ANFATIS S.P.A., based in Milan, in Viale Majno no. 40, tax identification number 04494350962 (hereinafter “ANFATIS S.P.A.”) respects the privacy of its users and is committed to protecting the personal data they submit to ANFATIS S.P.A. In general, the user can browse the ANFATIS S.P.A. website without providing any kind of personal information. ANFATIS S.P.A collects and processes personal data when necessary for the execution of services requested by the user, or when the user decides to disclose their personal data. Under such circumstances, this privacy policy illustrates the methods used and the nature of collection and processing of the user’s personal data. ANFATIS S.P.A. processes personal data provided by users in compliance with relative laws and regulations in force.

Data controller and Data Protection Officer

The Data Controller of your Personal Data is ANFATIS S.P.A. based in Viale Majno, 40 – Milan (MI), tax identification number 04494350962 Dr. Jacopo Jacopetti is the Data Protection Officer (DPO) and can be contacted by the data subject at any time by phone at 049761980 or 049761865, or by e-mail at j.jacopetti@anfatis.it, or by certified email at ANFATIS@legalmail.it

Personal Data Collection

Personal data means any information that can be used to identify an individual, a company or other body and which can provide information on their characteristics, habits, lifestyle, personal relations, health, economic situation or similar. By way of example but not of limitation: name and surname, e-mail address, a postal address or another physical address, other information necessary for contacting the user, qualification, date of birth, sex, work, commercial activity, personal interests and other information necessary for the provision of services requested by the user.

Visitors to the ANFATIS S.P.A. website browse anonymously. ANFATIS S.P.A. does not perform automatic user data collection operations, including by e-mail. ANFATIS S.P.A.records the user’s IP address (Internet Protocol, the internet address of the user’s computer) to find out the area of the website visited by the user, in compliance with personal data protection laws and regulations. However, ANFATIS S.P.A. does not correlate the user’s IP address with other personal information regarding the user unless duly informing them of the relative processing involved and obtaining their consent to processing, strictly limited to users registered on the ANFATIS S.P.A website. As with many other websites of a services-oriented nature and with contents to this effect, the ANFATIS S.P.A. website may use a standard technology called a “cookie” to collect information on user website use. For further information, the user is invited to consult the “Cookie Policy” section

Conservation of Personal Data

Personal data processed for the purpose of “Service Provision/ Contractual obligations” will be stored for the time strictly necessary for the pursuit of said purposes. In any case, given that Personal Data are processed for the purpose of providing Services, the Data Controller may conserve them for a longer period, especially if necessary for the purpose of protecting their own rights, also with reference to any claims or actions that may be brought against them in relation to the provision of Services.

Personal Data processed for the purpose of the Sending of commercial information will be conserved by the Data Controller until the data subject objects to processing.

Personal Data processed for the purposes of fulfilling statutory obligations set forth in legislation, regulations or by order of Judicial or Administrative Authorities, will be conserved by the Data Controller for the period specified by applicable legislation or by order of the Administrative of Judicial Authorities.

Methods and Purposes of Collected Data Processing

ANFATIS S.P.A.processes the user’s personal data for the following general purposes: to satisfy requests pertaining to specific products or services, to update the user on the latest news regarding services by ANFATIS S.P.A., or other information that ANFATIS S.P.A. believes may be of interest to the user, from ANFATIS S.P.A. or its partners, and to gain a better understanding of the user’s needs while also providing enhanced services. The processing of the user’s personal data by ANFATIS S.P.A. for the aforementioned specified purposes takes place in compliance with personal data protection regulations in force.

Recipients of Personal Data

The Data Subject’s Personal Data may be shared with persons or entities listed here below (“Recipients”):

– persons or entities who typically act in their capacity as data processors, therefore: persons, companies or professional firms that provide assistance and consultancy services for accounting, administrative, legal, tributary, financial or credit recovery services, pertaining to the provision of Services, the mailing of advertising material or contractual notifications, companies that provide market analysis

– persons or entities with whom interaction is required for the purposes of the provision of communication Services, events and seminars, including online;

– persons or entities appointed to carry out technical maintenance (including the maintenance of network devices and electronic communication networks);

– affiliate companies of the Group, for internal administrative purposes;

– factoring companies, credit institutes, credit insurance companies;

– professional boards or training bodies accredited with said Boards;

persons, entities or competent Authorities to whom Personal Data disclosure is a mandatory requirement, in order to comply with the law, counter abuse or fraud, or by order of Authorities.

Rights of the data subject

In their capacity as data subject, persons enjoy the rights specified under sections 2, 3 and 4 of paragraph II of (EU) Regulation 2016/679 (e.g. the right to request any of the following from the Data Controller: access to personal data, the rectification or erasure thereof; limitation of processing regarding them and the right to object to the processing thereof). Specifically, the Data subject has the right to:

1) Obtain confirmation on the existence or otherwise of personal data regarding them, even if they are not yet registered, and under such circumstances, to obtain access to Personal Data and other information as provided for in art. 15 EU Regulation no. 679, 27th April 2016, and the communication thereof in an intelligible form;

2) Obtain the following information: a) the origin of Personal data; b) the purposes and methods of Personal Data processing; c) the method applied to processing, if carried out using electronic tools; d) the identification details of persons or entities or categories of persons or entities to which personal data may be disclosed, or which may come into the knowledge of said data in their capacity as designated supervisor within State territory;

3) obtain: a) the updating, rectification, or when you have an interest in doing so, the integration of data; the erasure, transformation into anonymous form or the blocking of Personal Data processed in breach of the law, including those for which conservation is not necessary in relation to the purpose for which data were collected or successively processed, c) certification that operations as set forth under letters a) and b) have been brought to the attention of those to whom data has been disclosed or provided, with reference to content, except for in cases when such notification proves impossible or requires the use of means clearly disproportionate to the right being protected;

4) obtain the limitation of processing from the data controller when: a) the data subject contests the exactness of personal data, for the period necessary for the Data Controller to verify the inaccuracy of said personal data; b) when processing is illicit but the data subject objects to erasure and instead requests the application of limitation measures or requests that processing occurs in order to ascertain or in defence of one of their rights in legal proceedings; 5) object to, in full or in part: a) the processing of personal data regarding them for legitimate reasons, even if still pertinent to the purpose for which they were collected; b) the processing of personal data regarding them, for the purposes of sending advertising material or for carrying out market research or for commercial communication purposes;

5) object to the processing of personal data regarding them under the conditions specified in Art. 21, paragraph 2, EU Regulation no. 679, 27th April 2016.

Procedures for the exercising of rights

The data subject can exercise the aforementioned rights at any time:

– by sending a registered letter with return receipt to Anfatis S.p.a. (Operating Office) in Corso Spagna 18, Padua 35127

or

– by sending a message by Certified Email to the following certified email address: ANFATIS@legalmail.it.

DATA SECURITY

ANFATIS S.P.A. adopts all security measures and physical, electronic and organisational procedures required by regulations in force. Even if ANFATIS S.P.A. does all that it reasonably can to protect the user’s personal data, ANFATIS S.P.A. cannot guarantee the full security of data submitted by users during communications and therefore ANFATIS S.P.A. warmly invites the user to adopt all precautionary measures for the protection of their personal data when browsing on the internet.

Third Party Websites

The ANFATIS S.P.A. website contains links to other websites. ANFATIS S.P.A. does not share the user’s personal data with this website and is not responsible regarding the practices of said website in relation to the safeguarding and processing of personal data. ANFATIS S.P.A. invites all users to read the privacy policies of such websites to find out about the processing and collection methods applied by said third party websites.

Amendments to the Privacy Policy

ANFATIS S.P.A. will modify this Privacy Policy on a time to time basis. Should ANFATIS S.P.A. substantially modify methods used for processing the user’s personal data, such information will be made public in a specific statement on its website.

Questions or Suggestions

In the event of any questions or doubts regarding the collection, use, processing, disclosure or distribution of your personal data, the user can send an e-mail to the following e-mail address info@anfatis.it