PRIVACY POLICY
(PURSUANT TO AND FOR THE EFFECTS OF EU REGULATION N.679 / 2016)

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Main informations

When using this website, the mobile application or another digital service owned and / or managed by "Cinque Elementi di Crisci Silvia" or when filling in a paper form, releasing the necessary data to finalize an online purchase, by participating in competitions or events organized or by or using "Cinque Elementi di Crisci Silvia" of the contents herein, the latter and third parties acquire some information about you.

The company / natural person who manages this website intends to inform end users about the practices used to ensure the protection of privacy relating to the management and supply of all digital services.

It is essential that you have knowledge of these processes, as a subject that the European Legislator intends to protect.
Therefore, we invite you to read the complete Privacy Policy below.

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Data processed:

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This section indicates the information acquired and processed; so in particular:

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• Those provided by you while using the website https://www.studiocinqueelementi.it and all digital services connected to it. By way of example, comments, newsletters, account creation. During the process of using content, purchasing or registering, your contact, payment or demographic information may be acquired, even on a non-exclusive or main basis;

• Data provided by you in the course of participation in events, surveys, or similar initiatives;
• Information you have provided and relating to third parties eg. in the event that you should recommend the website https://www.studiocinqueelementi.it to friends, for the purchase of a product or for the use of a content;
• Data collected through the use of Cookies and the like. These technologies allow the detection of the type of device, browser used, IP address as well as useful and used data in order to carry out advertising profiling also through mobile devices; These technologies allow the tracking of the type of use made on the services offered, on the interaction with them. This type of collection takes place during navigation on the website and / or during the use of the digital service.

• In the event that geolocation is allowed on your device, and the service uses this type of tracking, the company "Cinque Elementi di Crisci Silvia" will be able to obtain detailed information about the location associated with your device;
• Information obtained from third-party sources by way of example: commercial partners, social networks and other data providers.

Practices for using the information collected and prerequisite legal foundations:

• Fulfillment of orders and to follow up on the supply of services, digital or otherwise, purchased. The payment information (credit / debit card number, holder, expiration date) are used only to process the transaction (including recurring payments where applicable) and therefore for the provision of the requested services and for further purposes of protecting one's own and third-party rights arising;
• The data available through tracking cookies are processed in order to analyze user interaction on the services offered, on purchase preferences and for the supply of products related to the user's habits / tastes.
• The data acquired through the contact form / newsletter subscription are used in order to interact with the end user, for example by sending marketing proposals.
• Unless otherwise specified, the acquisition of any sensitive data is carried out on the basis of the following legal bases:
o purposes of protecting the rights of the company "Cinque Elementi di Crisci Silvia" and third parties;
o to fulfill the obligation characterizing the contract for the supply of goods or provision of services;
o to pursue the interests of the company "Cinque Elementi di Crisci Silvia" as long as they are legitimate;
or to fulfill legal obligations. By way of example: GDPR, anti-money laundering legislation etc.

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Sharing of data:

The collected data can be shared:

• Internal use of the Cinque Elementi di Crisci Silvia company;
• With subjects that provide payment services and / or manage transactions;
• With companies that purchase advertising services;
• With social platforms;
• With business partners;
• Where necessary, with professionals / consultants appointed by "Cinque Elementi di Crisci Silvia" in order to protect the rights of the company itself.
• Judicial Authority for where this becomes necessary on the basis of a request, even if without formalities.

Your rights:

• You can limit the use of your data for interest-based advertising purposes; • You have the right, at any time, to unsubscribe from the newsletter using the appropriate link inserted in each email, or by sending an ordinary email to studiocinqueelementi@libero.it

Other Information

• The company uses security technologies and procedures to protect data from unauthorized access, use or disclosure
• The company, having concluded the contract, or the provision of the service, is authorized to delete your data.
• These data are kept for a period not exceeding 10 years starting from the end of the supply of goods or from the supply of the service.
• Thanks to the procedures adopted, the company guarantees the safety and protection of your data even in case of transmission of the latter to countries that do not have privacy legislation similar to that of the European Union or the UK.
• All goods supplied and / or services provided are not intended for use by minors under the age of 16;
• The Digital Services are not intended for use by minors under the age of 16.

Contacts:

For any clarification relating to this information, you have the right to contact the company:

• “Cinque Elementi di Crisci Silvia” - Registered office: Via G.Brodolini 30, Alessandria - email. studiocinqueelementi@libero.it

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PRIVACY INFORMATION 1. INTRODUCTION

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Dear user, I inform you that - for the purposes provided for by EU Regulation no. 2016/679, relating to the protection of individuals with regard to the processing of personal data - the processing of personal data provided by you and acquired through the aforementioned website will be processed in compliance with the legislation provided for by the aforementioned Regulation in compliance with the rights and consequent obligations.

This information, therefore, only analytically describes the methods of data collection.

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2. THE DATA COLLECTED

While using one (or all) digital services (e.g. website, mobile application, newsletter, etc.) the subject referred to in point 1. is able to acquire several

types of data and information on your person, and in particular on the use of the aforementioned digital services. The data collected consists of information that can identify you directly: generality, residence, contact details and information defined online identifiers or cookies.

The information collected is:
1. Those provided by you during the use of the service;
2. Information you provide on third parties;
3. Collected in the course of its interactions with the digital platforms owned by the company;
4. Provided to us by third parties;

1. Information you provide:

While browsing, you will be asked to consent to the use of certain data. You will have the right not to provide such consent, with the warning that in case of refusal, we may partially or completely limit the use of some features of the digital service you are using.

In particular, we will ask for your consent to use
• Contact information (eg name, postal address, email address or telephone number).
• Demographic information, personal interests and family information (eg age, gender or education).
• Payment information for purchases made through digital channels (eg number and expiry date of the card used for payments and billing data).
• Comments, photos, videos and other content or data that you decide to post on the Digital Services or to share with the company in any way.
• Information you provide in the course of participating in surveys, sweepstakes, contests, promotions (including information about your participation in reward-generating activities) or events.
• Location information, including precise location information when allowing Digital Services to access your device's location. To prevent the collection of precise location information, you must necessarily consult the instructions of the service provider for mobile devices or the manufacturer of the device.
• Other information that you consent to access through your device's authorization settings, such as contacts, address book or photos.
• Information on transactions and activities (eg requests, searches or orders).

2. Information you provide on third parties

It will have the possibility to provide information on third parties, such as name and email address, with whom it intends to share a product or content. In this case, please do not share information from such individuals with us that we do not have

expressly authorized and consented to such sharing. These data are processed in accordance with this information.

3. Information Collected in the course of your interactions with the digital platforms owned by the company;

Digital channels, in some cases, automatically record information relating to visits to the Digital Services:
• number and frequency of users,
• technical information on the browsers and devices used to access the Services,

• information on computer blockages or other technical problems.

Based on the preferences expressed, certain data relating to the activities carried out over time within the Digital Services will be automatically collected, including from third parties, through automated tools.
This technology is also applicable to mobile applications or other third party media. These tools vary depending on the Digital Services and include cookies, web beacons, tags, scripts, pixels, local shared objects (including HTML5 cookies) and software development kits ("SDK") (jointly referred to as "Cookies and Similar Technologies") .

The automatically collected data includes the following information:

• Information relating to the computer, device, browser and operating system (eg type, model or version) used.
• Internet Protocol (IP) address, also used to know the general geographical area (eg city and country).

• Mobile device identifiers.
• Information on interactions with digital channels, including navigation and data on the sequence of clicks, which reflect the content used, clicked and / or viewed.
• Information on referrals of the Digital Services, including data on websites visited or applications opened immediately before or after accessing the Digital Service. • Demographic information, personal interests and household information.
• Information relating to interactions with e-mail messages and other communications.

Some cookies attribute or collect unique cookie identifiers or other identifiers associated with the browser or device.
Cookies and Similar Technologies can collect information during the use of the services / channels, but also while these are running in the background on the device.

4. Information Provided to Us by Third Parties

The company has the right to access information concerning it from other sources:
1. Operators of third-party sites or applications, content distribution channels and platforms, voice-activated assistants or other devices and technologies, in the course of interacting with the content we provide, products, services or advertisements available on such channels, and platforms. The information we receive includes information about the content you view, as well as your demographic information and interest-related information.

2. Third party data providers, such as data aggregators, data resellers, public databases and business partners. Social Media Platforms and Similar Services ("Social Media Platforms"). This includes username or user ID and demographic information, based on the privacy settings and practices of the Social Media Platform in question. We acquire this information directly from the Social Media Platform or through plug-ins, integrations or applications.

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C. USE OF INFORMATION COLLECTED

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The use of the information collected (through digital and traditional channels) takes place for the following purposes

1. For the supply of goods or the provision of services or Other Services Required.

• Fulfillment of inquiries relating to the supply of goods or services or participation in a survey, sweepstakes, contest, event or similar initiative.
• Provision of customer service or technical support.

• Personalization of contents,
• Management and development of digital channels and related contents, products or services
• Acquisition of information relating to the users of the aforementioned channels in order to analyze the interaction with them and the reaction;

2. Communication:

• Sending information communications on digital channels (eg to confirm registration or notify you of changes to a Digital Service).
• Sending marketing or promotional communications, including offers or promotions regarding the products, services or initiatives proposed or products, services or initiatives of third parties.

3. Marketing and advertising purposes based on the user's interests:

Depending on the preferences set, the collection of information through cookies has the purpose of
• Develop, manage and conduct advertising and marketing campaigns relating to:

o promotions and offers;
o content, products and services
o own products and / or own services,
or products. third party services and initiatives.
• User interest-based advertising (also known as targeted or personalized advertising) is advertising based on the activities carried out over the course of browsing time, not necessarily on proprietary digital channels. Such user interest-based advertising consists of text ads, images, animations or videos displayed based on various factors:
or context of the site or mobile application in which it appears
or information provided by the user to the site or mobile application manager
or user activity on the site or application
o demographic information,
o information relating to personal interests and the family unit.
• The company and its service providers use automated tools, including Cookies and Similar Technologies, on mobile app sites and digital services / channels in general, or on other third-party media, to
to. collect information for the purpose of advertising based on the interests of the user;
b. display advertising based on the user's interests;

• By providing consent to the use of Cookies and Similar Technologies on the Digital Services, unique identifiers can be associated with the browser or device used in order to provide interest-based advertising for the user.
• The company uses collected online and offline information, including personal data, to deliver interest-based advertising for the user.
• The interest-based advertising of the user can be offered by third parties, eg. online advertising networks or platforms.
• The end user has the right to limit the collection of such data through Cookies and Similar Technologies even the use of the same for the purposes of advertising based on the user's interests.
• The methods for withdrawing consent vary according to whether it is a web environment or mobile applications and are specific to each browser and device.
• Cross-device linking. By accessing the Digital channels from multiple browsers or devices, we will try to establish links to relate the different browsers and devices used during navigation in order to provide a seamless experience between the various browsers and devices used.
• Analyze and measure the results, effectiveness and reach of proposed advertising (including interest-based advertising of the user) and of our marketing activities on the Digital Services and elsewhere.

4. Protection of own rights and those of third parties.

• Identification, prevention and reaction following fraud, even attempted or potentially illegal activities, improper use of the Digital Services, infringement of intellectual property or other violations of the law.
• Carrying out checks, evaluations and verifications or troubleshooting activities.

• Back up systems (including for disaster recovery purposes) • Fulfillment of contractual obligations.
• Execution of acts originating from the Judicial Authority.

D. LEGAL BASES FOR THE USE OF THE INFORMATION

• Fulfillment of contractual obligations. The treatment is carried out in order to fulfill the obligation deriving from the stipulation of the distance contract for the supply of goods or the provision of services. This is also the assumption on the basis of which the company sends communications confirming the order, tracking the goods shipped etc.
• Pursuit of legitimate interests. The processing is carried out in order to pursue the legitimate interests of the company, or to provide goods and / or provide services.
• Fulfillment of legal obligations. The processing is also carried out in order to fulfill all the obligations deriving from the law, by way of example only: anti-money laundering legislation, GDPR, TUIR etc.

E. Sharing of Information
Information can be shared with:

1. Company employees;
2. Affiliated and / or subsidiary companies
3. Advertising Clients, Service Providers and Partners in the field of Advertising and Marketing. Social Media Platforms
4. Business Partners
5. Other subjects, where required by law or if necessary to protect rights.
6. Business Operators.

F. Rights of the interested party

In compliance with the aforementioned EU Reg., It is finally communicated that the interested party has the right to:
• Access, rectify, cancel, limit and oppose the processing of data without prejudice to the provisions of point c) of this deed;
• Obtain without hindrance from the data controller referred to in point g) the data in a structured format of common use and readable by an automatic device to transmit them to another data controller;
• WITHDRAW THE CONSENT to the processing, without prejudice to the lawfulness of the

treatment based on the consent acquired before the revocation;
• lodge a complaint with the Guarantor for the Protection of Personal Data.

to. OPTIONS THAT CAN BE EXERCISED, INCLUDING THE RIGHT OF OPPOSITION TO MARKETING AND ADVERTISING COMMUNICATIONS? BASED ON USER INTERESTS

As a user, you have the right to object to Direct Marketing carried out through:

1. Email marketing. Requesting not to receive marketing or promotional emails also sent by third parties With the warning that, excluding the receipt of marketing or promotional emails, emails relating to order transactions, other communications regarding the use of the Digital Services will still be sent ( e.g., to confirm registration, changes to a Service or in response to a password recovery request).

2. Marketing via SMS.
3. Mail Marketing.
4. Third Party Marketing.
5. Joint sponsorship or promotional initiatives with Commercial Partners.

Right to object to the sending of advertising based on the user's interests

The consent relating to the use of such advertising, based on the use of cookies and similar technologies, can be revoked directly on the advertising agency (eg Google Adsense)

More options

1. Device settings. You can check and change your usage preferences for Digital Services by updating the settings on your device (e.g. by revoking previously granted permissions).
2. Push Notifications. You can check and change your preferences for using push notifications, depending on the model of operating system used.

G. Protection and retention of DATA

A number of technologies are used to protect data from unauthorized access, use or disclosure.

Data retention will take place for the period of time necessary to provide the goods or provide the service and in any case for a period not exceeding 10 years. This term starts from the end of the service. This term is considered appropriate in order to:

• Draw up company documentation in order to analyze market trends and / or for verification purposes and to improve the Digital Services.
• Meet document retention requirements under applicable laws or other applicable legal or regulatory obligations.

• Defend, ascertain, exercise existing or potential rights in court or initiate related legal actions.
• Detect and prevent fraud.
• Handle any complaints regarding the Digital Services, our products and services.

H. INTERNATIONAL TRANSFER OF DATA

Thanks to the procedures adopted, the company guarantees the safety and protection of your data even in case of transmission of the latter to countries that do not have privacy legislation similar to that of the European Union or the UK.

I. MINOR PRIVACY RIGHTS

The Digital Services are not intended for use by children, especially children under the age of 16, and we do not knowingly collect personal data from children under the age of 16.

K. CHANGES TO THE PRIVACY POLICY

This Privacy Notice is periodically updated to reflect changes in privacy practices or applicable regulations

L. CONTACTS

For any clarification relating to this information, or, for the exercise of each right, you have the right to contact the company:

• “Cinque Elementi di Crisci Silvia” - Registered office: Via G.Brodolini 30, Alessandria - email. studiocinqueelementi@libero.it