Privacy Notice

PRIVACY NOTICE

(pursuant to Article 13 of the GDPR)

DATA CONTROLLER DETAILS

Name: Ulixe Group S.r.l.

VAT number: 03305250122

Registered office: Lungo Dora Pietro Colletta 67, 10153, Turin (To)

Ulixe Group S.r.l. (hereinafter referred to as the "Data Controller" or "Ulixe"), in its capacity as Data controller, informs Data Subjects (hereinafter referred to as "Data Subject" or "User") pursuant to Article 13 of EU Regulation No. 2016/679 (hereinafter referred to as the "GDPR") that the Data Subjects' Data will be processed in the following manner and for the following purposes:

1. Data processed

The Data Controller processes identifying data and usage data of the Data subject (hereinafter referred to as "Personal Data" or simply "Data") generated during their interaction with the Data Controller's website (the "Site"), accessible at the following address www.ulixe.com.

The User's device data and technical information about the User's network (e.g. IP address) may also be processed by the Website.

2. Purposes and Lawfulness of Processing.

The User's Data is processed for the following purposes:

(a) Processing the Data subject's requests by completing the appropriate form;

b) Acquiring metrics aimed at ensuring the proper functioning of the Site through the use of technical cookies;

(c) Ascertain, exercise, or defend the rights of the Data Controller (e.g., defense of legal claims).

The lawful bases of the processing operations listed above are the following:

• ith regard to purpose a), the legal basis is the consent of the Data subject (Art. 6 (a) of the GDPR) expressed through an unequivocal affirmative action of the Data Subject consisting of freely and unconditionally completing the form.
• With regard to purposes b) and c), the lawfulness is grounded in the legitimate interest of the Data Controller, e.g., monitoring the correct operation of the Website and exercising the rights of the Data Controller (such as the defense of legal claims).

The provision of Data for the aforementioned purposes is optional. In the event of non-disclosure of the Data, the Data Controller will not be able to allow the User to interact with the Website and the User would not receive any answer to the requests sent to the Controller.

Furthermore, the Data may be processed only with the explicit consent of the User, for the following purposes:

(d) Statistical Purposes (upon consenting to non-technical cookies);

(e) Remarketing and Retargeting Purposes (upon consenting to cookies).

The provision of Data for statistical purposes referred to in point (d) and for Remarketing and Retargeting activities referred to in point (e) is optional. The User may therefore choose not to provide any data or subsequently deny the possibility of processing data already provided. The User may withdraw their consent to the processing of Data at any time without affecting the lawfulness of processing based on consent before revocation. Full details on the cookies used are provided in the cookie policy: https://www.iubenda.com/privacy-policy/21050801/cookie-policy.

3. Storage period

Personal data will be kept for the time necessary to fulfill the purposes described in this Privacy Notice.

The Data Controller will store for 10 (ten) years copies of correspondence of legal and commercial relevance. The remaining messages will be kept for 2 (two) years.

Finally, the User's Data may be kept for the time necessary to ensure the defense in court or to prosecute any abuse in the use of the Website.

The User's personal Data processed through the use of cookies will be deleted in the ways indicated in the Cookie policy: https://www.iubenda.com/privacy-policy/21050801/cookie-policy.

4. Communication of Data

User's data will not be disclosed but may be made accessible, where necessary for the provision of services or by law:

• to employees and consultants of the Data Controller in Italy and abroad, as authorized subjects to the processing of personal data and/or system administrators;
• to third-party companies or other subjects that perform outsourcing activities on behalf of the Data Controller, such as Data Processors.

Only in cases provided for by law, the Data Controller may communicate the User's data for the purposes specified in points 2(a)-(c) of this Privacy Policy to supervisory bodies, judicial authorities, as well as to those subjects to whom communication is mandatory by law."

5. Data Transfer

The User's Data are stored on servers located within the European Union, managed by third party companies duly appointed as Data Processors.

For specific purposes, the User's Data may be transferred by the Controller to countries outside the European Union (EU). The Data will be transferred exclusively to countries considered "adequate" - and therefore "safe" - by the European Commission or to companies that have adhered to specific international standards (e.g., Standard Contractual Clauses).

6. Data Subject Rights

The Data Subject may exercise, in relation to the Data Processing, the following rights:

a. Access rights - receive confirmation that the User's Data is held by the Data Controller, and access its content;

b. Right of rectification - update, modify and/or correct the User's Data;

c. Right to be forgotten and right to limitation - request the cancellation of Data and/or limitation of the Data Processing if the User believe that the Data is being processed in ways that do not comply with the present Privacy Notice;

d. Right to object - object to the processing of the User's Data;

e. Right to object to automated decision-making processes;

f. Right to Data Portability - receive an electronic copy of the Data concerning the User (when such Data has been rendered in the context of the contract) and request that the Data in question be transmitted to another data controller.

The right to object can be exercised in accordance with the procedures outlined in Article 21 of the GDPR.

The Data subject has the right to lodge a complaint with the relevant supervisory authority if they believe that the processing of their Data is in violation of the European Regulation for the protection of personal data.

7. Contact details of the Data Controller

The Data Controller is:

Ulixe Group S.r.l.

Headquarters: Lungo Dora Pietro Colletta 67, 10153, Turin (To). The Data Subject may exercise their rights at any time by sending an email to: [email protected].

8. Contact Details of the Data Protection Officer

The Data Protection Officer (DPO) can be contacted for any inquiries at the following email address: [email protected].

9. Information Not Contained in this Notice

Further information relating to the processing of personal Data may be requested at any time from the Data Controller using the contact information provided in this Privacy Notice.

10. Changes to this Notice

This Privacy Notice may be subject to change. Therefore, it is recommended to regularly check this notice and refer to the most updated version.

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