In compliance with Legislative Decree. 30 June 2003, no. 196 as amended (“ Privacy Code ”) and with the European Regulation no. 679 of 2016 (the “ Privacy Regulation ”), Tecnosystemi S.p.A. Società Benefit wishes to inform you and all users of the “ Tecnosystemi ” app (respectively referred to as the “ Users ” and the “ App ”), regarding the use of personal data collected through the same App.

1. Data Controller and Data Processors

The personal Data Controller is Tecnosystemi S.p.A. Società Benefit], with registered office in Vittorio Veneto, Via dell’Industria 2/4, VAT number 02535780247, e-mail info@tecnosystemi.com (hereinafter referred to as the “ Controller ”).

The updated list of designated Data Processors can be provided upon Users’ request at the email info@tecnosystemi.com

2. Personal Data Processed

2.1 Information collected automatically by the App

Our App uses log files, in which information collected automatically during your visits is stored. Indeed, the computer systems and software procedures which operate the App automatically acquire some information during use, whose transmission is implicit in the use of Internet communication protocols. To access the App and browse it, the information collected is as follows:

▪ Internet Protocol (IP) address or domain name of the device you use;

▪ the addresses in URI (Uniform Resource Identifier) notation of the requested resources or the method used to submit the request to the server;

▪ name of the internet service provider (ISP);

▪ the numerical code indicating the status of the response given by the server (successful, error, etc.);

▪ other parameters relating to the operating system and IT environment of your device;
This information is processed in an automated form and collected exclusively in aggregate form in order to verify the correct functioning of the App.

2.2 Information provided by you to use the App

The information necessary to use the App and access the services offered and requested therein (e.g. newsletter, activation of the control and command of the air conditioning systems) are the common identification and contact data relating to the last setting of the air conditioning system.

3. Purpose of the processing

We need your data to allow you to:

- proceed with registration and access the App to exploit the related functions;
- receive the newsletter as you requested.

Your data is processed for the following purposes:

(i) compliance with legal obligations;

(ii) to carry out the technical management of the App;

(iii) to access the App to activate the control and command of the air conditioning systems;
(iv) to receive the newsletter.

The data provided by you will be processed mainly with IT tools and under the authority of the Data Controller, by people specifically designated, authorised and trained to carry out the processing, pursuant to articles 29 of the Privacy Regulation and 2- quaterdecies of the Privacy Code. We inform you that suitable security measures are complied with also pursuant to articles 5 and 32 of the Privacy Regulation to prevent data loss, illegitimate or incorrect use and unauthorised access.

4. Nature of the provision of data and legal basis of the processing

For the purposes referred to in points (i), (ii) and (iii) of art. 3 above, the provision of your personal data is necessary, as without it you will not be able to use the services offered by the App. Consequently, for the purposes referred to in point (i) the legal basis of the processing is the fulfilment of legal obligations, in compliance with art. 6 paragraph 1, letter. c) of the Privacy Regulation, while for the purposes referred to in points (ii) and (iii) the legal basis of the processing is the performance of the services provided through the App and requested by you, in compliance with article 6, paragraph 1 , lit. b) of the Privacy Regulation.

With reference to the purpose referred to in point (iv) of art. 3 above, the provision of your data is optional and any refusal to provide them and to give the relevant consent makes it impossible for the Data Controller to follow up on the newsletter service, but does not affect the possibility for the applicant to use the services of command and control of the air conditioning systems that can be activated via the App. The legal basis of the processing is your freely expressed consent (pursuant to art. 6, paragraph 1, letter a) of the Privacy Regulation).

5. To whom and in what context can we transmit your data

Your data may be communicated, within the EU, to external structures, subjects and companies (including consultants and service providers) used by the Data Controller for the management of the App and for carrying out activities that are related instrumental or consequent to the performance of the services offered through the App.

6. Your rights

Articles 15 et seq. of the Privacy Regulation give the data holder the right to obtain, under the conditions and within the limits established by art. 2- undecies of the Privacy Code and art. 12 of the Privacy Regulation:

▪ confirmation of the existence or otherwise of personal data concerning them, even if not yet registered, and their communication in an intelligible form;

▪ the indication of the origin of the personal data, the purposes and methods of processing, the logic applied in case of processing carried out with the aid of electronic instruments, the identification details of the controller;

▪ the updating, rectification, integration, cancellation, transformation into anonymous form or blocking of data processed in violation of the law - including those whose retention is not necessary in relation to the purposes for which the data are collected or subsequently processed -, the certification that such operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfilment proves impossible or involves a manifestly disproportionate use of means with respect to the protected right.

The data subject is also entitled:

▪ to revoke at any time the consent (where given) to the processing of personal data (without prejudice to the lawfulness of the processing based on the consent given before the revocation);

▪ to oppose, in whole or in part, for legitimate reasons, the processing of personal data concerning them, even if it is pertinent to the purpose of the collection;

▪ to oppose, in whole or in part, the processing of personal data concerning them for the purposes of sending advertising material or direct sales or for carrying out market research or sales communication;

▪ to lodge a complaint with the Guarantor for the protection of personal data in the cases envisaged by the Privacy Regulation, by contacting the Guarantor for the protection of personal data directly: Web App www.garanteprivacy.it E-mail: protocollo@gpdp.it Telephone switchboard: (+39) 06.69677.1;

▪ to the portability of personal data within the limits envisaged in art. 20 of the Privacy Regulation.

To exercise your rights, you must send an email to info@tecnosystemi.com

7. Duration of Processing

Without prejudice to legal and judicial protection obligations, your personal data will be retained for a specific period, according to criteria based on the nature of the services provided. In particular, the data referred to in art. 2.1 will be processed for a period not exceeding 7 days, while the personal data referred to in art. 2.2 and that is processed for registration and access to the services provided through the App will be processed until the User uninstalls the App and stored for a period not exceeding 6 months. Please note that the data relating to the air conditioning settings will be retained for the aforementioned period only with regard to the last setting entered .

As to the newsletter service, personal data will be processed until the User exercises the right to unsubscribe from the newsletter by revoking the consent given.

8. Security measures

Through the App, your data is processed in compliance with applicable law and using adequate security measures in compliance with the legislation in force also pursuant to articles 5 and 32 of the Privacy Regulation.

In this regard, we confirm, among other things, the implementation of appropriate security measures aimed at preventing unauthorised access, theft, disclosure, modification or unauthorised destruction of your data.

9. Changes to the Privacy Policy

The Controller reserves the right to make changes to this Privacy Policy. In this case, you will be promptly informed when you use the App again.