The Company Padoan Swiss SA (hereinafter referred to as Padoan) practices its activity professionally, in collaboration with international companies, guaranteeing to preserve the confidentiality of personal data of natural persons according to the principles of fairness, lawfulness, transparency.
Therefore, in compliance with art. 13-14 of the European Regulation no. 16/679 and with the Leg. Decree no. 196/2003, it notifies all the Persons Concerned of the actual processing of personal data that is carried out.

1. TYPES OF DATA PROCESSED BY THE CONTROLLER AND PURPOSES OF THE PROCESSING
A. DATA COLLECTED THROUGH THE WEBSITE

Padoan’s company website www.padoanswiss.ch (hereinafter referred to as “Website”) is addressed to professionals and its purpose is to illustrate, publicize and give information on products and services provided by Padoan Swiss SA; however, by browsing or voluntarily registering to the Website, data relating to an identified or identifiable natural person can be processed: personal data is collected and processed with purposes strictly connected to the Website use, to the registration processes referred to therein, and to the use of services reserved to registered Users provided via the Website.

Data Controller and place of processing of personal data
The Data Controller is Padoan Swiss SA (Taxpayer’ s code and VAT Registration no. CHE-203.203.291) based in Via Pra Proed 1, San Vittore Cantone dei Grigioni 6534 – Switzerland, e-mail info@padoanswiss.ch, Tel. +41 (0)91 2228877.
Processing of data linked to the Website’s services takes place at the Data Controller premises and is carried out by the appointed office personnel.

Types of data processed
The types of data of the Persons Concerned that can be processed as a consequence of their visits to the Website are listed below:

Web browsing data

IT systems and software procedures necessary for the functioning of the Website collect, during their normal activity, some personal data whose transmission is implicit in the use of communication protocols on the Internet. Said information is not collected to be matched to identified persons but, for its nature, it could, through data processing and association, allow to identify the Persons Concerned.
This category of data includes the following:

• IP addresses or domain names of computers used by Users connecting to the Website;
• time of the request;
• the method used to make the request to the server;
• the size of the file received in response;
• the numerical code given in response by the server.

This data is used for the sole purpose of obtaining anonymous statistics on the use of the Website and to check that it works properly.
Without prejudice to the case in which data could be used to verify responsibility in the event of any offences to the detriment of the website, said data is kept for the amount of time indicated by the relevant legal regulation and necessary to provide the Person Concerned with the requested service and to guarantee communication.

Data voluntarily provided by the Person Concerned

Without prejudice to what stated for the necessary browsing data, the provision of personal data by the Persons Concerned is free and optional, even if functional to the provision of specific services; in such cases, failure to provide data can make the provision of the service difficult or impossible. Personal data provided by the Persons Concerned that voluntarily interact with the Website to obtain specific services (registration processes, subscription to the newsletter, information requests, email sending) is processed to the only purpose of carrying out the requested service or activity and is transmitted to third parties only to the extent that it is necessary for that purpose.

The personal data that the Person Concerned can voluntarily provide is the following:

• name and surname;
• e-mail address;
• name of the company;
• telephone numbers;
• reason for the request.

Purposes of Data Processing

Personal data voluntarily provided by the Person Concerned interested in the browsing of the Website is
processed for the following purposes:

• to successfully register to the Website;
• to send answers via e-mail with information on products and services provided by Padoan;
• to gather anonymous statistics (e.g. the number of visits);
• to send the newsletter via e-mail;
• to comply with legal obligations.

Data retention period

Data of the Persons Concerned shall be retained only for the period of time necessary to guarantee the
proper provision of the services requested via the Website. In case of cancellation or disabling of the account,
data will be retained only for administrative purposes for a period no longer than one year, without prejudice
to possible specific requirements provided for by the law.
With regard to the processing of personal data, which consists of sending the newsletter and informative
material concerning the Controller’s commercial initiatives via email, it will be possible to withdraw consent
by sending an e-mail to info@padoanswiss.ch stating “Newsletter subscription cancellation” in the e-mail subject
line.

✓ Cookies

Some areas of the Website can use cookies to improve the browsing quality and tailor the Website to the
needs of the Person Concerned.
Cookies are small data files that the sites visited by the User send to the terminal or device, where they can
be eliminated at the end of the working session, or can be stored to be transmitted again to the same websites
during the next visit by the same user. Cookies allow a website to recognise the device used by the Person
Concerned, to track browsing through the different pages of the website, and to identify the users who visit
the website again.
The Website uses Google Analytics to periodically monitor the number of visits to the website and the web
traffic data, and also uses the AddThis tool which enables the content to be shared via the social media.
It is possible to reject cookies, but this could limit the functions available on the Website. The browser offers
also the possibility to delete cookies (by selecting the “Clear browsing history” option).
For further information refer to the Browser Settings Guide.
By browsing the website the use of cookies will be considered as accepted.
The retention period of the collected data depends on the types of cookie used.

How to turn off cookies (opt-out)

The majority of the Internet browsers are set to automatically accept cookies. This means that the User may,
at any time, change the browser’s setting to accept all cookies, only some of them or disable their use by the
websites. It is also normally possible to set browser preferences to receive a notification every time a cookie
is stored in the computer. At the end of every browsing session, it is also possible to delete the collected
cookies from the hard disk. To eliminate cookies installed in the browser’s cookie folder, it is important to
remember that every browser has different procedures to manage settings.
Consult the instructions for your specific browser via one of the links below:

Google Chrome (https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies)

Mozilla Firefox (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie)

Microsoft Windows Explorer (http://windows.microsoft.com/it‐it/windows‐vista/block‐or‐allow-cookies)

Moreover, if you do not want to receive Google Analytics cookies, please visit the following page:
https://tools.google.com/dlpage/gaoptout/

As an alternative, it is possible to disable only Google Analytics cookies by using the opt-out additional
extension provided by Google for the main browsers.

For more information on cookies please visit https://www.garanteprivacy.it/cookie.

Cookies services provided by Third Parties

The Person Concerned can oppose to data tracking in case of services provided by third parties by following
the procedures indicated in their privacy policies, through the opt-out link or by directly contacting them.

Links to social networks

The Website provides the Persons Concerned with links to social network related services. In particular, the
Website provides a special plug-in for Instagram, Facebook and LinkedIn. Said plug-ins set a cookie. The
collection and processing of data by third parties are regulated by their relevant privacy policies; to which
reference should be made.

DATA COLLECTED WHEN SENDING COMMERCIAL OFFERS, MANAGING ORDERS AND
SIGNING SUPPLY CONTRACTS

Data Controller and place of processing

The Data Controller is Padoan Swiss SA (Taxpayer’ s code and VAT Registration no. CHE-203.203.291) based in Via Pra Proed 1, San Vittore Cantone dei Grigioni 6534 – Switzerland, e-mail info@padoanswiss.ch, Tel. +39 0422/362172

Processing of data collected when sending commercial offers, managing orders and signing supply contracts
takes place in the above-mentioned Data Controller premises and is carried out by the appointed office
personnel.

Types of data processed

The following are the types of data whose provision is necessary for the useful conduct of the commercial
and contractual relationship with the Person Concerned:

• name and surname;
• e-mail address;
• name and data of the company (corporate name, address, VAT registration number and taxpayer’s
  code, company registration details);
• bank account details;
• telephone numbers (landlines and mobile);
• Website domain.

Purposes of Data Processing

Data is collected for the following purposes, which are strictly correlated to the establishment and continuation of the commercial and/or contractual relationship with the client and include, but are not limited to, the list below:

• preparation of offers;
• customer management, administration of contracts, orders, shipments, and invoices;
• management of complaints;
• checks on the clients’ reliability and solvency;
• keeping records about certified companies, products and personnel;
• fulfilment of fiscal or accounting obligations and of contractual obligations;
• detection of the degree of client satisfaction;
• marketing information and communications;
• managing any breach of contractual obligations, warning notices, transactions, debt collection,
  arbitration proceedings, and judicial controversies.

Said data is processed in order to guarantee the correct management of the offers and/or of supply orders,
of commercial relationships and of any related activity.

Data retention period

The provided personal data is retained for the whole duration of the contract and, at the conclusion of the
same, said data will be retained for administrative purposes for a period no longer than one year, without
prejudice to possible specific requirements provided for by the law.

C. DATA COLLECTED WHEN ACCESSING COMPANY PREMISES

Data Controller and place of processing

The Controller of the data collected when accessing Padoan Swiss SA company premises is Padoan Swiss SA itself.
(Taxpayer’s code and VAT Registration no. CHE-203.203.291) based in Via Pra Proed 1, San Vittore Cantone dei Grigioni 6534 – Switzerland, e-mail info@padoanswiss.ch, Tel. +39 0422/362172

Processing of data connected to access to the company premises will take place at the above-mentioned
Data Controller premises and is carried out by the appointed office personnel.

Types of data processed

The collected data is the following:

• name and surname;
• name of the company;
• reason for the visit;
• entrance and exit date and time.

Purposes of Data Processing

Every Controller collects data solely to safeguard its personnel and visitors. The collected data is used for
the only purpose of contacting the visitors in case of need.

Data retention period

Cancellation of the collected data takes place at the end of the month, 60 days after its collection.

D. DATA COLLECTED AT FAIRS, EVENTS, CONFERENCES, CONVENTIONS AND ANY OTHER
SIMILAR OCCASION

Data Controller and place of processing

The Controller of the data collected at fairs and events in which Padoan Swiss SA takes part, organises or
contributes to is Padoan Swiss SA itself. (Taxpayer’ s code and VAT Registration no. CHE-203.203.291) based in Via Pra Proed 1, San Vittore Cantone dei Grigioni 6534 – Switzerland, e-mail info@padoanswiss.ch, Tel. +39 0422/362172

Processing of data linked to those collected at fairs, events, meetings with clients, conferences, conventions,training programmes and any other similar occasion will take place at the above-mentioned Data Controller premises and is carried out by the appointed office personnel.

Types of data processed

Data provided on specifically prepared paper and/or digital forms, as follows:

• name and surname;
• e-mail address;
• telephone number;
• name of the company;
• function, role and activity carried out within the company;
• Skype contact details;
• social network profiles;
• website.

In this case, the paper and/or digital form acts as a declaration of consent for the processing of personal data.
The provided data is transmitted to a digital database for marketing purposes.

Purposes of Data Processing

Padoan Swiss SA collects data solely to offer the potential client information on products and services provided, as well as for events promotion and for this purpose it will send free communications on a regular basis. It is possible for the Person Concerned to withdraw consent at any time by sending and e-mail to info@padoanswiss.ch stating “Newsletter subscription cancellation” in the e-mail subject line.

Data retention period

The provided data is retained until the client, or potential client, decides to cancel his/her subscription. In case of cancellation, the provided data is retained for administrative purposes for a period no longer than one year, without prejudice to possible specific requirements provided for by the law.

2. PERSONAL DATA PROCESSING METHODS

Personal data is processed mainly with automated and electronic tools by the appointed personnel in
compliance with Leg. Decree no.196/2003 and with EU Regulation no.679/2016, for no longer than necessary
to fulfil the purposes for which the data was originally collected.

Specific security measures are observed to avoid loss of data, illegal or improper use of the same and
unauthorized access, in order to ensure access solely to those selected or appointed for this task, in
compliance with the laws in force.

Personal data collected also through paper forms will be stored on electronic media, safeguarded and filed
at the Padoan company premises.

3. DATA COMMUNICATION AND TRANSMISSION

Notwithstanding the conditions performed in accordance with the fulfilment of law obligations, all personal
data collected and processed for the above-mentioned purposes can be transmitted to the following:

• Personnel instructed by Padoan and part of the Purchase, Technical, Planning, Management,
  Production, Marketing, Administrative and Direction Offices, and in any case appointed by the Data
  Controller;
• External professionals, appointed in compliance with art. 28 of UE Regulation no. 2016/679;
• Professionals appointed by Padoan;
• Rating and insurance agencies;
• Subsidiaries and/or affiliates of Padoan, also performing business activities abroad;

The complete and updated list of all persons responsible for data processing in accordance with art. 28 of
the EU Reg. no. 16/679 can be requested to the above-mentioned Data Controller by sending an e-mail to
info@padoanswiss.ch.

4. RIGHTS OF THE PERSONS CONCERNED

The privacy laws and regulations (the Leg. Decree no.196/2003 and the EU Regulation no. 679/2016)
guarantee the Persons Concerned the right to be informed on the processing of their personal data, the right
to have access at any time to said data and to request the integration and amendment of the same. Where
the conditions provided for by the laws and regulations apply, the person concerned can exercise the right to
delete his/her data, to limit their processing, to data portability and to oppose data processing for specific purposes.

Should the processing of personal data be based on the consent of the Person concerned, the latter has the
right to withdraw the consent given.

In order to exercise these rights, it is possible to contact the Data Controller by sending a request via e-mail to info@padoanswiss.ch.

Should the Person Concerned think his/her rights are not respected, it is also possible to file a claim to the Italian Data Protection Authority.

5. PRIVACY POLICY UPDATE

In order to guarantee the protection of confidentiality of personal data of natural persons, this Policy can be subject to amendments.

We advise all the Persons Concerned to periodically consult the amendments made to this policy in compliance with the law regulations in force.