INFORMATION RELATING TO THE PROCESSING OF PERSONAL DATA (PRIVACY) Based on Legislative Decree 196/2003 "Code regarding the protection of personal data" and EU Regulation 2016/679

With reference to the provisions of Legislative Decree 196/2003 "Code regarding the protection of personal data", and of EU Regulation 2016/679, in particular with regard to articles 12 and 13, we inform you that your personal data will be treated in accordance with current legislation.

ATER TUMTI BY AURIEMMA GIUSEPPINA

with headquarters in Via Vignariello, 84 80049 Somma Vesuviana (NA) 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 Data Protection Regulation are implemented of the European Union (hereinafter in the text "GDPR" acronym of General Data Protection Regulation) and other legal provisions, including, in particular, those of the Code regarding the protection of personal data (hereinafter "Privacy Code" or "Code").

1. Who is the data controller? ATER TUMTI DI AURIEMMA GIUSEPPINA with headquarters in Via Vignariello, 84 80049 Somma Vesuviana (NA) (hereinafter in the text "ATER TUMTI DI AURIEMMA GIUSEPPINA" or "we"), is the data controller of your personal data according to the meaning of the GDPR and of the Code.

2. What data do we process? Personal data means any type of information relating to an identified or identifiable natural person (hereinafter "Data").

Data provided by you: all the data you have provided us to request the sale of goods 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 box), 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, constitutes a necessary requirement for the conclusion of the Contract; failure to communicate such data may make it impossible for ATER TUMTI DI AURIEMMA GIUSEPPINA to conclude the Contract and/or provide the related services and products. The aforementioned data may have already been provided by you to member companies and/or companies belonging to the ATER TUMTI DI AURIEMMA GIUSEPPINA Group.

ATER TUMTI DI AURIEMMA GIUSEPPINA does not acquire and does not process categories of personal data, such as, for example, information revealing your racial origin, your political opinions, your religious or philosophical beliefs.
3. On which legal basis and according to which 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 provisions of the Code:

• Consent art. 6(1) paragraph 1(a), art. 7 GDPR): we will process certain Data exclusively in the presence of your preliminary, free and express consent. You have the right to revoke the consent given at any time with effect for the future.

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

• Compliance with a legal obligation art. 6(1) paragraph 1(c) GDPR): in order to ensure compliance with these requirements, we must process certain data

4. For what purposes are your data processed? Your Data will be processed by us only and exclusively for the purposes permitted by data protection legislation such as: a) purposes previously approved by you; b) data processing in order to execute the Contract; c) execution of pre-contractual measures upon your request; d) fulfillment of legal obligations to which we are subject; e) safeguarding our legitimate interests or the legitimate interests of third parties, unless your interests prevail over them; f) assessment, exercise or defense of a legal right or claim; g) for reasons of significant public interest; h) marketing and advertising, in particular direct marketing activities.

Among other things, we will process your data for the specific purposes as set out below by way of example:

- for purposes relating to the Contract: above all to execute the Contract stipulated with you;

- contact you in relation to the Contract and for the management of the same;

- customer service: in order to offer you a valid customer service, we will regularly process your data, in order, for example, to give you complete advice. Furthermore, for the sole purpose of improving the quality of customer care and staff training processes, we could 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 .

- management of requests for legal guarantees, product conformity, assistance, requests for withdrawal, management and termination of the Contract;

- collaboration with member companies and/or companies belonging to ATER TUMTI DI AURIEMMA GIUSEPPINA for a better management of your requests/needs;

- transfer of data to third parties only and solely for the management of the request if made with "remote" procedures via video, internet and only and solely for the Personal Data requested from the operators of the platforms used for these procedures

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, possibly based on 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, studies on customer satisfaction with our services. In the context of market research activities, we only 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 in this regard, 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 telephone, SMS, email: obviously you can object at any time to the processing for these purposes.

In addition to the above, ATER TUMTI DI AURIEMMA GIUSEPPINA may process your data to comply with legal obligations and, therefore, for compliance with any rule or legal provision that we intend and must comply with or for data security for indispensable measures to ensure security of your data and company data from external attacks and/or in order to prevent external attacks. Still to comply with legal obligations imposed on us and/or in order to prevent fraud or in the event of a dispute. Finally, for mandatory tax, accounting and administrative purposes, always in accordance with and in compliance with current regulations.

In some cases, certain functions of the site and/or of the ATER TUMTI DI AURIEMMA GIUSEPPINA application and/or of certain promotions and/or operations may be limited for persons of a younger age than that indicated on the ATER TUMTI DI AURIEMMA site GIUSEPPINA and/or established by current regulations; in such cases, an additional express consent may be required to use certain services and/or features.

Finally, ATER TUMTI DI AURIEMMA GIUSEPPINA may process your data for the protection of legitimate interests of the same ATER TUMTI DI AURIEMMA GIUSEPPINA except in the case in which your interests prevail. This is done with sales controls to improve the services rendered and in aggregate and anonymous form without your identity being indicated or for studies aimed at improving the products and services rendered as well as our procedures.

5. How long will we process your data? As expressly provided for by art. 5, co. 1, lit. 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, it will be automatically deleted or saved in a format that does not allow any direct conclusions to be drawn regarding your identity, as soon as the last specific purpose has been fulfilled. In order for all your data to be canceled or made anonymous in line with the principle of data minimization and in compliance with art. 5, co. 1, lit. e) of the GDPR.

Indicatively, your data will be kept for the following periods: - fiscal / administrative obligations: 10 years; - regulatory obligations regarding product warranty: 28 months; - contractual obligations regarding additional after-sales services: from 36 to 78 months based on the service chosen.

How is your data protected? ATER TUMTI DI AURIEMMA GIUSEPPINA will process your personal data on the basis of the security obligations relating to data processing pursuant to art. 32 GDPR. In order to ensure an adequate level of data protection aimed at limiting the risk of using them improperly or illegally, technical and organizational measures have been implemented that comply with internationally recognized IT standards, these measures are constantly monitored .

With whom will your data be shared? Your data may be shared with third parties including:

• subjects belonging to ATER TUMTI DI AURIEMMA GIUSEPPINA and/or member companies of ATER TUMTI DI AURIEMMA GIUSEPPINA always adopting adequate measures to ensure that your data are processed, protected and transferred in compliance with the applicable legal provisions, by way of example, in order to improve IT services, in cases where you have consented to sharing your data with other Group companies for commercial or marketing purposes, for group reporting, to verify complaints and requests, to manage defects and damages of the goods sold , provision of the additional services requested

• external third parties to the extent that this is necessary or appropriate for the achievement of 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, in the context of the following contexts:

- enveloping, sorting and transmission of communications to customers, as well as filing and substitutive storage of data;

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

- customer assistance activities (also with call center, help desk);

- appraisal, auditing and balance sheet certification activities;

- commercial information activities carried out by external companies with the legal authorizations in compliance with current regulations, organization of events or advertising campaigns, detection of the quality level of products and services, market surveys;

- professional consultancy and assistance activities.

ATER TUMTI DI AURIEMMA GIUSEPPINA will appoint all the aforementioned subjects as Data Processors, in the event that the relative conditions exist, and in any case will bind these third parties to maintain confidentiality in relation to your Data.

ATER TUMTI DI AURIEMMA GIUSEPPINA undertakes not to transfer your data outside the European Community.

Your rights. Based on the GDPR and other applicable data protection provisions, you have specific and non-limitable rights.

As an interested party, you have in particular the following rights under the GDPR, against ATER TUMTI DI AURIEMMA GIUSEPPINA:

- Right of access (art. 15 GDPR): you may request at any time to be provided with information on your data stored by us. This information refers, among other things, to the categories of data processed by us, the purposes of the processing, the origin of the Data in the event that we did not obtain it directly from you, as well as the recipients to whom we may have transferred your Data where applicable. You will be able to receive a free copy of your data which are the subject of the contract.
- Right of rectification (art. 16 GDPR): you may request a rectification of your data. We will adopt appropriate measures aimed at ensuring that your data stored and processed by us on an ongoing basis are kept correct, complete, updated and pertinent, based on the most recent information you provide to us.

- Right of cancellation (art. 17 GDPR): you may request the cancellation of your data, provided that the relative conditions established by law exist. For example, this could occur on the basis of art. 17 of the GDPR:

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

• - if you withdraw your consent on which the data processing is based, and there is no other legal basis for the processing;

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

• - if the Data has been processed unlawfully; unless the processing is necessary: ​​- for the fulfillment of a legal obligation that requires the processing of your data; in particular with regard to the retention periods of documents required by law; - for the assessment, exercise or defense of a legal right or claim.

- Right to limitation of treatment (art. 18 GDPR): you can obtain a limitation of the processing of your data if these are not accurate or if they are no longer necessary;

- Right to data portability (art. 20 GDPR): you have the right to receive a copy of your data, previously provided by you directly to ATER TUMTI DI AURIEMMA GIUSEPPINA, and if expressly requested by you we undertake to transfer the same - where this is technically possible – to another data controller indicated by you;

- Right to object (art. 21 GDPR): You may object at any time, for reasons related to your particular situation, to the processing of your data, pursuant to art. 6, paragraph 1, letters e) or f) of the GDPR, or if personal data are processed for direct marketing purposes. In this case, we will no longer process your data. The latter condition does not apply if we can demonstrate the existence of compelling legitimate reasons which justify the processing and which outweigh your interests, or if we need your data to ascertain, exercise or defend a right in court.
- Right to withdraw consent at any time (art. 13 GDPR) if the treatment is based on consent - without prejudice to the lawfulness of the treatment based on the consent given before the revocation, by sending the relative request to the contacts listed below or through the technical methods possibly made available by ATER TUMTI DI AURIEMMA GIUSEPPINA.

ATER TUMTI DI AURIEMMA GIUSEPPINA will try to manage all requests in a reasonable period and, indicatively, within 30 days, unless a reasoned extension is indicated and communicated.

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

In any case, you will be able to find any broader reference on the subject 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:

http://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 ATER TUMTI DI AURIEMMA GIUSEPPINA, in the person of the Legal Representative.

For all requests for information and to exercise your rights, you can contact ATER TUMTI DI AURIEMMA GIUSEPPINA:

- by post to ATER TUMTI DI AURIEMMA GIUSEPPINA Via Vignariello, 84 80049 Somma Vesuviana (NA);

- by email at info@ater-tumti.it.

The Data Protection Officer can be contacted directly at the following email address: info@ info@ater-tumti.it.

ATER TUMTI DI AURIEMMA GIUSEPPINA will promptly inform you where there should be substantial changes with reference to the way in which your data are processed, we will promptly inform you of such changes.

Cookies (use, purpose, deactivation)

Cookies

Cookies are computer files that can be saved on the user's computer (or other internet-enabled devices, such as smartphones or tablets) when they visit websites. Usually, a cookie contains the name of the website from which the cookie itself comes from and the 'lifetime' of the cookie (i.e. how long it will remain on the user's device).

Cookies inserted as essential for the functioning of the Websites

The Websites use session and persistent cookies, for the sole purpose of offering a more efficient service.

The use of these cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the services and functions of the Websites to be provided in a complete way.

The cookies used on the Websites avoid the use of other IT techniques potentially prejudicial to the privacy of users' browsing and do not allow the acquisition of data directly identifying the user.

Interested parties who do not want the cookies in question can delete them after browsing by simply going to the privacy settings of their browser and selecting the option to delete cookies.

Cookies inserted for aggregate analysis of site visits

ATER TUMTI DI AURIEMMA GIUSEPPINA makes use of aggregate analysis tools of navigation data that allow to improve the Websites (Web Trends and Google Analytics).

In particular, Google Analytics, a system made available by Google Inc., uses cookies that are stored on the user's computer in order to allow the website manager to analyze how users use the sites themselves. The information generated by the cookie on the use of the Websites by the user (including the anonymised IP address by removing some digits) will be transmitted to, and stored on, Google's servers in the United States. Google will use this information for the purpose of evaluating the use of the Websites by the user, compiling reports on Website activity for the operators of the same and providing other services relating to Website activity and Internet usage .

Users who do not want the cookies in question can prevent them from being stored on their computer through the appropriate "Browser add-on for deactivating Google Analytics" made available by Google at the address:

https://tools.google.com/dlpage/gaoptout

To activate the component, which prevents the system from sending information about the user's visit, simply install it by following the instructions on the screen, close and reopen the browser.

Cookies placed to serve interest-based ads

The Website may use third-party cookies to publish advertisements defined on the basis of users' interests. This information is collected during the user's browsing and is in no way linked to the account with which the user accesses the Website.

In particular, Google Adwords of Google Inc. uses navigation data within its online advertising circuit, to offer advertisements more relevant to the user's interests.

ATER TUMTI DI AURIEMMA GIUSEPPINA exploits this technology and uses the navigation data within its own website to offer the user targeted advertising based on interests.

The user can disable, in part or completely, the use of cookies by Google Adwords by visiting the pages:

https://www.google.it/ads/preferences and https://www.google.it/settings/ads/onweb

More generally, each browser allows the user to deactivate third-party cookies aimed at allowing online advertising based on the user's interests.

For example, in the case of the Firefox browser, the deactivation of the cookies in question can be carried out by following the instructions on the page: http://support.mozilla.org/it/kb/Disattivare%20i%20cookie%20di%20terze%20parti

In the case of Internet Explorer, the instructions on deactivating third-party cookies are given at the following link: http://support.microsoft.com/kb/283185/it

How to disable cookies

Most internet browsers are initially set to accept cookies automatically. The user can change these settings to block cookies or to warn that cookies are being sent to the user's device. There are various ways to manage cookies. The user can refer to the instruction manual or the help screen of his browser to find out how to adjust or change the settings of his browser. In the case of different devices (for example computers, smartphones, tablets, etc.), the user must ensure that each browser on each device is adjusted to reflect their cookie preferences.