Privacy Policy

Dear customer,
In accordance with the Italian law for the defence of personal privacy (article 13 D.Lgsl.196/2003) Flywithus Italia Ltd. would like to inform you about the use of your personal data, as well as about your rights:

1. The personal data collected by Flywithus Italia Ltd. after your agreement, including data related to the computer traffic, will be processed for the following objects:
   1. fulfilment of the requested services (computer connection and every other requested service);
   2. maintenance and technical assistance for products or services;
   3. management of possible claims and/or cases
   4. prevention/ repression of frauds or any illegal activity.

With regard to the prevention of possible frauds, Flywithus Italia Ltd. will make use of a data bank.

Customers’ personal data will be collected in this data bank, in order to check possible arrearages, insolvency, therefore every possible information will be used in order to prevent frauds.

These data will be processed by their co-owners, wit the same purposes, also per PC. All data recorded in the data bank will not be communicated to third persons; however they can be used by persons appointed by partner societies (customer care, legal and credit recovery societies) to fulfil these duties.

In accordance with the Italian law for the defence of personal privacy (article 13 D.Lgsl.196/2003) and following alterations, all data concerning PC traffic (log files) are kept for six (6) months only in order to invoice or to ask for payment (in case of fee services) as provided by the article 123 of this law 196/03. The period begins with the invoice’s date of expiry .

These data have to be given in order to complete the above mentioned services, without your data it will be impossible to provide you with the requested services.

2. Subject to your clear assent and until its repeal, your data will be processed directly or through third persons per PC or by other means (by phone, email, automatic answering systems, fax) in order to fulfil the above mentioned aims, as well as for different purposes like:
   
   
   1. promotions for Flywithus Italia Srl services and/or products;
      
      
   2. delivery (per sms or e-mail) of adv. material, and commercial information.
      
   3. direct or indirect sales in different ways
      
      
   4. interactive commercial communications
      
      
   5. Customer satisfaction’s surveys (also through third persons)
      
      
   6. Advertising and promotion for third companies
      
   7. marketing researches

The approval to the above mentioned secondary aims (point 2) is not compulsory; if you do not agree with it, Flywithus Italia Ltd will process your data only for the purposes mentioned at point 1.

The processing of your data (see points 1 and 2) will be fulfilled using paper documents and PC, always in conformity with the laws in force.

At Flywithus Italia Ltd your personal data will be processed by our staff working for these offices: customer care, commercial and marketing, invoicing and technology. Our employees work under the direct responsibility of the person in charge with the data processing, and they all had clear operating instructions.

Data processing may also be made by third persons in Italy and abroad, who have been clearly authorized by Flywithus Italia Ltd. In this case these persons will be fully responsible for their work, because they have been charged with this data processing. These persons will be well trained and particularly informed, with regard to confidentiality, personal identity and the right to personal data protection. These persons mainly belong to these categories: credit recovery societies, invoice data processing societies, societies appointed to the print and delivery of invoices to customers, consulting firms, telemarketing and call centre societies, agents and franchisee procurers.

Co-holder of your data processing: Flywithus Italia Ltd, registred office in via Bartocci, 12 - 05100 Terni

Responsible person inside Flywithus Italia Ltd is Mr. Nuh Atilla Duvarci, resident in via Bartocci, 12 - 05100 Terni; Flywithus Italia Ltd informs you about the following: trusted societies can be used in order to supply some technical services to the customer. These society are direct collaborators and they process your personal data as fully responsible.

With regard to your personal data processing, you can always exercise your rights, in conformity with the section of the law (which is fully quoted here below) writing to: Flywithus Italia S.r.l. in via Bartocci, 12 - 05100 Terni or per e-mail: privacy@flypgs.it

Section 7 - (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.