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Information regarding the processing of personal data

Pursuant to Article 13 of EU Regulation 2016/679 of 27 April 2016 ("Regulations" or "Applicable Regulations"), we wish to provide, as data controllers, appropriate information about the fundamental elements of the processing performed by us.

Tobiz di Filippo Piervittori (hereinafter, the "Owner") takes the utmost account of the right to privacy and the protection of personal data as guaranteed by the Applicable Regulation.

For any information regarding this privacy policy, you can contact the Data Controller at any time, using the following methods:

By sending a registered letter a / r to the registered office of the Holder: ToBiz by Filippo Piervittori, Via Cerva 20 – 20122 Milan

By sending an e-mail message to the address: info@tobiz.it

You can also contact the Data Protection Officer (RPD or DPO) of the Data Controller, whose contact details are as follows: name Filippo, surname Piervittori, mail filippo.piervittori@pec.tobiz.it

1. Purpose of the processing

1.1. Any personal data collected by the Data Controller for the purposes of concluding or executing existing contracts will be processed lawfully by the Data Controller pursuant to art. 6 of the Regulation exclusively for the following processing purposes:

a) Contractual obligations, exclusively for purposes related to the existing contractual relationship and its execution. The personal data collected by the Data Controller for the purposes of any establishment and / or execution of the contractual relationship include: name and surname, business name, address, email address, telephone number, as well as any personal information voluntarily provided to the Data Controller including any data of collaborators and appointees, even future, who may come into contact with the Data Controller. Without prejudice to what is provided elsewhere in this privacy policy, in no case will the Data Controller make your personal data accessible to third parties;

b) Administrative and accounting purposes, or to carry out activities of an organizational, administrative, financial and accounting nature, such as internal organizational activities and activities functional to the fulfillment of contractual and pre-contractual obligations, including the possible phase of protection of the Data Controller's rights;

c) Obligations of the law, or to fulfill obligations set by law, an authority, a regulation or European legislation.

1.2. The provision of personal data for the aforementioned processing purposes is optional but necessary, since failure to provide them could make it impossible for the Data Controller to establish the, or execute, the contractual relationship. The provision of data is obligatory when it meets specific legal provisions.

2. Further processing purposes: marketing

2.1. With the free and optional consent of the data subject, the Data Controller will use some personal data (that is, the name, surname, email address, telephone number) may be processed by the Data Controller also for marketing and newsletter purposes (sending material advertising, direct sales, commercial communication, sending newsletters containing information in relation to news relevant to the sector relating to the activities of the Data Controller), or for the Data Controller to contact it by post, e-mail, telephone (fixed and / or mobile, with systems automated call or call communication with and / or without the intervention of an operator) and / or SMS and / or MMS to propose the purchase of products and / or services offered by the same Owner and / or third party companies, to present offers, promotions and business opportunities.

2.2. In the event of non-consent, the possibility of pursuing the purposes referred to in paragraph 1.1. will not be affected in any way.

2.3. In the event of consent, the same may be revoked at any time by making a request to the Data Controller in the manner indicated in paragraph 5 below.

You can also easily oppose further sending of promotional communications via email even by clicking on the appropriate link for revocation of consent, which is present in each promotional email. Once the consent has been revoked, the Data Controller will send an e-mail message to confirm the revocation of the consent.

If you intend to revoke your consent to send promotional communications by phone, while continuing to receive promotional communications via email, or vice versa, please send a request to the Controller in the manner indicated in paragraph 5 below.

Following the exercise of the right to object to the sending of promotional communications via email, it is possible that, for technical and operational reasons (eg formation of contact lists already completed shortly before receipt by the holder of the opposition request) continue to receive some additional promotional messages.

Should you continue to receive promotional messages after 24 hours have elapsed from exercising your right to object, please report the problem to the Owner, using the contacts indicated in the following paragraph 5.

3. Processing methods and data retention times

The Data Controller will process personal data using manual and IT tools, with logics strictly related to the same purposes and, in any case, so as to guarantee the security and confidentiality of the data.

Personal data will be kept for the time strictly necessary to carry out the primary purposes illustrated in paragraph 1 above, or in any case according to what is necessary for the civil protection of the interests of both the interested parties and the Data Controller.

In the cases referred to in paragraph 2 above, personal data will be stored for the time strictly necessary to carry out the purposes described therein and, in any case, for no more than twenty-four (24) months.

4. Scope of communication and dissemination of data

Employees and / or collaborators of the Data Controller responsible for managing contractual relations may become aware of the personal data. These subjects are formally appointed by the Data Controller to process personal data exclusively for the purposes indicated in this information document and in compliance with the provisions of the Applicable Regulations.

Your personal data may also be disclosed to third parties who may process personal data on behalf of the Data Controller as "External Data Processors" or as independent data controllers, such as, by way of example:

. service providers (such as administrative, IT, mailing services, credit recovery companies, etc.);

. consultants (such as accountants, auditors, lawyers, etc.);

. companies of the same group, associated companies;

. banks and financial institutions;

. Authorities and public bodies.

The Owner informs you that he has the right to obtain a list of any data processors appointed by the Data Controller, by making a request to the Data Controller in the manner indicated in paragraph 5 below.

5. Rights of the interested parties

The rights guaranteed by the Applicable Regulation may be exercised by contacting the Owner in the following ways:

. By sending a registered letter a / r to the registered office of the ToBiz Owner of Filippo Piervittori Via Cerva 20 20122 Milan

. By sending an e-mail message to info@tobiz.it

You can also contact the Data Protection Officer (RPD or DPO) of the Data Controller, whose contact details are as follows: name Filippo, surname Piervittori, mail filippo.piervittori@pec.tobiz.it

Under the Applicable Regulations, the Owner informs you that he has the right to obtain the indication (i) of the origin of the personal data; (ii) the purposes and methods of processing; (iii) the logic applied in the case of processing carried out with the aid of electronic means; (iv) of the identification data concerning the data controller and data processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as managers or agents.

Furthermore, he has the right to obtain:

a) access, updating, rectification or, when interested, integration of data;

b) the deletion, transformation into anonymous form or blocking of data processed in violation of the law, including data which does not need to be kept for the purposes for which the data was collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the event that such fulfillment occurs it proves impossible or involves a manifestly disproportionate use of resources with respect to the protected right.

Moreover, it has:

a) the right to withdraw consent at any time, if the processing is based on your consent;

b) if applicable, the right to data portability (right to receive all personal data concerning you in a structured format, commonly used and readable by an automatic device), the right to limit the processing of personal data and the right to cancellation ("right to oblivion");

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning you, even though they are relevant to the purpose of the collection;

ii) in whole or in part, to the processing of personal data concerning you for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication;

iii) if personal data is processed for direct marketing purposes, at any time, to the processing of your data for this purpose, including profiling to the extent that it is connected to such direct marketing.

d) if he considers that the processing of personal data carried out by the Data Controller violates the Regulations, the right to lodge a complaint with a Control Authority (in the Member State in which he habitually resides, in the one in which he works or in the one in which it occurred) the alleged violation).

The Italian Control Authority is the Guarantor for the protection of personal data, with headquarters in Piazza di Monte Citorio n. 121, 00186 – Rome (www.garanteprivacy.it).

The Owner is not responsible for updating all the links displayed in this Policy, therefore whenever a link is not functioning and / or updated, you acknowledge and agree that it must always refer to the document and / or section of the websites referred to. from that link.

CHECK-LIST RIGHTS – ANNEX TO THE NOTICE

Dear Sir / Madam, pursuant to art. 13 of the EU Regulation 2016/679 of 27 April 2016 ("Regulations" or "Applicable Regulations"), in its capacity as "Interested Party", ie of a natural person to whom the personal data subject to processing by Filippo's ToBiz refer Piervittori (hereinafter, the "Owner"), has been provided with a privacy policy (hereinafter, "Information") by which the Owner has provided you with all the elements required by the Applicable Regulation.

Without prejudice to the provisions of the Disclosure, with this document the Data Controller wishes to provide you with further information for the exercise of your rights towards the Data Controller in order to facilitate the exercise of your rights.

To make your request to the Owner, you will not have to use particular formalities and, if necessary, will also be able to proceed orally. The Owner, in any case, is willing to receive his requests also in the following ways:

• registered letter a / r to the registered office of the holder Via Cerva 20, 20122 Milan

• e-mail message to the address info@tobiz.it e-mail message to the Data Protection Officer address of the Owner filippo.piervittori@pec.tobiz.it

• The Owner will provide you with feedback in written form (including through electronic means), unless you request an oral response (pursuant to Article 12, paragraph 1 and Article 15, paragraph 3 of the Rules).

The owner will have 1 month's time to respond to his request to exercise his rights.

In principle, the exercise of your rights towards the owner is free. However, pursuant to art. 12, paragraph 5 of the Rules, the Owner will assess the complexity of the response to your request and establish, if necessary, the amount of the possible contribution that you will have to pay, if your request is manifestly groundless or excessive or if You request more "copies" of personal data (in case of right of access, pursuant to Article 15, paragraph 3). To establish this reasonable amount, the Holder will take into account the administrative costs incurred.

Right of access (Article 15 Regulation)

In case of exercise of the right of access, the Owner will provide you with a copy of your personal data subject to processing (and which requires access). Among the information that the Owner will also provide you with are:

(i) the purpose and methods of processing, as well as the categories of personal data processed;

(ii) data recipients;

(iii) the expected retention period (or the criteria used to define this period);

(iv) (if any) transfer of personal data abroad (and tools used and guarantees adopted).

Right of rectification (art. 16 Regulation)

In the event of the right of rectification being exercised, the Data Controller will rectify your inaccurate personal data or integrate your incomplete personal data (taking into account the purposes of the processing), also through an additional declaration.

If you exercise your right of rectification, the Owner will notify the exercise of this right to each of the recipients to whom the data was transmitted.

Right to cancellation or right to be forgotten (art. 17 Regulation)

You can exercise the right to cancellation:

(i) if the data are no longer necessary for the pursuit of the purposes for which the Data Controller has collected them;

(ii) if you have revoked your consent and there is no other legal basis on which the Data Controller can base the processing;

(iii) if you objected to the processing and there is no prevailing legitimate reason for the Data Controller to continue processing;

(iv) if the data has been processed unlawfully;

(v) if there is a legal obligation requiring cancellation.

The right to cancellation cannot be exercised if the processing is carried out by the Owner for the fulfillment of a legal obligation.

In the event that the Data Controller has made public his personal data, the Data Controller, taking into account the available technology and implementation costs, will take reasonable, technical measures to inform the other holders who process your personal data of your request for cancellation (including links, copies or reproductions of your data).

In the event that you exercise your right to cancel, the Data Controller will notify the exercise of this right to each of the recipients to whom the data was transmitted.

Right to treatment limitation (Article 18 of the Regulation)

You can exercise your right to limit the processing in the case where

(i) you contest the accuracy of the data (pending verification in this sense by the Owner);

(ii) there has been a violation by the Data Controller of the conditions of lawfulness of the processing (and you are opposed to the deletion of data and instead request that it be limited to use);

(iii) personal data is necessary for you to ascertain, exercise or defend a right in court (even if the Owner no longer needs it);

(iv) You have objected to the processing and are awaiting an assessment of your request by the Data Controller for any assessment of the prevalence of your legitimate interest in continuing the treatment.

The Holder will freeze the data, "marking it" pending further determinations

this means that no other processing of the personal data for which you have requested the limitation will be carried out by the Owner, if not the storage of personal data, unless certain circumstances exist (such as your consent, the verification of rights in place judicial, the protection of the rights of another natural or legal person, or a significant public interest).

In case of exercise of your right to limitation, the Owner will notify the exercise of this right to each of the recipients to whom the data was transmitted.

Right to data portability (Article 20 Regulation)

You may exercise the right to data portability only in the event that the processing of your data by the Data Controller is based on your consent or is based on a contract stipulated with the Data Controller.

Furthermore, you may exercise your right to portability for only the data you have provided to the Owner.

You may not exercise the right to the portability of data in the event that the processing of your data is carried out for the fulfillment of legal obligations of the Data Controller. Furthermore, you cannot exercise the right to the portability of data in the event that the processing carried out by the Data Controller is not automated (for example, the right to portability cannot be exercised by you in the case of personal data contained in an archive or in a paper register).

If this right is exercised, the Data Controller will send you personal data in a structured format, commonly used and readable by an automatic device. Currently the format chosen by the Owner is as follows: Excel.

Furthermore, if requested by you, the Data Controller will directly transmit your personal data to another data controller (where and to the extent that this is technically feasible).

Opposition right (art. 21 Regulation)

You may exercise your right to object, for reasons connected with your particular situation, if the Data Controller is processing your personal data on the basis of a legitimate interest of the Data Controller. In this case, the Data Controller will not process your data, unless the Data Controller can demonstrate the existence of legitimate reasons that prevail over your interests.

If your data is processed for direct marketing purposes by the Data Controller, you may object to the processing and personal data will no longer be processed for these purposes by the Data Controller.

Right to lodge a complaint with the competent authority (Article 77 of the Regulations)

If you believe that the treatment concerning you violates the Rules, the right to lodge a complaint with a Supervisory Authority:

• in the Member State where he habitually resides;

• in the one in which he works; or

• in the one in which the alleged violation occurred.

Milan, 24/05/2018

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