DATA PROTECTION POLICY AND LEGAL NOTES

INFORMATION UNDER ART. 7, D.LGS 70/2003 AND EUROPEAN REGULATION 2016/679 (GDPR)

The following information is hereby provided under art. 7, D.Lgs [Legislative Decree] 70/03 “Implementation of Directive 2000/31/EC on certain legal aspects of information society services, in particular electronic commerce, in the internal market” and under art. 13 and14 of the European Regulation (679/2016 (GDPR).

Leonardo Trade s.r.l. unipersonale wants to inform you that your personal data collected on this Website and any other information that may be associated with you, either directly or indirectly, are treated following the principles of the EU Regulation 679/2016 (GDPR).

1. DATA CONTROLLER

The data controller is Leonardo Trade s.r.l. unipersonale (hereinafter the Controller)

• registered office: Via Eugenio Rigo 37, Prata Di Pordenone, PN 33080
• contacts: +39 0434 611202
• vat number: IT01588480937
• Rea: PN-88607
• Data Protection Officer, if appointed: request information from +39 0434 611202
• Share capital: € 25.000 fully paid up

2. PURPOSE OF PROCESSING AND LEGAL BASIS

For the effects and purposes of the above Regulation, the Controller informs you that any data acquired through the Website will be mainly processed by computerised means and procedures, for the following purposes:

• To enable you to register on the Website and take advantage of services reserved for registered users.
  Providing your data for this purpose is optional. If you do not provide your data, you will not be able to use the services offered in your personal area.
  The legal basis for the processing is the need to execute a contract to which you are a party and/or your explicit consent to the processing of your personal data.
• To allow the conclusion of the purchase contract and the correct execution of the administrative-accounting operations connected to the same.
  Providing your personal data for this purpose is compulsory, since, in case of non-conferment, Leonardo Trade s.r.l. unipersonale would not be able to process your order.
  The legal basis for the processing is the need to execute a contract to which you are a party and the need to fulfil legal obligations.
• Subject to your express consent, for the Controller to send you information and promotional communications (including newsletters and other marketing communications) relating to the products offered for sale on the Website, new arrivals, exclusive products, offers and promotions.
  Providing your personal data for this purpose is optional and you may object to such processing at any time.
  The legal basis for the processing is the legitimate interest of the Company in developing relations with its customers.
• Responding to your questions via contact forms and/or other channels (including live chat).
  Providing your personal data for this purpose is optional. However, in the absence of such consent, it will not be possible for Leonardo Trade s.r.l. unipersonale to respond to your requests.
  The legal basis on which the processing is based is the legitimate interest of the Company to develop relations with its customers.
• To keep a database of the most frequent questions, proposals, communications.
  Providing your personal data for this purpose is optional.
  The legal basis on which the processing is based is the interest of the Company to develop relations with the customers and to keep trace of the received requests to offer a better service.
• Technical management of the navigation (see also the “Cookie Policy” section).
  Providing your data for this option is optional.

3. SCOPE OF DATA COMMUNICATION (PERSONS WITH ACCESS TO THE DATA)

The personal data provided by you for the fulfilment of the purposes as per art. 2, may be brought to the attention of:

• employees and/or collaborators of Leonardo Trade s.r.l. unipersonale for the performance of administration, accounting and IT and logistical support activities who act as data processors;
• subjects that manage online payment transactions;
• public and/or private individuals and/or legal entities (legal, administrative and tax consultancy firms), if the communication is necessary or functional to the correct fulfilment of contractual obligations undertaken in relation to the services provided through the Website, as well as obligations arising from the law;
• subjects (including Public Authorities) who have access to the data by virtue of regulatory or administrative provisions;
• shippers and subjects in charge of delivery and/or collection of purchased products;

The persons in charge are bound by secrecy and confidentiality obligations, also based on an internal regulation on this subject. In any event, your data will never be disclosed to third parties.

4. DATA CONSERVATION

The Data Controller will keep the personal data you provide for a period of time no longer than is necessary to achieve the purposes for which they were collected and processed. In compliance with the regulations in force, including the accounting one, Leonardo Trade s.r.l. unipersonale will keep your personal data acquired through the sale of its products for a period not exceeding 10 years.

Leonardo Trade s.r.l. unipersonale will keep your data for marketing purposes for a period not longer than 24 months from the date you provide it and for profiling purposes for a period not longer than 12 months from the date you provide it.

In any case, once the purposes for which your personal data have been collected and processed have been achieved, we will remove them from our systems and records and/or take appropriate measures to make them anonymous so that you cannot be identified.

5. RIGHTS OF THE DATA SUBJECT

In relation of the treatment of your personal data, under the GDPR Regulation, the data subject has the right to:

• withdraw consent to the processing at any time. It should be noted, however, that revoking consent does not affect the lawfulness of the processing based on the consent before revocation, as provided for in Article 7(3) GDPR;
• request access to personal data from the Data Controller, as provided for in Article 15 GDPR;
• obtain from the Data Controller the rectification and integration of personal data deemed to be inaccurate, also by providing a simple supplementary declaration, as provided for by Article 16 GDPR;
• obtain from the Data Controller the deletion of personal data if any of the reasons set forth in Article 17 GDPR apply;
• obtain from the Data Controller the limitation of the processing of personal data if any of the cases provided for by Article 18 GDPR apply;
• receive from the Data Controller the personal data concerning him/her in a structured, commonly used and machine-readable format, as well as the right to transmit such data to another data controller without hindrance, as provided for in Article 20 GDPR;
• object at any time, on grounds relating to your particular situation, to the processing of personal data carried out pursuant to Article 6(1)(e) or (f), including profiling on the basis of those provisions, as provided for in Article 21 GDPR;
• to lodge a complaint with a supervisory authority (Art. 77) or bring an action before the appropriate courts (Art. 79), if you consider that the processing concerning you is in breach of the GDPR. The complaint may be lodged in the Member State in which you habitually reside, work or in the place where the alleged infringement has occurred.

You have the right to assert your rights against the Data Controller in the person of its legal representative or against the Data Protection Officer if the Data Controller has appointed one. The exercise of the aforementioned rights is subject to the limits, rules and procedures provided for in the aforementioned Regulations, which you must be aware of and implement. Furthermore, in accordance with the provisions of Article 12, paragraph 3, the Data Controller shall provide the data subject with information on the action taken without undue delay and, in any event, no later than one month from receipt of the request. This term may be extended by two months, if necessary, taking into account the complexity and number of the requests. The Controller shall inform the Data Subject of such extension, and of the reasons for the delay, within one month of receipt of the request.

INFORMATION ON THE USE OF COOKIE

Our website uses technical Cookie for a better performance and to ensure services provided by third parties.

Technical cookie are only used for the purpose of transmitting a communication over an electronic communication network, or to the extent strictly necessary for the provider of an information society service expressly requested by the subscriber or user to provide such service. They are not used for any other purposes, and are normally installed when you visit our pages. They may be subdivided into navigation or session cookie, which ensure the normal navigation and use of a website (by permitting to complete a purchase or to log in to enter reserved areas); functionality cookies, which allow the user to navigate taking into account a series of features previously chosen (e.g., language, products selected for purchase, etc.) in order to improve the service provided to the same. The installation of these cookies does not require the previous consent of the user, but there is an obligation to provide this information under art. 13 of the EU Regulation 2016/679 on the protection of personal data.

When browsing a website, a user can also receive, on his or her terminal, cookie of other sites or web servers (so-called “third-party” cookies); this is because the visited website may contain such elements as images, maps, sounds, specific links to webpages of other domains hosted on servers other than the one on which the requested page is. Leonardo Trade s.r.l. unipersonale uses analytics cookie, in particular cookies issues by Google Analytics services (used by Google to collect and then provide information, in aggregate form, regarding the number of users and how the same visit the website). The information generated by the cookie on the use of the website are communicated to Google Inc. (for information on the relevant use and disabling, see http://www.google.com/analytics/learn/privacy.html)

Third-party cookie may also be used on the website from:

• Facebook
• Instagram
• LinkedIn
• YouTube
• AdWords
• Smartlook
• Chat Zendesk

These cookie are not on the website servers, and therefore are not sent by the website on the user’s terminal. These cookie are enabled if the user clicks on the FB, IG, IN, YT icon, or enters their respective social sites, or uses the relevant services in API.

To revoke your consent to these cookie you can refer to the following sites:

• http://www.youronlinechoices.com/uk/your-ad-choices
• http://www.allaboutcookies.org/manage-cookies/index.html

In view of the particularly invasive nature that these devices may have with regard to the users’ privacy, we have asked you to consent in advance to their use, by a specific form in the home page of our website.