Ex. Art. 13 LEGISLATIVE DECREE No. 196 of 30 June 2003

1. Data Controllers and Data Processors

The Data Controller of the users personal details is I.C.M. S.r.l., VAT number and tax code 01474700182, with registered office in Santa Maria della Versa (Pavia), Via Francesco Crispi no. 200, 27047,, (hereinafter I.C.M.).

The Data Processor is Paola Polloni, who may be contacted at

To obtain an up-to-date list of the data processors, requests should be sent by email to

2. Purpose of data processing 

Personal details provided voluntarily may be acquired for the purposes of:

a) Allowing products to be purchased via e-commerce;

b) Allowing the sending of advertising and commercial correspondence, by printed and traditional means, or using digital or automated tools.

3. Method of data processing

The data subjects details will be processed in print and using automated digital and online tools and data processing and organisation systems related to the above purposes, and in a way that guarantees the security and confidentiality of all data and correspondence. Personal details may also be processed in print. 

4. Mandatory or optional provision of data

In relation to the purposes indicated in paragraph 2a), the provision of all other personal data is optional and entirely at the discretion of the data subject. 

If the data subject does not provide personal details for those purposes, there will be no prejudicial consequences, except that it will be impossible to conclude the online contract for the sale of goods, to which this privacy policy statement refers.

With regard to the processing of personal details as indicated in paragraph 2b), the consent of the data subject is optional, however if consent is not given, no such promotional or commercial correspondence can be sent.

5. Area of disclosure

The employees of I.C.M. appointed as data recipients may be provided with the usersdata, for the purposes indicated above.

Paola Polloni, as the data processor, may also acquire the data.

The data may be communicated inside or outside the European Union. 

The userspersonal details will not be circulated.

6. Cookies policy

The data subject is required to read the cookies policy, which is available at [insert  link].

7. Rights of the data subject

In accordance with Article 7 of Italian legislative decree 196/03 the user, as the data subject, may obtain confirmation of the existence of his/her personal details even if not yet registered, and their communication in an intelligible form. 

The data subject may obtain information about:

the origin of the data;

the purposes of processing;

the data processing system;

details identifying the data controller and data processors;

the parties to whom the data may be disclosed.

The data subject may also obtain:

the updating, amendment or integration of data collected;

the deletion, transformation into an anonymous form or blocking of data processed in violation of the law, including any data that no longer needs to be

retained in relation to the purposes for which it was collected or subsequently processed;

confirmation that the operations referred to in the above paragraphs have been brought to the attention of the persons to whom the data was disclosed or

circulated, except where this is impossible or entails the use of resources that is manifestly disproportionate to the right being protected.

The data subject may also object, wholly or partially:

for legitimate reasons, to the processing of his or her personal data, even if relevant to the purpose of collection;

to the processing of personal data regarding him or her, for the purposes of sending publicity material.

In such a case, the data subject may exercise all or part of his or her right to object to the processing of his/her personal data in accordance with Art. 7(4)(B) of the Code or may object, for example, only to the sending of promotional communications using printed, digital and/or automated means.

Requests made under Art. 7 of legislative decree 196/03 must be sent directly to the data controller, I.C.M., at the following email address: Alternatively, rights may be exercised by sending a communication by registered post with return receipt to the address indicated in paragraph 1) hereof.


This statement may be amended in the future. Previous privacy policy statements are available from

Users are invited to consult this page periodically.

Milan, 14 March 2017