Privacy and Cookie Policy

DATE OF UPDATE: 25-05-2018

INTRODUZIONE
Società Italo Britannica L. Manetti - H. Roberts & C. p.A., with registered office in Florence, Via Pelliceria 8 (the "Company" or "we"), acting in the role of independent data controller and as an affiliate of the business group known as Bolton Group (the "Group"), employs on this website (the "Site") technologies to collect information that help us to improve your online experience, in compliance with all applicable laws and regulations on data protection and with particular reference to: (i) pursuant to Article 13 of the Personal Data Protection Code (Legislative Decree No. 196 of 30 June 2003); (ii) Regulation (EU) No. 679 of 27 April 2016 (the so-called General Data Protection Code, or "GDPR"), effective as of 25 May 2018; and (iii) any other act, order, regulation or provision of the competent data protection authorities at the national and European levels - jointly defined hereinafter as the "Applicable Data Protection Legislation".

1. WHAT IS A COOKIE?

   Cookies are small text files stored on your computer or mobile device. They are widely used to make the website work, or to make it work better and more efficiently. This is possible because websites can read and write these files, so as to recognize and remember important information that will make it easier for you to use the website (e.g. remembering your preferences as a user).

2. WHICH COOKIES DO WE USE?

   Below there is a list of the different types of cookies we may use on the Site.

   Essential cookies (so-called technical cookies). These cookies are essential to our Site to enable you to navigate the Site and use its functionality. Without these essential cookies, we may not be able to provide certain services or features and our Site will not function as smoothly as we would like.

   Performance Cookies. Performance cookies, sometimes referred to as analytical cookies, collect information about your use of this Site and allow us to improve its operation. For example, performance cookies show us which pages are most visited on the website, allow us to analyze overall patterns of website usage, help us record any difficulties you have with the website and tell us whether or not our advertising is effective.

   Functionality cookies. In some circumstances, we may use feature cookies. Functionality cookies allow us to remember choices made on our website and to provide improved and more user-focused features, such as customizing a particular website, remembering if we asked you to participate in a promotion, and for other services requested, such as watching a video or commenting on a blog. All these features help us to improve your visit to the website.

   First part profiling cookies. In some circumstances, we use first-part profiling cookies. These cookies allow you to provide a better online experience that best suits your choices and preferences when you use our website. All of these features help us to continually improve your experience of using the Site and to show you products or services that may be of interest to you.
   Third-party profiling cookies. Third party cookies are cookies placed on our website by third party business partners. These cookies allow us to provide you with our commercial offers on other affiliated websites as well. We do not control the information in these third-party profiling cookies nor do we have access to this data. This information is entirely controlled by the third party companies as described in their respective policies. You may disable these cookies on the respective third party websites (see next section for deactivation methods).

3. HOW DO I CONTROL COOKIES?

   By changing your browser settings, you may decide to make the installation of any cookie dependent on your prior acceptance or to prevent the installation of any cookie altogether. For more information about cookies, please visit www.youronlinechoices.com. Please note that the configuration of each browser is different. Below there is a list of links to the most commonly used web browsers from which you can disable cookies.

   • Google Chrome
   • Mozilla Firefox
   • Internet Explorer
   • Opera
   • Safari

4. UPDATING THIS COOKIE POLICY

   We may also modify or update this Cookie Policy by following different interpretations, decisions, opinions and orders related to future data protection laws and regulations. Please refer to the Effective Date at the beginning of this Cookie Policy to see when the Policy was last implemented.

   Any changes to this Cookie Policy will be notified in advance and will in any case be available when we post the revised version of the Policy on our Site. If we make significant changes to this Cookie Policy that extend our rights to use personal information already collected from you, we will notify you and provide you with a choice regarding our future use of personal information.

5. CONTACTS

   If you have any questions about this Cookie Policy or if you would like to exercise your fundamental rights, please read our Privacy Policy below or contact us at privacy@manettiroberts.it

PRIVACY
DATE OF ENTRY INTO FORCE 25-05-2018

INTRODUCTION
Società Italo Britannica L. Manetti - H. Roberts & C. p.A. with registered office in Florence, Via Pelliceria 8 (the "Company" or "we"), which acts as an independent data controller and as an affiliate of the business group known as Bolton Group (the "Group"), intends to inform you about the ways in which it collects, uses and discloses personal data about you through the site ("Site") and its services ("Services"), in compliance with all applicable laws and regulations on data protection and with particular reference to: (i) pursuant to Article 13 of the Personal Data Protection Code (Legislative Decree no. 196 of 30 June 2003); (ii) Regulation (EU) no. 679 of 27 April 2016 (the so-called General Data Protection Regulation or "GDPR"), in force since 25 May 2018; and (iii) any further laws, ordinances, regulations or provisions of the competent national and European data protection authorities - hereinafter collectively referred to as the "Applicable Data Protection Legislation".

It should be noted that the Services may include, among other things, the possibility of participating in prize contests, lotteries, competitions and/or other initiatives organized by the Company in individual cases, also in collaboration with the Group.

1. TO WHAT AND TO WHOM DOES THIS POLICY APPLY?

   The Company is the owner of the processing of personal data (i.e. all information regarding an identified or identifiable natural person as data subject) collected from you or on you through the Site and Services, which are processed in accordance with the provisions of this Privacy Policy.

   This Privacy Policy and our Cookie Policy www.manettiroberts.it/cookie.html apply to all users, including those who use the Site and Services without registering or subscribing to a specific service.

2. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?

   The Company collects (1) data that you have voluntarily shared with the Company, (2) activity data collected when you access and interact with the Site or Services, and (3) other information. More specifically, the Company collects the following personal data:

   1. Registration data: collected through the registration form.1. Registration data: collected through the registration form.
   2. Data that you have voluntarily shared with the Company: We may collect your personal data (such as your first name, last name, e-mail address, telephone number, etc.) if you submit a request using the contact form available on the Site, if you register for an account or if you wish to benefit from the Services we provide;
   3. Activity Data: While you are accessing or interacting with the Site, we may collect certain information about such visits. For example, to enable you to connect to the Site or services, our servers receive and record information about your computer, device and browser, including, potentially, your IP address, browser type and other software and hardware information. If you are logged in from a mobile or other device, we may collect the unique identifier assigned to it, geolocation data or other information about your operations with that device. We may also use cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology with cookies), which may also be used to collect and store information about your use of the Site or services, such as pages you visit, content you view, searches you make, and advertisements you view. More information can be found in our Cookie Policy (at the top of this page, at www.manettiroberts.it/cookie.html).
   4. Information from other sources. The information collected may be supplemented by data from other sources, e.g. publicly available and commercially available information.

   If the information collected by and about you does not identify you as a specific person (e.g., raw data, aggregated or anonymous), directly or indirectly, may be used for any purpose or shared with third parties, to the extent permitted by applicable legislation on protection of personal data.

   We don't collect

   • Financial Data from Payment Service Providers: In some cases, we may use an affiliate payment service to enable you to purchase a product or make payments. In such a case, the information you provide is subject to the privacy policy of that provider, rather than this Policy.• Financial Data from Payment Service Providers: In some cases, we may use an affiliate payment service to enable you to purchase a product or make payments. In such a case, the information you provide is subject to the privacy policy of that provider, rather than this Policy.
   • Special Categories of Personal Data: We expressly ask you not to submit or disclose to us on or through the Site, the Services or otherwise information included in special categories of personal data (such as social security numbers, information regarding racial or ethnic origin, political opinions, religious or other beliefs, health, criminal records or union membership).

   Related services. The Services may also be linked to sites operated by non-affiliated companies, and may contain advertising or offer content, features, games, newsletters, contests or sweepstakes, or applications developed and operated by non-affiliated companies. We are not responsible for the privacy practices of such non-affiliated companies and therefore, by leaving the Services or clicking on advertisements, we recommend that you check their privacy policies.

3. WHY DO WE COLLECT PERSONAL INFORMATION?

   We process personal information collected from you and from you for:

   • allow you to use the Site and Services;
   • allow you to use the Site and Services;
   • evaluate and improve our Services and their features;
   • improve your experience when you browse the Site and use the Services;
   • provide customer support and respond to requests;
   • comply with legal obligations (including the provision of services); or respond to requests from public and state authorities;
   • protect the rights of the Company and others: more specifically, in some cases the Company may disclose personal data, even in situations where the Company believes in good faith that such processing is necessary: (i) to protect, assert or defend the legal, privacy, security or property rights of the Company or its employees, agents and contractors (including the enforcement of our contracts and terms of use); (ii) to protect the security and privacy of users of the Site or Services or other persons; and (iii) for fraud protection or risk management purposes;
   • with your optional consent, to send you promotional and marketing communications by automated means (sms, mms, e-mail, unmanned calls, etc.) and non-automated means (operator calls or paper correspondence);
   • with your optional consent, to understand your preferences and personal choices, to always provide you with the services you prefer;
   • with your optional consent, to share your data with trusted business partners, including other Group companies, to enable them to send you commercial messages.

   Where data collected from or about you does not personally identify you, we may use that information for additional purposes or share it with third parties.

4. WHAT ARE THE LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL DATA?

   The processing of personal data for the purposes of the

   • paragraph 3, points a) to d) of this Privacy Policy is necessary for the management of the website and the provision of the Services;
   • paragraph 3, points a) to d) of this Privacy Policy is necessary for the management of the website and the provision of the Services;
   • paragraph 3, letter e) of this Privacy Policy is mandatory as required by applicable law;o paragraph 3, letter f) of this Privacy Policy is based on the legitimate interest of the Company, if any;
   • paragraph 3, letters g), h) and i) of this Privacy Policy is made on the basis of the optional consent of the user and, where possible, the legitimate interest of the Company.

   These data processing activities are not mandatory and the user may object or revoke consent at any time using the methods described in paragraph 10 of this Policy.

5. HOW LONG DO WE KEEP PERSONAL DATA?

   The Company shall process personal data for a period of time not exceeding the achievement of the purposes set out in accordance with paragraph 3 above. In any case, the following retention periods apply:

   • the data collected for the purposes referred to in paragraph 3, letters a) to d) are kept for the period strictly necessary to allow the user to use the website or the Services;
   • the data collected for the purposes referred to in paragraph 3, letters a) to d) are kept for the period strictly necessary to allow the user to use the website or the Services;
   • the data collected for the purposes referred to in paragraph 3, letter e) are kept for ten (10) years in order to respond to requests from interested parties and comply with applicable laws and regulations, including in relation to the Services;
   • the data collected for the purposes referred to in paragraph 3, letter f) are kept for the period strictly necessary to pursue the legitimate interests of the Company;o the data collected for the purposes referred to in paragraph 3(g) and (h) shall be kept for the period strictly necessary to fulfil the purposes for which they were originally collected and, in any event, no longer than five years;
   • the data collected for the purposes referred to in paragraph 3(i) shall be kept for the period strictly necessary to fulfil the purposes for which they were originally collected, as determined by the recipients of such data.

6. HOW ARE PERSONAL DATA PROCESSED?

   For the purposes mentioned above, the data are processed by electronic and manual means, and are protected by appropriate security measures. In this regard, although the Company applies adequate administrative, technical, physical and personnel measures to safeguard the data in its possession from loss, theft, unauthorized use, disclosure and modification, can not guarantee the exclusion of all possible computer risks.

7. WHO HAS ACCESS TO PERSONAL DATA?

   For purposes consistent with those indicated in paragraph 3 of this Privacy Policy, the Company may share personal data with the following categories of recipients located inside or outside the European Union in compliance with and within the limits of the provisions of paragraph 7 below:

   • Other Group companies, as the case may be;o Other Group companies, as the case may be;
   • Third party service providers entrusted with processing activities and data processors or sub-responsibles duly appointed if required by applicable legislation (e.g. cloud service providers, other Group companies, service providers instrumental to or supporting the Services - and therefore, by way of example and not limited to, companies providing IT services, experts, consultants and lawyers, companies resulting from any mergers, demergers or other transformation);
   • Competent national authorities in compliance with applicable legislation;
   • Trusted business partners, with the express consent of the person concerned. The sectors to which these business partners belong are: (i) consumer goods; (ii) personal hygiene; (iii) aesthetics; (iv) household cleaning; (v) glues and sealants.

8. ARE PERSONAL DATA TRANSFERRED ABROAD?

   Personal data may be transferred to countries within or outside the European Economic Area (EEA).

   The European Commission has recognised the adequacy of the protection of personal data in accordance with EEA standards in some non-EEA countries. The complete list of these countries is available https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

   It is recalled that adequate data protection safeguards have been put in place for the transfer of data to countries outside the EEA, therefore such transfers comply with the requirements and obligations of the applicable data protection law.

   We do not transfer personal data to countries outside the European Economic Area.

9. CHILDREN UNDER THE AGE OF 18 YEARS OLD

   The Site is not intended for people under the age of 18 and the Company does not knowingly collect personal information from children.

10. QUALI DIRITTI SI POSSONO AFFERMARE IN RELAZIONE AI DATI PERSONALI?

    The User has and/or may exercise the following rights at any time, free of charge:

    • right to be informed about the purposes and methods of the processing;
    • right to be informed about the purposes and methods of the processing;
    • right of access;
    • right to obtain a copy of the data held abroad and information on where it is held;
    • right to request the updating, rectification or integration of data;
    • the right to request the erasure, anonymisation or blocking of data;
    • the right to object to the processing, in whole or in part, even where it is carried out by automated decision making, including profiling;
    • the right to withdraw consent to the processing of data freely and at any time;
    • the right to contact the Data Protection Officer, where appropriate;
    • the right to lodge a complaint with the national data protection authority or judicial authorities.

    In addition to the rights listed above, from 25 May 2018 the User may also exercise the following rights, following the full applicability of Regulation (EU) No. 679 of 27 April 2016:

    • right to data portability (i.e. to receive an electronic copy of the personal data concerning him/her, for possible transfer to the User or to another data controller);o right to data portability (i.e. to receive an electronic copy of the personal data concerning him/her, for possible transfer to the User or to another data controller);
    • right to limit the processing.

    If you have any doubts, comments or complaints regarding the collection or use of your personal data, please do not hesitate to contact us at privacy@manettiroberts.it

11. CHANGES AND UPDATES

    This Privacy Policy shall take effect on the date specified in the introduction. The Company may modify and/or supplement this Privacy Policy also following the modification and/or integration of the applicable legislation on data protection. These changes will be periodically communicated to you in advance by the Company.