Privacy Policy

NOTICE ON THE USE OF PERSONAL DATA

Notice on the use of personal data under art. 13 and 14 EU Regulation 2016/679 (hereafter “GDPR”)

Thank you for choosing the Olimpia Splendid App.

The privacy and security of our customers' personal data is of utmost importance to us. That is why we constantly strive to use data accurately, lawfully and transparently in accordance with the rights of the data subject.

With this notice, we intend to outline how and why we collect, store, share and use our customers' personal data, as well as set out the choices and rights they may freely exercise.

1.WHAT PERSONAL DATA DO WE PROCESS?

Our company processes the personal data provided by the customer at the time of registration and during App use:

·version and type of operating system on the mobile device

·device serial number

·geolocalization data

·IP address

·e-mail address

Our company collects anonymous information associated with App download and use solely for the purpose of collecting statistical data on the number of users that have downloaded or are actively using the App.

In any event, we do not use the data collected for customer profiling, to offer products or for other commercial purposes.

Please be informed, however, that the third-party IT systems and software procedures required to run the App (Apple Store, Google Play) may collect, in the provision of their services, some user data the transmission of which is implicit in the use of the Internet communication protocols, smartphones and other devices used. Our company is not involved in these processes, which are carried out autonomously and exclusively by the respective Data Controllers, nor can it be held liable for them. You are therefore invited to also read the privacy notices published on these platforms before using the service. Simply uninstalling the App from your mobile device will stop any further data being collected by our company with immediate effect.

2.REASON AND LAWFUL BASIS FOR PROCESSING DATA

The aforementioned personal data will be processed solely:

a.For the purposes strictly connected to downloading and activating the App. In particular, to download the App, and solely for reasons associated with providing the service, the user must allow the App to access certain mobile device resources, such as the device's geolocalization data.

b.As a company, we must comply with the legal obligations and provisions, such as the obligation to store data in accordance with commercial and tax laws. Therefore, we process the customer's personal data in accordance with the legal obligations, while at the same ensuring that the personal data of any individual customer is divulged solely in the presence of a legal obligation to the public and judicial authorities.

c.To pursue a legitimate interest on behalf of the Data Controllers (e.g. defence in court of the Data Controller's rights).

The lawful basis for processing is the consent given by the data subject under point a), the fulfilment of the legal obligations under point b) and the legitimate interest of the data controller under point c).

3.HOW WE PROCESS YOUR DATA

The Customer's data will be processed mainly, though not exclusively, with the use of electronic or computer tools in constant and essential compliance with the security measures laid down in art. 32 of GDPR and exclusively for the aforementioned purposes. In addition, data will be managed and protected at sites with controlled access. Personal data is processed as laid down in art. 4(2) of GDPR, namely: data collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, locking, communication, erasure and destruction. We limit access to customer data solely to those needing to use it for legitimate and relevant purposes. In any case, such data will be collected and processed without being subject to profiling.

4.HOW LONG DO WE STORE YOUR PERSONAL DATA?

Data will be collected directly from the customer, from the Olimpia Splendid product or from its mobile device through our App. Where the law does not impose specific storage requirements, we store the customer's personal data for the term indicated in the App subscription contract plus a further period of 10 years and six months or 15 years and six months from the end of the contract (depending on the terms of limitation of rights in relation to which we may need to defend ourselves or on the legal requirement to store data for tax purposes), if such data is required to continue the contract between us or to carry out operations arranged/requested by the data subject or to fulfil our legitimate interest. Subsequently, data will be deleted securely and definitively or may be rendered anonymous and aggregate, i.e. with no direct or indirect reference to natural persons, and will be stored exclusively for statistical purposes.

5.PERSONAL DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA

The customer's personal data is stored on our protected servers located both in and outside the European Union. In the event of international transfers from the European Economic Area (EEA) in which the European Commission has recognised a non-EEA country an adequate level of data protection, the personal data will be transferred on this basis. You are also informed that, for the purposes associated with provision of the service provided through this App, the customer's personal data, processed by the Olimpia Splendid platform, will be processed by a data processor identified by Olimpia Splendid S.p.A. and located outside the EEA, with whom we have implemented adequate data protection measures, including the signing of standard contractual clauses approved by the European Commission. We invite the customer to contact us in reference to point 9 if he/she wishes to obtain further information or ask to view a copy of the specific safeguards applied to the export of personal data.

6.WHO DO WE SHARE YOUR PERSONAL DATA WITH?

The customer's personal data may be shared with: our organisation's employees and collaborators in their capacity as authorised/designated data processors and/or system administrators; other companies or third parties to which the role of Data Processor has been outsourced by the Data Controller. The aforementioned data may be shared and entrusted to subjects who may access the data in accordance with the law, regulations or community standards, within the limits envisaged by the same. Without the need for express consent (under art. 6(b) and (c) GDPR), the Data Controller may send the aforementioned data to Supervisory Committees, Judicial Authorities and those parties to whom communication is obligatory by law for the aforesaid purposes. These parties will process the data in their capacity as autonomous data controllers. In any case, the customer's personal data will not be shared.

7.WHAT IF YOU REFUSE TO PROVIDE YOUR PERSONAL DATA?

Providing personal data is optional but necessary in order to use the service. Refusing to provide data means the App cannot be used.

8.WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

In compliance with the current regulation (art. 15-22 GDPR), in relation to the processing of the personal data we collect, the Customer may exercise the following rights:

• access: information on personal data processing and a copy of this personal data may be obtained;

• rectification: if you feel your personal data is inaccurate, not up-to-date or incomplete, you may ask for this personal data to be corrected or completed;

• erasure: you may ask to have your personal data erased if reasons envisaged by law exist for doing so;

• restriction: you may ask to obtain restriction of data processing if reasons envisaged by law exist for doing so;

• objection: you may object to data processing carried out on the basis of our legitimate interest for reasons relating to your particular situation. You may also object to data processing carried out for the purposes of direct marketing, including any associated profiling;

• data portability: where legally possible, you may receive or obtain the direct transmission of the personal data you provided and that generated in the course of our contract to another controller (if technically possible). Data resulting from our processing and evaluations is excluded if processing is based on consent or on a contract and is carried out by automated means;

• withdrawal: you may withdraw your consent to us processing your personal data at any time.

These rights may be exercised by sending a request to the Data Controller as follows:

·by post to Olimpia Splendid S.p.A., Via Industriale 1/3 - 25060 Cellatica (BS)

·by e-mail to: privacy@olimpiasplendid.it

The Customer may withdraw consent to data processing at any time and may lodge a complaint with the personal data protection supervisory authority (Privacy Guarantor) at the following link: http://www.garanteprivacy.it, or with the European Data Protection Guarantor at the following link: http://www.edps.europa.eu.

9.Contact details of the data controller and data protection officer (DPO)

The data controller is:

Olimpia Splendid S.p.A. based in Via Industriale 1/3 - 25060 Cellatica (BS), e-mail: privacy@olimpiasplendid.it

Olimpia Splendid S.p.A.has appointed a Data Protection Officer (DPO) who may be contacted at the following address: dpo@olimpiasplendid.it

10.NOTICE UPDATES

In a world in which technology is constantly changing, it may be necessary to periodically update this Notice. We will keep you updated on any changes via the App or through our other usual communication channels.

CONSENT TO PROCESS PERSONAL DATA

Having received the above notice and acquired the information provided by the data controller under article 7 of EU Regulation 2016/679, by subscribing to the service the customer consents to the processing of his/her data for the purposes laid down in point 2(a) of the notice (downloading and activating the Olimpia Splendid App, including, but limited to, the geolocalization of his/her mobile device).