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Privacy Policy

Subject: Information. 13 D.LGS. 196/2003
Innovaway S.p.A. informs that is compliant with the Legislative Decree No. 196 of 30 June 2003 and its next amendments (hereinafter the “Privacy Policy”) which provides protection related to processing of individuals, corporations, organizations and associations data.
Under the Privacy Policy, personal data treatment is processed in compliance with the principles of correctness, legacy and transparency and the protection of privacy and rights.
According to article 13 of the Privacy Policy, Innovaway S.p.A. provides the following information.

Purposes and methods of data processing
Since Innovaway S.p.A. is a group operating in the ICT services (Information & Communication Technology) “ processing of personal data” means the collection, recording, organization, storage, processing, modification, selection, extraction, comparison, use, dissemination, cancellation, distribution, interconnection and everything is useful for the establishment of a relationship with Innovaway S.p.A., including the combination of two or more of these operations.

In particular, the personal data will be used to fulfill the requirements of the law and regulations as well as for:

a. input of personal data in the company’s database;
b. accounting;
c. statistics;
d. analysis and market research;
e. promotional activities;
f. customer satisfaction.

The treatment will be done on paper and computers by the owner, by the responsible persons and by those in charge, with observance of all cautionary measures that ensures security and confidentiality.

Nature of data collection and the consequence of a lack of provision
Provision of personal data, although not mandatory, is necessary in order to make possible the establishment of the relationship with Innovaway S.p.A.

Lack of provision may result in failure to establish a relationship,
or prevention of proper conduct or continuation of relationship.

Communication and dissemination of data
All personal data, for established relationship and for the purposes outlined above, may be communicated to all natural and legal persons in all circumstances where the communication is necessary for the purposes outlined above.

Some categories of subjects to whom the communication can be carried out are listed as follows:

a. persons who perform services for the acquisition and processing of data arising from documents and supports;
b. subjects engaged in the storage of documentation;
c. entities that provide assistance to customers (telephone/information technology assistance);
d. external consultants;
e. persons engaged in marketing or market research.
The recipients of the communication will be appointed with or responsible for the data processing.

Data communication is also carried out for the fulfillment of legal requirements: chambers of commerce, financial institutions, labor chambers and offices, etc.

The data collected will be likely to spread to the same subjects mentioned above.

Rights of the involved person
At any time he/she can exercise his/her rights towards the owner or manager (if indicated) of the treatment under Article 7 of the Privacy Policy, which states that:

- He/She has the right to obtain confirmation of the existence or not of personal data concerning him/her, even if not yet recorded, and their communication in intelligible form;

- He/She has the right to obtain the indication of:
1 Origin of personal data;
2 Purposes and methods of treatment;
3 Logic applied in case of treatment with the aid of electronic instruments;
4 Identity of the owner, manager and the representative appointed under article 5, paragraph 2 of the Privacy Policy;
5 Subjects or categories of subjects to whom personal data may be communicated or who may become aware of it as appointed representative in Italy, managers or agents.

- He/She has the right to obtain:
1. The ‘updating, rectification or, when interested, integration of data;
2. The cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
3. The statement that the operations in letters a) and b) have been notified, as also related to their contents, to those to whom the data were communicated or disseminated, except where this requirement proves impossible or involves the use of means manifestly disproportionate to the protected right.

- He/She has the right to object, in whole or in part:
1. For legitimate reasons, the processing of personal data, even if pertinent to the purpose of collection;
2. the processing of personal data concerning him/her for purposes of sending advertising materials or direct selling or for carrying out market research or commercial communication.
3. The rights under article 7 shall be exercised by making a request to the owner or manager, including by means of an agent, which shall be acknowledged without delay.

The request to the data controller or processor may also be sent by letter, email or fax.

The contact details are:

Innovaway S.p.A.

Via Giovanni Porzio n°4, Centro Direzionale Is.G1 – Naples 80143

switchboard: 081/0346100
fax: 081/0346101

Treatment owner
The owner of the treatment is Innovaway SpA, with registered office in Via Giovanni Porzio No. 4, Is.G1 Management Centre – 80143 Naples, in the person of its legal representative pro tempore.

Responsible for the processing
The Responsible for the processing is Dr Raffaele Spadaro

Representative of the owner in Italy
The representative of the owner in Italy is the CEO of Innovaway SpA.