PRIVACY POLICY – PERSONAL DATA PROCESSING AND PROTECTION LEGISLATIVE DECREE 30 JUNE 2003, NO. 196 AND GENERAL DATA PROTECTION REGULATION (EU) 2016/679

The data controller - VARINELLI SRL - informs you under and for the effects of the legislation in question that:

1) A series of obligations are foreseen for who carries out the processing (i.e. collection, registration, processing, retention, transmission, dissemination, etc.) of personal data regarding other subjects (so-called "data subjects").

2) The processing of your personal data at our disposal and/or that will be requested and/or that will be provided by you and/or by third parties will be carried out to fulfill:
- legal obligations - (e.g. invoicing, mandatory accounting records and entries, etc.);
- contractual obligations as well as related modifications and additions;
- other purposes related to the contractual relationship.

3) The processing will take place through manual and/or automated systems designed to store, manage and transmit the data, with logic strictly related to the purposes, based on the data at our disposal and with your commitment to promptly notify us of any corrections , additions and/or updates.

4) Your data may be transmitted to:
- the data processing center;
- administrative offices, commercial offices, technical offices of our Company;
- service companies;
- public and private bodies, also after inspections or verifications - (e.g. Tax Administration, Tax Police, Judicial Authorities, Italian Exchange Office, Labor Inspectorate, Local Health Authorities, Social Security Agencies, National assistance board for commercial agents and representatives, Chamber of Commerce, etc.);
- subjects who can access your data under the provisions of law or secondary or community legislation;
- our network of agents, factoring companies, credit institutes, credit recovery companies, insurance companies, credit insurance companies, commercial information companies, professionals and consultants, companies operating in the transport sector.

5) The scope of the possible transmission of data will be national or foreign exclusively for the purposes specified above.

6) The provision of your data is mandatory in relation to the different purposes of the processing.
Your refusal to provide data and/or to consent to their processing or transmission may have the following consequences:
- the impossibility to establish or continue the contractual relationship, or to carry out some operations, if the data are necessary for the execution of the relationship or operation;
- the impossibility to carry out some operations that presuppose the transmission of data to subjects functionally connected to the execution of those operations; the impossibility to transmit the data to subjects who perform other activities, not functionally related to the execution of the contractual relationship.

7) Towards you the exercise of some rights is foreseen, in particular of:
- the right to be aware of the existence or not of personal data concerning you and their transmission in an intelligible form;
- the right to be informed about the data controller, the purposes and methods of the processing and about the possible person in charge of the processing, about the subjects or categories of subjects to whom the personal data can be transmitted;
- the right to obtain the update, correction or integration of data;
- the right to obtain the cancellation, transformation into anonymous form or blocking thereof;
- the right to object to the processing of data for legitimate reasons, subject to the limits set by law;
- the right to object to the sending of advertising material or for the carrying out of market research or of commercial communication.

8) The data controller is VARINELLI SRL in the person of the Sole Director Mr. Christoph Klink with head office in Via Del Bruno, 46, 20862 Arcore (MB).
The data controller informs you that your data will be retained for the time necessary to comply with legal duties and, therefore, the same will be retained for the duration of the statutory prescription for the exercise of the related right.
We therefore kindly ask you to express your written consent to the aforementioned processing and to the consequent possible communications and/or disseminations, as well as your commitment to promptly notify us of any changes in the data at our disposal, sending us a copy of this document signed for acceptance and confirmation, via e-mail to the following address: sales@varinelli.com