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Privacy Policy

The purpose of this document is to inform the natural person (hereinafter “Data Subject”) about the processing of his/her personal data (hereinafter “Personal Data”) collected by the data controller, ALTHINK s.r.l., with registered oô€€¤ce in Via Brenta 21 57025 Piombino LI, Tax Code/VAT No. 02023680495, e-mail address info@althink.it, (hereinafter “Data Controller”), via a n d www.althink.it (hereinafter “Application”).

Changes and updates will be e􀀸ective as soon as they are published on the Application. In case of non-acceptance of the changes made to the Privacy Policy, the Data Subject shall stop using this Application and may ask the Data Controller to delete his/her Personal Data.

1. Categories of Personal Data processed
The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:
- Contact Data: ô€€½rst name, last name, address, e-mail address, phone number, pictures, authentication credentials, any further
information sent by the Data Subject, etc.
- Fiscal and payment Data: tax code, VAT number, credit card data, bank account details, etc.
If the Data Subject decides not to provide Personal Data for which there is a legal or contractual obligation, or if such data is a
necessary requirement for the conclusion of the contract with the Data Controller, it will be impossible for the Data Controller to
establish or continue any relationship with the Data Subject.
The Data Subject who communicates Personal Data of third parties to the Data Controller is directly and exclusively liable for their
origin, collection, processing, communication or divulgation.

2. Cookies and similar technologies
Cookies are not used for the transmission of personal information, and neither are persistent cookies of any kind used, i.e.
systems for tracing the Data Subjects. Therefore, the Application does not acquire the Personal Data of the Data Subjects using
these technologies. Use is made of session technical cookies (not persistent), strictly limited to what is necessary for the safe and
efficient navigation of the Application.

3. Legal basis and purpose of data processing
The processing of Personal Data is necessary:
a. for the performance of the contract with the Data Subject and especially:
1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject
2. support and contact with the Data Subject: to answer the Data Subject's requests
3. management of payment: to manage payments by credit card, bank transfer or other methods
b. for legal obligations and especially:
1. the ful􀀡lment of any obligation provided for by the applicable norms, laws and regulations, in particular, on tax and
fiscal matters
c. for the legitimate interest of the Data Controller, for:
1. marketing purposes by e-mail of products and/or services of the Data Controller to directly sell the Data Controller's
products or services using the email provided by the Data Subject in the context of the sale of a product or service similar to
the one being sold
d. on the basis the Data Subject's consent, for:
1. pro􀀡ling the Data Subject for marketing purposes: to provide the Data Subject with information on the Data Controller's
products and/or services through automated processing designed to collect personal information to predict or assess the
Data Subject's preferences or behaviors
2. marketing purposes of the Data Controller’s products and/or services: to send information or commercial and/or
promotional materials, to perform direct sales activities of the Data Controller’s products and/or services or to conduct
market research with automated and traditional methods
The Data Subject's Personal Data may also be used by the Data Controller to protect itself in judicial proceedings before the
competent courts.

4. Data processing methods and receivers of Personal Data
The processing of Personal Data is performed via paper-based and computer tools with methods of organization and logics strictly
related to the specified purposes and through the adoption of appropriate security measures.
Personal Data are processed exclusively by:
- persons authorized by the Data Controller to process Personal Data who have committed themselves to conô€€½dentiality or have
an appropriate legal obligation of confidentiality;
- subjects that operate independently as separate data controllers or by subjects designated as data processors by the Data
Controller in order to carry out all the processing activities necessary to pursue the purposes set out in this policy (for example,
business partners, consultants, IT companies, service providers, hosting providers);
- subjects or bodies to whom it is mandatory to communicate Personal Data by law or by order of the authorities.
The subjects listed above are required to use appropriate measures and guarantees to protect Personal Data and may only access
data necessary to perform their duties.
Personal Data will not be indiscriminately shared in any way.

5. Place
Personal Data will not be transferred outside the territory of the European Economic Area (EEA).

6. Personal Data storage period
Personal Data will be stored for the period of time that is required to fulfill the purposes for which it was collected. In particular:
- for purposes related to the execution of the contract between the Data Controller and the Data Subject, will be stored for the
entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the
event of legal disputes, for the entire duration of such disputes, until the time limit for appeals has expired
- for purposes related to legitimate interests of the Data Controller, they will be stored until the fulfilment of such interest
- in compliance with legal obligations, by order of an authority and for legal protection, they shall be stored according to the
relevant timeframes provided for by such obligations, regulations and, in any case, until the expiry of the prescriptive term
provided for by the rules in force
- for purposes based on the consent of the Data Subject, they will be stored until the consent is revoked
At the end of the conservation period, all Personal Data will be deleted or stored in a form that does not allow the identiô€€½cation of
the Data Subject.

7. Rights of the Data Subject
Data Subjects may exercise speciô€€½c rights regarding the Personal Data processed by the Data Controller. In particular, the Data
Subject has the right to:
- be informed about the processing of their Personal Data
- withdraw consent at any time
- restrict the processing of his or her Personal Data
- object to the processing of their Personal Data
- access their Personal Data
- verify and request the rectification of their Personal Data
- restrict the processing of their Personal Data
- obtain the erasure of their Personal Data
- transfer their Personal Data to another data controller
- file a complaint with the Personal Data protection supervisory authority and/or take legal action.
In order to use their rights, Data Subjects may send a request to the following e-mail address info@althink.it. Requests will be
immediately treated by the Data Controller and processed as soon as possible, in any case within 30 days.

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