# INFORMATION EX ART. 13 EU 2016/679 REGULATION (GDPR) FOR DATA PROCESSED THROUGH THE WEBSITE

La società Avvale S.p.A. con sede in Milano (MI), Via Melzi D’Eril 34, P. IVA: IT04113150967 (hereinafter, "Owner"), as the data controller, informs you pursuant to art. 13 EU Regulation no. 2016/679 (hereinafter, "GDPR") that the data you provide and those that will be provided in the future or otherwise acquired, will be processed by the Owner, in accordance with the provisions of current legislation and in compliance with the obligation of confidentiality.

# EMAIL MESSAGE SENDING AND FORM COMPILATION – “CONTACTS” SECTION

The optional and free sending of email to the addresses indicated on this website or the completion of the dedicated form in the “contacts” section entails the acquisition of the sender’s address, necessary to reply to requests, as well as any other personal data included in the form and in the body of the message.

No data deriving from the email or messaging service of “contacts” is disseminated; data collected through the form or by sending email, are managed exclusively by employees and / or collaborators of the Owner, duly authorized for processing.

The user is completely free to provide the personal data indicated in “contacts” with our company to request the sending of informative documentation, newsletters or other communications.

Failure to provide such data may make it impossible to obtain what is requested.

Personal data are processed by automated tools only for the time strictly necessary to achieve the purposes for which it was collected.

Security measures are implemented to prevent loss of data, offense or incorrect use and unauthorized access.

# GENERAL INFORMATION ON PERSONAL DATA PROCESSING OF CUSTOMERS AND SUPPLIERS

1. **Processed data disposition.** Lookcast srl will process both personal and fiscal data of customers and suppliers, as well as the economic data necessary for the performance of the contractual relationships.

2. **Purpose of the processing.** Personal data are processed for the following Service Purposes (art. 6 lett. B) and c) GDPR):

The Owner can collect the following information: name, gender, place and date of birth, nationality, tax identification number, contact details such as address, telephone number, email, for:

- close contracts for the services provided by the Owner (management of subscriptions, activities relating to sales and after-sales services, management of user attendance in promotions or other contractual initiatives promoted through the Website);
- fulfill pre-contractual, contractual and fiscal obligations deriving from existing relationships with the user (eg. managing payments);
- fulfill the obligations provided for by the law, by a regulation, by EU legislation or by a directive of the Authority (such as anti-money laundering).

3. **Processing methods.** The processing of personal data is carried out by the operations indicated in the art. 4 n. 2) GDPR especially: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Personal data are processed both on paper and electronic and / or automated.

4. **Transfer of personal data.** Personal data is managed through Softlayer cloud services with IBM data center located in Dallas (USA). The Privacy Policy, respecting the standards set by the European Regulation, can be consulted at the following link: [IBM Privacy Policy](https://www.ibm.com/privacy/us/en/)

5. **Personal data storage length.** In compliance with the principles of lawfulness, limitation of purposes and minimization of data, pursuant to art. 5 GDPR, the period of storage of personal data is established for a time not exceeding the achievement of the purposes for which they are collected and processed. Personal data will be stored in our archives as follows: administrative data will be stored for 10 years; technical documentation and customer / supplier contracts for 5 years; data collected for marketing purposes for 2 years.

6. **Obligation or right to provide data and effect of any refusal.** The provision of data for the purposes referred in art. 2 is mandatory. In their absence, we will not be able to guarantee the contractual services.

7. **Communication and dissemination.** Your data may be given available for the purposes referred in art. 2:

- to employees and collaborators of the Owner in their role of authorized to data processing;
- to third-party companies or others (for example: credit institutions, professional offices, consultants, insurance companies for providing insurance services, etc.) that carry out activities in outsourcing on behalf of the Owner, in their role as external managers of the processing.

## NAVIGATION DATA AND COOKIES POLICY

According with the measure of the Italian Data Protection Authority for personal data protection of 8 May 2014, containing “Individuazione delle modalità semplificate per l’informativa e l’acquisizione del consenso per l’uso dei cookie”, the Owner informs the user as the following:

1. **What are Cookies?** Cookies are small text strings that browsed websites by the user send to their terminal, where they are stored before being re-transmitted to the same websites when the same user visit again the pages.

2. **What are the main Cookies type?** For the goal of this measure, two macro-categories are therefore identified: “technical” cookies and “profiling” cookies.

**A. Essential technical Cookies** Technical cookies are necessary for the proper operation of the website. They are not used for other purposes and are usually installed directly from the website owner.

**B. Profiling cookies.** These cookies allow you to create user profiles, to identify, anonymously or not, user preferences.

3. **Third-party cookies without direct control.** This type of cookie is usually used if the website includes features provided by external sites.

4. **How manage cookies** To deny consent to use of one or more profiling cookies, you can access listed links above or follow the disable procedure provided by the main browsers.

## RIGHTS OF THE INTERESTED PARTY:

The interested party can always carry out the rights approved in the art. 15 GDPR:

- Access to personal data;
- Obtain the changing, the cancellation or the limitation of the processing of the interested party;
- Deny the processing;
- To data portability;
- Lodge a complaint to the supervisory authority.

## CONTACT DATA OF THE OWNER:

Il Titolare del Trattamento è Avvale S.p.A.

## CONTACT DATA OF THE DATA PROTECTION MANAGER:

The Data Protection Officer who can be contacted to carry out the rights listed above can be reached at the following e-mail address: [dpo@lookcast.com](mailto:dpo@lookcast.com)

Changes to this Policy

La Avvale S.p.A. è impegnata a rispettare i principi fondamentali della privacy e della protezione dei dati.
