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1. FOREWORD

BRUNEAU ITALIA attaches great importance to the protection and confidentiality of your personal data and ensures day-to-day compliance with the applicable legislation in force and, in particular, with the General Data Protection Regulation ("GDPR").

We therefore invite you to consult this information notice, the purpose of which is to describe how we process your personal data for the purpose of proposing and carrying out our services and to explain how you can exercise your rights regarding the use of your personal data.

2. WHO ARE WE?

BRUNEAU ITALIA subsidiary of the JM Bruneau Group is a single-member company, registered in the Milan Companies Register under no. 06975290286, with share capital of €3,000,000, registered office located at Centro Direzionale Milanofiori, Strada 1 Palazzo E Scala 3-4, and holder of the processing of users' personal data.

3. WHY DO WE PROCESS USERS' PERSONAL DATA AND ON WHAT LEGAL BASIS DO WE DO SO?

The data we process is mostly collected directly from users through the completion of forms and questionnaires published on our website, catalogues or during the creation of a customer account by our users.

We may also collect information about users indirectly, i.e. through our partners.

Data is collected and processed solely for the purpose of carrying out the processing operations listed below, which are necessary for the provision of our services:

- customer relationship management;
- management of the relationship with potential customers;
- management of orders and deliveries;
- administrative management of the customer account;
- management of cancellation requests for subscriptions and subscriptions;
- maintenance of data due to legal, security and tax obligations;
- service improvement and customer satisfaction surveys;
- behavioural analysis and targeting;
- management of promotional offers;
- marketing studies and statistics;
- newsletter management;
- anti-fraud management

This list is as exhaustive as possible. Any new use, modification or deletion of existing processing will be communicated to users by means of an amendment to this Policy.

We may also communicate promotional offers or news about our company to users if we have obtained their consent to such communications.

4. WHAT CATEGORIES OF USER DATA DO WE PROCESS?

In order to provide users with all the services offered by BRUNEAU ITALIA, we inevitably have to collect and process certain personal data, including:

Please note that we respect the principle of data minimisation, according to which we only collect data that is strictly necessary for the processing carried out by BRUNEAU ITALIA in order to provide the services.

5. WITH WHOM IS USER DATA SHARED?

We undertake to ensure that user data is only shared with internal or external recipients authorised for this purpose, which are:

- internally, the authorised services of BRUNEAU ITALIA, (e.g. sales department, accounting, etc.);
- externally, our subcontractors authorised and selected for this purpose and, where appropriate, our partners.

Please note that any third party authorised to access the data is obliged to comply with the requirements of the GDPR and liable to sanctions in the event of misuse of personal data.

. The data may also be communicated to any authority legally authorised to know them, in particular in the event of judicial requisition by judicial, police or administrative authorities.

6. HOW LONG DO WE KEEP USERS' DATA?

The rules on retention of your personal data are determined by our legal and contractual obligations or otherwise by our business needs, as described below:

After the aforementioned time limits, the data is deleted or retained after being anonymised, in particular for statistical purposes. The data may be retained in the event of pre-litigation and litigation.

Please note that the deletion or anonymisation of data are irreversible operations and that BRUNEAU ITALIA will no longer be able to restore the data after performing them.

7. USERS' RIGHTS

The collection of personal data does not mean that users lose ownership of them. On the contrary, users or potential customers of BRUNEAU ITALIA enjoy the following rights over the data concerning them:

- Right of access and copy: users have the right to obtain from BRUNEAU ITALIA confirmation that their personal data is being processed or not and, if it is being processed, to have access to it. Users may also obtain from BRUNEAU ITALIA information on the purposes of the processing, the categories of data processed and the recipients / categories of recipients.

Users also have the right to obtain a copy of the personal data processed. Upon request for additional copies, BRUNEAU ITALIA may require payment of the relevant costs. If the request is made electronically, the information shall be provided in the digital format in current use, unless otherwise requested by the user.

- Right of rectification and cancellation: users may obtain from BRUNEAU ITALIA, as soon as possible, the rectification of their personal data that is inaccurate or incomplete. Users also have the right to obtain the deletion, as soon as possible, of their data, in particular when it is no longer necessary to achieve the purposes for which it was collected or processed.

- Right to restriction of processing: users have the right to request the restriction of processing, in particular when they contest the accuracy or lawfulness of the use of their data. The restriction of processing remains effective for as long as BRUNEAU ITALIA verifies the veracity of the request or for as long as discussions with a supervisory authority take place. Users may also obtain from BRUNEAU ITALIA the restriction of processing when BRUNEAU ITALIA no longer needs the data for processing.

- Right to data portability: users may only benefit from the right to data portability when three necessary cumulative conditions are met and, in particular, when consent to processing has been obtained by automated means, which is not the case within the scope of the services provided by BRUNEAU ITALIA.

- Right to object: users may object, for reasons related to their particular situation, to the processing of their personal data if the processing is based on the legitimate interest of BRUNEAU ITALIA. Users may also object to the processing carried out for marketing purposes.

- Right to define the post-mortem destination of their personal data rights: users may have their personal data stored, deleted and communicated after their death.

- Right to lodge a complaint with a supervisory authority: users may lodge a complaint with the Personal Data Protection Guarantor if they consider that the processing of their data constitutes a violation of the applicable legislation on the subject. Contact:

Garante per la protezione dei dati personali, at the following address:
Piazza Venezia 11 - 00187 Roma
or by phone at +39 06.696771

8. EXERCISE OF USERS' RIGHTS

If you wish to exercise any of the above rights in person, please contact us at the following address:
gdpr@bruneau.it

In order to handle requests efficiently and quickly, please indicate the rights you wish to exercise. For all useful purposes, please note that in the event of doubt as to the identity of the applicant, we may ask you to send us a copy of your identity document.

9. DATA CONTROLLER

BRUNEAU ITALIA may bring in a data controller of its choice in order to provide its services to users (e.g. data hosting, commercial prospecting).

In this case, we ensure that our data controllers comply with the obligations set out in the GDPR. In particular, we undertake to enter into a written contract with them governing our relationship and obligations with them.

10. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

In general, your personal data is not transferred and processed outside the EU and is always stored within the EU perimeter.

However, if such an eventuality should occur, we are scrupulously committed to complying with the requirements of the applicable data protection legislation in order to ensure its confidentiality and security.

11. SECURITY

BRUNEAU ITALIA defines and implements security measures to prevent the destruction, loss, alteration or unauthorised disclosure of user data. The computer systems and paper media we use are organised and protected to ensure data security and confidentiality.

12. UPDATING THIS POLICY

We reserve the right to change the presentation and content of this Policy. Any new version of the Policy will be posted on our website and will replace the previous version.

13. FURTHER INFORMATION

For further information on the protection of personal data, please contact our Data Protection Officer at: gdpr@bruneau.it.
For any other information, please consult the Data Protection Authority's website at: www.garanteprivacy.it.