THE COMPANY WITH A BUSINESS NAME

H.A.R.G. S.B. S.R.L., with registered office in Via Cefalonia, 70, – 25124 Brescia BS, C.F. 03940290988, P.I. 03940290988 (hereinafter, “Data Controller”), as data controller, informs you in accordance with EU Regulation no. 2016/679 (hereinafter, “GDPR”) that your data will be processed in the following manner and for the following purposes:

1. OBJECT OF TREATMENT

The Controller will process data that falls within the definitions of Art. 4(1) of the Regulations collected during the execution of the mandate, including but not limited to your first name, last name, mobile phone number, e-mail address, and in general contact details of your contact persons, hereinafter and collectively only “Personal Data”.

2. PURPOSE OF PROCESSING

Your personal data are processed:

1. A) without your express consent ex art. 6 lett. b), (c) GDPR), for the following purposes:
   • Conclude contracts for the Holder’s services;

• Fulfill pre-contractual, contractual and tax obligations arising from existing relationships with you;
• Fulfilling legal obligations or orders of the Authority;
• Exercise the rights and legitimate interests of the Owner (e.g., the right to defense in court).

1. B) Only with your specific and separate consent (art. 7 GDPR), for the following marketing purposes:
   • To send you via e-mail, mail and/or text message and/or telephone contact, newsletters, commercial communications and/or advertising material on products or services offered by the Owner and satisfaction survey on the quality of services;
   • To send you via e-mail, mail and/or text message and/or telephone contact commercial and/or promotional communications from third parties (for example: business partners).

3. MODE OF TREATMENT

The processing of your personal data is carried out by means of the operations specified in Art. 4 n. 2) GDPR and namely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data. Your personal data are subject to both paper and electronic and/or automated processing.

The Data Controller will process personal data for as long as necessary to fulfill the above purposes and in any case for no longer than 10 years after the termination of the relationship for the purposes under art. 2 A) and for no more than 2 years after the collection of data for the purposes under art. 2 B).

4. DATA ACCESS

Your data may be made accessible for the purposes of Art. 2.A) and 2.B):

• to employees and collaborators of the Owner, in their capacity as internal data controllers or appointed by them to carry out specific processing activities pursuant to Article 28 no. 4 GDPR;
• to third parties (by way of example: credit institutions, professional firms, consultants) carrying out activities on behalf of the Controller, in their capacity as external data processors.

5. COMMUNICATION OF DATA

Without the need for express consent (Art. 6 lett. (b) and (c) GDPR), the Controller may disclose your data for the purposes set forth in Art. 2.A) to those persons to whom disclosure is required by law or for the fulfillment of such purposes.

6. DATA TRANSFER

Personal data are stored on servers located at Via Morandi, 17 26039 Vescovato CR, within the European Union.

In case of data transfer to non-EU countries, the Data Controller assures as of now that the data transfer will take place in accordance with the provisions of Chapter V GDPR.

7. NATURE OF DATA PROVISION AND CONSEQUENCES OF REFUSAL TO RESPOND

The provision of data for the purposes of Art. 2.A) is mandatory. In their absence, we will not be able to guarantee you the services of Art. 2.A).

The provision of data for the purposes of Art. 2.B) is, on the other hand, optional.If the requested data is not provided, you will not be able to receive newsletters, commercial communications and advertising material related to the services offered by the Owner. He will still continue to be entitled to the services under Art. 2.A).

8. RIGHTS OF THE DATA SUBJECT

In your capacity as a data subject, you are entitled to exercise your rights under Articles 14 n.2 and 15 GDPR, namely the rights to:

1. To obtain confirmation of processing of personal data concerning you and in that case to obtain access to such personal data and the following information: purpose of the processing; categories of personal data; recipients to whom they have been or will be communicated; storage period or criteria used to determine it; all available information on their origin; the existence of an automated decision-making process.
2. To revoke the consent given under Art. 7 n. 3) GDPR
3. Propose a complaint to a supervisory authority under Art. 14(e)and 77 GDPR
4. obtain:
   1. The rectification of inaccurate personal data concerning you in accordance with Art. 16 GDPR;
   2. The deletion of data in accordance with Art. 17 GDPR;
   3. A statement that the transactions referred to in paras. (a) and (b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves the use of means manifestly disproportionate to the right protected;
   4. The limitation of processing under Art. 18 GDPR;
   5. The portability of data under Art. 20 GDPR.
5. object in whole or in part under Art. 21 GDPR:
   1. for legitimate reasons to the processing of personal data concerning you, even if relevant to the purpose of collection;
   2. to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator by e-mail and/or through traditional marketing methods by telephone and/or paper mail.

It should be noted that the data subject’s right to object, set forth in (b) above, for direct marketing purposes by automated means extends to traditional methods, and that, in any case, the data subject’s right to object may still be exercised even in part. Therefore, the data subject may choose to receive only communications by traditional means or only automated communications or neither type of communication.

9. WAYS OF EXERCISING RIGHTS

You may at any time exercise your rights by sending:

• A registered letter with return receipt to H.A.R.G. S.B. S.R.L. – with operational headquarters at Via Morandi, 17, 26039 Vescovato CR;
• an e-mail to info@harg.it.

10. OWNER, MANAGER AND APPOINTEES

The data controller is.

H.A.R.G. S.B. S.R.L. with registered office in Via Cefalonia, 70, – 25124 Brescia BS.

The updated list of data processors and proxies is kept at the registered office of the Data Controller.

11. DATA PROTECTION OFFICER

The Data Protection Officer pursuant to Art. 37 of Reg. EU 2016/679 is Dr Davide Allegrini, contact: email: dav.allegrini@pec.it.
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H.A.R.G. S.B. S.R.L.