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Personal Data Protection Code

Spea Ingegneria Europea S.p.A. informs people interested in visiting its Istitutional Web Site - www.spea-autostrade.it - that we take care of the protection and handling of personal data according to D.Lgs n. 196/2003.

The access to the web site does not require the communication of one's own Personal Data, except when people (as defined in paragraph I ) art. 4 of the Personal Data Protection Code, as natural person, juridical person, Institution and Association to which personal data are referred ) want to submit their application form by sending their CVs selecting /clicking on the section "Work with us", or if they want to have a business contact with Spea Ingegneria Europea S.p.A. (i.e.: as suppliers) sending their Personal Data.

In both cases the person gives his agreement and authorizes directly the Company, Spea Ingegneria Europea S.p.A., to the personal data processing referred to the aims specified above.

Spea Ingegneria Europea S.p.A. will carry out the personal data treatment (as reported in art. 4 letter a of Personal Data Protection Code) in conformity with the discipline fixed in the Code referring to personal data protection, linking to the specific purposes for which they have been communicated in accordance with correctness, legality, transparency and privacy protection.

IPersonal Data will be collected and treated through papers and electronic system, they will be stored for a maximum period of 3 years, then they will be deleted. They could be communicated to the Companies that belong to Autostrade per l'Italia S.p.A..

The one who gives his or her personal data for the purposes written above, can access his/her own data according to art.7 of the D.Lgs. n. 196/2003.

The personal data processing holder is the Spea Ingegneria Europea CEO. He also appoints as Executive Managers of the process, managed by single Department as ordered by art.29 of the Code, the following roles.

Executive Managers who are in charge of each Dept. for these purposes are:

	"Direzione Operativa Progettazione ed Esecuzione Lavori ASPI" Executive Manager
	"Direzione Operativa Sviluppo Infrastrutture" Executive Manager
	"Funzione Servizi per l'Esercizio" Executive Manager
	"Amministrazione" Executive Manager
	"Risorse Umane e Affari Generali" Executive Manager
	"Approvvigionamenti e Servizi Generali" Executive Manager
	"Sistemi Informativi" Executive Manager
	"Legale, Societario e Assicurazioni" Executive Manager
	"Sviluppo" Executive Manager

For any further information, please, write to Spea Ingegneria Europea S.p.A., Via G. Vida 11, 20127 Milan.

References

Part 1 General Provisions - Title I - Section 4: Definitions

a) "processing" means that any operation, or set of operations, are carried out with or without the help of electronic or automated means, concerning the collection, recording, organisation, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasure and destruction of data, whether the data are contained or not in a data bank;

Part 1 General Provisions - Title II - Section 7: Right to access Personal Data and Other Rights

1. A data subject shall have the right to obtain confirmation 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 about
a) the source of the personal data;
b) the purposes and methods of the processing;
c) the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) the identification data concerning data controller, data processors and the representative designated as per Section 5 (2);
e) the institutions or categories of institutionsto 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
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been unlawfully processed, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations a) and b) have been notified, as also related to their contents, to the institutions 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,
a) pon legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) 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.

Part 1 General Provisions - Title IV - Section 29: Data Processor

1. The data processor may be designated by the data controller on an optional basis.

2. Where designated, the data processor shall be selected among entities that can ensure, on account of their experience, capabilities and reliability, thorough compliance with the provisions in force applying to processing as also related to security matters.

3. If necessary on account of organizational requirements, several entities may be designated as data processors also by subdividing the relevant tasks.

4. The tasks committed to the data processor shall be detailed in writing by the data controller.

5. The data processor shall abide by the instructions given by the data controller in carrying out the processing. The data controller shall supervise over thorough compliance with both mentioned instructions and the provisions referred to in paragraph 2, also by means of regular controls.