Legal Basis for Processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

•The User has given consent for one or more specific purposes.

•The processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations.

•The processing is necessary for compliance with a legal obligation to which the Data Controller is subject.

•The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

•The processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

It is always possible to request the Data Controller to clarify the specific legal basis for each processing activity and, in particular, to specify whether the processing is based on law, required by a contract, or necessary to enter into a contract.

Additional Information on Data Retention

Unless otherwise stated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be retained for a longer period due to any legal obligations or based on the Users’ consent.

Therefore:

•Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed.

•Personal Data collected for the purposes of the legitimate interests of the Data Controller will be retained until such interest has been satisfied. Users can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

•When processing is based on the User’s consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, after the expiration of this period, the right of access, deletion, rectification, and the right to data portability can no longer be exercised.

User Rights Under the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Data Controller. In particular, within the limits provided by law, the User has the right to:

•Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.

•Object to the processing of their Data. The User can object to the processing of their Data when it is carried out on a legal basis other than consent.

•Access their Data. The User has the right to obtain information about their Data processed by the Data Controller, about certain aspects of the processing, and to receive a copy of the Data processed.

•Verify and request rectification. The User can verify the accuracy of their Data and request that it be updated or corrected.

•Obtain the restriction of processing. The User can request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.

•Obtain the deletion or removal of their Personal Data. The User can request the deletion of their Data by the Data Controller.

•Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transferred to another controller without any hindrance.

•Lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.

Users have the right to obtain information about the legal basis for transferring Data outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, and about the security measures taken by the Data Controller to protect their Data.

Details About the Right to Object

When Personal Data is processed for the public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing for reasons related to their particular situation.

Users are reminded that, where their Data is processed for direct marketing purposes, they can object to the processing at any time without providing any justification. If Users object to the processing for direct marketing purposes, the Personal Data will no longer be processed for these purposes. To find out whether the Data Controller processes Data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to Exercise Rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. The request is free of charge, and the Data Controller will respond as quickly as possible, in any case within one month, providing the User with all information required by law. Any corrections, deletions, or limitations of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. The Data Controller will inform the User about these recipients if the User so requests.