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Privacy and Data Protection Policy (under Italian Legislative Decree No. 196/2003 regarding privacy and the protection of personal data)

Dear Customer/Supplier, According to Italian Legislative Decree No. 196/2003 regarding privacy and the protection of personal data, the undersigned “Gilmar Divisione Industria S.p.A.” wishes to inform you that, in the role of data controller, we will take every reasonable step necessary to maintain the security, integrity and privacy of any information we obtain as a result of doing business with you. Under the abovementioned Privacy and Data Protection Policy, we will comply fully with all of the relative confidentiality and transparency provisions. We also wish to inform you that the company staff processing your data will carry out the individual operations on the basis of written instructions and will have access solely to information essential to performing assigned tasks. The personal data collected and processed by Gilmar Divisione Industria S.p.A. are as follows: ID info (name of firm, business address, telephone and fax numbers, email address, tax identification code, etc.); information of a financial and/or business nature (order status, solvency situation, international bank account number, accounting and tax information, etc.). We may receive this information either directly from you or through third party data controllers (for example, from our own network of sales agents/representatives with respect to contract and/or order info; from business registries and public databanks with respect to financial solvency info, etc.). In addition, we wish to inform you that Gilmar Divisione Industria S.p.A. will process your personal data expressly for the following purposes: activities pertinent to executing contracts stipulated with you; fulfillment of all contractual and relative legal obligations; organizational/commercial contract management (for instance, concerning relations with sales agents and representatives); protection of contractual rights; in-house statistical anylyses; marketing activities involving mailing promotional and advertising materials about products or services analogous to the ones object of present business dealings; gaining information relative to financial solvency. Providing the information and subsequent processing of the data are intrinsic to enabling us to execute all activities necessary for fulfilling contractual and relative legal obligations. Providing the information is therefore mandatory on your part. Any refusal to provide the data for these purposes may prevent Gilmar Divisione Industria S.p.A. from proceeding with the contract and/or fulfilling the legal obligations stipulated therein. By contrast, providing the information and subsequent processing of the data become optional if they serve to conduct in-house statistical analyses and/or to carry out marketing activities that involve mailing promotional and advertising materials about products or services analogous to the ones object of current dealings. The same holds true for the financial solvency info. The personal data will be processed and kept in paper and electronic form. They will be entered into customer, supplier, administrative assistant and/or sales agent databanks where they may be accessed by members of the various commercial, production, IT/computer management staffs. The data that Gilmar Divisione Industria S.p.A. collects and processes for purposes of performing activities pertinent to executing contracts stipulated with you, fulfilling all contractual and relative legal obligations, as well as protecting inherent contractual rights, may be sent or otherwise communicated to the following subjects or categories of subjects: Transport and shipping companies for freight consignment and customs matters; Insurance companies; Banks for receipt and payment management; Financial authorities, firms or similar public bodies re fulfillment of legal obligations; Law firms re protection of contractual rights; Certification institutes; External consultants; Hardware and software assistance companies. For purposes of proper contract management on organizational and commercial levels (for example, concerning relations with sales agents and representatives, or with contractors re projects on customer premises), your personal data may be sent or otherwise communicated to agents and representatives who work for us and/or to independent contractors and client companies. We wish to inform you that in order to carry out in-house statistical analyses there is no provision for communicating your personal information other than in aggregate and anonymous form through the divulgation of the statistical results. With regard to processing your data for marketing purposes, there is in general no provision for communicating the same to external parties other than in the case of agents or representatives who work for us and serve in the role of autonomous data controllers. To receive financial solvency info, we may communicate your personal data to business information agencies and firms. Your personal data will not be circulated. As a result of previous business dealings with you, we have on hand the email address info that you provided us with. In compliance with Article 130, comma 4, of Italian Legislative Decree No. 196/2003, we will use this information to keep you up to date on our offers through the mailing of relative notices and/or advertising materials. Lastly, we kindly ask you to keep in mind that Gilmar Divisione Industria S.p.A. recognizes your rights pursuant to Article 7 of Italian Legislative Decree No. 196/2003, in particular your rights to access, amend, update, delete and contest the data you have provided, as well as your rights to block the data in case of violation of law and to oppose the data processing in any case for lawful reasons. You must do so by addressing your request to data controller Gilmar Divisione Industria S.p.A., Via Malpasso, 723-725, San Giovanni in Marignano (Rimini) 47842, Italy.