POLICY FOR DATA SUBJECTS REQUESTING INFORMATION VIA THE CONTACT FORM

ON THE PROTECTION OF PERSONAL DATA PURSUANT TO ART. 13 OF LGS. D. NO. 196 OF 30.06.2003

In compliance with the provisions of art. 13 of Lgs.D. of 30 June 2003, Altaeco S.p.a., with registered office in Via Giovanni Pascoli 4/6, 20010 Vittuone, Milan (MI), as data controller, hereby informs the data subjects about the processing purposes and methods of the personal data collected, its scope of disclosure and dissemination, as well as the nature of its provision.

PERSONAL DATA SUBJECT TO PROCESSING AND PROCESSING PURPOSE

The personal, identification (name, surname, email and possible telephone number, etc.) and IT data collected from data subjects and spontaneously communicated by the same through the section of the corporate web site called “Request Information”, subject to processing, are used directly by the Data Controller for the proper management of the request made by the data subject and, if necessary, to provide feedback to the same, as well as, with the appropriate consent, for marketing and commercial communication activities also through telephone, text message, MMS, paper and electronic mail.

DATA PROCESSING METHODS

Data is processed using IT and electronic means by specially assigned in-house individuals. The data is stored in IT and electronic files, with full assurance of the implementation of the minimum security measures required by law.

Any communications of marketing or promotional nature related to the activities and the services of the Data Controller will be delivered via automatic contact methods or using traditional channels (e.g. snail mail and/or calls with an operator) in compliance with art. 130 of Lgs. D. 196/2003.

DISCLOSURE AND DISSEMINATION OF DATA

The data collected will not be disseminated, sold or exchanged with third parties without the express consent of the data subject, except for any disclosures to authorised third parties - committed to confidentiality or in the case of appointed data processors pursuant to art. 29 of Lgs.D. no. 196/2003 - (such as IT support companies) where necessary for the purposes of this policy. The data may be disclosed to the competent authorities in accordance with the law.

In order to better fulfil the marketing purposes, in addition to the above-mentioned parties, the data may also be disclosed to marketing service providers; also processing by such third parties must be carried out according to correctness and in compliance with the provisions of current legislation, subject to prior authorisation by the Data Controller.

RETENTION TIMES

The data will be stored in compliance with the law as also specified by the Authority for the Protection of Personal Data, and in any case subject to objection to processing by the data subject. Objection to processing may be made by the data subject using any of the transmission methods.

In compliance with the provisions of the above mentioned provision, data processed in connection with promotional and/or commercial communications will be retained for a period not exceeding 2 years.

RIGHTS OF THE DATA SUBJECT

The data subject may exercise his/her rights as provided for by articles 7, 8, 9 and 10 of Lgs. D. no. 196 by contacting the data controller. In particular, according to art. 7, the data subject has the right to obtain confirmation of the existence or otherwise of personal data related to him/her, including data that has not yet been recorded and to obtain that data in a clearly understandable form. The data subject has the right to obtain information regarding: a) the source of any personal data; b) the purposes and methods of processing; c) the logic applied in the event of electronic processing; d) identification details relating to the Data Controller, the data processors and the representative designated in compliance with article 5, paragraph 2; e) the subjects and categories of subjects to whom the personal data may be communicated or who may become acquainted with said data, in their capacity as data processors, persons in charge of data processing and appointed representatives in Italy. The data subject has the right to obtain: a) that said data is updated, amended and, if in the interest of the data subject, completed; b) that any data processed in violation of the law be cancelled, made anonymous or blocked, including any information that does not need to be held for the purposes for which it was collected or subsequently processed; c) receive confirmation that the operations in a) and b) have been made known, also as regards their content, to the parties to whom the data has been communicated or disclosed, except in cases where this is impossible or requires the use of means that are clearly disproportionate with the protected right. The data subject has the right to oppose, either in full or in part a), for legitimate reasons, to the processing of personal data relating to him/her even if relevant to the purposes it was collected for; b) to the processing of personal data relating to him/her for the purposes of delivering advertising material, direct sales, market surveys or for marketing communications.

DATA CONTROLLER, DATA PROCESSORS AND PRIVACY COMMUNICATION

The Data Controller is Altaeco S.p.A., with registered office in Via G. Pascoli 4/6, 20010 Vittuone, Milan (MI).

The updated list of data processors is available at the company's registered office. For any communication regarding articles 7 et seq of Lgs.D. no. 196/2003, as amended and supplemented, the Data Controller has provided the e-mail address privacy@altaeco.com

NATURE OF PROVISION

The provision of data is optional; however, any refusal to reply will make it impossible for the data controller to carry out the requests made as well as to send commercial communications.

CONSENT

It is pointed out that consent is considered freely granted by checking the box "I consent".

pursuant to art. 23 of Lgs.D. 196/2003, consent to the processing of personal data is necessary with regard to the purpose of marketing and sending commercial communications to be carried out as provided for in the section "processing purpose”. It is pointed out that, in compliance with Measure 330 of 04 July 2013 of the Authority for the Protection of Personal Data, consent given for automated methods also extends to traditional ones. This without prejudice to the rights already expressed in this policy in the paragraph "rights of the data subject".