefore, invites Users to supply their personal data in return for suitable guarantees of confidentiality, and to take the greatest care before accepting services offered by such parties, in relation to which Info Draft cannot exercise any control, nor shall it be in any other way involved or held responsible.


11. It being understood that Info Draft does not in any case perform any processing operation other than those expressly authorised and/or requested by each User, the information contained in this notification may be subject to changes required to comply with new legal regulations or to changes in Info Draft’s data processing policy.
Each updated version of this notification shall be made available on the Website in the appropriate section: Info Draft therefore invites all Users to periodically consult the Website in order to remain constantly informed of the latest version in force.

LAST UPDATE: September 4, 2009