PRIVACY POLICY

European Privacy Policy n. 679/2016 (“GDPR”)

A. Who are we and why are we providing this document?

Elpower s.r.l. company has considered for years the protection of personal data of its customers and / or potential customers and users to be fundamental, ensuring that the processing of personal data, carried out by any means, both automatic and manual, takes place in full compliance with the protections and rights recognized by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, as well as on the free movement of such data (hereinafter the “Rules”) and further applicable rules on the protection of personal data.

With the term personal data, reference is made to the definition contained in article 4 in point 1) of the Regulation, ie “any information concerning an identified or identifiable natural person; an identifiable natural person can be identified, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identification or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social “(hereinafter ” Personal Data “).

The Regulation provides that, before proceeding with the processing of Personal Data – with this term referring to, according to the relative definition contained in Article 4 in point 2) of the Rules, “any operation or set of operations, performed with or without the support of automated processes applied to personal data or sets of personal data, such as collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, the communication by transmission, diffusion or any other form of making available, the comparison or the interconnection, the limitation, the cancellation or the destruction “(hereinafter the” Treatment “) – it is necessary that the person to whom such Personal Data belong is informed about the reasons such data are requested and how they will be used.

In this regard, this document is intended to provide you, in a simple and intuitive way, all the useful and necessary information so that you can give your personal data in a conscious and informed and at any time, request and obtain clarification and / or adjustments.

The present informative note, therefore, has been drawn up on the basis of the principle of transparency and all the elements required by Article 13 of the Rugulation and is divided into individual sections (hereinafter “Sections” and individually “Section”) each of them deals with one specific topic in order to make the reading faster, easy and simple to understand (hereinafter the “Information”).

If necessary, this Notice may be accompanied by a specific form for the issue of consent as provided for in Article 7 of the Regualtion, articulated on the basis of the additional type of use that we intend to make of your Personal Data.

B. Who will process your Personal Data?

The company that will process your Personal Data for the main purpose referred to in Section D of this Information Notice and who will therefore play the role of data controller according to the related definition contained in Article 4 in point 7) of the Regulation, “the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data “is:

Elpower S.r.l. with registered office in Via Beggiato, 23 – 36025 Noventa Vicentina (VI), registered in the Register of Business in Vicenza REA VI-324212 , fiscal code and VAT number n. 03421010244

(hereinafter the “Data Controller”)

To the Data Controller, for some processings, as identified in the following Section E, the following companies will act as co-controllers of the processing meaning for these “two or more companies that jointly determine the purposes and means of the treatment” as required by Article 26 of the Regulation.

C. Who can you contact?

In order to facilitate relations between you, as an interested party, ie the “identified or identifiable natural person” referred to in the Personal Data in Article 4 in point 1) of the Regulation (hereinafter the “Interested Party”) and the Data Controller, you can freely contact the Data Controller for all matters relating to the processing of your Personal Data and / or if you wish to exercise your rights as set out in Section I of this Information, by sending a written notice to the email address info@elpower.it and / or by writing to the Owner Elpower srl, via Beggiato, 23 – 36025 – Noventa Vicentina (VI) and / or by calling the number +39 0444 787882.

At any time you can consult the “Privacy” section of the Website where you will find all the information concerning the use and processing of your Personal Data, the detailed references of the Company, updated information on contacts and communication channels made available to all interested parties by the Data Controller.

D. For what main purpose will your Personal Data be processed?

The Data Controller, in order to allow you to register on hiswebsite, if you have the possibility to register, and / or send requests for information using the contact forms and / or subscribe to the newsletter service, needs to collect some of your Personal Information as requested in the registration form on the Website. The website of the Data Controller for which this Policy is issued is the one indicated in the Company’s Privacy Policy available at the link http://www.elpower.it/privacy-policy (hereinafter the “Website “). The processing of your Personal Data will be conducted by the Data Controller to allow you, therefore, to access your profile, receive newsletters, send requests for information; The processing of your Personal Data will be legally based on the contractual relationship that will be created between you and the Data Controller as a result of your acceptance of the conditions for participation on the Website.

To allow the Data Controller to carry out the processing activities for the above purposes, it will be necessary to provide the Personal Data marked with the symbol *. In the absence of even one of the marked data, it will not be possible to process your Personal Data and, consequently, you will not be allowed to complete your registration to the Internet Sites and / or benefit from the services provided by the same for which requested a provision of Personal Data.

The Personal Data that will be required for the pursuit of the aforementioned purposes will be those indicated in the registration and / or contact form, that is, by way of example and not exhaustive: name, surname, username, date of birth, home address / residence, e-mail address, telephone numbers of fixed and / or mobile users, tax code.

If you decide to access the Website through the use of your social media profile (eg Facebook profile), where provided, the collection of your Personal Data will be carried out by the Data Controller at third parties or at the manager of the social you used to access the Internet site. In this case you will be able to read this information in the Privacy section of the site.

E. Which subjects can your Personal Data be disclosed to?

Your Personal Data may be disclosed to specific subjects considered recipients of such Personal Data. In fact, Article 4 in point 9) of the Rules defines as the recipient of a Personal Data “the natural or legal person, public authority, service or another body that receives communication of personal data, whether or not it is of third parties “(hereinafter the” Recipients “).

With this in mind, in order to correctly perform all the Processing activities necessary to pursue the purposes set out in this Notice, the following Recipients may be in a position to process your Personal Data:

* third parties who take part in the processing and / or activities connected and instrumental to them on behalf of the Data Controller or Co-data Controllers of the Processing. These persons have been appointed as data processors, meant individually with this expression, in accordance with Article 4, paragraph 8, of the Regulation, “the natural or legal person, public authority, service or other body that processes Personal Data. on behalf of the Data Controller “(hereinafter the” Data Processor “);

* individuals, employees and / or collaborators of the Data Controller or of the co-data Controllers, who have been entrusted with specific and / or more processing activities on your Personal Data. These individuals have been given specific instructions on the safety and correct use of Personal Data and are defined, in accordance with Article 4 paragraph 10) of the Regulation, “persons authorized to process Personal Data under the direct authority of the Data Controller or the Data Processor “(hereinafter the” Authorized Persons “).

* If required by law or to prevent or suppress the commission of a crime your Personal Data may be disclosed to public bodies or judicial authorities without them being defined as Recipients. In fact, pursuant to article 4 of point 9) of the Regulation, “public authorities that may receive communication of Personal Data in the context of a specific investigation in accordance with Union or Member State law are not considered Recipients”.

F. How long will your Personal Data be processed?

One of the principles applicable to the processing of your Personal Data concerns the limitation of the retention period, governed by Article 5, paragraph 1, point e) of the Regulation that states “Personal Data are stored in a form that allows the identification of data subjects for a period of time not exceeding the achievement of the purposes for which they are processed; Personal Data may be stored for longer periods provided they are processed exclusively for archival purposes in the public interest, for scientific or historical research or for statistical purposes, in accordance with Article 89, paragraph 1, with the exception of adequate technical and organizational measures as required by this regulation to protect the rights and freedoms of the interested party “.

In light of this principle, your Personal Data will be processed by the Data Controller limited to what is necessary for the pursuit of the purposes referred to in Section D of this Information. In particular, your Personal Data will be processed for a period of time equal to the minimum necessary, as indicated in 39 of the Regulation, ie until the termination of the contractual relations between you and the Data Controller with the exception of an additional retention period which may be imposed by law as also provided for by 65 of the Regulation

G. Is it possible to revoke the consent given and how?

As required by the Regulations, if you have given your consent to the processing of your Personal Data for one or more purposes for which you have been requested, you can, at any time, withdraw it totally and / or partially without prejudice to the lawfulness of the treatment based on the consent given before the revocation.

The methods of revoking consent are very simple and intuitive, just contact the Data Controller using the contact channels reported in this information and in section C respectively.

H. What are your rights?

As required by Article 15 of the Regulation, you can access your Personal Data, request correction and updating, if incomplete or wrong, request cancellation if the collection was made in violation of a law or regulation, as well as oppose to the treatment for legitimate and specific reasons.

In particular, we list below all your rights that you can exercise, at any time, towards the Data Controller:

* Right of access: you will have the right, in accordance with Article 15, paragraph 1 of the Regulation, to obtain from the Data Controller the confirmation that a Personal Data Processing is in progress and, if so, to obtain the access to such Personal Data and to the following information: a) the purposes of the processing; b) the categories of Personal Data in question; c) Recipients or categories of Recipients to whom your Personal Data have been or will be communicated, in particular if Recipients of third countries or international organizations; d) whenever possible, the provided retention period of the Personal Data or, if not possible, the criteria used to determine this period; e) the existence of the right of the interested party to request the Data Controller to rectify or delete Personal Data or limit the processing of personal data concerning him or to oppose their processing; f) the right to lodge a complaint with a supervisory authority; g) if the Personal Data are not collected at the interested subject, all information available about their origin; h) the existence of an automated decision-making process, including the profiling referred to in Article 22, paragraphs 1 and 4 of the Rugulation and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such treatment for the interested party. All this information can be found in this information that will always be available to you within the privacy section of each of the website.

* Right of rectification: you can obtain, in accordance with Article 16 of the Regulation, the correction of your Personal Data that are incorrect. Taking into account the purposes of the processing, moreover, you can obtain the integration of your Personal Data that are incomplete, also by providing an additional declaration.

* Right to cancel: you can obtain, in accordance with Article 17, paragraph 1 of the Regulation, the cancellation of your Personal Data without undue delay and the Data Controller will have the obligation to delete your Personal Data, if there is even one of the following reasons: a) Personal Data are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) you have withdrawn the consent on which the processing of your Personal Data is based and there is no other legal basis for their processing; c) you have opposed to the processing according to Article 21, paragraph 1 or 2 of the Regulation and there is no longer any legitimate predominant reason to proceed with the processing of your Personal Data; d) your Personal Data has been processed unlawfully; e) it is necessary to delete your Personal Data in order to comply with a legal obligation provided for by a community or national law. In some cases, as foreseen by article 17, paragraph 3 of the Regulation, the Data Controller is entitled not to provide for the cancellation of your Personal Data if their processing is necessary, for example, for the exercise of the

right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest, for purposes of archiving in the public interest, scientific or historical research or for statistical purposes, for the assessment, exercise or defense of a right in court.

* Right to limit the processing: you can obtain the limitation of processing, in accordance with Article 18 of the Rugulation, if one of the following hypotheses occurs: a) you have contested the accuracy of your Personal Data (the limitation will continue for the period necessary for the Data Controller to verify the accuracy of such Personal Data); b) The processing is illegal but you are opposed to the deletion of your Personal Data asking, on the contrary, that it has a limited use; c) although the Data Controller no longer needs it for the purposes of processing, your Personal Data are used for the assessment, exercise or defense of a right in court; d) you have opposed to the processing pursuant to Article 21, paragraph 1, of the Regulation and you are awaiting the verification of the possible prevalence of the legitimate reasons of the Data Controller with respect to yours. In case of limitation of processing, your Personal Data will be processed, except for storage, only with your consent or for the assessment, exercise or defense of a right in court or to protect the rights of a other natural or legal person or for reasons of significant public interest. We will inform you, in any case, before this limitation is revoked.

* Right to data portability: you can, at any time, request and receive, pursuant to Article 20, paragraph 1 of the Regulation, all of your Personal Data processed by the Data Controller and / or the Co-data Controllers in a structured format, with a common and legible use or request the transmission to another holder of the treatment without impediments. In this case, it will be your responsibility to provide us with all the exact details of the new data controller to whom you intend to transfer your Personal Data by providing written authorization.

* Right to oppose: pursuant to Article 21, paragraph 2 of the Regulation and as also reiterated by Recital 70, you may object, at any time, to the processing of your Personal Data if these are processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

* The right to lodge a complaint with the supervisory authority: without prejudice to your right to appeal to any other administrative or jurisdictional office, if you believe that the processing of your Personal Data carried out by the Data Controller and / or the Co-data Controllers is in violation of the Regulations and / or applicable legislation you can lodge a complaint with the competent Data Protection Authority.

To exercise all your rights as identified above, simply contact the Data Controller and / or the Co-data Controllers in the following ways:

By sending a written communication to the e-mail address info@elpower.it and / or by writing to the Owner Elpower s.r.l., via Beggiato, 23 – 36025 – Noventa Vicentina (VI) and / or by calling the number +39 0444 787882.

I. Where will your Personal Data be processed?

Your Personal Data will be processed by the Data Controller and / or by the Co-data Controllers within the European Union. If for technical and / or operational reasons it is necessary to make use of subjects located outside the European Union, we inform you from now on that these subjects will be appointed as Data Processors pursuant to and for the purposes of article 28 of the Regulations and the transfer of your Personal Data to these subjects, limited to the performance of specific treatment activities, will be regulated in accordance with the provisions of Chapter V of the Regulation. All necessary precautions will therefore be taken to ensure the fullest protection of your Personal Data by basing this transfer: (a) on adequacy decisions of the third country recipients expressed by the European Commission; (b) on appropriate guarantees expressed by the recipient third party pursuant to Article 46 of the Regulation; (c) on the adoption of binding corporate rules, c.d. corporate binding rules.