Processing of customers’ personal data

Polti S.p.A. sole shareholder, via Ferloni, 83 - 22070, Bulgarograsso, Como, tax code and VAT number 01457440137 (hereinafter referred to as Polti), the parent company of:

• POLTI ESPAÑA S.A. - Paseo del Ferrocarril 381- 08850 Gavà - ES
• POLTI FRANCE S.A.S. - 11/13 Rue des Aulnes - 69760 Limonest - FR
• POLTI UK LTD. - The Junction - Merchants Quay - M50 3SG Manchester - GB
• POLTI DEUTSCHLAND G.M.B.H. - Hafeninsel 11, - 63067 Offenbach am Main - DE
• POLTI USA INC. - 5301 Beethoven Street, Suite 170 - Los Angeles, CA 90066 - US
• POLTIPLAST S.R.L. - Via Monte Rosa n. 13 - 22070 Bulgarograsso (CO) - IT

in the performance of its own activities in its capacity as data controller, collects and processes personal data provided by the data subjects. In order to guarantee the protection and exercise of the rights provided for by law with regard to the protection of personal data, the data subject is informed of the following:

Section A. Processing of personal data for commercial purposes

The data provided by the data subjects will be processed in order to comply with the stipulations of the contract, which encompasses one or several of the following purposes:

• 1. Management of commercial activity and the pre-contractual and contractual relationship.

In addition to the staff responsible for managing your contract, the data may be processed by the following entities:

• Postage and logistics companies
• IT service provider companies
• Public bodies
• Credit institutions
• Consultancy firms
• Law firms
• Financial brokerage firms
• Trading agents

In the context of the activities provided for by the contract that could be entered into, Polti may send the personal data of the data subjects outside the EEA, the UK or your country of residence, as applicable, we will take steps to ensure that your data receives the same level of protection as if it were processed within the EEA, the UK or your country of residence, as applicable. For example, we may include standard contractual clauses adopted by the European Commission in our contracts with third parties or our group companies to ensure that safeguards are in place to protect your personal data for purposes inherent to the contractual activities.

Storage period of the data

Data subjects are informed that personal data will be kept on Polti's systems for as long as necessary to fulfil the specified purposes. Any data that could be generated by virtue of additional contractual relationships (e.g. tax documentation) will be kept in accordance with the legal provisions.

Section B. Processing of personal data for support and customer care purposes

The data provided by the data subject will be processed in order to comply with the stipulations of the contract entered into, which encompasses the following purposes:

• 1. Management of the obligations provided for in relation to customer support activities
• 2. Assessment of the level of customer satisfaction in relation to the products offered and the support received from Polti sole shareholder
• 3. Promotional activities

In addition to the staff responsible for managing contact with you, the data may be processed by the following entities:

• Postage and logistics companies
• IT service provider companies
• Repair and maintenance service provider companies
• Consultancy firms
• Law firms

Storage period of the data

Data subjects are informed that, with regard to Purposes 2 and 3 in this section, their personal data will be kept on Polti’s systems until the data subject withdraws his/her explicit consent.

Absence of consent

Data subjects are informed that, Polti may not carry out research or submit questionnaires aimed at assessing the level of customer satisfaction (Purpose 2) and may not perform promotional activities (Purpose 3) if said data subject decides not to give his/her consent for the specified purposes. Data subjects are informed that if they do not give their consent for Purposes 2 and 3, this will not affect the processing of their data for the purposes of point 1.

Section C. Processing of personal data for web services and communication purposes

The data provided by data subjects will be processed in order to fulfil the following purposes:

• 1. Supply of dedicated web services (e.g., quick purchase)
• 2. To send promotional communications relating to services and products offered by Polti by email on a recurrent basis (newsletter).
• 3. Linking the user to the data subject’s Google account.

In addition to the staff responsible for managing contact with you, the data may be processed by the following entities:

• Marketing consultancy firms
• Other companies in the Polti group
• IT service provider companies

Storage period of the data

Data subjects are informed that personal data will be kept on Polti’s systems for the entire duration of the supply of web services. Data subjects are informed that, with regard to Purpose 2 in this notice, their personal data will be kept on Polti's systems until the data subject withdraws his/her explicit consent.

Absence of consent

Data subjects are informed that, Polti may not send marketing communications (Purpose 2) mettere link al Purposes of the data processing to the data subjects who have not provided their consent in response to this notice.This Website uses Google Signals, a Google Analytics feature that associates the information on the views collected by this Website with Google information from the accounts of Google users who have consented to this association for the personalization of advertisements. This Google information may include the User's location, search history, YouTube history and Data from Google partner sites and is used to provide aggregate and anonymous information on the cross-sectional behavior of Users. If a User falls within the association described above, he/she may access and/or delete such Data through the MyActivity function provided by Google (at https://myactivity.google.com/myactivity?pli=1).

Data subject’s rights and methods of exercise

Data subjects must be informed of the methods by which they may exercise their rights. Data subjects are informed that:

• a. in the case that a request is made by the data subject to exercise the rights provided below, Polti has a period of one month in which to respond
• b. In the case of multiple requests, this period may be extended by two months.

Rights of the data subjects

Polti undertakes to ensure that data subjects are able to fully exercise their rights, provided that this does not harm a legitimate right or the rights of other data subjects. Data subjects wishing to exercise such rights may do so by writing to the following address: privacy@polti.com

Polti has appointed the DPO before the guarantor authority who can be contacted at dpo@polti.com.

Data subjects are informed that, in the case of serious breaches or failure to comply by Polti with one of the rights set forth in this notice, data subjects may file a formal complaint with the relevant national Data Protection Authority.

Normative sources

The following document has been prepared in accordance with the General Data Protection Regulation (GDPR), which is the EU’s agreed standards for data protection, which has also been implemented in UK law through the Data Protection Act 2018 (DPA 2018). The transition period for leaving the EU ended on 31 December 2020. The GDPR has been retained in UK law as the UK GDPR and will continue to be read alongside the DPA 2018, with technical amendments to ensure it can operate in UK law. To read more about the GDPR, please visit the ICO Information Commissioner’s Office website – it’s an independent authority that upholds information rights in the public interest.