Policy issued by Coswell S.p.A. pursuant to Article 13 of European Regulation 2016/679

Whereas

1) as a result of your visits to our websites, compilation of forms, your participation in our competitions, receipt of your requests/queries, preliminary contacts, surveys and market research, possible establishment of business relations, our company will collect and process your personal data;2) For the sake of clarity, we hereby point out the following definitions provided in European Regulation 2016/679:
Personal data: means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.Now, therefore, pursuant to Article 13 of European Regulation 2016/679, 

we hereby inform you

that the collection and processing of personal data will be carried out by the undersigned company in accordance with the following:
a) general purposes: the data will be processed to satisfy requests/queries, for the correct execution of bureaucratic, accounting, tax, commercial, technical and corporate activities required by law and in any case strictly related to existing relationships;
b) "direct marketing" purposes: your data may be used only and exclusively with your free, optional, specific and explicit consent which is revocable at any time, also for sending advertising material/communications by post, e-mail, telephone, fax, text message, MMS, WhatsApp and similar tools; after having given consent, it is however your right to object, at any time and without charge, to the processing of your data for this purpose;
c) methods: the data will be processed with both paper and electronic/IT/telematic tools/media, in full compliance with the law, according to the principles of lawfulness and integrity and in a manner such as to protect your privacy; 
d) optional provision: the provision of your data is optional and not mandatory;                    
e) consequences of possible refusal: the refusal to provide data or complete objection to its processing for the purposes referred to in point a) may in any case make it impossible to satisfy certain requests; the refusal to use the data for the purposes referred to in point b), however, will not have any consequence on the recognition of benefits related to promotions or on existing relationships;
f) subjects or categories of subjects (recipients) to whom the data may be communicated or disseminated: the data may be communicated, subject to your specific and explicit consent, for the proper fulfillment of the purposes set out in points a) and b) to our subsidiaries and associates set out below: Incos S.p.A. . The data may also be communicated, only for the purposes referred to in point a), to other third parties, in order to fulfil any legal or contractual obligations. The data will not be disseminated under any circumstances; 
g) company data processors and persons in charge of processing: the data will be processed only and exclusively by a limited number of specifically authorised company representatives from the administrative, marketing, IT and commercial sectors;
h) automated decision-making processes (e.g. profiling): no automated decision-making processes are in any way managed;
i) rights of data subjects: you enjoy all the rights set out in European Regulation 2016/679, such as the right to request access to personal data and its correction, cancellation, limitation of processing and the right to object to its processing, in addition to the right to data portability. You also have the right to file a complaint with the Supervisory Authority;
j) transfers to third countries: any transfer of personal data to a third country outside the European Union or to an international organisation will take place on the basis of a decision of adequacy of the Commission or, in the case of transfers pursuant to Articles 46, 47 or 49, second paragraph, of the European Regulation, on the basis of appropriate safeguards;
k) data retention period: the data will be kept for the period strictly necessary to meet the requests of data subjects or in accordance with the provisions of current legislation or any contractual clauses;
l) data controller: the data controller is Coswell S.p.A., with registered office in Funo (BO), Via P. Gobetti 4, in the person of the legal representative pro tempore;
m) data protection officer: the data protection officer is Mr. Juri Torreggiani, with offices in Reggio Emilia, Via Piccard 16/G, tel. 0522/30.11.69, fax 0522/38.79.96: any request for clarification or information may be addressed to this officer. 
This policy may be supplemented, either verbally or in writing, with further elements and indications, in order to best meet any need for information on the subject of "Privacy" and to comply with regulatory developments.

Date: 20/04/2018
The data controller
Coswell S.p.A.