Statement on the Processing of Personal Data

(pursuant to Article 13 of Legislative Decree 196/2003)

As Data Controller of Personal Data, in accordance with Italian Legislative Decree no. 196 of 30 June 2003 “Code on the Protection of Personal Data” (hereinafter “Privacy Code”), Ober Alp S.p.A., promoter, pursuant to DPR (Decree of the President of the Italian Republic) n. 430/2001, of the competition “Get Vertical” (“Competition”), confirms that your personal data will be processed in accordance with the Privacy Code, which contains certain requirements regarding the processing of personal data, including ensuring that any processing of personal data is accurate, lawful and transparent. Your data will be processed in accordance with the Privacy Code and any confidentiality obligations as well as in compliance with your rights as a data subject.

1. Purposes of processing

The personal data collected (henceforth referred to as Personal Data) will be processed for the following reasons:

a) Compliance with national laws and regulations as well as European Union Law, in particular DPR n. 430/2001 regarding competitions.

Providing Personal Data for this purpose is mandatory and refusal to provide or providing incorrect or inaccurate Personal Data entails the impossibility of the data subject to take part in the competition. The corresponding processing does not require consent from the data subject

b) Enforcement and implementation of contractual obligations, respectively enforcing and implementing the regulation for the competition as well as compliance with specific requests of the data subject and management of the relationship with the data subject. Personal Data will be used by the Controller to verify the identity of the data subject (also through verification of the e-mail address), in order to avoid fraud or abuse, as well as to contact the data subject for reasons related to the competition (e.g. managing the participation in the competition, notifying the data subject of possible winnings and managing the assignment and delivery of prizes; contacting the data subject in order to obtain further information – like a copy of his/her ID card – which the notary or the functionary of the chamber of commerce responsible for competitions may request to verify the data subject’s identity to prevent fraud or abuse);

Providing Personal Data for this purpose is not mandatory, but refusal to provide or providing incorrect or inaccurate Personal Data may entail the impossibility to take part in the competition. The corresponding processing does not require consent of the data subject.

c) Communication of data for administrative-accounting purposes, respectively to carry out organizational, administrative, financial and accounting activities as well as functional operations related to competitions, pursuant to art. 24, para. 1, letter i-ter Privacy Code

Providing Personal Data for this purpose is not mandatory, but refusal to provide or providing incorrect or inaccurate Personal Data may entail the impossibility to take part in the competition. The corresponding processing does not require consent of the data subject.

d) Personal Data will be furthermore, with the consent of the data subject, processed for the following purpose:

i) Marketing, commercial and promotional activities, in particular

- Market Surveys

- Measurement of Customer Satisfaction

- Marketing and promotional activities related to events/advertising and promotional campaigns directed at informing the data subject of promotional sale initiatives through use of letters, phone, automated call systems, e-mails, fax, SMS, MMS and other types of messages;

- Invitation to events

ii) Subscription to the newsletter;


e) Creation of a personal account of the data subject on the website www.salewa.com. The data subject will receive an automatically generated e-mail containing the login details for the activation of his account.

The provision of Personal Data for this purpose is not mandatory and the corresponding processing necessitates of the data subject’s consent.

2. Method of processing

Personal Data are processed with the aid of manual, informatic and telematic instruments, with a view to the above indicated purposes, and, in any case, in ways which guarantee the security and confidentiality of the data subject’s Personal Data.

3. Disclosure

Notwithstanding disclosure in compliance with legal requirements, Personal Data shall be disclosed or transferred exclusively to parties competent to provide the services necessary for a proper management of the relationship with the data subject, respectively participant in the competition, and in ways guaranteeing the protection of the rights of the data subject.

Natural or legal persons included on the list indicated in article 5, in their capacity as processing officers (“responsabili del trattamento” for the purposes of the Privacy Code), or the employees of the administrative and commercial offices of the Controller, in their capacity as processors („incaricati“ for the purposes of the Privacy Code) and in relation to their assigned tasks, may acquire knowledge of Personal Data.

The personal data provided may be disclosed to third parties solely for the purposes indicated in article 1, letters a), b) and c), and specifically to:

  • forwarding agents, carriers, delivery services, mailing providers, logistics firms;
  • consultants and professionals, in one-off disclosures or as part of a course of dealing;
  • Italian and other group companies of the Ober Alp Group.

The personal data provided shall not be disseminated except in cases required by law.

Only for the purposes indicated in article 1, letter d)i) and ii), Personal Data will be disclosed, with the consent of the data subject, to Trentino Marketing, Alta Badia, San Martino di Castrozza and Gore-tex, which will process the Personal Data as autonomous controllers (jointly referred to as Partner). Personal Data may also be disclosed to legal entities and persons acting on behalf of Partners, which will use Personal Data exclusively for the purposes indicated in this paragraph. The complete statement on the processing of personal data carried out by Partners is available online on their respective websites.

4. Duration of processing

Personal Data will be processed for the duration of the contractual relation established between the Processor and the data subject, respectively for the duration of the competition, and thereafter where necessary in order to comply with legal requirements.

For the purpose indicated in article 1, letters d) and e), Personal Data will be processed until withdrawal of the data subject’s consent.

5. Controller

The Controller for the processing of personal data, according to Italian law, is Ober Alp S.p.A. with offices at Via Waltraud Gebert Deeg, 39100 Bolzano (BZ), VAT number 00122250210, registered at the Company Register of Bolzano at n. 71005, tel. 0471.242.900, e-mail: privacy@oberalp.

The data subject may contact the Controller at the above indicated seat of the company to exercise his/her rights under art. 7 legislative decree n. 196/2003, reproduced hereunder.

A list of the processing officers nominated by the Controller, whom Personal Data will be communicated to, is available at the headquarters of the Controller.

6. Rights of the data subject

The data subject has the right to require the Data Controller to stop processing or to update and correct the personal data that concern him/her and can generally exercise all the rights set forth in Article 7 of the Privacy Code, as more fully explained below:

6.1 Right to access personal data and other rights (Article 7 of Legislative Decree no. 196 of 30 June 2003)

1. Data subjects have the right to obtain confirmation as to whether or not personal data concerning them exist and are being processed, even if the data have not yet been recorded. The data subject is entitled to receive details of such data in intelligible form.

2. Data subjects have the right to be told:

  1. the source of the personal data;
  2. the purposes and modes of processing;
  3. the logic applied when the data is processed automatically by technical means;
  4. the identity of the data controller, data processing officers and any official representatives;
  5. the parties or categories of parties to whom the personal data may be disclosed or which may gain knowledge of them as designated representatives of the State, processing officers, or processors.

3. Data subjects have the right to:

  1. have their data updated, corrected, or if applicable, supplemented;
  2. the deletion, anonymisation, or blocking of data processed in violation of law, including those that need not be retained for the purposes for which the data were collected or subsequently processed;
  3. confirmation that the parties to whom the data have been transferred or disclosed have been notified of the operations specified in points a) and b), and the details thereof, except in circumstances where notification proves impossible or would be disproportionate to the right being protected.

4. Data subjects have the right to oppose, wholly or in part:

  1. for legitimate reasons the collection of their personal data;
  2. the processing of their personal data for marketing purposes.

This policy statement was last updated on 21.10.2016 and applies of your use of the website today but may be updated from time to time, for organizational reasons or because the law changes: we suggest you visit our websites regularly to see the latest version.