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Pursuant to Art. 13, EU Regulation 2016/679, please be informed that European Regulation No. 679 of 27 April 2016 on the processing of personal data provides for the protection of individuals with regard to the processing of personal data. Pursuant to Article 13 of EU REG. 2016/679, we therefore invite you to take note of the information.

The data controller is Carmodel S.R.L. with registered office in Viale Europa Unita snc -Zona Industriale -64032 Casoli Di Atri (TE) -ITALY - VAT No.: IT 01713310678 -Telephone: +39(0)85-9461625 - E-mail: [email protected]

Since the data controller does not fall within the cases of Reg. 679/2016 where the appointment of a DPO is mandatory, he decided not to proceed with the adoption of such a figure

In order to enable the conclusion and establishment of the contractual relationship with Carmodel or when you visit, consult, request or use Carmodel's services and/or products (including those available on this Site) we collect and use your personal data (i.e. any information that can directly or indirectly identify you). We list below the categories of personal data processed about you:

Identification, contact and access data such as your first name, last name, username, email address, postal address, telephone number, username ID and password, profile picture if any where set by you;

Product data such as data relating to products purchased by you;

Billing and payment information, such as VAT number, tax code, address, and company name if applicable;

Browsing data, such as connection data, IP addresses, domain names and other parameters relating to the browser and operating system used by you, log data, data relating to licences installed and configurations, data relating to registrations made, interaction and transaction processes, performance indicators, data relating to navigation flows and page views, usage and feature counts;

The processing of the categories of personal data listed above is carried out by the Company, in the course of its economic and commercial activities, for specific purposes, as better described below.

a) Allowing browsing on the Site;

b) Registering and managing your account (including account verification and recovery of account credentials, where applicable) and making use of the features associated with your account;

c) Performance of activities necessary for the conclusion and execution of the contract for the supply of the product you have requested or purchased, including through the Site;

d) Managing requests relating to newsletters, formulating estimates, processing orders, providing assistance and support;

e) Management of any complaints and requests for service communications and updates, both through traditional communication tools such as paper mail and through remote communication tools such as e-mail, chat, telephone, SMS, chatbots, banners, notification systems and other remote communication tools

f) Customer assistance activities to individual Customers, tutorship activities and management of    claims opened for after-sale assistance purposes, also through Usage Data;

g) Fulfilment of obligations deriving from applicable laws, regulations or EU legislation (e.g. tax and accounting obligations) or management and response to requests from competent administrative and tax authorities as well as from judicial authorities.

The purposes listed above are jointly referred to as ‘Contractual and Legal Purposes’ and no express consent of the data subject is required. The provision of your personal data for the above-mentioned purposes is necessary and obligatory so that, in case of refusal, we will not be able to continue the contractual relationship with you and the related provision of the requested services.

h) For statistical and research analyses with respect to the products purchased and the services provided to you and the use of the same, also for the purpose of improving and developing the products and services themselves. In compliance with the principle of minimisation, where possible, this activity will take place after anonymisation and aggregation of the data collected;

i) For the assessment of your satisfaction with the products purchased from Carmodel or the resolution of any difficulties and problems relating to their use.

j) In order to assert and defend the Company's rights, including in the context of debt collection procedures and the assignment of credits to authorised companies, including through third parties, and to prevent and combat possible fraud

k) In order to complete a potential merger, sale of assets, transfer of business, business unit or financial transaction by communicating and transferring the data to the third party(ies) involved;

l) In order to send via e-mail, pursuant to Article 130, paragraph 4 of Legislative Decree 196/2003 (‘Privacy Code’), marketing communications on products similar to those covered by the contract concluded with Carmodel, it being understood that, at any time, you will have the opportunity to object to the sending of such communications;

m) In order to perform customer segmentation activities, to which it is possible to send communications for Marketing Purposes on the basis of what is indicated in this privacy policy, based on non-invasive categories of membership, such as, among others, the professional category of membership, the city/province/region in which it is based, the type of product or service purchased. This customer segmentation activity could also be carried out on third party providers' platforms, through interconnection activities with the third party platform's own data. In this case, the communications for Marketing Purposes will be sent in compliance with the consents you have given and in accordance with what is indicated in this policy. In this context, the data may also be used for the purpose of detecting similar customer profiles.

The described ‘Purposes of Legitimate Interest’ do not require your specific consent as they fall within the exception of Article 6(1)(f) of the GDPR. In any case, in accordance with the GDPR, the Company has carried out a thorough balancing of interests aimed at protecting and guaranteeing the privacy and fundamental rights of the data subjects.

n) In order to send you updates on news and commercial offers of Carmodel products, also after interconnection of the Usage Data and analysis of your behaviour both with respect to navigation of the Site and, more generally, with respect to the use of Carmodel services and products, or to invite you to take part in events, conduct market research or other commercial initiatives both through traditional communication channels such as paper mail or telephone calls from an operator and through automated communication tools such as email, chat, messages (SMS and other instant messages), chatbots and other remote communication tools

o) In order to communicate your personal data to other companies in the Carmodel group and/or business partners belonging to its sales network, for the sending of marketing communications and for other commercial initiatives such as those indicated in point n).

The processing of your data for ‘Marketing Purposes’ is not compulsory. Your prior consent is therefore required, which the Company will request from time to time in the most appropriate form for each of the activities described above. Your express consent is revocable by you at all times without any consequences with respect to your contractual relationship with the Company.

Your personal data is processed by the Company using electronic and manual systems in accordance with the principles of correctness, fairness and transparency provided for by the applicable data protection legislation and protecting your confidentiality through technical and organisational security measures to ensure an adequate level of security. These processing operations take place at the Company's registered office and/or at the offices of external data processors who carry out the processing on behalf of companies in the Carmodel group. With reference to the Usage Data, in compliance with the purposes described and, where necessary, with your express consent, analysis activities may be carried out, also by interconnecting your data relating to the different products purchased by you from the companies of the Carmodel Group ‘in the cloud’, i.e. during the online use of the services themselves. For usage statistics, the Company uses tools that allow the collection of Usage Data.

Data will be retained for the period of time necessary to pursue the purposes for which such data were collected, as stated in this notice. In any event, the following retention periods will apply in relation to the processing of data for the purposes set out below:

(i) for the Contractual and Legitimate Interest Purposes, the data shall be retained for a period equal to the duration of the provision of the services requested by you and for 10 years thereafter (the period in which the statute of limitations for any contractual liability asserted by the customer against Carmodel accrues), except where retention for a later period is required for any litigation, requests by the competent authorities or pursuant to applicable legislation;

(ii) for Marketing Purposes, data is retained for a period of 24 months from the date consent is given or renewed when you purchase a new Carmodel-branded product or from the date of your last contact with you, which may include, among others, attending a Company event, using a product provided by the Company or opening a newsletter (collectively referred to as the ‘Last Contact’);

In compliance with the principle of purpose and minimisation, your personal data may be communicated to the following third parties who perform activities functional to those related to the Carmodel product purchased, such as (a) third party suppliers of assistance and consulting services for the Company with reference to the activities of the sectors (by way of example only) technological, accounting, administrative, legal, insurance, (b) companies of the Carmodel group, (c) in cases where the contractual relationship involves the intervention of business partners, the Company may share some of your personal data with its distributors, resellers and partners that are part of the distribution chain of Carmodel products (d) banks and credit institutions; (e) debt collection companies; (f) public entities and authorities whose right of access to your personal data is expressly recognised by law, regulations or measures issued by the competent authorities; (g) potential purchasers of the Company and entities resulting from the merger or any other form of transformation concerning the Company. (h) public databases and credit information systems.

For Marketing Purposes, and subject to your specific consent, your personal data may also be disclosed to third parties and business partners in charge of marketing campaigns carried out on behalf of the Company or other companies in the Carmodel group.

These recipients, as the case may be, process your data as autonomous data controllers, data processors or persons in charge of processing. A complete and up-to-date list of the recipients of data processing as data controllers is available upon request from the Data Protection Officer, according to the contact details indicated in this notice.

Notwithstanding the above mentioned information, your personal data may be freely transferred within the territory of the European Union. However, if, for the purposes indicated, the Company needs to transfer your personal data outside the European Union to countries that are not considered adequate by the European Commission (e.g. the United States), the Company will take the necessary measures to protect your personal data, in compliance with the guarantees provided by law, in accordance with the applicable legislation and in particular Articles 45 and 46 of the GDPR

We inform you that as a data subject you have the following rights which you may assert by making a specific request to the Data Controller and/or the Data Processor, as indicated in point 1.

Art. 15 - Right of access: The data subject has the right to obtain from the data controller confirmation as to whether or not personal data relating to him are being processed and, if so, to obtain access to the personal data and information relating to the processing.

Article 16 - Right of rectification: The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him without undue delay. Taking into account the purposes of the processing, the data subject has the right to obtain the integration of incomplete personal data, including by providing a supplementary declaration.

Art. 17 - Right to erasure (right to be forgotten): The data subject has the right to obtain from the data controller the erasure of personal data concerning him/her without undue delay, and the data controller has the obligation to erase the personal data without undue delay. Carmodel may only delete Personal Data if there is no legal obligation or legitimate right of Carmodel to retain it. In the event of deletion of Personal Data, it may not be possible to use any services linked to the data.

Art. 18 - Right to restriction of processing: The data subject has the right to obtain from the controller the restriction of processing when one of the following cases occurs

- the data subject contests the accuracy of the personal data, for the period necessary for the controller to verify the accuracy of such data

- the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead that their use be restricted;

- although the controller no longer needs the personal data for the purposes of processing, the personal data are necessary for the establishment, exercise or defence of legal claims by the data subject;

- the data subject has objected to the processing pursuant to Article 21(1), pending verification as to whether the legitimate reasons of the controller prevail over those of the data subject.

Article 20 - Right to data portability: The data subject shall have the right to receive in a structured, commonly used and machine-readable format personal data concerning him or her provided to a data controller and shall have the right to transmit those data to another data controller without hindrance from the data controller to whom he or she provided them. When exercising his or her data portability rights under paragraph 1, the data subject has the right to obtain the direct transmission of personal data from one controller to another, if technically feasible.

Article 21 - Right to object: The data subject has the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her pursuant to Article 6(1)(e) or (f), including profiling on the basis of these provisions. Carmodel will cease the use of Personal Data unless it can demonstrate a compelling legitimate interest in the continued processing of Personal Data.

Art. 22 - Right not to be subjected to automated decision-making, including profiling: The data subject has the right not to be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or which significantly affects him in a similar way.

To exercise these rights, you can contact the Data Controller, who can be contacted by sending a request to the address Carmodel S.r.l. with registered office in Viale Europa Unita snc -Zona Industriale -64032 Casoli Di Atri (TE) -ITALY - VAT No.: IT 01713310678 -Telephone: +39(0)85-9461625 - E-mail: [email protected]

This information notice may also be subject to change as a result of any regulatory changes and/or additions.