INFORMATION ON THE PROCESSING OF PERSONAL DATA

Dear User,

PALAZZETTI LELIO S.p.a., with headquarters in Via Roveredo, 103 - 33080 Porcia, Tel 0434 922922, email: privacy@palazzetti.it, as the Data Controller of personal data, communicates the following information, pursuant to and for the purposes of art. 13 of Regulation (EU) 2016/679 (hereinafter, “GDPR”), relating to the protection of individuals with regard to the processing of personal data.

Purposes of the processing and legal basis

Your personal data will be processed:

A. Without your express consent for the following purposes (cf. “Purpose of Service”):

a. the download and activation of the Palazzetti Application (“Palazzetti APP - Manage the stoves”);

b. diagnose problems in the APP;

c. investigate and respond to any comments or complaints that the User may send to us;

d. detect, prevent, or otherwise address fraud, technical or security issues, and piracy by helping to protect the User;

e. to provide the User with updates and technical information strictly related to the functionalities and services provided as well as advice on the use of the APP;

f. exercise the rights of the Data Controller.

In relation to these purposes, data processing is necessary to provide the requested Services or to comply with a legal obligation. The legal basis consists of the execution of contractual and pre-contractual obligations.

B. only with your specific and separate consent for the following purposes:

a. for sending information relating to your product or as part of the services provided by PALAZZETTI, or informational and/or advertising material (hereinafter, “Marketing Purposes”);

b. to identify and analyze your behavior by examining and mapping, for example, personal preferences, habits, movements, location (hereinafter, “Profiling Purposes”)

The legal basis for these purposes is the consent of the interested party.

The processing of your personal data will be based on the principles of fairness, lawfulness, transparency and the protection of your privacy and your rights.

In relation to the above purposes, PALAZZETTI may process “common” data that include, for example:

a. essential data for the identification of the user (e.g. name, tax code, addresses, e-mail, PEC, etc.)

b. essential data for the creation of the user's login profile (e.g. username, password and e-mail);

c. technical information such as information on device type, operating system, update status;

d. data essential for the management of the contract;

e. data relating to the use of the Services obtained during the use of the services by the User (e.g. specific functionalities used);

f. data relating to the geographical area from which you use the Services,

Data storage period

Your personal data will be processed for the time strictly necessary to achieve the above-mentioned purposes, after which they will be deleted or made anonymous.

With specific regard to the purposes described in point B), your personal data will be processed:

· for 12 months following the “Profiling” activities;

· for 24 months after the last submission with reference to “Marketing” activities;

Unless the revocation of your consent intervenes first, which may concern all, one or some of them.

Provision of data and consequences of failure to provide it

The provision of data for the purposes referred to in point A) is necessary for the provision of the service. The refusal to provide the service does not allow the provision of the service and the use of the APP [Palazzetti - Manage the stoves]”.

The provision of data for the Purposes referred to in point B) is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive invitations to events, newsletters and opinion and satisfaction surveys by e-mail and above all you will not receive information on personalized initiatives in line with your preferences. However, you will continue to receive the services referred to in point A).

Recipient categories

Your data may be communicated to third-party companies or other parties (suppliers, hardware and software support technicians, professional firms, etc.), who carry out outsourcing activities on behalf of the Data Controller as data processors.

If your data were to be processed on behalf of the Company by third parties, they will be designated as data controllers pursuant to art. 28 of the GDPR.

In any case, your data will NOT be disclosed.

Data transfer to a third country and/or an international organization

We may transfer your personal data to recipients outside the European Economic Area (EEA), to third countries. The transfer to these countries will always take place in accordance with the provisions of the legislation on the Protection of Personal Data, through the adoption of measures necessary to guarantee the security of the data being transferred, including the standard contractual clauses as developed by the European Commission.

Rights of interested parties

You have the right (see articles 15 - 22 of the GDPR) to ask our. Company to access your personal data and to rectify them if inaccurate, to delete them or limit their processing if the conditions are met, and to obtain the portability of the data you provide only if they are subject to automated processing based on your consent or on the contract.

You also have the right to revoke the consent given for the processing purposes that require it, without prejudice to the lawfulness of the processing carried out until the moment of revocation.

You can exercise your rights at any time by contacting the Data Controller at the references above.

You also have the right to lodge a complaint with the competent supervisory authority in the matter, Guarantor for the protection of personal data.

Update Date: June 2023