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DISCLOSURE PURSUANT TO ART. 13 OF THE EU Regulation 679/2016

The Legal Representative of Brambati SpA, Data Controller informs you that according to EU Regulation 679/2016 (and (It.) Legislative Decree 196/03 for the parts not contrasting with the aforementioned Regulation):

1. a series of obligations are provided for the Data Controller concerning, in particular, the methods of collection, recording, processing, storage, transfer to third parties and the measures adopted by the company to provide an adequate level of protection of personal data;

1. The legitimate interests pursued by the Data Controller are linked to the performance of information activities to users who request contact through the Brambati SpA corporate website. Pursuant to art. 6 of the EU regulation 679/16 the legality of the processing is based on the express consent given by the data subject with the acceptance, after reading the disclosure, of the appropriate box on the site. The personal data held by the Company are collected directly from users.

1. The provision of data must be considered mandatory as they are necessary for the Company to comply with legal obligations.

1. The data are processed within normal Company business and for the following purposes:

- request or supply of administrative, sales or technical information;

- sending notices/invitations related to events (trade fairs, ...) organised by the Company;

- statistical analyses.

1. Your personal data that the Data Controller may collect are as follows:

personal data

• identification data, such as surname and name, e-mail address, country of origin.

1. The processing of your personal data which Brambati SpA holds will be carried out exclusively by the Data Controller, by Data Processors appointed by them who may use persons authorized to process personal data under the direct authority of the Data Controller or the Data Processors.

1. In particular, the processing of your personal data will be carried out to:

• provide administrative, sales or technical information relating to the products/services of Brambati SpA;
• send notices/invitations related to trade fairs organised by the Company;
• statistical analyses.

Your personal data may be transferred by the Data Controller to the in-house Data Processor, who may use persons authorised to process personal data under the direct authority of the Data Controller or Data Processors or, also to the following persons or categories of persons:

• to companies that deal with the management of the website showing the names of users who have contacted Brambati SpA;

The Persons responsible for the processing of personal data have been appointed by the Data Controller of Brambati SpA;

1. Your personal data will be processed, in compliance with the security, integrity and confidentiality required, through the following methods:

• collection of data from the data subject;
• collected and recorded for specific, express and lawful purposes and used in further processing operations in terms compatible with these purposes.

The processing will take place with manual and/or automated systems (adopting appropriate technical and organisational measures that guarantee adequate security to prevent unauthorized access or use of personal data and equipment used, as well as their availability, integrity and confidentiality) to store, manage and transmit the data, with logic strictly related to the purposes, based on the data in our possession and with your undertaking to promptly notify us of any corrections, additions and/or updates. The Data Controller ensures that the Data Controllers appointed by them meet the security levels and appropriate technical and organizational measures for the nature of the data collected and for their processing. There is no automated decision making process. If you believe that the Data Controller does not process the data in compliance with the appropriate security you may make a complaint to the Supervisory Authority, in the manner required.

1. The Data Controller will not transfer your personal data to a third country or to an international organization;

1. The duration of the processing, with the exception of the obligations deriving from national and European regulations, is 10 years. At the end of the processing your personal data may:

• be subject to further processing should contracts be concluded with Brambati SpA (for example, customers, suppliers, associates, ...). In this case further information will be provided in relation to the data collected and the purposes of further processing;
• be deleted if they are unusable;
• be filed by adopting appropriate measures that guarantee integrity, availability and confidentiality.

1. The Data Controller is BRAMBATI SPA Via Strada Nuova no. 37 – 27050 Codevilla (PV) VAT no. 00516930187 Tel 0383373100 Fax 0383373078 in the person of its Legal Representative Mr. Fabrizio Brambati, e-mail titolare_trattamento@brambati.it , the in-house Data Processor is Mr. Andrea Brambati, e-mail responsabile_trattamento@brambati.it .

1. The data subject may at any time contact the Data Controller (through the contacts referred to in point 11) to exercise the rights reserved to him/her, as provided for by Regulation EU 679/16, such as:

Right of access by the data subject (art. 15 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d) where possible, the intended period for which the personal data will be stored, or, if not possible, the criteria used to determine said period;

e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

g) where the personal data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling, referred to in Article 22, paragraph 1 and 4 and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.

3. The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Right to rectification (art. 16 of EU regulation 679/16)

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (art. 17 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the data subject withdraws consent on which the processing is based according to Article 6, paragraph 1, letter a) or Article 9, paragraph 2, letter a) and where there is no other legal ground for the processing;

c) the data subject objects to the processing pursuant to Article 21, paragraph 1, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21, paragraph 2;

d) the personal data have been unlawfully processed;

e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

f) the personal data have been collected in relation to the offer of information society services referred to in Article 8, paragraph 1.

2. Where the Data Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Data Controllers which are processing the personal data that the data subject has requested the erasure by such Data Controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

a) for exercising the right of freedom of expression and information;

b) for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c) for reasons of public interest in the area of public health in accordance with Article 9, paragraph 2 letter h) and i) as well as Article 9, paragraph 3;

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89, paragraph 1 in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defence of legal claims.

Right to restriction of processing (art. 18 of EU regulation 679/16)

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

d) the data subject has objected to processing pursuant to Article 21, paragraph 1, pending the verification whether the legitimate grounds of the Data Controller override those of the data subject.

2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.

Right to data portability (art. 20 of EU regulation 679/16)

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided, where:

a) the processing is based on the consent pursuant to Article 6, paragraph 1, letter a) or Article 9, paragraph 2, letter a) or on a contract pursuant to Article 6 paragraph 1 letter b); and

b) the processing is carried out by automated means.

2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Right to object (art. 21 of EU regulation 679/16)

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on Article 6, paragraph 1, letter 3) or f), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research or statistical purposes pursuant to Article 89, paragraph1, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The complete text of Regulation EU 679/16 (GDPR) and (It.) Legislative Decree 196/03 (Privacy Code) is available on the website www.garanteprivacy.it.

Codevilla, February 2018.

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