PRIVACY POLICY

Welcome to the website of BTX Italian Retail and Brands S.r.l. (hereinafter referred to as Conbipel) at the URL www.conbipel.com (the “Site”).

This privacy policy is established for the purpose of informing the user of the website www.conbipel.com owned and managed by BTX Italian Retail and Brands S.r.l., with registered office in Milan (MI), via Vittor Pisani n. 20, Fiscal Code, VAT number, Registration number in the Commercial Register of Milano-Monza Brianza-Lodi No. 12148170967 "Conbipel", of the following terms:

• - Personal data collected by the website;
- The use made of these data; - Access to these data; - The rights of users of the Site; - The policy on the use of cookies which is regulated by the Cookie Policy at the URL www.conbipel.com.

Please read carefully this privacy policy, which applies to all accesses to the site, even regardless of the purchase of the products sold there.
We remind you that this privacy policy is governed by the European Regulation n. 2016/679 (the "Regulation") in force since 25 May 2018. The Regulation ensures that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the data subject, with particular reference to confidentiality, personal identity and the right to the protection of personal data.

1. DATA CONTROLLER

BTX Italian Retail and Brands s.r.l, with registered office in Via Vittor Pisani 20, Milan, Italy (hereinafter referred to as "Conbipel"), is the independent data controller of the personal data of users browsing the Site, including navigation and marketing data such as data related to and related to sales made through the store integrated into the Site and related support activities before and after sales.

2. DATA PROTECTION OFFICER

Conbipel has appointed the Personal Data Protection Officer, who can be contacted at the following email address privacy@conbipel.it for any information regarding the processing of your personal data and to exercise the rights described below.

3. NATURE AND PURPOSE OF THE PROCESSING CARRIED OUT ON THE SITE - LEGAL BASIS OF THE PROCESSING

This Privacy Policy is in addition to the General Conditions of Sale present at the URL www.conbipel.com on the Site.

In accordance with the General Data Protection Regulation, this privacy policy is subject to the following regulations:

The personal data are:

• - Handled lawfully and transparently;
- Collected for specific, explicit and legitimate purposes, and will not be further processed in a manner incompatible with those purposes. In accordance with Article 89.1 of the GDPR, the storage and processing of such data for storage in the public interest, for scientific or historical research purposes or for statistical purposes are not considered incompatible with the initial purposes; - Appropriate, relevant and limited to what is necessary for the purposes for which they are processed; - Accurate and, if necessary, up-to-date. All reasonable steps shall be taken to correct incorrect data for the purpose for which it was collected; - Kept in a form which allows the identification of the persons concerned for a period sufficient for their processing; - Processed in such a way as to ensure their safety, including in relation to unauthorised or unlawful processing, loss or destruction of such data, whether accidental or voluntary.

The processing of the collected data is lawful only if at least one of the following conditions is met:

• - The data subject has consented to the processing of the data for one or more specific purposes.
- Data processing is necessary for the performance of a contract to which the data subject is a party or for the execution of pre-contractual measures taken at the request of the data subject. - The processing is necessary for the fulfilment of a legal obligation to which the data controller, Conbipel, is subject. - Processing is necessary to safeguard the vital interests of any natural person. - The processing is necessary for the performance of a task of public interest entrusted to Conbipel. - Processing is necessary for the purposes of the legitimate interests pursued by the data controller or third parties, unless the interests, freedoms or fundamental rights of the data subject prevail.

By using the website www.conbipel.it users agree to:

• - All terms included in this Privacy Policy.
- The collection, use and storage of data listed in this privacy policy.

Different types of personal data are collected and processed through the Site, for different purposes and in different ways. More specifically:

• A. During the subsequent contact of the user with the customer service by telephone or e-mail, to know the user’s requests and to offer the services, assistance and information required on Conbipel and worldwide products or to join the Conte program, as well as the data provided by the user to submit their spontaneous application to the "Work with us" of the Site;
• B. The personal data provided by the user in the process of sending the order forms of the products to the online store for the conclusion of e-commerce transactions and interaction with users for the sale of functional and instrumental activities, as well as for any necessary pre- sales and after-sales assistance;
• C. Conbipel, with the express consent of the user, may process the personal data of the latter for marketing purposes, or to send to the user (through traditional tools and through electronic tools such as newsletters, e-mail, sms, MMS and smart messages) information and updates on products, sales, promotional campaigns, events and other initiatives promoted by Conbipel itself, including through commercial partners;
• D. With the express consent of the user, Conbipel may also process the personal data of the latter in order to study the habits and choices of consumers, to make their products and initiatives more suitable for the tastes and needs of their customers.

With the exception of navigation data, regulated by the Cookie Policy, the processing of personal data is based on:

• - Consent possibly given by the user for the purposes referred to in points C) and D);
• - The current or ongoing contractual relationship relating to the data relating to the sale, services related to the sale and subscription of the Con Te Card;
• - Conbipel’s legitimate interest in providing the services of the Site, and of the user himself to navigate the Site correctly and/or Conbipel’s legitimate interest to respond to any customer requests, as well as to receive requests for spontaneous use.

Please note that, according to the principle of legitimate interest, Conbipel may contact you to offer services and products similar to those previously purchased. Please note that, according to current legislation, this type of contact (cd "soft spam") does not require consent. However, you can, at any time, request the interruption of treatment and Conbipel will provide without delay.

4. TERMS OF PROCESSING OF PERSONAL DATA BY CONBIPEL

The personal data collected through the Conbipel website are processed with mainly computer and telematic methods and tools, adopting the necessary security measures in order to minimize the risk of destruction or loss, even accidental, of the data themselves, Unauthorized access or processing that is not permitted or otherwise incompatible with the collection purposes set out in this Privacy Policy.

However, due to the nature of the online medium, such measures cannot limit or exclude any risk of unauthorised access or data loss. To this end, it is appropriate to verify periodically that the computer is equipped with software devices suitable for the protection of data transmission over the network, both incoming and outgoing (such as updated antivirus systems) and that the Internet Service Provider takes appropriate measures for the security of data transmission over the network (such as firewalls and spam filters).

5. STUDY OF USER HABITS AND CONSUMPTION CHOICES

As indicated in point 2 (D) above and with your express consent, Conbipel may process your personal data in order to study consumer habits and choices in order to make Conbipel products and initiatives more responsive to the tastes and needs of its customers.
Conbipel will process, through automated tools, data on the value and frequency of purchases (even if made during the period of sales) and the type of products purchased (such as accessories, clothing, type) within a specified period of time. The sole objective of this study is to offer customers and users products, services and initiatives that are more suited to their tastes and needs. In this regard, it should be noted that the study of the behavior of users and customers will be non-invasive in the personal field.
As indicated in point 2 (A) above and with the express consent of the user, Conbipel may process the user’s personal data, using automated tools, to study cookies in order to verify navigation on the Site and to offer products and services. in line with navigation activity.

6. MANDATORY OR OPTIONAL NATURE OF THE PROVISION OF DATA

Except for navigation data (the provision and collection of which are governed by the "Cookie Policy"), the provision to Conbipel of personal data collected through the Site both for the processing of requests and queries of users, both for marketing purposes and study of habits is free, optional and voluntary. Failure to provide information does not limit the use of the Site, but may prevent Conbipel from responding to requests for information and questions, as well as evaluating the unsolicited application, or sending information material, updates, newsletters and invitations to Conbipel events.

The provision of personal data, in particular personal data, e-mail address, postal address, telephone number and bank details (in case of payment by credit card) is necessary in connection with the conclusion of the contract for the purchase of products through the site.
On the contrary, some of this data may be essential for the provision of other services rendered on the Site and related to the sale (pre- and post-sale services, such as the replacement service, etc.) or to fulfill obligations arising from law or legislation (tax compliance and anti-money laundering legislation). Failure to provide data may therefore constitute, depending on the case, a legitimate and justified reason for not executing the contract for the purchase of products on the online store and/or the provision of related services.
Depending on the case and, if applicable, the mandatory or optional nature of the provision of data will be indicated from time to time, with a special character attached to the mandatory information (*) or only the data necessary to provide the services and to purchase products on the Site. Failure to provide optional personal data will not entail any obligation or inconvenience.

7. CATEGORIES OF RECIPIENTS OF PERSONAL DATA

Conbipel communicates the personal data of users of the Site only to the extent permitted by law and as indicated below. Personal data may be known by:

• - Employees and collaborators of Conbipel, who will act as authorised data subjects for the internal organization of the company’s activities;
• - Companies that perform for Conbipel specific technical and organizational services related to the Site and the management of marketing and communication services, as subcontractors appointed by Conbipel itself.

Personal data may also be known by:

• - Third parties, exclusively to execute the contract for the purchase of the products on the Site (such as the credit institution for the execution of electronic distance payment services by credit/debit card);
• - To the police or the judicial authorities, in accordance with the law and at the formal request of such persons, or if there are reasonable grounds to believe that the disclosure of such data is reasonably necessary for (1) investigate, prevent or take measures relating to suspected illegal activities or assistance to state control and surveillance authorities; (2) defend against any claims or accusations of third parties, or protect the security of your website and company; or (3) exercise or protect the rights, property or security of Conbipel, its group companies, its affiliates, its customers, its employees or any other person.

Your data will not be disseminated and will only be transferred abroad ensuring adequate levels of protection and safeguards for data protection, according to current legislation.

Your personal data will be transferred exclusively abroad, including to non-EU countries, ensuring adequate levels of protection and legal safeguards, such as standard contractual clauses approved by the European Commission. For more information on the location of the data and to request a copy, you can contact the Data Protection Officer.