PRIVACY POLICY STATEMENT

1. DATA CONTROLLER

UMBRAGROUP S.p.A., with registered office at 1 Via V. Baldaccini - Z.I. Loc. Paciana, Foligno (Perugia), in the person of its legal representative pro tempore ANTONELLO MARCUCCI, is the data controller of your personal data (the "Controller" or "UMBRA").

2. DEFINITION OF PERSONAL DATA AND INFORMATION ON THE PROCESSING ACTIVITIES

Pursuant to the GDPR, the term “personal data” means: "any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (the "Data").

For the management of the contractual relationship initiated by the data subject’s request for the UMBRA newsletter service, the following types of personal data are processed:

- first name, surname;
- e-mail address.

The provision of your personal data is voluntary, as is subscription to the newsletter; however such data are indispensable for UMBRA to provide the requested newsletter service. If you do not provide your data, the contractual relationship will not be possible. The free, voluntary subscription to the newsletter, confirmed after a specific second request (double opt-in), shall be considered automatically as the provision of your consent to the processing of your data for the communication and marketing purposes indicated in paragraph 3 below.

The personal data you transmit to us will be used solely for the specific purposes indicated in paragraph 3 below, which may be carried out by the Controller exclusively via electronic communications. You may unsubscribe from the newsletter at any time simply by clicking on the specific link highlighted at the bottom of every message you receive. Cancellation of the newsletter subscription is intended as a withdrawal of the consent provided, but without prejudice to the lawfulness of the processing based on the consent provided before the withdrawal.

In any case, UMBRA agrees to ensure that the information collected and used is appropriate for the purposes described, and that its collection does not determine an invasion of your personal privacy.

3. PURPOSES OF THE PROCESSING

The purposes for which your personal data are collected and processed within the framework of the requested UMBRAGROUP newsletter service management are as follows:
a) Establishment and termination of contractual relationships and management of existing ones connected with the provision of the requested service;
b) Sending and dissemination of company and Group communications (for example: on projects of national interest in which Umbra participates and/or which it backs; awards received; events organized or in which it participates; institutional company videos; television or radio segments; press review);
c) Sending of promotional, advertising, and soft marketing communications, i.e., merely by way of example: information about and/or invitation to events organized by UMBRA at the sites of the various Group companies or at third-party facilities, information about and/or invitation to trade fairs and events in which UMBRA participates, promotion of advertising and marketing events, offers regarding new products or services offered by UMBRA. The promo-advertising communication is customized on the basis of the data subject’s business sector and the interests and preferences expressed when participating in the Controller’s various initiatives; this is in order to avoid undesired mailings and those which, in any case, would be of little interest to the data subject.

The legal basis for the processing of your data may be found, alternatively, in the following:

• the performance of obligations deriving from a contract for the provision of services requested by the data subject;
• the legitimate interest of the Data Controller;
• the clear, express, and free consent provided by the data subject.

4. TRANSFER OF DATA TO EU AND NON-EU PARTIES

UMBRA may transfer some of your data to parties on which it relies for the performance of activities connected with the management of the contractual relationship.

In particular, in order to achieve the purposes described in paragraph 3 above, as an integral part of the processing activities your data may be transferred to outside providers of IT services, as well as to outside consultants who will process your data in their capacity as Processors.

The list of Processors is kept up to date by the Internal Processing Representative, Administration and Finance Manager, and is available for consultation through that office.

Furthermore, the Controller may transfer your data both to parties to which it is bound by law to transmit them, and to the other Group companies located within the European Union, whether subsidiaries or affiliates.

There will be no dissemination of your data to unspecified parties.

5. STORAGE PERIOD

Your data will be processed by UMBRA for the entire duration of the contractual relationship entered into on subscribing to the newsletter and in any case until withdrawal of the consent provided, expressed by unsubscribing from the newsletter, and will be kept for a period of 12 months after the end of said relationship for statistical and analysis purposes.
In the case of a dispute in or out of court with the data subject and/or with third parties, the data will continue to be processed for the entire duration of the litigation, and in any case for as long as is necessary for the Data Controller to fully defend its rights.

6. YOUR RIGHTS AS A DATA SUBJECT

During the period in which UMBRA holds or processes your data, you, as the data subject, may exercise the following rights at any time:

• Right to access – You have the right to obtain confirmation of whether or not your data are being processed, as well as the right to receive all information concerning such processing;
• Right to rectification – You have the right to request the rectification of your data in our possession if they are incomplete or incorrect;
• Right to erasure – In certain circumstances, you have the right to request the erasure of your data present in our files;
• Right to restriction of the processing – Under certain conditions, you have the right to request a restriction of the processing of your data;
• Right to portability – You have the right to request the transfer of your data in our possession to a different Controller;
• Right to objection – You have the right to object to the processing of your data;
• Right to lodge a complaint with a supervisory authority – If UMBRA refuses to meet your requests for access, you will be informed of the reasons for said refusal. If you so decide, you have the right to lodge a complaint as described in paragraph 7 below;
• Right to withdrawal of the consent given, expressed by unsubscribing from the newsletter.

Such requests may be sent to UMBRA using exclusively the following e-mail address: privacy.ugi@umbragroup.com.

7. COMPLAINTS

If you wish to lodge a complaint with regard to how UMBRA processes your data, or with regard to the management of a complaint you have lodged, you have the right to do so directly to the supervisory authority.