Privacy Policy

INFORMATION ON THE PROCESSING OF PERSONAL DATA

MIRO EUROPE S.r.l., with registered office in Via Boggia 4 – 28013 – Not one (NO), CF and P.IVA 01831240039 (afterwards, “Holder”), as data controller, It informs you pursuant to art. 13 D.Lgs. 30.6.2003 n. 196 (afterwards, “Privacy Code”) and the art. 13 EU Regulation no. 2016/679 (afterwards, “GDPR”) that your data will be processed in the following ways and for the following purposes:
1. Object of the Processing
The Data Controller processes personal data, identifiers (for example, name, surname, company name, address, telephone, e-mail, bank and payment references) - afterwards, “personal data” or even “data”) communicated by you upon the conclusion of contracts for the Data Controller's services.
2. Purpose of the processing
Your personal data is processed:

1. without your express consent (art. 24 lett. a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:
   • conclude contracts for the Owner's services;
   • fulfill pre-contractual obligations, contractual and fiscal deriving from existing relationships with you;
   • fulfill the obligations established by law, by a regulation, by community legislation or by an order from the Authority (such as in anti-money laundering matters);
   • exercise the rights of the Owner, for example the right to defense in court;

1. only with your specific and distinct consent (articles. 23 e 130 Privacy Code and art. 7 GDPR), for the following Marketing Purposes:

• send them via email, mail and/or text messages and/or telephone contacts,newsletter, commercial communications and/or advertising material on products or services offered by the Owner and detection of the degree of satisfaction with the quality of the services;
• send them via email, post and/or text messages and/or telephone contacts commercial and/or promotional communications from third parties (for example, business partner, compagnie

We inform you that if you are already our customers, we may send you commercial communications relating to the Data Controller's services and products similar to those you have already used, subject to your dissent (art. 130 c. 4 Privacy Code).
3.Treatment methods
The processing of your personal data is carried out by means of the operations indicated in the art. 4 Privacy Code and art. 4 n. 2) GDPR and precisely: collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, usage, interconnection, block, communication, deletion and destruction of data.

Your personal data is subjected to both paper and electronic and/or automated processing.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no longer 10 years from the termination of the relationship for the Service Purposes and no later 2 years from data collection for Marketing Purposes.
4.Data access
Your data may be made accessible for the purposes referred to in the art. 2.a) e 2.b):

• to employees and collaborators of the Owner, in their capacity as internal data processors and/or managers and/or system administrators;
• to third-party companies or other subjects (for indicative purposes, credit institutions, professional studies, consultants, insurance company, etc.) who carry out outsourced activities on behalf of the Owner, in their capacity as external data controllers.

5.Data communication
Without the need for express consent (ex art. 24 lett. a), b), d) Privacy Code and art. 6 lett. b) e c) GDPR), the Data Controller may communicate your data for the purposes referred to in the art. 2.a) to Supervisory Bodies, Judicial authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom communication is mandatory by law for the fulfillment of the aforementioned purposes. These subjects will process the data in their capacity as independent data controllers.

Your data will not be disclosed.
6.Data transfer
Personal data is stored on the server located in Gattico – Veruno at the Data Controller's headquarters, within the European Union. In any case, it is understood that the Owner, where it becomes necessary, will have the right to move the servers even outside the EU. In that case, the Data Controller hereby ensures that the transfer of non-EU data will take place in compliance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of providing data and consequences of refusing to respond The provision of data for the purposes referred to in art. 2.a) it is mandatory. In their absence, we will not be able to guarantee the services of the art.a).

The provision of data for the purposes referred to in art. 2.b) however, it is optional. You can therefore decide not to provide any data or to subsequently deny the possibility of processing data already provided: in that case, you will not be able to receive newsletters, commercial communications and advertising material relating to the Services offered by the Owner. You will however continue to be entitled to the Services referred to in the art. 2.a).

8.Rights of the interested party
In your capacity as an interested party, has the rights referred to in the art. 7 Privacy Code and art. 15 GDPR and precisely the rights of:

1. obtain confirmation of the existence or otherwise of personal data concerning you, even if not yet registered, and their communication in an intelligible form;
2. get the indication: a) of the origin of the personal data; b) of the purposes and methods of processing; c) of the logic applied in case of processing carried out with the aid of electronic instruments; d)of the owner's identification details, of the managers and the representative designated pursuant to the art. 5, comma 2 Privacy Code and art. 3, comma 1, GDPR; e) of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as designated representative in the territory of the State, of managers or appointees;

• obtain: a) the update, rectification or, when you are interested, data integration; b) cancellation, the transformation into anonymous form or blocking of data processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

1. the certification that the operations referred to in letters a) e b) have been made aware, also regarding their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right;
   1. oppose, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if relevant to the purpose of the collection; b) to the processing of personal data concerning you for the purposes of sending advertising material or direct sales or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and/or through traditional marketing methods by telephone and/or paper mail. Please note that the interested party's right to object, set out in the previous point b), for direct marketing purposes using automated methods extends to traditional ones and in any case the possibility remains for the interested party to exercise the right of opposition even if only in

part. Therefore, the interested party can decide to receive only communications via traditional methods or only automated communications or neither of the two types of communication.

Where applicable, also has the rights referred to in the articles. 16-21 GDPR (Right of rectification, right to be forgotten, right to limit processing, right to data portability, right of opposition), as well as the right to complain to the Guarantor Authority.

9.Methods of exercising rights

You may exercise your rights at any time by sending:

– a registered letter with return receipt. to MIRO EUROPE SRL via Boggia 4 – 28013 Gattico – Veruno (NO);

– an email to the address info@miroeurope.net

10.Holder, responsible and in charge

The data controller is MIRO EUROPE S.r.l. with headquarters in via Boggia 4 – 28013 Gattico – Veruno (NO)

The updated list of data controllers and persons in charge of processing is kept at the headquarters of the Data Controller.