Information on the processing of personal data pursuant to articles 13-14 of the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Premise

This document contains information on the processing of data collected from the website www.primeur.com (hereinafter also referred to as the "Website").

Specific information regarding cookies is also reported hereinafter (the so-called Cookie Policy).

We hereby represent that this information is provided by Primeur Italy Srl only in relation to the Website and not to any other third-party internet websites which may be consulted by the Website user through any link therein contained.

2. Purpose of this document.

The purpose of this document is to provide users of the Website with the following information regarding the processing of data collected from the Website:

• what does processing mean;
• who is the data controller;
• which data are processed;
• which are the purposes and methods of processing;
• which is the timing of the data retention;
• which are the legal basis of processing;
• which is the nature (compulsory or optional) of the processing;
• who are the subjects and the categories of subjects to which the data could be communicated by Primeur and the scope of dissemination of such data;
• which are the rights of the Website user, in its quality of data subject;
• if the treatment involves automated decision-making processes (such as profiling);
• which kind of cookies are conveyed by the Website;
• which are the hyperlinks to the privacy policies of third parties;
• which are the methods available for disabling cookies.

3. Processing of data - definition.

Pursuant to art. 4 of the GDPR, the term "processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Controller

Data controller of the data collected from the Website is PRIMEUR ITALY SRL, with registered office in Via Uberto Visconti di Modrone n. 11, Milan (MI) - ITALY - CF and VAT no. 07615530966 (hereinafter also referred to as "Primeur"), in the person of its legal representative.

The e-mail address for contacting Primeur for the protection of personal data is: privacy@primeur.com .

5. Processors

Pursuant to art. 4 GDPR, Primeur may appoint third parties as data processors, whether they process personal data on behalf of the controller.

6. Data processed.

The Website may be used to collect and process browsing data and personal data supplied voluntarily by users through contact forms. Personal data includes but are not limited to:

First and last name, email address, country, telephone number, company name, job title.

By submitting the form, user authorizes Primeur to collect his/her data and process them in order to fulfill his/her specific request (eg. contact, download, event registration).

On the same forms, users have the ability to subscribe to Primeur’s marketing communications by placing a tick on specific checkboxes. These subscriptions are always optional and freely given by the user.

Sending an e-mail to the addresses published on this Website entails the subsequent acquisition of the sender's e-mail address, necessary to answer to requests, as well as any other personal data included in the message.

Furthermore, the computer systems and software procedures applied to operate the Website automatically acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which, by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of technical data includes IP addresses or domain names of the computers used by users who connect to the Website, the type of browser, information on the terminal from which you connect to the Website, data on the position (approximate) of the terminal that is used, addresses in URL notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters related to the operating system and the user's computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing.

The Website collects technical Cookies as well, referred to below in this statement (within the so-called Cookie Policy).

7. Purposes and methods of processing.

Primeur may collect and process Website users’ data for the following purposes:

a) answering requests sent to Primeur by means of contact forms on the Website;

b) sending messages for marketing purposes;

c) possible transmission of data to public authorities, if required under current legislation.

8. Processing time - data retention.

Personal data collected by Primeur through the Website will be stored on paper and / or electronic / IT format and for the time strictly necessary to satisfy the aforementioned purposes, in compliance with current regulations.

For direct marketing and profiling purposes, Primeur shall keep users’ data for a maximum period of 24 months. In the event that Primeur should have a legitimate interest storing the data for a longer time period, Primeur will provide an additional notice.

In case of express request by the user to delete personal data processed by the controller (exercise of the so-called “right to be forgotten”), such data will be stored, in a protected form and with restricted access, solely for purposes of investigation and prosecution of offenses, for a period not exceeding 12 months from the date of the request and subsequently will be erased securely or anonymised irreversibly.

9. Basis of the processing.

Pursuant to art. 6 of the GDPR, processing is to be considered lawful only if and to the extent that at least one of the following legal basis applies: consent, performance of a contract, fulfilment of a legal obligation, pursuit of a legitimate interest of the controller or of a third party, protection of the vital interests of the data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The processing of personal data provided by users of the Website is made by virtue of the following legal basis:

a) The user's consent, provided in relation to the following data:

• Personal data such as first and last name, email address, telephone number, country, company name, job title, provided voluntarily by the user through contact forms (such consent is mandatory for sending requests to Primeur and download some contents).

b) The fulfilment of any legal obligation applicable to Primeur, for the purpose of transmitting data to public bodies and authorities, should they be required in compliance with the regulations in force.

10. Recipients of the collected data.

Personal data collected by the Website may be accessed by other subsidiaries of the Primeur Group, in addition to suppliers providing hosting services, direct marketing services, advertising services, development of web application at Primeur, as detailed below:

a) HubSpot Ireland Ltd, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland (VAT: IE9849471F).

b) Microsoft SRL, located in Viale Pasubio 21, 20154 MILAN, CF 08106710158.

All the intellectual property rights of third parties relating to logos, names, company names and names of products listed above and elsewhere in this statement are reserved.

In accordance with the GDPR, Primeur provides for the appointment of its suppliers as data processors, if they process personal data collected through the Website, with the aim of guarantee adequate protection of the users and of the rights connected to them.

Personal data collected may be transferred outside the European Union to be processed by third parties providing services to Primeur. In such case, Primeur would ensure that this transfer takes place in compliance with current legislation and that an adequate level of protection of personal data is guaranteed, basing on the mechanisms envisaged for this purpose by the GDPR (such as adequacy decision adopted by the EU Commission, EU standard contractual clauses adopted by the Commission or by the competent supervisory authority, or Binding Corporate Rules).

Personal data collected may be reported to competent authorities, if and when required by law.

11. Rights of the data subject.

Any user of the Website is entitled to:

a) obtain from the controller, at any time, information about the existence of its personal data, the origin of the same, the purposes and methods of processing and, if existing, to obtain access to personal data and information referred to in Article 15 of the GDPR;

b) request the updating, rectification, integration, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation by law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;

c) oppose, in whole or in part, for legitimate reasons, to the processing of data, even if appropriate to the purpose of collection and processing of personal data provided for commercial information purposes or sending advertising material or direct selling or for the fulfilment of market research or commercial communication. Each user also has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;

d) receive its personal data, previously provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments;

e) propose a complaint to the relevant Authority for the protection of personal data (http://www.garanteprivacy.it/ ).

In case of request for elimination, limitation or opposition to the treatment, Primeur may keep some personal data within the limits of the current legislation and for the intended purposes (for example to exercise the contractual rights provided for or the right to defence).

For the purposes of exercising the above rights, a natural person who is a user of the Website may ask Primeur, via the contact details below, providing the information necessary to fulfil its own request:

• by e-mail, at the address: privacy@primeur.com
• by mail, at the following address:
  
  Primeur Italy Srl
  Via Imperia, 21/A
  20142 MILAN
  ITALY

12. Cookie policy.

Cookie

Cookies are data files that are sent from the Website to the internet browser of the user and are stored by this, only to be passed to the Website the next visit.

They can be used for different purposes, for example to monitor sessions, to authenticate a user so that he can access the Website without typing name and password each time, to memorize preferences, to store information on specific configurations concerning the users accessing the server, etc.

There are many categories of cookies, classified in various ways: for technical aspects, duration, origin, purpose, etc. The very purpose of the cookie is of the greatest importance. In this regard, we represent that the Website sends only technical cookies.

Technical cookies

They are necessary for the transmission of electronic communications network or for delivering the service requested by the user and are used for navigation and to facilitate access to and use of the Website by the user.

The use of technical cookies allows the safe and efficient use of the Website. Without the use of these cookies, some operations could not be completed or would be more complex and / or less secure. They are therefore not used for other purposes and are installed directly by the owner of the Website.

Technical cookies have a minimum degree of invasiveness, and for this reason they are exempt from consent.

Third-party cookies

In relation to the origin, it is possible to classify cookies sent to the browser directly from the Website, from those of third parties sent to the computer from other websites.

Browsing on the Website will cause third-party technical cookies to be installed, as detailed below. They are sent from the domains of the aforementioned third parties, external to the Website.

The use of these cookies is governed by the rules set by the third parties themselves, therefore, Primeur invites Website users to read the privacy policies and instructions to manage or disable individual cookies (whether available), published on their respective web pages, as detailed below.

The Website uses the following cookies and third-party services:

The cookies used in the Site are of the following sub-types:

• Browsing or session cookies, which permit ordinary browsing and use of the Website and anonymously collect information on how users use the Website, how many visitors the Website has, where they come from, and the other websites they have visited. As they are not stored on the user’s computer, these cookies disappear when the browser is closed.

13. Security of data provided.

The security and confidentiality of data collected through the Website is assured by Primeur pursuant to art. 32 of the GDPR, by means of the procedures and of the technical and organizational measures taken.

14. Changes to this document.

This document, published at the URL www.primeur.com/privacy constitutes the website privacy notice of the Primeur Group. It may be subject to changes or updates. In case of significant changes and updates, these may be notified with appropriate notifications to users.

This privacy policy was lastly updated on October 17^th, 2023.

Information on the processing of personal data pursuant to articles 13-14 of the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Premise

This document contains information on the processing of data collected from the third-level domain website https://licenserequest.primeur.com/ (hereinafter also referred to as the "Website").

Specific information regarding cookies is also reported hereinafter (the so-called Cookie Policy).

We hereby represent that this information is provided by Primeur Italy S.r.l. only in relation to the Website and not to any other third-party internet websites which may be consulted by the Website user through any link therein contained.

2. Purpose of this document.

The purpose of this document is to provide users of the Website with the following information regarding the processing of data collected from the Website:

• what does processing mean;
• who is the data controller;
• which data are processed;
• which are the purposes and methods of processing;
• if the treatment involves automated decision-making processes (such as profiling);
• which is the timing of the data retention;
• which are the legal basis of processing;
• which is the nature (compulsory or optional) of the processing;
• who are the subjects and the categories of subjects to which the data could be communicated by Primeur and the scope of dissemination of such data;
• which are the rights of the Website user, in its quality of data subject;
• which kind of cookies are conveyed by the Website.

3. Processing of data - definition.

Pursuant to art. 4 of the GDPR, the term "processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

4. Controller

Data controller of the data collected from the Website is PRIMEUR ITALY S.r.l. with registered office in Via Uberto Visconti di Modrone n. 11, Milan (MI) - ITALY - CF and VAT no. 07615530966 (hereinafter also referred to as "Primeur"), in the person of its legal representative.

The e-mail address for contacting Primeur for the protection of personal data is: privacy@primeur.com .

5. Processors

Pursuant to art. 4 GDPR, Primeur may appoint third parties as data processors, whether they process personal data on behalf of the controller.

6. Data processed.

The Website may be used to collect and process browsing data and personal data supplied voluntarily by users through contact forms. Personal data includes but are not limited to:

First and last name, email address, country, telephone number, company name, Town.

By submitting the form, user authorizes Primeur to collect his/her data and process them in order to fulfill his/her specific request (temporary (30 days) emergency SPAZIO MFT/S software license).

Sending an e-mail to the addresses published on this Website entails the subsequent acquisition of the sender's e-mail address, necessary to answer to requests, as well as any other personal data included in the message.

Furthermore, the computer systems and software procedures applied to operate the Website automatically acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected to be associated with identified interested parties, but which, by their very nature could, through processing and association with data held by third parties, allow users to be identified.

This category of technical data includes IP addresses or domain names of the computers used by users who connect to the Website, the type of browser, information on the terminal from which you connect to the Website, data on the position (approximate) of the terminal that is used, addresses in URL notation of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters related to the operating system and the user's computer environment.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct functioning and are deleted immediately after processing.

7. Purposes and methods of processing.

Primeur may collect and process Website users’ data for the following purposes:

a) answering requests sent to Primeur by means of contact forms on the Website;

b) possible transmission of data to public authorities, if required under current legislation.

No automated decision-making processes (such as profiling) are performed on data collected.

8. Processing time - data retention.

Personal data collected by Primeur through the Website will be stored on paper and / or electronic / IT format and for the time strictly necessary to satisfy the aforementioned purposes, in compliance with current regulations.

For managing Temporary Emergency Licenses released, Primeur shall keep users’ data for a maximum period of 12 months. In the event that Primeur should have a legitimate interest storing the data for a longer time period, Primeur will provide an additional notice.

In case of express request by the user to delete personal data processed by the controller (exercise of the so-called “right to be forgotten”), such data will be stored, in a protected form and with restricted access, solely for purposes of investigation and prosecution of offenses, for a period not exceeding 12 months from the date of the request and subsequently will be erased securely or anonymised irreversibly.

9. Basis of the processing.

Pursuant to art. 6 of the GDPR, processing is to be considered lawful only if and to the extent that at least one of the following legal basis applies: consent, performance of a contract, fulfilment of a legal obligation, pursuit of a legitimate interest of the controller or of a third party, protection of the vital interests of the data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The processing of personal data provided by users of the Website is made by virtue of the following legal basis:

a) The user's consent, provided in relation to the following data:

• Personal data such as first and last name, email address, country, telephone number, company name, Town, provided voluntarily by the user through contact forms (such consent is mandatory for sending requests to Primeur).

b) The fulfilment of any legal obligation applicable to Primeur, for the purpose of transmitting data to public bodies and authorities, should they be required in compliance with the regulations in force.

10. Recipients of the collected data.

Personal data collected by the Website may be accessed by other subsidiaries of the Primeur Group, in addition to suppliers providing services (such as hosting services, direct marketing services, advertising services, development of web application, etc.) at Primeur, as detailed below:

a) Microsoft SRL, located in Viale Pasubio 21, 20154 MILAN, CF 08106710158.

All the intellectual property rights of third parties relating to logos, names, company names and names of products listed above and elsewhere in this statement are reserved.

In accordance with the GDPR, Primeur provides for the appointment of its suppliers as data processors, if they process personal data collected through the Website, with the aim of guarantee adequate protection of the users and of the rights connected to them.

Personal data collected may be transferred outside the European Union to be processed by third parties providing services to Primeur. In such case, Primeur would ensure that this transfer takes place in compliance with current legislation and that an adequate level of protection of personal data is guaranteed, basing on the mechanisms envisaged for this purpose by the GDPR (such as adequacy decision adopted by the EU Commission, EU standard contractual clauses adopted by the Commission or by the competent supervisory authority, or Binding Corporate Rules).

Personal data collected may be reported to competent authorities, if and when required by law.

11. Rights of the data subject.

Any user of the Website is entitled to:

a) obtain from the controller, at any time, information about the existence of its personal data, the origin of the same, the purposes and methods of processing and, if existing, to obtain access to personal data and information referred to in Article 15 of the GDPR;

b) request the updating, rectification, integration, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation by law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;

c) oppose, in whole or in part, for legitimate reasons, to the processing of data, even if appropriate to the purpose of collection and processing of personal data provided for commercial information purposes or sending advertising material or direct selling or for the fulfilment of market research or commercial communication. Each user also has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given prior to the revocation;

d) receive its personal data, previously provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments;

e) propose a complaint to the relevant Authority for the protection of personal data (http://www.garanteprivacy.it/ ).

In case of request for elimination, limitation or opposition to the treatment, Primeur may keep some personal data within the limits of the current legislation and for the intended purposes (for example to exercise the contractual rights provided for or the right to defence).

For the purposes of exercising the above rights, a natural person who is a user of the Website may ask Primeur, via the contact details below, providing the information necessary to fulfil its own request:

• by e-mail, at the address: privacy@primeur.com
• by mail, at the following address:

Primeur Italy Srl

Via Imperia, 21/A

20142 MILAN

ITALY

12. Cookie policy.

Cookie

Cookies are data files that are sent from the websites to the internet browser of the users and are stored by this, only to be passed to the websites the next visit.

They can be used for different purposes, for example to monitor sessions, to authenticate a user so that he can access a website without typing name and password each time, to memorize preferences, to store information on specific configurations concerning the users accessing the server, etc.

There are many categories of cookies, classified in various ways: for technical aspects, duration, origin, purpose, etc. The very purpose of the cookie is of the greatest importance. In this regard, we represent that the Website does not send any cookie.

13. Security of data provided.

The security and confidentiality of data collected through the Website is assured by Primeur pursuant to art. 32 of the GDPR, by means of the procedures and of the technical and organizational measures taken.

14. Changes to this document.

This document, published at the URL www.primeur.com/privacy constitutes the website privacy notice of the Primeur Group – License Request service. It may be subject to changes or updates. In case of significant changes and updates, these may be notified with appropriate notifications to users.

This privacy policy was lastly updated on October 17^th, 2023.