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Personal Data Protection Information The Italian legislative decree n196 of 30 June 2003 on the personal data protection act, hereinafter referred to as “code”, shall ensure that personal data are processed by respecting data subjects’ rights and the subject shall be informed of said rights and where necessary give express consent to their handling. According to article 4 of the Code, processing personal data shall mean any operation, or set of operations, carried out with or without the help of electronic or automated means, concerning the collection, recording, organisation, keeping, interrogation, elaboration, modification, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasure and destruction of data, whether the latter are contained or not in a data bank; Article 23 of the Code allows the processing of personal data by private entities only if the data subject gives his/her express consent. The data subject’s consent shall only be deemed to be effective if it is given freely and specifically with regard to a clearly identified processing operation if it is documented in writing Consent shall not be required in the cases noted in article 24 of the Code if the processing a) is necessary to comply with an obligation imposed by a law, regulations or community legislation; or b)is necessary for the performance of obligations resulting from a contract to which the data subject is a party, or else in order to comply with specific requests made by the data subject prior to entering into a contract or c) concerns data taken form public registers, lists, documents or records that are publicly available. Nextplora S.p.a manages the website www.nextplora.com and its connection services, it is therefore owner of the personal data handling and furnishes in accordance with article 13 of the Code, information on the use of the aforementioned data. Please examine closely the following information that illustrates the data subject’s rights and the management on the part of Nextplora S.p.a and give your consent to the use and handling of said data. 1. Data source I. The personal data in our possession were furnished by yourself when registering or compiling a market research questionnaire through the site www.nextplora.com. 2. Nature of personal data handled The personal data subject to processing is i) personal identification data such as name, address, email address, telephone numbers. ii) personal profile information of the data subject such as marital status, family status, nationality, educational background, cultural background, personality, preferences, lifestyle habits. iii) other sensitive data relative to political opinion. 3. Methods of personal data handling- security requirements. 3.1 Personal data is handled by Nextplora S.p.a, it is handled anonymously through electronic transmission, non electronic means and through organization of the same into prevalently automatic data banks. Data is processed in accordance with articles 11 and 31 of the Code pertaining to processing and security requirements of data handling and the preventative security measures for safe-keeping and control. 3.2 Nextplora S.p.a guarantees discretion in it’s data privacy protection using the most suitable technological innovations in line with Italian and European standards in such a way as to minimise security risk, unauthorized access , loss, and destruction, whether by accident of not 3.3 Minors under the age of 18 can only utilize Nextplora S.p.a services with parental supervision. 4. Communication and circulation limits of data handling. 4.1 Personal data will be handled in full compliance with the Code where relevant to Nextplora S.p.a activities and www.nextplora.com website management, and connected services in particular: (i) for administrative and accounting purposes fiscal and no, for service provider and client management and internal control. (ii) to provide the necessary assistance and information for using Nextplora S.p.a services. As well as, with express consent: (iii) for direct and indirect mailing of advertising material relative to Nextplora S.p.a services and Nextplora client products and services, whether by traditional post, electronic post, facsimile, SMS, or automated call systems; (iv) for promotional materials, market research, sampling, gathering of statistics, whether marketing and general, via automated call systems, facsimile, SMS and similar including after the cessation of relations; (v) for customer and user satisfaction surveys whether through automated call systems, or facsimile; (vi) for commercial and sales use of personal data; (vii) for orchestration of anonymous profiling; (viii) for payment service management; (ix) for third party communication necessary to carry out payments, whether for commercial activities or asset and service distribution. 4.2. Data handling processes referred to in section 2 are applicable nationally and internationally 5. Third party disclosure 5.1. Within the limits of the Code, personal data supplied by the data subject to Nextplora S.p.a, may be disclosed to the following third parties: (i) government and private agencies in accordance with the law; (ii) government and private entities that hold public registers and directories, which are matters of public record. As well as with express consent to: (iii) societies in collaboration and/or controlled by Nextplora S.p.a to the same ends as stated in article 2; (iv) government and private entities with whom Nextplora S.p.a has contractual agreements exclusively for a) market research, sampling and statistic gathering, and marketing activities, b) promotional and advertising activities for goods and services, and c) commercial sales and distribution of goods and services; (v) banks, credit institutions, and other non-banking financial institutions for service management and payments; (vi) public security authorities or the police; (vii) Nextplora S.p.A. consultants and professionals (legal council, accountant, etc). 5.2. The dissemination of personal data cited in section 5.1. above refers to national and international distribution, whether within or outside of the European Union. 6. Personal data keeping 6.1. Personal data is kept on the Nextplora S.p.a. server. To eliminate personal data from the Nextplora S.p.a server send an email to unsubscribe@nextplora.com with "Cancel my personal data". The subject’s data will be cancelled within 60 days of the request date. 6.2. Upon account suspension, all of the personal data in the possession of Nextplora S.p.a. will be eliminated excepting: a) personal data that responds to specific request by judicial authority. b) data necessary for invoicing. The data in point 6.2 will be kept by Nextplora S.p.a. exclusively for the above mentioned purposes for the longer of either a period of 5 years or that period required by law. 7. Communication of mandatory and facoltative data 7.1The communication of certain data, where specified in the registration form, is mandatory in order to use Nextplora S.p.a services. In the cases not specified, the communication of personal data is facultative. 7.2 Nextplora S.p.a will not provide services upon the failure to communicate the requested mandatory personal data and, where required by law, consent to the handling of said personal data. 8. Data subject rights Article 7 of the Code details certain rights of the data subject, in particular: 1) A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.. 2) A data subject shall have the right to be informed: a) of the source of the personal data; b) of the purposes and methods of the processing; c) of the logic applied to the processing, if the latter is carried out with the help of electronic means; d) Of the identification data concerning data controller, data processors and the representative designated; e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.. 3) A data subject shall have the right to obtain: a) updating, rectification or, where interested therein, integration of the data; b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a)and b)have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.. 4) A data subject shall have the right to object, in whole or in part,: a) on legitimate grounds, to the processing of personal data concerning him/her even though they are relevant to the purpose of the collection; b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.. For Exercising the Data subject’s rights, refer to article 8 (Exercise of Rights), article. 9 (Mechanisms to Exercise Rights) and article.10 (Response to Data Subjects) of the Personal Data Protection Code. 9. Data Controller With regards to personal data handled directly by us we inform you that: a) the data controller, in accordance with article 28 of The Privacy Code, is Nextplora S.p.a, the legal representative is Mr Andrea Giovenali based in 3 Viale Gian Galeazzo, Milan Italy. b) the agency responsible for data handling is Sinergia S.r.l based in Vittorio Emanuele II, 237 Turin, to whom interested subjects can exercise their rights according to article 7 of the Code, in such a case, requests will be forwarded to the data owner, who will respond directly to the data subject.

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