Information about privacy for customers – secretariat

(Art. 13 D.Lgs. 30 giugno 2003 n° 196)

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In accordance with article 13, Legislative Decree 30 June 2003 no. 196 (personal data protection code), Casino de la Vallée S.p.A., in its role as Data Controller and temporary legal representative will inform the customers how and for what reason the personal data will be used, its sphere of communication and diffusion and the rights of all those concerned according to the law.

a) The data collected during the validity period of the Service Contract offered by our company, which is finalised on emission of the Membership Card or daily Entry Card (provided at the request of the customer), will be subject to data processing to check access to the Casino, to ensure that the economic obligations of the company are respected, to check that the game proceeds correctly, for the security of the venues, people and patrimony, for the fulfilment of the obligations in the General Conditions of the Contract – found on the back of the daily Entry Card or available on the relative notices inside the casino – and the fulfilment of all other legal requirements, for promotional reasons and to ensure that all services offered to the customers are of good quality.

For reasons of safety, to reduce waiting times as much as possible on entry and to offer high-quality reception services, on 22 April 2009 the Company Management started to collect and record photographic images of customers. Consent for the conservation of the pictures will be asked for verbally; if given, the operator will fill in the relative section of the privacy consent for the conservation of photographic images for a period of two years after the last visit, if not, the conservation period will not exceed seven days, in accordance with the Guarantor’s directive on the subject of video surveillance.
The collection of data using video cameras for the safety of both people and patrimony is indicated on notices. Specific information is available regarding the processing of it.

Personal information recorded with the audio-visual system is regulated by the trade union agreement, in accordance with and due to article 4 of law 20.05.1970, no. 300, and is used to ensure the correctness of the game and the safety of the company patrimony.

b) In order to place customers at the centre of its business and offer them complete and high-quality services, Casino de la Vallée S.p.A. has implemented a system of Customer Relationship Management (CRM), which includes further processing of members’ personal details, according to the following system:
adhesion to the CRM system by the customer is optional, as is the communication of the required personal details, but refusing to do so will prevent Casino de la Vallée S.p.A. from providing the services intended for members.

After adhering to the system, the customer can withdraw from the project with a written request addressed to the person in the company who is responsible for privacy, at the following email address: generale [at] casinodelavallee [dot] it;
the processing of data will take place on paper or electronically;
application for membership of CRM requires the obligatory provision of all personal details: name, surname, place and date of birth and residency address, or alternatively a fixed or mobile telephone number or an email address. The following personal details will also be requested but they are given if the customer chooses to do so: profession, favourite games in our Casino, favourite hobbies (theatre, sport, music), preferences with regard to prizes which he/she’d like to receive with the points accumulated, preferences regarding hospitality, if he/she smokes.

If you give us your written consent (form available on the company intranet), the personal data can be used to send text messages, emails or letters to the number/address you gave on the registration form, in order to promote services offered by the Casino. The quantity of texts, emails or letters sent will be kept within reasonable limits and they can be stopped at any time simply by sending an email to the following address: generale [at] casinodelavallee [dot] it;
The following information regards the processing of the personal data of clients who use the electronic games: the data collected will be processed for the following purposes:
a) for the collection of points on the membership card when it is inserted into the relevant electronic game;
b) to take part in all future promotional activities reserved for customers who are members;
c) to receive information about events by the means indicated on the signed consent form; the use of the membership card for collecting points will lead to the points accumulated during play, the length of each session of play and the “Total Bet” being recorded in the relevant database. The “Total Bet” data shows the amount in Euros played by the customer using the membership card and includes both the amount bet by the customer as well as the amount won and put back into the game.

The processing of the abovementioned data will take place in full respect of the regulations in the Act on the subject of privacy (approved by Legislative Decree 30 June 2003, no. 196) and will permit the Casino to extract a customer profile, with the aim of improving the services provided for the best customers in terms of personalised services and promotional initiatives aimed at satisfying customers’ wishes. When the card is inserted into the card reader, the phrase “Benvenuto/a nome di battesimo del cliente – Saldo PUNTI: n° di punti (Welcome, first name, POINTS balance:xxx)”, can be seen on the display. It can be removed manually, if required (the appearance of this phrase on the display shows that it is working correctly).

This data, recorded in the dedicated database, will be processed automatically with logic strictly linked to the aforementioned purposes. The processed data will be protected by electronic security measures to avoid its loss or diffusion, including accidentally.

The Casino, for the purposes of promotional activity, can use the electronic system which manages the points accumulated, to edit the classifications during competitions or tournaments involving the electronic games. The classifications will be conserved for the time strictly necessary to award prizes and receipts to the members in such a way as to safeguard the maximum privacy of the competitors (e.g. publication of lists with only the membership number instead of the name).

The game data collected will be conserved for statistics and customer marketing purposes for a maximum of two years. The paper documents confirming that the customer has collected the prize must be conserved for administrative and fiscal reasons according to law;

Your data will be known only to the employees of our company who have the job of processing it and who have been given instructions to ensure full respect of the legal regulations on the matter.

The provision of the data indicated in a) is optional, but refusing to do so prevents a contractual agreement from being established with Casino de la Vallée S.p.A., and therefore access to the gaming room. The provision of the data indicated in b) is also optional, but refusing to provide it will prevent membership status from being established.

The data will not be communicated to third parties and will be kept for the time period established by law and by the measures of the Guarantor. The same data can be passed to the Surveillance and Inspection Authority under the terms of the law.
The request for access to the Casino using a Membership Card and the subsequent collection of the related Daily Entry Card, as specified in the General Conditions of Contract, and without any further indications regarding the treatment stated above, is a sign of the customer’s consent on the matter, except in the case of communication with the customer, which requires written consent.

One can exercise one’s rights at any time, by contacting the Controller or the person responsible for privacy, in accordance with articles 7, 8, 9 and 10 of Legislative Decree 30 June 2003, no. 196; specifically, one can ask about the existence of data processing which may relate to them, have that data immediately communicated to them in an intelligible form, ask about its origin, its annulment or transformation into an anonymous form or a freeze on data processed in violation of the law; the updating, amending, or integration of the data; confirmation that the people to whom the data was communicated were informed of the aforementioned activities, excluding when such fulfilment is impossible or involves a large effort disproportionate to the rights being safeguarded; to oppose for legitimate reasons, totally or in part, the processing of personal data even if it is pertinent to the reasons for data collection.

The data controller is Casino de la Vallée S.p.A. with its headquarters in Saint-Vincent (AO), Via Italo Mus Tel. 0166/5221.

The person responsible for privacy is Dr. Stefano Rizzo, who can be contacted via fax (0166 522477) or via email at generale [at] casinodelavallee [dot] it.

Any request for access to information must be made in writing, and must be accompanied by a copy of a valid identity document of the interested party.

Any further information about our company can be found on our website at www.casinodelavallee.it.

Casino de la Vallée S.p.A., 14 june 2010