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Subject: Information statement on the processing of your personal data, issued pursuant to Art. 13 of the Legislative Decree 196/2003, which refers applicable legislation on the protection of personal data, and a request for your permission for the processing of certain data.

1. The Italian “Data Protection Code” (Legislative Decree 196/2003) introduced legislation pertaining to the processing of personal data. In keeping with the provisions of said code, the processing of personal data by our organisation is effected in a manner that is consistent with the principles of good faith, lawfulness and transparency, and in a manner designed to protect the privacy and the rights of the individuals to which said data refer.

2. Within this context, we issue this policy statement as required by Art. 13 of Legislative Decree 196/2003 and we ask that you express your permission to the processing of the data, to be defined hereafter, for the following purposes: a) processing your request for information and/or booking with a view to providing you with relative instructions

3. In order that the above purposes be achieved, it is necessary that you supply the required data. Failure to provide said data in full and accurately may make it impossible to provide you with the requested services.

4. In the event that you provide your authorisation, and until such a time as this authorisation is withdrawn, your personal data will be processed for the following additional purposes: a) processing and carrying out statistical and market research; b) issuing information, marketing and commercial materials, via physical post, electronic mail and/or telephonic channels; c) effecting direct and indirect sales and employment-related activities; d) effecting interactive commercial communications; e) gathering customer satisfaction data relative to the quality of services provided (where necessary through third party providers). You are entitled to withdraw your authorisation for the processing of your data for these purposes at any moment, and may do so by contacting the data controller indicated in section 10. You are not obliged to provide authorisation for the processing of your data for the purposes listed in this section 4. In the event you refuse to grant authorisation, your data will be processed solely for the purposes indicated in section 2.

5. As far as customers and potential customers are concerned, the personal data processed generally fall into certain common categories, essentially consisting of basic identity data. We declare that, in the event that you should indicate, in any field that is not accompanied by specific directions, data which would be classed, pursuant to Art. 4(d) of the Legislative Decree 196/2003, as sensitive data and which would therefore qualify for particular protections, such data will be processed by us within the terms provided by the Data Protection Code. We note that, in general terms, Art. 4(d) of Legislative Decree 196/2003 defines as sensitive data, such personal data as allows “the disclosure of racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organisations of a religious, philosophical, political or trade-unionist character, as well as personal data disclosing health and sex life.”

6. Data collected shall be processed using paper-based and/or electronic instruments, and in any case in a manner that conforms to the relevant applicable legislation.

7. We specifically undertake, as an organisation, to put in place all necessary organisational, physical and logical measures as are required to guarantee the safety of your data, with particular reference to the provisions of Appendix B of Legislative Decree 196/2003 “TECHNICAL SPECIFICATIONS CONCERNING MINIMUM SECURITY MEASURES”.

8 In addition to the processing of your data by direct employees of the Company, in certain cases your data may be processed by third parties which our organisation entrusts with the performance (in full or in part) of certain activities required for the supply of the services mentioned above. These third parties may be based in Italy or abroad. In such cases, these parties shall be considered as independent data controllers, or else shall be designated as data supervisors or as persons responsible for data processing. In the interests of ensuring the privacy and security of the data, all data supervisors and persons responsible for data processing thus identified shall receive adequate operational instructions, with particular reference to the implementation of the minimum security measures. The third parties referred to above essentially fall into the following categories: debt recovery companies, companies engaged in processing traffic data for the purposes of billing, companies engaged in printing and issuing invoices to customers, consultancy companies, debt purchasing companies, agents and salespersons, franchise holders, suppliers of technological services, content providers. We here include an extract from Art. 7 of Legislative Decree 196/2003 as a reminder to you that you may exercise the following rights in our regard: a) the right to obtain confirmation as to whether or not personal data concerning you exist, regardless of their being already recorded, and to obtain communication of such data in intelligible form; b) the right to be informed of the source of the personal data and of the purposes and methods of the processing; c) the right to be informed of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) the right to be informed of the identification data concerning the data controller and data processors; e) the right to be informed of the entities or categories of entity to which the personal data may be communicated or which may get to know said data in their capacity as designated representative(s) in the State’s territory, as data processor(s) or as person(s) in charge of the processing; f) the right to have the data updated, rectified or, where it interests you, integrated; g) the right to obtain the erasure, anonymisation or blocking of data whose retention is no longer necessary for the purposes for which they were originally collected or subsequently processed; i) the right to obtain certification to the effect that the operations of updating, rectification, integration, deletion, anonymisation, or blocking have been notified, as also related to their contents, to any entities to which the data have been communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; j) the right to object, in whole or in part, on legitimate grounds, to the processing of personal data concerning you, even though said processing is relevant to the purpose of the collection; k) the right to object, in whole or in part, to the processing of personal data concerning you, where said processing is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. To exercise these rights, please contact the data controller. The person responsible for the processing in question is {resp}, {resp_address}.


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