REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND COUNCIL OF 27 APRIL 2016

Pursuant to Article 13 of Regulation (EU) no. 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 (General Regulation on Data Protection, hereinafter also referred to as the "Regulation" or "GDPR"), which repeals Directive 95/46/EC, we hereby inform you that the personal data you voluntarily made available to Virgilio Pandolfi (hereinafter also referred to as "the Company") will be processed in compliance with current legislation on the protection of personal data and, in any case, the principles of confidentiality the Company's activities are based on..

1. Processed data categories

Virgilio Pandolfi will process the following personal data provided by the party concerned:

Personal data (such as: name, surname), company name, VAT number, address, house number, city, postal code, Province, Country, email, mobile phone

2. Purpose of processing

The personal data you have made available to Virgilio Pandolfi may be used for the following purposes

a) consent to and manage your membership/subscription in relation to offers

b) allow you to use the products and/or services, as well as perform the activities reserved to you by virtue of adherence to the offer;

c) for administrative accounting purposes and for the fulfilment of obligations under current law;

d) after your specific consent, sending information and commercial communications, also of a promotional nature (including our newsletter), advertising material and/or offers of goods and services, by any means (known or not), including, for example, mail, Internet, telephone, e-mail, MMS, SMS from Italy or abroad (also from countries not belonging to the European Community) by Virgilio Pandolfi, parent companies, affiliates and/or subsidiaries thereof, as well as by natural or legal persons contractually related to Virgilio Pandolfi who send communications on behalf of Virgilio Pandolfi;

e) after your specific consent, profiling your activities, or allowing the processing and completion of studies and statistical and market research, as well as for the analysis of tastes, preferences, habits, needs and consumption choices and to receive customised offers based on Virgilio Pandolfi's purchase preferences of parent companies, affiliates and/or subsidiaries thereof, as well as, on behalf of Virgilio Pandolfi, by related natural or legal persons contractually related to Virgilio Pandolfi and/or who, in any case, collaborate in Virgilio Pandolfi’s commercial activities;

f) following your specific consent, transfer of data to Virgilio Pandolfi business partners for the purpose of receiving their communications.

We would like to remind you that, with reference to the purposes described in points a), b) and c), the provision of your personal data is mandatory. Your possible refusal and/or the provision of incorrect and/or incomplete information will prevent

- in reference to the purpose referred to in point a): your membership/subscription to offers;;

- in relation to the purpose referred to in point b): use of the products and/or services, as well as performing the activities reserved to you by virtue of adherence to the offer;

- in relation to the purpose referred to in point c): for Virgilio Pandolfi, the performance of administrative and accounting activities and the fulfilment of regulatory obligations.

With reference to the other purposes described in points d), e) and f) the provision of your personal data, and consent to the processing of the same for the above-mentioned purposes, is optional. However, your refusal to provide your data and/or consent to processing for the above-mentioned purposes and/or the provision of inaccurate and/or incomplete information may prevent the Company:

- in relation to the purpose referred to in point d): sending promotional communications by Virgilio Pandolfi;

- in relation to the purpose referred to in point e): carrying out profiling activities and sending customised offers based on your purchase preferences by Virgilio Pandolfi;

- in relation to the purpose referred to in point f): the transfer of your data to Virgilio Pandolfi business partners for sending their communications.

3. Processing methods

Your personal data will be processed using appropriate hard-copy, electronic and/or telematic means, with a logic strictly related to the aforementioned purposes and, in any case, in such a way as to ensure the security and confidentiality of the data.

4. Recipients or categories of recipients of personal data

The following may come into contact with your data in carrying their functions: shareholders, Data Protection Officer, members of the Board of Directors or other administrative body and, in any case, the Managers designated by Virgilio Pandolfi and the persons in charge of processing personal data appointed by the Company.

Your personal data may be disclosed to any qualified persons who provide Virgilio Pandolfi with services instrumental to the purposes indicated in section 1 above, for example, parent companies, subsidiaries, investee companies and/or affiliates; suppliers, contractors, subcontractors, banking and/or insurance institutions or other entities and/or bodies that provide (on behalf of Virgilio Pandolfi):

- management and/or maintenance of websites and electronic and/or telematic tools used by Virgilio Pandolfi;

- management of access/subscription to offers;

- the sending of informative and promotional communications, also of a commercial nature, of advertising material and/or offers of goods and services;

- carrying out profiling activities, including the identification of habits, tastes, preferences and consumption choices, as well as the development and completion of studies and market research

Your personal data may be transferred abroad, in accordance with the provisions of current legislation, even in countries that do not belong to the European Union where the Company pursues its interests.

Transfer to countries outside the EU, in addition to cases in which this is ensured by Committee Decisions on Adequacy, carried out in such a way as to provide appropriate and opportune guarantees pursuant to article 46 or 47 or 49 of the Regulation

5. Duration of the processing and criteria used for the storage of data

The data will be processed only for the time necessary to fulfil the above-mentioned purposes.

The data processed for the purposes of marketing, profiling and communication to third parties will be processed until consent by the party concerned is revoked.

Your data will be stored according to the following criteria:

- the data processed for membership/subscription to loyalty programs will be stored as long as you adhere to such programmes and for a period of 10 years following the termination of the relationship, unless there is a need for further conservation, in order to allow Virgilio Pandolfi to defend its rights;

- with particular reference to the data processed for profiling purposes, personal data relating to the purchase details (or associated to the latter) will be processed for a maximum period of 24 months

6. Rights of the party concerned

We inform you that at any time in relation to your data, you may exercise the rights provided for within the limits and conditions set forth in articles 7 and 15-22 of the Regulation.

In order to exercise these rights, as described below, please contact the Data Controller via the Privacy office at the e-mail address info@virgiliopandolfi.com. Your request will receive appropriate feedback within the time prescribed by the GDPR.

In detail, the party concerned has the right to:

- revoke consent that was previously given, without prejudice to the lawfulness of the processing based on consent before revocation;

- ask the Data Controller to access, correct or delete ("Right to Oblivion") personal data or limit the processing of personal data concerning you or to object to its processing;

- obtain data portability;

- oppose its processing;

- propose a complaint to the Supervisory Authority for the protection of personal data if you believe that your rights have been violated.

7. Data controller and data processor.

The data controller in relation to your data is EVANTHIA INTERNATIONAL LIMITED - Trident House, Dublin Road, W91 VY6W - Naas - Ireland.

Any request relating to personal data processed by Virgilio Pandolfi. may be sent to the Company's registered office, or by sending an e-mail to info@virgiliopandolfi.com. An updated list of Managers is available from the Company and may be obtained via a specific request formulated in the manner indicated above.

The following is the Data Protection Officer: info@virgiliopandolfi.com

This information will be subject to updates. Virgilio Pandolfi therefore invites Users who wish to know how the personal data collected by Virgilio Pandolfi is processed to visit this page periodically.