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PRIVACY POLICY

Information on the Processing of Personal Data

DST Group Srl , with headquarters in San Giuseppe Vesuviano (NA), at Via Pianillo n. 149 (VAT no. 05873991219) in the person of the legal representative pro tempore Mr. Alessandro Casillo (the “Owner”), exclusive owner of the “ZU Elements” brand, is constantly committed to protecting the online privacy of users of the website www.zuelements.it (the site "). This document (the “ Information ”) has been drawn up in order to allow you to understand how your Personal Data, as defined below, will be processed when using the Site. The Information is intended to provide you with information necessary so that you can express explicit and informed consent to the processing carried out through the Site, if you deem it appropriate.

In general, any information or Personal Data that you provide to the Owner via the Site, or that is collected in another way through the Site, or that you provide to the Owner by registering on tablet devices in our flag stores, as part of the use of the services offered by DST Group Srl (the " Services "), as better defined in the following Paragraph 3, will be treated according to the principles prescribed by EU Regulation 2016/679 and internationally recognized, of lawfulness, correctness, transparency, purpose limitation and conservation, data minimization, accuracy, integrity and confidentiality

1. DATA CONTROLLER AND DATA PROTECTION OFFICER

DST Group Srl, as identified at the beginning of the Information, is the Data Controller in relation to all Personal Data that is processed through the Site.

You can contact the Data Protection Officer (“ DPO ”) of DST Group Srl at the following address: info@dstgroup.it.

2. THE PERSONAL DATA SUBJECT TO PROCESSING

Following navigation of the Site, we inform you that the Owner will process your Personal Data, which may consist - also depending on your decisions on how to use the Services - by an identifier such as your name, your e-mail address, a identification number, an online identifier or one or more characteristic elements of your physical, physiological, mental, economic, cultural or social identity capable of making you identified or identifiable (hereinafter only " Personal Data ").

Your Personal Data may be collected either because you voluntarily provide it (e.g. when you sign up for the Newsletter or register through our flag stores) or simply by analyzing your behavior on the Site.

The Personal Data processed through the Site are as follows:

A. Name, contact details and other Personal Data

In various sections of the Site, in particular the one relating to the creation of a personal account, you will be asked to enter information such as your name, telephone number, email address, date of birth, country of residence, gender , postcode etc.

Furthermore, when you communicate with the Owner through the contacts you find on the Site or with Customer Care, the Owner may collect any additional information you decide to provide.

B. Location Data

To provide you with increasingly precise and useful Services, the Owners may ask you to manually enter a physical address, postal code or simply the State to find the nearest ZU Elements Store.

Alternatively, and subject to your prior and explicit consent, your Internet browsing program (so-called " Browser ") could share with the Site an approximation of your geographical position through information on wireless access points in your vicinity and on the the IP address of your device.

In both cases, it is a treatment for the use of Personal Data that is entirely optional but extremely useful to the Data Controllers for the provision of increasingly useful Services. If you feel that accessing your approximate location through sharing via Browser is too invasive, you can always withdraw your consent from your Browser settings (or your operating system settings). For further information, please consult the specific privacy policies of your browser.

C. Special categories of personal data

Some sections of the Site include free fields in which you can provide the Owners with some information, which may contain Personal Data.

Since these fields are free, you may use them to communicate (voluntarily or otherwise) some sensitive categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to a natural person's health or sex life or sexual orientation.

The Data Controllers invite you not to send such Personal Data unless strictly necessary. Indeed, these special categories of Personal Data can only be processed with your explicit consent (manifestable via the flag on the Application screen) and in compliance with the legislation in force at the time. The Data Controllers therefore underline the importance of expressing your explicit consent to the processing of special categories of Personal Data, should you decide to share such information.

D. Data provided voluntarily by the interested party

As already mentioned above, in some parts of the Site you are allowed to insert text messages or information, visible to the Owner, which may contain Personal Data of other people.

With respect to these hypotheses, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you grant on this point the broadest indemnity with respect to any dispute, claim, request for compensation for damage caused by treatment, etc. that should reach the Data Controller from third parties whose Personal Data has been processed through your use of the Site's functions in violation of the applicable personal data protection regulations. In any case, if you provide or otherwise process Personal Data of third parties when using the Site, you guarantee from now on - assuming all related responsibility - that this particular processing hypothesis is based on the consent of said third party or on another suitable legal basis that legitimizes the processing of the information in question.

E. Browsing data

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the addresses in URI (Uniform Resource Identifier) ​​notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site or third parties: except for this eventuality, data on web contacts currently do not persist for more than 50 days.

F. Cookies

Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on their computer or mobile device, to be then re-transmitted to the same sites on the next visit. Thanks to cookies, a site remembers the user's actions and preferences (such as, for example, the chosen language, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns. to visit said site or navigate from one page to another of it. Cookies, therefore, are used to perform computer authentication, monitor sessions and store information regarding the activities of users who access a site and can also contain a unique identification code that allows tracking of the user's navigation within of the site itself for statistical or advertising purposes. While browsing a site, the user may also receive cookies on his computer from sites or web servers other than the one he is visiting (so-called "third party" cookies ).

Some operations could not be carried out without the use of cookies, which in certain cases are therefore technically necessary for the functioning of the site.

There are various types of cookies, depending on their characteristics and functions, and these can remain on the user's computer for different periods of time: so-called session cookies , which are automatically deleted when the browser is closed; so-called persistent cookies , which remain on the user's equipment until a pre-established expiry date.

Based on applicable legislation, express user consent is not always required for the use of cookies. In particular, "technical cookies" do not usually require such consent, i.e. those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user. In other words, these are cookies that are essential for the functioning of the site or necessary to carry out activities requested by the user.

For " profiling cookies ", vice versa, i.e. those aimed at creating profiles relating to the user and used in order to send advertising messages in line with the preferences expressed by the user when browsing the net, prior consent is usually required of the user, as far as it depends on the applicable legislation.

Types of cookies used by the Site and possibility of (de-)selection

The Site uses the following cookies which can be de-selected, except for third-party cookies for which you will have to refer directly to the relevant selection and de-selection methods of the respective cookies, indicated via links:

• Technical navigation or session cookies , strictly necessary for the functioning of the Site or to allow you to use the contents and services requested.

•Analytical cookies , which allow us to understand how the Site is used. With these cookies, no information about your identity or any Personal Data is collected. The information is processed in an aggregate and anonymous form.

• Functionality cookies , i.e. used to activate specific features of the Site and a series of selected criteria (for example, the language) in order to improve the service provided.

•Profiling cookies used to send advertising messages in line with the preferences expressed by you when browsing the internet.

The Data Controller also uses third-party cookies , i.e. cookies from sites or web servers other than that of DST Group Srl, used for the purposes of said third parties, including profiling cookies. It should be noted that these third parties, listed below with the relevant links to the privacy policies, are typically independent data controllers of the data collected through the cookies they serve, or act as data controllers for the Data Controllers (i.e. they process Personal Data on behalf of the Data Controllers).

As regards third parties who send cookies via the Site, below you will find the links to their respective privacy policies:

· Google : https://www.google.com/policies/privacy/partners/ https://tools.google.com/dlpage/gaoptout.

· DoubleClick – Google : https://policies.google.com/privacy?hl=en

· Adform : https://site.adform.com/privacy-policy-opt-out/

· Facebook : https://it-it.facebook.com/about/privacy/update

· Youtube: https://www.youtube.com/static?gl=IT&hl=it&template=terms

Cookie settings

Cookie settings

You can block or delete (in whole or in part) technical and functional cookies through the specific functions of your browser. However, we inform you that not authorizing technical cookies could make it impossible to use the Site, view its contents and use the related services. Inhibiting functionality cookies could mean that some services or certain functions of the Site are not available or do not work properly and you may be forced to modify or manually enter some information or preferences each time you visit the Site.

The choices made in relation to the Site's cookies will in turn be recorded in a specific cookie. This cookie may, however, in some circumstances not work correctly: in such cases, we recommend that you delete unwanted cookies and inhibit their use also through the functionality of your browsers.

Your preferences regarding cookies will need to be reset if you use different devices or browsers to access the Site.

How to view and modify cookies through the browser

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your browser. For more information on how to set preferences on the use of cookies through the browser, you can consult the relevant instructions:

Internet Explorer

Firefox
Chrome
Safari

You can also manage your choices regarding third-party cookies using online platforms such as AdChoice .

ATTENTION : by disabling technical and/or functional cookies the Site may not be available for consultation or some services or certain functions of the Site may be unavailable or may not function correctly and you may be forced to modify or manually enter some information or preferences every time you visit the site.

3. PURPOSE OF THE PROCESSING

The Owner will use your Personal Data, collected through the Site, for the following purposes:

•provide Services such as: sending you the ZU Elements newsletter that you requested as a Service by subscribing and which contains only informative and non-commercial material; find the ZU Elements Store closest to you and provide you with any other Service you request (“ Service Provision ”);

• send you marketing communications from stores through instant messaging apps/platforms (e.g. Whatsapp, Telegram, Hangouts, Messanger etc.);

• send you marketing communications, promotions and advertising, market research and surveys, via e-mail, SMS, push notifications, by telephone, via banner, instant messaging, via an operator, through the Owners' official social media pages, relating to products and/or services relating to ZU Elements and/or third parties (“ Marketing ”);
•to create your profile through the use of profiling cookies, where accepted, therefore collecting and analyzing information on the selections and choices you make on the Site. This profile will be used to provide you with information on other products and/or services that the Owner believes they may be of interest to you and to show you advertisements that may be relevant to your tastes. All algorithms involved in this automated or semi-automated process are regularly tested to ensure that you are not offered products that you are not interested in (“ Profiling ”);

• fulfill legal obligations that require the Data Controllers to collect and/or further process certain types of Personal Data (“ Compliance ”);

•prevent or identify any abuse in the use of the Site, or any fraudulent activity and therefore allow the Owners to protect themselves in court (“ Abuse/Fraud ”).

4. LEGAL BASIS AND MANDATORY OR OPTIONAL NATURE OF THE PROCESSING

The legal bases used by the Data Controllers to process your Data, according to the purposes indicated in the previous Paragraph 3, are the following:

•Provision of the Service : processing for this purpose is necessary to be able to provide you with the Services and, therefore, for the execution of the contract with you. It is not mandatory to provide the Owner with your Personal Data for this purpose, but otherwise it will not be possible to provide you with any Service. The same applies to the newsletter service which arises from your specific request by entering an e-mail address and which you can revoke at any time by following the instructions in Paragraph 8 of this Policy.
•Marketing : processing for this purpose is based on your consent. It is not mandatory to give your consent to the Owner for this purpose and you are free to revoke it at any time without any consequences (except for the fact that you will no longer receive marketing communications from the Owner). You can revoke your consent previously given by following the instructions in Paragraph 8 of this Policy.
•Profiling : the processing for this purpose is based on your consent. It is not mandatory to give your consent to the Owner for this purpose and you are free to revoke it at any time without any consequences (except the impossibility of benefiting from the personalization of the commercial offers you will receive from the Owner). You can revoke your consent previously given by following the instructions in Paragraph 8 of this Policy.

•Compliance : processing for this purpose is necessary for the Data Controller to fulfill any legal obligations. When you provide Personal Data to the Owner, they must be processed in accordance with applicable legislation, which may involve their retention and communication to the Authorities for accounting, tax or other obligations.
•Abuse/Fraud : the information collected for this purpose will be used exclusively to prevent and/or identify any fraudulent activities or abuses in the use of the Site and therefore allows the Owner to protect himself in court.

5. RECIPIENTS OF PERSONAL DATA

Your Personal Data may be shared with the subjects indicated below (the " Recipients "):

• subjects who typically act as data controllers, i.e.: i) people, companies or professional firms that provide assistance and consultancy to the Data Controllers in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services ;

•subjects with whom it is necessary to interact for the provision of the Services (for example hosting providers or providers of platforms for sending emails);

•subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communications networks);

• persons authorized by the Data Controllers to process Personal Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of the Data Controllers);
•subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data for Compliance, Abuse or Fraud purposes, or by orders of the authorities;

6. TRANSFERS OF PERSONAL DATA

Personal data is stored on servers located within the European Union. In any case, it is understood that the Owner, if necessary, will have the right to move the servers even outside the EU. In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

Further information is available from DST Group Srl by writing to the following address: info@dstgroup.it.

7. STORAGE OF PERSONAL DATA

The Personal Data processed for the purpose of Provision of the Services will be kept by the Data Controller for the time strictly necessary for the aforementioned purpose (e.g. for sending the purchased product). In any case, since such Personal Data is processed to provide you with Services, the Data Controller may retain them for a longer period, in any case not exceeding 10 years from the termination of the relationship for the purposes of supplying goods and/or services, in particular as far as it may be necessary in order to protect the interests of the Owner from possible complaints relating to the Services.

The Personal Data processed for Marketing and Profiling purposes will be retained by the Data Controller until you revoke your consent. In any case we will remind you of the consent you have given us every 24 months. Once consent has been revoked, the Data Controller will no longer use your Personal Data for these purposes, but may still retain them, in particular as may be necessary to protect the Data Controller's interests from possible complaints based on such processing.

Personal Data processed for Compliance purposes will be retained by the Data Controllers for the period required by specific legal obligations or applicable legislation.

The Personal Data processed for the purpose of preventing Abuse/Fraud will be kept by the Data Controllers for the time strictly necessary for the aforementioned purpose and therefore until the moment in which the Data Controllers are required to keep them to protect themselves in court and to communicate said data to the competent Authorities.

8. RIGHTS OF THE INTERESTED PARTY

You have the right to ask the Owner, at any time:

• access to your Personal Data, (or a copy of such Personal Data), as well as further information on the processing in progress on them;

• the rectification or updating of your Personal Data processed by the Owner, where they are incomplete or not updated;

•the deletion of your Personal Data from the Data Controller's database;

• the limitation of the processing of your Personal Data by the Owner;

as well as you can:

•object to the processing of your Personal Data by the Owner;
•revoke your consent for Marketing and Profiling purposes.

When requesting the Services, you may have selected which communication channels through which you want to be contacted for Marketing purposes (i.e. telephone, text message, email, post, push notifications, social media).

You can revoke your consent for Marketing relating to each of these communication channels. You can also revoke your consent to Marketing sent by e-mail and stop using the appropriate link found at the bottom of each e-mail received. The same method may be used to stop receiving the newsletter, if you have requested it as a Service.

Consent to Profiling through cookies can be revoked using the methods indicated in the previous Paragraph 2.f.

You can exercise your rights by writing to the Owner at the following address: info@dstgroup.it.

In any case, you always have the right to lodge a complaint with the competent Supervisory Authority (Personal Data Protection Authority) if you believe that the processing of your Personal Data is contrary to the legislation in force.

9. MODIFICATIONS

This privacy policy is in force from 11.30.2021. The Owner reserves the right to modify or simply update its content, in part or completely, also due to changes in applicable legislation. The Owner will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Site. The Owner therefore invites you to regularly visit this section to become aware of the most recent and updated version of the privacy policy in order to always be up to date on the data collected and the use made of it by the Data Controller.