Privacy Policy of Rete SIAS project

Data Controller: Techinnova S.p.A. , via Giovanni Durando, 38 20158 Milano (MI) – VAT number 03015970126

Types of Data collected
Among the types of Personal Data that our Company collects there are: Cookies, Usage Data,
email address, first name, last name, gender, date of birth, phone number, address,
username, company name, country, profession, province, state, ZIP/Postal code, city and
website. Complete details on each type of Personal Data collected are provided in the
dedicated sections of this privacy policy or by specific explanation texts displayed prior to the
Data collection.
Any use of Cookies – or of other tracking tools – by our website serves the purpose of
providing the Service required by the User, in addition to any other purposes described in
the present document and in the Cookie Policy, if available.

Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access,
disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following
organizational procedures and modes strictly related to the purposes indicated. In addition
to the Owner, in some cases, the Data may be accessible to certain types of persons in
charge, involved with the operation of our Company (administration, sales, marketing,
legal, system administration) or external parties (such as third-party technical service
providers, mail carriers, hosting providers, IT companies, communications agencies)
appointed, if necessary, as Data Processors by the Owner. The updated list of these
parties may be requested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
– Users have given their consent for one or more specific purposes. Note: Under some
legislations the Owner may be allowed to process Personal Data until the User objects to
such processing (“opt-out”), without having to rely on consent or any other of the following
legal bases. This, however, does not apply, whenever the processing of Personal Data is
subject to European data protection law;
– provision of Data is necessary for the performance of an agreement with the User
and/or for any pre-contractual obligations thereof;
– processing is necessary for compliance with a legal obligation to which the Owner is
subject;
– processing is related to a task that is carried out in the public interest or in the
exercise of official authority vested in the Owner;
– processing is necessary for the purposes of the legitimate interests pursued by the Owner
or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or
contractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner’s operating offices and in any other places where the
parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to
a country other than their own. To find out more about the place of processing of such
transferred Data, Users can check the section containing details about the processing of
Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside
the European Union or to any international organization governed by public international
law or set up by two or more countries, such as the UN, and about the security measures
taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections
of this document or inquire with the Owner using the information provided in the contact
section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they
have been collected for.
Therefore:
– Personal Data collected for purposes related to the performance of a contract between
the Owner and the User shall be retained until such contract has been fully performed.
– Personal Data collected for the purposes of the Owner’s legitimate interests shall be
retained as long as needed to fulfill such purposes. Users may find specific information
regarding the legitimate interests pursued by the Owner within the relevant sections of
this document or by contacting the Owner.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as
well as for the following purposes: Analytics, Access to third-party accounts, Managing
contacts and sending messages and Contacting the User.
Users can find further detailed information about such purposes of processing and about
the specific Personal Data used for each purpose in the respective sections of this
document.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner. In
particular, Users have the right to do the following:
– Withdraw their consent at any time. Users have the right to withdraw consent where
they have previously given their consent to the processing of their Personal Data.
– Object to processing of their Data. Users have the right to object to the processing of
their Data if the processing is carried out on a legal basis other than consent. Further details
are provided in the dedicated section below.
– Access their Data. Users have the right to learn if Data is being processed by the
Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of
the Data undergoing processing
– Withdraw their consent at any time. Users have the right to withdraw
consent where they have previously given their consent to the processing of
their Personal Data.
– Object to processing of their Data. Users have the right to object to the
processing of their Data if the processing is carried out on a legal basis
other than consent. Further details are provided in the dedicated section
below.
– Access their Data. Users have the right to learn if Data is being processed by the
Owner, obtain disclosure regarding certain aspects of the processing and obtain a
copy of the Data undergoing processing
– Verify and seek rectification. Users have the right to verify the accuracy of their Data
and ask for it to be updated or corrected.
– Restrict the processing of their Data. Users have the right, under certain
circumstances, to restrict the processing of their Data. In this case, the Owner will not
process their Data for any purpose other than storing it.
– Have their Personal Data deleted or otherwise removed. Users have the right, under
certain circumstances, to obtain the erasure of their Data from the Owner.
– Receive their Data and have it transferred to another controller. Users have the right
to receive their Data in a structured, commonly used and machine readable format
and, if technically feasible, to have it transmitted to another controller without any
hindrance. This provision is applicable provided that the Data is processed by
automated means and that the processing is based on the User’s consent, on a
contract which the User is part of or on pre-contractual obligations thereof.
– Lodge a complaint. Users have the right to bring a claim before their competent data
protection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official
authority vested in the Owner or for the purposes of the legitimate interests pursued by the
Owner, Users may object to such processing by providing a ground related to their particular
situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct
marketing purposes, they can object to that processing at any time without providing any
justification. To learn, whether the Owner is processing Personal Data for direct marketing
purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact
details provided in this document. These requests can be exercised free of charge and will
be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the
stages leading to possible legal action arising from improper use of our Identity or the
related Services.
The User declares to be aware that the Owner may be required to reveal personal data
upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, our Company may provide the
User with additional and contextual information concerning particular Services or the
collection and processing of Personal Data upon request.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested
from the Owner at any time. Please see the contact information at the beginning of this
document.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving
notice to its Users on this page and possibly within our Company and/or – as far as
technically and legally feasible – sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often, referring to the
date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s
consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a
personal identification number — allows for the identification or identifiability of a natural
person.

Usage Data
Information collected automatically through our website, which can include: the IP
addresses or domain names of the computers utilized by the Users who use this
Application, the URI addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the file received in response,
the numerical code indicating the status of the server’s answer (successful outcome, error,
etc.), the country of origin, the features of the browser and the operating system utilized by
the User, the various time details per visit (e.g., the time spent on each page within the
website) and the details about the path followed within the website with special reference to
the sequence of pages visited, and other parameters about the device operating system
and/or the User’s IT environment.

Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes
Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly
with others, determines the purposes and means of the processing of Personal Data,
including the security measures concerning the operation and use of our Identity.
The Data Controller, unless otherwise specified, is the Owner of the Company.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union
include all current member states to the European Union and the European Economic Area.
Cookies
Small sets of data stored in the User’s device.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations,
including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This
privacy policy relates solely to our Company if not stated otherwise within this document.
Latest update: January 22, 2021