INFORMATION REGARDING THE PROCESSING OF PERSONAL DATA (PRIVACY)

Based on EU Regulation 2016/679

With reference to the provisions of EU Regulation 2016/679, in particular with regard to articles 12 and 13, we inform you that your personal data will be processed in accordance with current legislation.

CLICK HELP SAS based in Palermo, Via L. Settembrini, 29 is constantly committed to adopting technical and organizational solutions aimed at guaranteeing high standards of lawfulness, security and protection in the processing of personal data: the requirements of the General Regulations are implemented on data protection of the European Union (hereinafter in the text ”GDPR" acronym for General Data Protection Regulation ) and other legal provisions, including, in particular, those of the Code regarding the protection of personal data Legislative Decree 30 June 2003, n. 196 (hereinafter ”Privacy Code" or ”Code") and the subsequent Legislative Decree 10 August 2018, n. 101.

1. Who is the data controller?

CLICK HELP SAS based in Palermo, Via L. Settembrini, 29 (hereinafter in the text ”CLICK HELP" or ”we"), is the owner of the processing of your personal data in accordance with the GDPR and the Code.

2. What data are processed by us?

Personal data means any type of information relating to an identified or identifiable natural person (hereinafter ”Data" ).

Data you provide: all the data you have provided to us to request the purchase and sale of a good and / or the provision of a service; the Data could, by way of example, be: your name and surname, your contact details (including address, telephone number and e-mail address), profession, date and place of birth, tax code. The provision of such information, if required by the contract or essential for the execution of the same, is a necessary requirement for the conclusion of the Contract; failure to communicate such data may make it impossible to conclude the Contract and / or provide the related services and products by CLICK HELP. The aforementioned data may have already been provided by you to partner companies previously. The navigation data that the computer systems and software procedures used to operate the Site acquire, during the ordinary operation, are also processed, such as the IP addresses or domain names of the computers used by users who connect to the website that may be used for the sole purpose of obtaining anonymous statistical information and to check the correct functioning of the site and any abuses or anomalies.

For more information on the technologies that allow us to offer you the services described so far, we invite you to read our Cookies Policy.

CLICK HELP does not acquire and does not process categories of personal data, such as information revealing your racial origin, your political opinions, your religious or philosophical beliefs.

3. On what legal bases and under what rules will we process your data?

Personal data means any type of information relating to an identified or identifiable natural person (hereinafter ”Data"). We will only process your Data where permitted by applicable legal provisions. Specifically, we will process your data on the basis of articles. 6 and 9 GDPR and on the basis of consent pursuant to art. 7 GDPR, as well as in compliance with the corresponding rules of the Code:

Execution of a contract: in order to conclude and execute the requested contract, it is necessary to have access and process certain Data.

for purposes related to the Contract: especially to execute the Contract entered into with you;

customer service: in order to offer you a valid customer service, we will regularly process your data, in order, for example, to give you advice in complete way. For the sole purpose of improving the quality of the customer care and staff training processes, moreover, we may process the personal data collected through the sample recording of telephone calls, in compliance with the privacy legislation and the provisions of the Guarantor for the protection of personal data . .

collaboration with partner companies for better management of your requests / needs;

Processing of your data subject to consent: in the following cases we will process your data only and only if you have given your express consent for:

i) Market research, profiling activities: we conduct market research regarding the interests of our customers, in order to offer them interesting and targeted offers. This includes, for example, customer satisfaction studies with our services. As part of our market research activities, we exclusively process - whenever possible - anonymised and aggregated data. For these activities, however, we may also process your personal data .

ii) Advertising and marketing: if you have previously given your consent to this effect, we will process your data to inform you of any offer that may interest you and we will contact you using the communication channels expressly authorized by you. The promotional and marketing activities (including participation in competitions and prize operations) in question can be carried out by sending telephone messages, such as by way of example SMS, and / or e-mail: obviously you can object in any at any time to the processing for these purposes.

In addition to the above, CLICK HELP may process your data to comply with legal obligations and, therefore, for compliance with any rule or provision of law that we intend and must comply with or for the security of the Data for indispensable measures to ensure the security of your data and company data from external attacks and / or in order to prevent external attacks. Again to comply with legal obligations imposed on us and / or in order to prevent fraud or in the event of a dispute. Lastly, for mandatory fiscal, accounting and administrative purposes, always in compliance and in compliance with current regulations. In some cases, certain functionalities of the site and / or the CLICK HELP application and / or certain promotions and / or operations may be limited for subjects younger than that indicated on the CLICK HELP site and / or established by current regulations; in such cases, additional express consent may be required to use certain services and / or features. Finally, CLICK HELP may process your data to safeguard the legitimate interests of the same CLICK HELP unless your interests prevail. This is done with checks on sales to improve the services rendered and in aggregate and anonymous form without indicating your identity or for studies aimed at improving the products and services rendered as well as our procedures.

5. For what period will we process your data?

As expressly provided for by art. 5, co. 1, lett. e) of the GDPR, we will keep your data only for the time necessary to process them for the purposes for which they are processed. If we process the Data for multiple purposes, they will be automatically deleted or saved in a format that does not allow us to reach any direct conclusion in relation to your identity, as soon as the last specific purpose has been fulfilled. In order for all your data to be deleted or made anonymous in line with the principle of data minimization and in compliance with art. 5, co. 1, lett. e) of the GDPR. Indicatively, your data will be kept for the following periods: - fiscal / administrative obligations: 10 years; - regulatory obligations regarding product warranty: 30 months; - contractual obligations regarding additional after-sales services: from 36 to 78 months depending on the service chosen.

6. How is your data protected ?

CLICK HELP will process your personal data on the basis of the security obligations relating to data processing pursuant to art. 32 GDPR. In order to guarantee an adequate level of data protection aimed at limiting the risk of using the same in an improper or illicit way, technical and organizational measures have been implemented that comply with internationally recognized IT standards, these measures are constantly subject to verification. .

7. With whom will your data be shared ?

Your data may be shared with third parties including:

external third parties to the extent that this is necessary or appropriate to achieve the purposes referred to in points 3 and 4, or in the context of any legal obligation regarding information and reporting. These third parties are, in particular, external service providers including IT services, external consultants or collaborators, within the following contexts:

Supply and management of administrative procedures and IT systems, communication networks and protection and security systems;

after-sales assistance and technical interventions in the field of legal guarantee / lack of conformity of the products sold (manufacturers or importers of the products, authorized technical assistance centers); - appraisal, auditing and certification of financial statements;

Professional consultancy and assistance.

CLICK HELP will appoint all the aforementioned subjects where necessary as Data Processors or they will act as autonomous controllers in compliance with current legislation, in the event that the relative conditions exist. CLICK HELP undertakes not to transfer your data outside the European Community .

8. Your rights

You, according to the GDPR and other applicable provisions on data protection, have specific and unlimited rights.

As an interested party, you have in particular the following rights under the GDPR, towards CLICK HELP:

Right of rectification (art. 16 GDPR): you may request a rectification of your data. We will take appropriate measures aimed at ensuring that your Data stored and processed by us on an ongoing basis is kept correct, complete, up-to-date and relevant, based on the most recent information provided to us.

if the Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

if you oppose the processing of your data and there are no overriding legitimate reasons to proceed with the processing, or if you oppose the processing of data for direct marketing purposes;

Right to limitation of treatment (Article 18 GDPR): you will be able to obtain a limitation of the processing of your data if these are not accurate or if they are no longer needed;

Right to object (Article 21 GDPR): You may object at any time, for reasons connected with your particular situation, to the processing of your Data, pursuant to art. 6, paragraph 1, letters e) or f) of the GDPR, or if the personal data are processed for direct marketing purposes. In this case, we will no longer process your data. This last condition does not apply if we can demonstrate the existence of compelling legitimate reasons that justify the processing and that prevail over your interests, or if we need your data to ascertain, exercise or defend a right in court.

Complaint: You always have the right to make a report and lodge a complaint with a competent data protection authority, pursuant to of the art. 77 of the GDPR.

In any case, you can find any broader reference in terms of current legislation on the website of our Guarantor for the protection of personal data at the internet address www.garanteprivacy.it and the complete text of the GDPR can be consulted by accessing the following website :

<phttps://eur-lex.europa.eu/legal-content/IT/TXT/?uri=uriserv:OJ.L_.2016.119.01.0001.01.ITA&toc=OJ:L:2016:119:TOC

The data controller is CLICK HELP SAS, in the person of the Legal Representative, who can be contacted at the following address Via Luigi Settembrini, 29 - 90145 Palermo.

For all requests for information and to exercise your rights, you can contact CLICK HELP SAS:

by phone at 0917829153;

by e-mail to [email protected].

The Data Protection Officer can be contacted directly at the following email address: [email protected].

CLICK HELP will promptly inform you if there are substantial changes with reference to the way your data is processed, we will promptly inform you of such changes.

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