Privacy

Privacy

Information on the processing of personal data

Welcome to 'www.dipaolotrade.it', (referred to hereafter as the Site).

Please read our Privacy Policy, which applies when you browse the site, regardless of whether you decide to use the services and/or purchase products. The processing of the Personal Data of users of the site will be carried out in Italy and conducted in compliance with the applicable European legislation: European Data Protection Regulation no. 2016/679 (GDPR), which governs the processing of personal data carried out by anyone who is resident or based in Italy. Di Paolo Trade S.r.l., with registered office in Italy, Via Cesare Battisti n. 80, 64020 Bellante TERAMO C.F. and P.IVA 01978750675, is responsible for the execution of e-commerce services and the sale of products through the Site.

1. THE POLICY Every person has the right to the protection of their personal data. Di Paolo Trade S.r.l., with registered office in Italy, Via Cesare Battisti n. 80, 64020 Bellante TERAMO C.F. and P.IVA 01978750675 respects the right of its users to be informed about the collection and processing of their personal data. We always try to respect a principle of strict necessity in the processing of data that can identify you, even indirectly. For this reason, we have configured the Site so that the use of your personal data is reduced to the minimum necessary and so that processing is excluded when the purposes pursued in individual cases can be achieved through the use of anonymous data or by other means, which allow the person concerned to be identified only in cases of necessity or at the request of the authorities and the police. This Privacy Policy provides you with all the information you need to understand how we collect and use information that identifies users of the Site. For further information on our Privacy Policy you can send requests via e-mail to info@dipaolotrade.it.

2. WHO PROCESSES THE DATA, HOW AND FOR WHAT PURPOSES

Subscribe to DeepL Pro to edit this document. Visit www.DeepL.com/pro for more information.

Di Paolo Trade S.r.l., with registered office in Italy, Via Cesare Battisti n. 80, 64020 Bellante TERAMO C.F. and P.IVA 01978750675 is the owner of the processing of the Personal Data of the users of the Site, aimed at the management, conclusion and execution of commercial transactions, communication of a commercial nature also through profiling activities, through the same site. In the case of communication and profiling purposes, the legal basis of the processing is the consent of the person concerned. For exclusively organisational and functional requirements, we have appointed an external DPO, for purposes strictly connected and related to the provision of services on the Site, including the sale of products. The DPO was chosen because he or she has proven to possess skills, experience and reliability, and to provide suitable guarantees of full compliance with current processing provisions, including the data security profile.

The purposes of the processing of personal data may be explained in a non-explicit manner:

• provision of the services requested by the customer or available on portals managed by Di Paolo Trade S.r.l., (personnel selection, newsletters, information material, complimentary material) as well as conclusion of the contract to which the interested party is a party;

• administrative and accounting purposes related to service contracts;

• market and statistical surveys, marketing and referrals on advertising (press, radio, TV, internet, etc.), product preferences;

• sending promotional and advertising communications for commercial purposes via email marketing and/or sms systems

Any refusal to consent to the processing of data shall make it impossible to use the service requested by the user. By registering for our Newsletter, you consent to the use of the data that is strictly necessary and instrumental for this purpose, i.e. the data disclosed separately, for the regular dispatch of our e-mail newsletter on the basis of the consent obtained. You may cancel your subscription to the Newsletter at any time, either by sending a message to our contact persons, by using the appropriate link in each Newsletter, or from your personal area. In the event of a cancellation request, we will delete the e-mail address, unless the user has expressly consented to further use of the data and subject to our reservation as to further use of the data, of which you have been correctly informed in this statement in accordance with the statutory provisions.

In any case, www.dipaolotrade.it may freely forward automated emails in order to make possible and to the benefit of the customer what is stated as the content of the specific email from time to time.

Such as:

1. Welcome emails, to welcome new subscribers to the website; 2. The birthday emails, to offer a discount or a dedicated gift; 3. Reminders, short communications sent to remind you of appointments, deadlines, events and unmissable dates; 4. Feedback requests and reviews, to gather information about your customers' shopping experience; 5. Reactivation emails, communications that the platform sends to dormant contacts after a certain period of inactivity to invite them to return to the site. To obtain a list of the persons responsible for processing your data, please contact Customer Service or send an email to the following address: info@dipaolotrade.it. In particular, in the pursuit of the purposes, within the process of purchasing products on the Site we collect Personal Data (such as, for example, personal data, e-mail address, postal address, credit card and bank details, telephone number) through the order form for the sale of products on the Site or through other sections of the same not specified because related to future developments. Your personal data is mainly processed electronically and in some cases also in paper format, such as when the processing of your data is necessary to prevent fraud on the Site. Your personal data will be kept in a form that allows your identification for the time strictly necessary for the purpose for which it was collected and subsequently processed and, in any case, within the limits of the law.

We retain your personal information to enable you to use our Services on an ongoing basis for as long as necessary to fulfill the purposes described in this Privacy Policy, as required by law for example for tax and accounting purposes or as otherwise disclosed to you. For example, we keep your transaction history so that you can review the purchases you have made (and repeat orders if you wish) and to which addresses you have requested orders to be sent, as well as to improve the suitability of the products and content we recommend. In order to ensure that your personal data is always accurate, up-to-date, complete and relevant, please report any changes to the following e-mail address: info@dipaolotrade.it Except as otherwise provided herein, your personal data will not be disclosed to third parties for any purpose not permitted by law or without your express consent.

Your data is also made available to third parties for purposes ancillary to and related to the provision of the services you requested (e.g. for purchase transactions). For details on this aspect, see what is said later in paragraph 4 (to whom we disclose your personal data). You may request and obtain an updated list of data processors at any time by writing to the following e-mail address:

info@dipaolotrade.it. Your data may be disclosed to the police or to judicial authorities, for example, as part of the anti-fraud services of the Site, in accordance with the law and when required. Your data will also be accessible to the Data Processors, as indicated in this paragraph 2, and for the specific purposes indicated in the same paragraph. Your personal data will not be transferred abroad, to countries outside the European Union, which do not ensure an adequate level of protection of individuals. Should this be necessary to achieve the Purposes, we assure you that the transfer of your personal data towards countries that do not belong to the European Union and that do not ensure adequate protection levels, will be carried out only after the conclusion between Di Paolo Arredamenti S.a.s. and said subjects of specific contracts, containing adequate safeguard clauses for the protection of your personal data, in compliance with the applicable laws and regulations. The purposes for which your personal data will be used are known specifically, from time to time, in the information text submitted in the page where the conferment of personal data is requested. It may happen that Di Paolo Trade S.r.l. processes personal data of third parties communicated directly by its users to Di Paolo Trade S.r.l., e.g. when the user intends to recommend a service or a product for sale on the Site to a friend, or when the person who pays the purchase price is different from the person to whom the product is sent. In the aforementioned cases you are invited to obtain the consent of the person to whom the data refers before communicating it to Di Paolo Trade S.r.l., and to inform him/her of this Privacy Policy because you will be the one and only person responsible for the communication of information and data relating to third parties, without their express request, and for their incorrect or unlawful use. In any case, Di Paolo Trade S.r.l., within the limits of what is prescribed by the law, will fulfil its obligation to inform the reported user and, where necessary, will request his/her express consent, at the time of recording the relevant personal data in its archives.

3. FAILURE TO PROVIDE PERSONAL DATA AND CONSEQUENCES The provision of your personal data to Di Paolo Trade S.r.l. and, in particular, your personal details, your e-mail address, your postal address, your credit/debit card and bank details and telephone number is necessary in order to achieve the Purposes. Some of these data may be indispensable in order to comply with obligations deriving from laws or regulations or for the provision of other services rendered on the Site and requested by you. Failure to provide certain necessary data, identified on the Site with an asterisk (*), may make it impossible to execute the contract for the purchase of products or to properly fulfil legal and regulatory obligations. Failure to provide data may therefore constitute, depending on the case, a legitimate and justified reason for

not executing the contract for the purchase of products on the Site or the provision of services through the Site. The indication to Di Paolo Trade S.r.l. of further Personal Data, other than those which must be provided, is instead optional and does not entail any consequence in relation to the purchase of products on the Site.

4. TO WHOM WE COMMUNICATE PERSONAL DATA AND FURTHER PURPOSES Di Paolo Trade S.r.l. will process the data provided by users for the exclusive purpose of providing services to users, such as in particular: communications and commercial information, also from partner companies, by means of newsletters and/or in order to reply to any communications received, as well as related activities (including, but not limited to, administrative, managerial, statistical, marketing and commercial purposes), both manually and electronically and/or automatically. The data may be processed by third parties who provide services functional to the management of the browsing experience on the site: such as companies that provide virtual assistance services, live chat or user interaction management. The data will not be communicated, assigned or, in any other way, transferred to other third parties, without the users being informed in advance and, with their consent, when required by law.

We also process your personal data to carry out, provide and improve the Services we offer to our customers. These purposes include:

• Purchase and delivery of products and services. We use your personal data to receive and process orders, deliver products and services, process payments and communicate with you about your orders, products, services and promotional offers.

• Payment management Payment management services allow Di Paolo Trade S.r.l. to process payments by credit card, bank transfer or other instruments. The data used for payment are acquired directly by the manager of the payment service requested without being processed in any way by Di Paolo Trade S.r.l. Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding payment.

• Fraud and credit risk prevention. We process personal data to prevent and detect fraud and abuse in order to protect the safety of our customers and others. We may also use creditworthiness indices to assess and manage credit-related risks.

• Fulfilling legal obligations. In some cases we collect and use your personal data to fulfil our legal obligations. For example, we collect information from third party vendors regarding their location and bank account for identification and other purposes.

• Communicating with you. We use your personal data to communicate with you about our services through various channels (e.g. by telephone, e-mail and chat and by other means not explicitly stated here).

5. HOW WE COLLECT YOUR DATA ON THE SITE Di Paolo Trade S.r.l. collects personal data and other information as part of the process of registering online at the Site or sending order forms for the purchase of products on the Site in order to conclude e-commerce transactions. This data is processed by Di Paolo Trade S.r.l. within the limits and for the purposes illustrated in the information notice presented to the user in the specific data collection section.

6. SECURITY MEASURES We have adopted security measures in order to minimise the risks of destruction or loss, including accidental loss, of data, unauthorised access or processing that is either unauthorised or not in accordance with the purposes of collection as set out in our Privacy Policy. However, since it is not possible to guarantee that the security measures taken to protect the Site and the transmission of data and information on the Site will limit or exclude any risk of unauthorised access or dispersion of data, please ensure that your computer is equipped with up-to-date antivirus software to protect network data transmission, both incoming and outgoing, and that your Internet service provider has implemented firewalls and spam filters or other appropriate security measures to protect network data transmission.

7. YOUR RIGHT OF ACCESS TO DATA AND OTHER RIGHTS As provided for in Articles 15 - 22 of the GDPR, you always have the right to obtain confirmation as to whether or not personal data concerning you exist, even if they have not yet been recorded, and communication of such data in intelligible form. You also have the right to obtain information about the source of your personal data, the purposes and methods of the processing of your personal data, the logic applied in the event of processing carried out with the aid of electronic instruments, the identification details of the data controller and data processors, the names of the persons or categories of persons to whom the personal data may be communicated or who may become aware of it in their

capacity as, for example, data processors or persons in charge of processing. In part, this information is contained in our Privacy Policy; to find out more, you can send an e-mail to info@dipaolotrade.it. You always have the right to obtain from Di Paolo Trade S.r.l:

• updating, rectification or, when you have an interest, integration of your personal data;

• the deletion, transformation into anonymous form or blocking of your personal data that may have been processed in breach of the law, including data whose storage is not necessary for the purposes for which the data were collected or subsequently processed;

• certification that the above operations have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves a manifestly disproportionate effort compared to the right protected.

You will, however, have the right to object in whole or in part:

• for legitimate reasons to the processing of personal data concerning you, even if they are relevant to the purpose of collection;

• the processing of personal data concerning you for the purpose of sending advertising or direct marketing material or for carrying out market research or commercial communication.

You may freely and at any time exercise your rights, provided you do so within the limits of the law, with a request addressed to Di Paolo Trade S.r.l. at the e-mail address info@dipaolotrade.it to which we will provide an appropriate response.

8. LINKS TO OTHER WEBSITES Di Paolo Trade S.r.l. does not control or monitor such websites and their contents. Di Paolo Trade S.r.l. cannot be held responsible for the contents of these sites and the rules adopted by them, also with regard to your privacy and processing of your personal data during your navigation operations. We therefore kindly ask you to be careful when you connect to these websites through the links present on our website and to carefully read their conditions of use and privacy regulations. The Privacy Policy of the Site does not apply to the websites of third parties, nor is Di Paolo Trade S.r.l. in any way responsible for the privacy policy applied by such websites. The Site provides links to these websites solely to facilitate the user's research and navigation and to facilitate hypertext links on the Internet to other websites. Activation of the links does not imply any recommendation or recommendation by Di Paolo Trade S.r.l. for accessing and browsing these websites, nor any guarantee as to their contents, services or goods supplied and sold by them to Internet users.

9. OWNER AND RESPONSIBLE FOR PROTECTION The Data Controller is Di Paolo Trade S.r.l., with registered office in Italy, Via Cesare Battisti n. 80, 64020 Bellante TERAMO C.F. and P.IVA 01978750675. The Data Protection Manager is Mr Roberto Di Paolo, Via Cesare Battisti, 80 64020 BELLANTE (TERAMO). If you wish to receive further information on how Di Paolo Trade S.r.l.. processes your personal data, please write an e-mail to the following address: info@dipaolotrade.it To find out about your rights and be kept up to date on the legislation on the protection of persons with regard to the processing of personal data, we advise you to visit the website of the Guarantor for the protection of personal data at http://www.garanteprivacy.it/

10. COMPLAINT TO THE COMPETENT AUTHORITY Complaints may be made in relation to the processing of personal data to the competent authority: Garante sulla Protezione dei Dati personali, Piazza di Monte Citorio n. 121 00186 ROMA, Fax: (+39) 06.69677.3785, Telephone switchboard: (+39) 06.696771, E-mail: garante@gpdp.it

11. APPLICABLE LAW This Privacy Policy is defined on the basis of the GDPR. The GDPR ensures that the processing of personal data is carried out with respect for the fundamental rights and freedoms and the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to protection of personal data.

12. CHANGES AND UPDATES TO THE SITE'S PRIVACY POLICY Di Paolo Trade S.r.l may amend or simply update all or part of the Site Privacy Policy, also in consideration of changes to the laws and regulations that govern this matter and protect your rights. Changes and updates to the Privacy Policy of the Site will be binding as soon as they are published on the website in this section. We therefore ask you to regularly access this section to check the publication of the most recent and updated Privacy Policy of the Site.

14. INFORMATION ON COOKIES A "cookie" is a text file saved on the user's computer when the user accesses a website with the purpose of providing information each time the user returns to the same site. It is a kind of reminder of the internet page visited. With the cookie, the web server sends information to the user's browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) that is stored on the user's

computer, and will be re-read and updated each time the user returns to the site. In this way, the website can automatically adapt to the user. During navigation, the user may also receive cookies from different sites ("third party" cookies) on his terminal, set directly by the managers of these websites and used for the purposes and in the manner defined by them. Depending on their duration, a distinction is made between session cookies (i.e. those that are temporary and automatically deleted from the terminal at the end of the browsing session by closing the browser) and persistent cookies (i.e. those that remain stored on the terminal until they expire or are deleted by the user). Depending on the function and purpose of use, cookies can be divided into technical cookies, profiling cookies and third party cookies.

14.1 Technical cookies Some cookies are used to perform computer authentication, session tracking and store specific information about users accessing a web page. These so-called technical cookies are often useful to enable you to browse a website and use all of its functionalities. Technical cookies are those whose use does not require the user's consent. Analytics cookies also belong to this category. These are cookies that collect information about a user's use of a website and allow the website to function better. For example, analytics cookies show which pages are visited most frequently, allow us to see what the recurring patterns of use of a website are, and help us understand any difficulties the user encounters in using it.

14.2 Profiling cookies Other cookies may be used to monitor and profile users while they are browsing, studying their movements and web browsing or consumption habits (what they buy, what they read, etc.), also for the purpose of sending targeted and personalised service advertisements. We speak in this case of profiling cookies. The use of said cookies requires the prior acquisition of the user's free and informed consent pursuant to Article 7 of EU Regulation 2016/679.

14.3 Third-party cookies It may also happen that a web page contains cookies coming from other sites and contained in various elements hosted on the page itself, such as advertising banners, images, videos, maps or specific links to web pages of other domains that reside on servers other than the one on which the requested page is located. In other words, these cookies are set directly by website operators or servers other than this website. We speak, in these cases, of so-called third-party cookies, which are usually used for profiling purposes. The use of these cookies requires the prior acquisition of the user's free and informed consent. Among the 'third party' operators that may install tracking cookies we have:

• Google;

• Criteo;

• Facebook;

• Pinterest;

15. DATA DELETION To request deletion of your data, please send a request to info@dipaolotrade.it with the subject 'Data Deletion Request' and include your name and email address. We will delete your data from our systems.