Palumbo Group

CENTRO ITALIA SRL® PRIVACY POLICY PURSUANT TO 2016/679 EU REGULATION OF THE EUROPEAN PARLIAMENT AND COUNCIL DECISION as of April 27, 2016 In compliance with the obligations deriving from national legislation (Decree Law June 30, 2003 no. 196, Personal Data Protection Code) and European Community legislation (European Regulation for the protection of personal data no. 679/2016, GDPR) and subsequent amendments, this Privacy Policy is intended to transparently and confidentially inform about the personal information (hereinafter, "Data") collected by Centro Italia Srl® (hereinafter "Centro Italia®"), with registered office in Rome at via Silvio Giovaninetti no. 37 – 00123 Rome (RM), through its Website and how such Data are used in compliance with current legislation on the protection of personal data. By visiting and consulting the Centro Italia® Website, the user expressly consents to the processing of their personal data in relation to the methods and purposes described below, including the possible disclosure to third parties if necessary for the provision of a service. The provision of data and therefore consent to the collection and processing of data is optional; therefore, the user can deny consent or revoke it at any time, if already provided previously, being aware that such events may result in the impossibility to provide certain services and/or compromise the browsing experience on the Website. Any changes to this Policy will be regularly published on the Centro Italia Website. If, following notification of such changes, you continue to use the Website, then we will consider the changes to the Policy accepted by you. Data processing location Processing related to the Website and the services provided by Centro Italia® take place at Centro Italia® headquarters and are handled only by personnel authorized to process them, or by any person in charge of maintenance operations. Data resulting from services offered within the Website may be communicated to the technological and instrumental partners used by Centro Italia for the provision of the services requested by visiting users. Personal data provided by visiting users who submit requests for the sending of informational material (information requests, responses to inquiries, etc.) or other communications are used only to perform the service or provision requested and are communicated to third parties only if necessary for this purpose (provision of services requested through the technological and instrumental partner). Acquired data When a customer visits the Centro Italia® Website, certain information may be collected or requested in order to facilitate Centro Italia® in managing the relationship with the customer. This information may include: - contact details such as name, mailing address, email address, and phone number; - information provided to Centro Italia® by the customer in order to receive assistance; - information about third parties that the customer may provide through services provided within the Website; - information about the computer or device used, including browser type and settings, IP address, and traffic data relating to the customer's Internet connection. Use of customer data We may use customer data to: - verify the customer's identity for purposes related to the services provided; - provide quotations for products or services; - subscribe the customer to a newsletter, send updates on the services offered; - request feedback in order to improve the quality of service; - allow the provision of services ensuring compliance with legal requirements by Centro Italia®. Marketing purposes messages In addition to the purposes described above, we may, in compliance with consent obligations, use customer Data to send advertising messages, promotions, and information about services tailored to the customer and their needs. Where permitted, this may involve the use of demographic or trend data provided by third parties. Contact information such as phone numbers and email addresses may also be used for contact purposes. If you do not wish your Data to be used for this purpose, you can simply deny consent on the web pages and/or within the online forms through which Centro Italia® collects customer Data. Please note that in some regions, refusal of consent may be expressed by deselecting a checkbox. The customer also has the option to unsubscribe from promotional email messages at any time. Google Analytics To monitor the performance of Website visits, Centro Italia® uses the Google Analytics tool, whose configuration has been set up to anonymize the IP address of the Website user. It is also noted that by installing a specific browser add-on, it is possible to disable the sharing of data acquired through Google Analytics. The add-on prevents the Google Analytics JavaScript code running on the Website from sharing information with Google Analytics about the visit activity. Cookies The Centro Italia® Website uses cookies, small text strings stored within the visitor's computer that are generated as soon as the Website pages are accessed. Typically, the usefulness of cookies lies in the ability to obtain information about visitor preferences, to improve Website functionality, to simplify navigation by automating procedures (e.g., login, website language), and for Website usage analysis. Below are the various types of cookies used: - Navigation cookies are essential for distinguishing between connected users and are useful to prevent a requested functionality from being provided to the wrong user, as well as for security purposes to prevent attacks on the website. Navigation cookies do not contain personal data and last only for the current session, i.e., until the browser is closed. No consent is required for them. - Functional cookies serve to store preferences and support users in a more effective use of the site, such as remembering language, identifying the region of origin, etc. These cookies are not essential for the operation of the site but improve the browsing experience. The information collected by them will not track browser activity on other sites nor will it be able to identify an individual from this information. - Technical analytical cookies help us understand how the user uses our site in order to optimize and improve it. The information collected includes: the first and last URL from which the User arrives at our site, the search keywords used, the sections viewed during navigation, and the time spent. We use cookies to make advertising more attractive based on what is most relevant to customers, improve campaign processing reports, and avoid displaying already viewed ads. We cannot identify an individual through this information. - Third-party cookies are generated by clicking on social media buttons or viewing videos hosted on other websites. They are set by a domain other than our own and are subject to relevant regulations regarding their use. We will not have access to data stored by cookies from other sites while browsing within them. A list of third-party cookies is provided, along with information on the type of cookies used by each third party, how to manage and disable cookies, and the type of information collected, within the Privacy Policy of the respective third parties listed on the above web pages. During the first visit, browsing our website will imply the implicit acceptance of Centro Italia® use of cookies as explained in this Policy. The user can decide to revoke their consent at any time by deleting cookies from their computer (or mobile device) using the Internet browser's settings and configuration. However, disabling cookies may prevent the correct use of some Website functions and/or related services. Instructions for disabling cookies can be found on the following web pages: - Mozilla Firefox - Microsoft Internet Explorer - Microsoft Edge - Google Chrome - Opera - Apple Safari Transfer of data to non-EU countries This Website may share some of the data collected with services located outside the European Union. In particular with Google, Facebook, and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized based on specific decisions of the European Union and the Guarantor for the protection of personal data, in particular decision 1250/2016 (Privacy Shield), for which no further consent is required. The aforementioned companies guarantee their adherence to the Privacy Shield. Processing methods and storage Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illegal or incorrect use, and unauthorized access. Information collected by Centro Italia® may be stored on Centro Italia servers and in any region where its suppliers operate. Privacy of minors Centro Italia® will not knowingly collect personal information from a person who is not legally an adult according to the definition of local law. Centro Italia® does not target minors in relation to the Website and related services. In the event that Centro Italia uses or publishes the personal data of a person who is not legally an adult, it will request parental consent in accordance with local laws and regulations in order to protect this person. Right to be forgotten Centro Italia® undertakes to take reasonable measures to ensure that any request for the deletion of personal information is processed with existing technology and executed in a reasonable time. However, this practice does not apply to information made available to third parties, beyond what Centro Italia® can delete. Every effort will be made to delete personal information if the user withdraws consent (opt-out) from receiving information and requests the right to be forgotten. Requests can be forwarded to Centro Italia srl as Data Controller: - by email, to the email address: privacy@centroitalia.it - by regular mail to: Centro Italia srl – Silvio Giovaninetti no. 37 – 00123 Rome (RM)

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