Terms of use

Why the present document

This page describes the site's procedures for the processing of the personal data of its users. Data are always processed within the law and to the highest ethical standards in accordance with all relevant legal requirements ((and thus also in accordance with the principles of ethics, legality, transparency and the protection of privacy and rights) and thus by methods strictly correlated to the purposes pursued.
Giving due consideration to technological innovations, suitable prevent measures are adopted by Tennis Photographer Pty Ltd (hereinafter also 'Ray Giubilo - Tennis Photographer' or 'Company') when using personal data, in order to minimise the risk of even accidental destruction or loss, unauthorised access to the data, or uses which are illegal or incompatible with the purposes for which the data were acquired. Tennis Photographer Pty Ltd will only perform on the data the operations necessary for the pursuance of the purposes specified in the aforesaid notice and in the privacy policy statement given to the users to the collection of personal data.
Data will be conserved and used for a period appropriate to the relative purposes and compliant with the relevant legal requirements. Data may also be organised in databanks/databases, including electronic databases.
The privacy policy information is also provided as a short notice pursuant to art. 13 of Italian Legislative Decree 196/03 (Italian data protection law, implementing Directive 95-46-EC), to all those who interact with the web services of this site, for the purposes of the protection of the personal data accessible by internet through the address: http://www.tennisphotographer.com the address of the site's home page.
The information is provided solely for the site specifically referred to and not for any other websites the user may visit by means of links. The aforesaid websites are independent data controllers (except in the case of sites belonging to the company) and users should refer to the sites concerned.
The information is also based on Recommendation n. 2/2001, adopted by the European data protection authorities, meeting in the Group established by art. 29 of Directive 95-46-EC, on 17th May 2001 to set a number of minimum requirements for the on-line acquisition of personal data, and especially procedures, times, and the information the data controllers are required to provide to users when they log on to web pages, regardless of their reason for doing so.
The server on which the website resides is at web farm Aruba S.p.a, Via Sergio Ramelli 8 - 52100 Arezzo (AR) - Italy.
In addition to server address, data may be processed at Tennis Photographer Pty Ltd's head-office or wherever data processors appointed by Tennis Photographer Pty Ltd may be based (as well as on the premises of third parties to whom the data can be communicated in quality of Data Processors and that are indicated in such policy or in appropriate privacy policy statement inside of the site).
Users are however advised to view all the specific information provided in the various sections of the site.

Types of data processed and procedures of processing data

Navigation data

During their normal operation, the IT systems and software procedures which operate this website acquire some personal data the transmission of which is implicit in the use of Internet communications protocols.
These data are not gathered for association with identified subjects, but by their very nature, when processed or associated with data held by third parties, they might allow users to be identified.
This category of data includes the IP addresses or domain names of the computers used by users who log onto the site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used when submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the server's response status (concluded successfully, error, etc.) and other parameters relating to the user's operating system and IT environment.
These data are used for the sole purpose of obtaining anonymous statistical information concerning use of the site and to check that it is operating correctly and are deleted immediately after processing. The data might be used to identify those responsible in the event of IT crime against the site or more generally against the company.
The data could be processed by Tennis Photographer Pty Ltd manually, on paper or using IT or telematic means (and therefore Tennis Photographer Pty Ltd will store and process the data on paper or IT media).

Cookies

Definition of cookies

Cookies are small text files that are sent to your computer.

Session cookies

So-called session cookies (i.e. temporary cookies that are erased when the browser is closed at the end of a surfing session) are solely used for transmitting session identifying data in the form of numbers randomly generated by the server. These cookies are necessary to ensure secure and efficient site browsing.
Session cookies are used in this site precisely to ensure maximum user privacy during surfing as they do not permit acquisition of user's personal details that would otherwise permit user identification and recognition.

Data supplied voluntarily by the user

For specific provisions for which there is a specific form (e.g. form of registration) it is better to refer to the specific privacy policy statement.
The optional, explicit, voluntary dispatch of electronic mail to the addresses provided on this site (in the event in which it is only indicated address email and does not exist an appropriate form in presence of which it is better to refer to the specific notices that regulate the provision in the various form), leads by Tennis Photographer Pty Ltd to the subsequent acquisition of the sender's address, necessary in order to reply to the enquiry, and any other personal data included in the message (and its attachments) or the specific forms used. In this case (where email address is provided alone, without a specific form of compilation in the presence of which refer to specific information governing the provision in various forms) the provision of data is optional but failure to provide an address or other data necessary for dealing with the request will make any reply to the email, and thus the fulfilment of the request, impossible. With the sending of the e-mail the person concerned shall authorize Tennis Photographer Pty Ltd to the processing of data for responding to the requests.
In case of requests for material shipment, the necessary data to the shipment could be communicated by Tennis Photographer Pty Ltd to mail-carriers.
Data, in paper or electronic format, could be dealt by Tennis Photographer Pty Ltd manually or with computerized instruments.

Data controller, Data processor and data subject's rights

The Data controller is Tennis Photographer Pty Ltd.
The data processor, whom you may contact to exercise your rights under art. 7 of Italian Legislative Decree 196/03, within the times and by the procedures envisaged by the law, and to obtain the full, up-to-date list of any other data processors, is the Information Systems and Process Organisation Manager, who can be contacted for the purposes of this role at the Company's addresses.
For any information required, users may write to raygiubilo@gmail.com, to the attention of the data processor, with subject 'privacy'.

Section 7 of D.Lgs. 196/2003 (Right to Access Personal Data and Other Rights)

  1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
  2. A data subject shall have the right to be informed
    1. of the source of the personal data;
    2. of the purposes and methods of the processing;
    3. of the logic applied to the processing, if the latter is carried out with the help of electronic means;
    4. of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
    5. of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.
  3. A data subject shall have the right to obtain
    1. updating, rectification or, where interested therein, integration of the data;
    2. erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
    3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
  4. A data subject shall have the right to object, in whole or in part,
    1. on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
    2. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

Context of communication and disclosure of personal data

No data is being disclosed by Tennis Photographer Pty Ltd
For specific processing for which there is a specific form (e.g. form of registration) it is better to refer to the specific notices.
For the other processing the data submitted by the users are known (and processed on behalf of Tennis Photographer Pty Ltd) by subjects appointed by Tennis Photographer Pty Ltd as persons in charge of processing the data (IT staff that can also carry out tasks of system administrators being appointed as such in this case, IT technicians also external to the Company, that can also carry out tasks of system administrators being appointed as such in this case, envelope filling and mailing staff also external to the Company, website management staff also external to the Company, legal staff, consultants also external to the Company, staff of data processors that process the data for performing the same tasks that the data processors perform on behalf of Tennis Photographer Pty Ltd. Data Processor appointed by da Tennis Photographer Pty Ltd may also know and process the data (also external companies that perform activities of mailing, management and maintenance of server, website management). These external subjects process the data also through their staff as persons in charge of processing on behalf of Tennis Photographer Pty Ltd and perform the same tasks that the external subjects appointed data processor perform on behalf of Tennis Photographer Pty Ltd in addition to tasks of management and maintenance of server/pc on which the data of Tennis Photographer Pty Ltd are hosted.
Persons in charge of processing and data processors may process the data if the process is necessary for the performance of their tasks only carrying out the operations necessary for the performance of the said tasks.
If necessary, the data can also be communicated by Tennis Photographer Pty Ltd to judicial bodies or to the police or to anyone it is necessary in order to satisfy obligation provided for the law, regulations or EU law or in order to assert a right during judicial proceedings.

Optional or compulsory provision data and procedures of processing

For a complete information on the processing of the data by Tennis Photographer Pty Ltd, we invite you to take vision of all the information contained within the various areas of application of the data and all sections of this privacy policy.

Specific Notices

The various sections of the website also contain specific notices, which should be referred to with regard to the uses of the data which they cover.

Information updated as at 19/02/2014. Such update is carried out inside of policy of constant review of the informative ones. The versions of the previous policy statements are available writing to raygiubilo@gmail.com.

Policy statement in accordance with provisions of the Italian Privacy Law (art. 13 of Legislative Decree 196/03) - update as at 19 February 2014 (for the data collected on the registration form)

With the present policy statement, Tennis Photographer Pty Ltd, (hereby referred to as the 'Company' or 'Ray Giubilo - Tennis Photographer') informs you on the purposes and modalities for processing the personal data (provided by yourself) which it shall possess.

  1. We inform you that Tennis Photographer Pty Ltd shall process said data in manual, paper, electronic, and telematic forms (and data shall be stored in electronic and printed form). Tennis Photographer Pty Ltd shall observe specific security measures to prevent the loss of data, its illicit or incorrect use, and unauthorized access. All of this data shall be conserved and processed by Tennis Photographer Pty Ltd in full compliance with the protection of privacy pursuant to all existing norms (and thus in keeping with the principles of fairness, lawfulness, transparency, and protection of privacy) and in a manner strictly related to the purposes indicated in this policy statement. Tennis Photographer Pty Ltd shall process the data only to the extent and in such a manner necessary to fulfilling the stated purposes. The data shall be stored at Tennis Photographer Pty Ltd offices and at the Data Processors appointed by Tennis Photographer Pty Ltd (along with the third parties to whom data is communicated as Data Controllers and listed under point 3 of the present policy statement) and can be stored in databases, including electronic databases.
  2. Data can be processed by Tennis Photographer Pty Ltd (which shall only process the data necessary for fulfilling the stated purposes, and only to the extent and in such a manner necessary to fulfilling the stated purposes) for the following purposes:
    1. to allow you to register yourself in the website, to recognize you as an authorized user, and to grant you access to the reserved areas and documentation (in accordance with the purpose you have indicated);
    2. to uphold or defend Tennis Photographer Pty Ltd's rights in a court of law or to comply with obligations set out in Italian law and in Community norms and regulations (data can be processed in such a way even without the consent of the data subject pursuant to art. 24 lett. a, f of Legislative Decree 196/03).
  3. Tennis Photographer Pty Ltd shall be authorized to communicate the data for the purposes described in point 2 lett. B of this policy statement (communicating only the data necessary for fulfilling these purposes) to: judicial authorities, excise and revenue police, law enforcement agencies, and public bodies (whenever there is the obligation to do so) as well as law firms, legal consultants, post offices and couriers (who shall be able to see the address in order to send any written communications). Tennis Photographer Pty Ltd shall not communicate the data for the purposes described in point 2 lett. A of this policy statement. The following shall be authorized to access the data, in their position as persons in charge appointed by Tennis Photographer Pty Ltd, and they shall only process the data to the extent and in such a manner necessary to fulfilling the stated purposes: envelope filling and mailing staff also external to the Company; marketing staff and website management staff also external to the Company; IT technicians also external to the Company, that can also carry out tasks of system administrators being appointed as such in this case; IT staff that can also carry out tasks of system administrators being appointed as such in this case; external relations officers, also external to the Company; legal office staff; freelancers and consultants/collaborators, also external to the Company working under the direct authority of the Company, such as legal consultants and IT technicians. The following shall be authorized to access the data, in their position as data processors appointed by Tennis Photographer Pty Ltd, and in their position as data processors shall only process the data to the extent and in such a manner necessary to fulfilling the stated purposes: data processors such as the data processor under point 7 of the present policy statement, and companies performing activities instrumental to those of Tennis Photographer Pty Ltd, such as, for example, marketing, shipping, call centers, public relations, management of information systems, and website management. External Data Processors are authorized to process data directly or through employees/collaborators appointed by Tennis Photographer Pty Ltd who are undertaking the activities that said external subjects are undertaking on behalf of Tennis Photographer Pty Ltd, along with management of their information systems should they host Tennis Photographer Pty Ltd data.
  4. Provision.
    1. The provision of data indicated as mandatory in the form and requested for the purposes set out under point 2 lett. A of the present policy statement is optional for the purposes set out under point 2 lett. A of the present policy statement; nevertheless, it is indispensable for website registration and for accessing the website's services. The provision of data indicated as optional is optional, and failure to provide said data shall not result in any prejudice to the possibility of registering with the website and accessing the services contained therein (said data can only be used for better identifying those who register). It is evident that failure to consent to data processing for the purposes set out under point 2 lett. A of the present policy statement shall result in failure to register with the website and failure to access the services contained therein.
    2. The provision of data (personal data, address, and other data requested in case of controversies or to exert one's rights pursuant to art. 7 of Legislative Decree 196/03 ) for the purposes set out under point 2 lett. B of the present policy statement is necessary, and failure to do so shall result in failure to register.
  5. The Company will conserve and use the data for a period appropriate to the purposes for which they are used and compliant with the relevant legal requirements.
  6. The Data Controller is the Company Tennis Photographer Pty Ltd, author of this statement, email raygiubilo@gmail.com .
  7. The Data Processor whom you can contact for all matters concerning data processing, in particular in order to exert your rights pursuant to art. 7 of D.Lgs. 196/03 in accordance with the procedures and timeframes set by law is Tennis Photographer Pty Ltd, whom you can contact for this purpose at Tennis Photographer Pty Ltd's offices (communications and requests made in writing must be addressed to 'the Data Processor', with 'privacy' in the subject line). Any information and requests (including those pursuant to art. 7 of Legislative Decree 196/03) regarding data processing can also be made to raygiubilo@gmail.com by including the subject line 'request for privacy information to the attention of the Personal Data Processor'.
  8. Should you insert contact information for the company/agency/body for which you work, you shall assume the obligation and responsibility of obtaining authorization to insert the data from said company/agency/body and additionally you shall assume the obligation and responsibility of informing the company/agency/body for which you work of the full content of this policy statement, which thus also applies to the data of the company/agency/body for which you work.
  9. You may at any time exert your rights pursuant to art. 7 of D.Lgs. 196/03 in accordance with the procedures and timeframes set by law, which we summarize below:
    1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
    2. A data subject shall have the right to be informed
      1. of the source of the personal data;
      2. of the purposes and methods of the processing;
      3. of the logic applied to the processing, if the latter is carried out with the help of electronic means;
      4. of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
      5. of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.
    3. A data subject shall have the right to obtain
      1. updating, rectification or, where interested therein, integration of the data;
      2. erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
      3. certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
    4. A data subject shall have the right to object, in whole or in part,
      1. on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
      2. to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.