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Privacy

ON THE PROTECTION OF PERSONAL DATA PURSUANT TO ART. 12 AND FOLLOWING EU REGULATION 679/

Pursuant to the new EU Regulation 679/2016, in accordance with the accountability principle, all processing of personal data must be lawful and fair. It must be transparent to individuals how their personal data is collected, accessed, or otherwise processed, as well as the extent to which such data is or will be processed.

The principle of transparency requires that information and communications relating to the processing of such data be easily accessible and understandable and that clear and simple language be used.

This principle concerns, in particular, informing data subjects about the identity of the Data Controller and the purposes of the processing, as well as further information (see Articles 13 and 14 of EU Regulation 679/2016) to ensure fair and transparent processing with regard to the natural persons concerned and their rights to obtain confirmation and communication of whether or not personal data concerning them is being processed (on this point, see Recital 39, EU Regulation 679/2016).

In this context, please read the following information.

Stella Srl with registered office in via carmignani 4, Montecarlo – Lucca – Italy, VAT number 02383430465 certified email address stellasrl2015@pec.it email address: privacy@ruedesmille.com and New Gold Srl with registered office in Via dei Mille, 99 – La Spezia – Italy, VAT number 0 0 2 9 3 4 8 0 1 1 7 , Tel./Fax 0583.22050 certified email address newgoldsrl@per.it - ​​email address: privacy@ruedesmille.com , as Joint Data Controllers pursuant to and for the purposes of EU Regulation 2016/679, hereby inform the interested party that the personal data collected concerning him, acquired by the Joint Data Controllers or that will be requested subsequently and/or communicated by third parties, will be used for the purposes indicated below.

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PURPOSE AND LEGALITY OF THE PROCESSING

Pursuant to EU Regulation 679/2016, personal data:

  • They are processed lawfully, fairly and in a transparent manner in relation to the interested party (art. 5);
  • These are collected for specific, explicit and legitimate purposes, and subsequently processed in a manner

that is not incompatible with these purposes (art. 5);

The purposes for which the data is collected are as follows:

  • comply with any legal obligations relating to civil, fiscal and accounting regulations

etc. for the administrative management of any relationship you may have established with Stella Srl or New Gold Srl as well as for our legal protection;

  • fulfill contractual obligations, delivery/return of goods, technical support and

technical information, after-sales assistance and satisfaction checks for the products you are interested in;

  • carry out market research and statistics, carry out marketing, forward offers,

relating to the products covered by the activity of Stella Srl or New Gold Srl;

  • for the communication/forwarding of commercial information on initiatives, announcements of

products, services and offers, brochures, from Stella Srl or New Gold Srl by sending emails, newsletters, text messages and also paper copies by post.

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PROCESSING METHODS AND CONFIDENTIALITY OBLIGATION

Data processing is performed using computerized tools and/or paper-based media, by parties committed to confidentiality, using logic related to the purposes and in any case ensuring data security and confidentiality. The data will be processed automatically using software, management systems, and other programs that assist us in processing and carrying out the activities listed above, including marketing.

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COMMUNICATION TO THIRD PARTIES

Your personal data may be disclosed to third parties known to us solely and exclusively for the aforementioned purposes and, in particular, to the following categories of subjects:

  • Third-party companies that perform services on our behalf;
  • Institutions and public administrations for legal compliance;
  • Professionals who can assist with compliance;
  • Service/product providers for example to process credit card and payment data,

shipping, delivery, hosting, data management, email forwarding, product promotion management, research and analysis, and administration of certain services;

When we share data with third parties, we enter into agreements requiring them to implement appropriate technical and organizational measures to protect personal data. These parties will process personal data as external data processors.

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STORAGE PERIODS

Pursuant to Article 5 of EU Regulation 679/2016, "Principles relating to processing of personal data," personal data are retained in a form that permits identification of data subjects for no longer than is necessary for the purposes for which they are processed.

Data subjects' personal data may also be retained for longer periods in compliance with applicable laws (for example, accounting requirements) and, in any case, by applying any technical and organizational measures necessary to activate data anonymization mechanisms.

The data will be retained for a period of time no longer than is necessary to achieve the purposes and interests for which they are processed and will be promptly deleted upon simple request, including by writing to privacy@ruedesmille.com

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RIGHTS OF THE INTERESTED PARTY

Pursuant to current legislation, the interested party may assert his or her rights towards each of the Joint Data Controllers (also using the downloadable form Http://ruedesmille.com/unsubscribe.pdf ) , as expressed in EU Regulation 679/2016, namely:

RIGHT OF ACCESS art. 15

The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her is being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the right of the data subject to request from the data controller rectification or erasure of personal data or restriction of processing of personal data concerning him or her or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

(g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Article 22, paragraphs 1 and 4, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

  1. Where personal data are transferred to a third country or to an international organisation,

The data subject has the right to be informed of the existence of appropriate safeguards pursuant to Article 46 relating to the transfer. 2. The data controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the data controller may charge a reasonable fee based on administrative costs. If the data subject submits the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic format.

The right to obtain a copy must not adversely affect the rights and freedoms of others. RIGHT TO RECTIFICATION art. 16

The data subject has the right to obtain from the data controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by providing a supplementary statement.

RIGHT TO ERASURE art. 17

  1. The interested party has the right to obtain from the data controller the erasure of personal data which

concern him without undue delay and the data controller has the obligation to erase personal data without undue delay, if one of the following reasons exists:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws consent on which the processing is based according to Article 6, paragraph 1, point (a), or Article 9, paragraph 2, point (a), and where there is no other legal ground for the processing;

(c) the data subject objects to the processing pursuant to Article 21, paragraph 1, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21, paragraph 2;

d) the personal data have been unlawfully processed;

e) the personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1.

  1. The data controller, if he has made personal data public and is obliged, pursuant to paragraph 1, to

to eliminate them, taking into account the available technology and the implementation costs, adopts the measures

reasonable means, including technical means, to inform data controllers who are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

  1. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) for the exercise of the right to freedom of expression and information;

b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) for reasons of public interest in the area of ​​public health in accordance with Article 9(2)(h) and (i) and Article 9(3);

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defense of legal claims.

RIGHT TO LIMIT PROCESSING art. 18

  1. The data subject has the right to obtain from the data controller the restriction of processing when

one of the following hypotheses applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) although the data controller no longer needs the personal data for the purposes of the processing, they are required by the data subject for the establishment, exercise or defence of legal claims;

d) the data subject has objected to processing pursuant to Article 21, paragraph 1, pending the verification whether the legitimate grounds of the controller override those of the data subject.

  1. Where processing has been restricted under paragraph 1, such personal data shall be processed, except for the

storage, only with the consent of the interested party or for the establishment, exercise or defense of legal claims

right in court or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

  1. The data subject who has obtained the restriction of processing pursuant to paragraph 1 shall be informed by the

data controller before such restriction is revoked.

RIGHT TO DATA PORTABILITY art. 20

  1. The interested party has the right to receive in a structured, commonly used and machine-readable format

The person shall have the right to automatically obtain the personal data concerning him or her which he or she has provided to a controller and shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and

b) the processing is carried out by automated means.

  1. In exercising his or her rights to data portability under paragraph 1, the data subject

The data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

RIGHT TO OBJECT TO PROCESSING art. 21

  1. The interested party has the right to object at any time, for reasons related to his/her situation

In particular, to the processing of personal data concerning him or her pursuant to Article 6, paragraph 1, letters e) or f), including profiling based on those provisions. The data controller shall refrain from

further process the personal data unless the controller demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

  1. Where personal data are processed for direct marketing purposes, the data subject has the right to object.

at any time, to the processing of personal data concerning him or her for such purposes, including profiling to the extent that it is related to such direct marketing. 3. If the data subject objects to processing for direct marketing purposes, the personal data will no longer be processed for such purposes. 4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the data subject's attention and presented clearly and separately from any other information at the latest at the time of the first communication with the data subject. 5. In the context of the use of information society services, and without prejudice to Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89, paragraph 1, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In addition to the aforementioned rights, the interested party has the right to withdraw consent upon appropriate request, as well as to lodge a complaint with the Supervisory Authority Garante per la protezione dei dati personali - website: http://www.garanteprivacy.it - ​​email address: garante@gpdp.it .

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JOINT CONTROLLERS AND PRIVACY COMMUNICATIONS

Stella Srl with registered office in via Carmignani 4 - Montecarlo – Lucca – Italy, VAT number 02383430465 certified email address stellasrl2015@pec.it email address: privacy@ruedesmille.com and New Gold Srl with registered office in Via dei Mille, 99 – La Spezia – Italy, VAT number 00293480117, Tel./Fax 0583.22050 certified email address newgoldsrl@per.it - ​​email address: privacy@ruedesmille.com .

For further information, including information on how to exercise these rights, and any other communications, we are at your disposal.

Tel./Fax 0583.22050

Email address: privacy@ruedesmille.com

You can also visit the website of the Privacy Guarantor and in particular the section dedicated to your rights: http://www.garanteprivacy.it/home/diritti