ESPRINET GROUP PRIVACY POLICY General Information TYPES OF DATA PROCESSED, PURPOSES AND RETENTION PERIOD Already registered / Becoming a customer Filling out forms (Becoming a supplier, Requesting information) Newsletter Product Support/Assistance Area Webinar Filling out the “Work with us” form Cookies To whom we disclose personal data Transfers outside the European Economic Area Rights of data subjects This page describes the rules for processing personal data of visitors to the Websites and related pages (e.g. landing pages) and summarises the main processing operations performed by Esprinet Group companies. General Information The Data Controller in charge of the personal data collected and exchanged via the following websites is the Esprinet Group company shown in the following table. The table also shows, for each company mentioned, the email address that can be contacted for more information regarding personal data processing activities. Company/processor and domains within the remit of the processor: Domain Data Controller Registered office Email address that can be contacted for further information Data Protection Officer www.esprinet.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com EsprinetHUB.it Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com esprinetsmarthome.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com it-careers.esprinet.com/ Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com es-careers.esprinet.com/ Esprinet Iberica,S.L.U. Campus 3·84 - Nave 1, Calle Osca, 2 Pol. PLAZA (Zaragoza Logistics Platform) 50197, Zaragoza, Spain privacy@esprinet.com dpo@esprinet.com 4sidesrl.it 4Side srl Piazza E. Morelli 9, 20025 Legnano (MI) privacy@esprinet.com dacomaidc.com Dacom Spa Via Crocefisso 5, 20122 Milano privacy@dacomaidc.com assoteam.it Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com b2b.esprinet.com Esprinet SpA Via Energy Parl 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com b2bservices.esprinet.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com register.esprinet.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com cloud.esprinet.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com okretail.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com intranet.okretail.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com nilox.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com intranet.nilox.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com celly.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com v-valley.com V-Valley Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com ewebclub.com Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com vinzeo.com Vinzeo Technologies, S.A.U. Plaza Euskadi No. 5, 9º planta 48009, Bilbao, Spain privacy@vinzeo.com dpo@esprinet.com v-valley.es V-Valley Advanced Solutions España, S.A.U. Calle Quintanadueñas nº 6 Planta 3, 28050, Madrid privacy@v-valley-es.com dpo@esprinet.com gti.es GTI Software y Networking, S.A.U P.E. San Fernando - Ed. Europe. 2º Planta. Escalera A C/ Sierra de Guadarrama, 3 28830, San Fernando de Henares, Madrid, Spain gti.es planetmarket.it Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com b2b.v-valley.com V-Valley Srl Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com landingmarketing.info Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com newslettermarketing.info Esprinet SpA Via Energy Park 20, 20871 Vimercate (MB) privacy@esprinet.com dpo@esprinet.com TYPES OF DATA PROCESSED, PURPOSES AND RETENTION PERIOD Already registered / Becoming a customer: The identification, biographical and delivery personal data (address, telephone and email) provided are processed for the following purposes and kept for the relevant retention periods: providing the registration service: period required by law managing the contractual relationship: period required by law carrying out direct marketing activities, including profiling (with consent): until the withdrawal of consent or termination of the contractual relationship. Filling out forms (becoming a supplier, requesting information): personal data provided by the user spontaneously and voluntarily by filling out forms for requests for information, contacts and similar are processed to comply with the requests. The data collected are kept for 1 year. Newsletters: the delivery (email) data provided for the completion of the registration form will be used to send communications and/or information and sales/marketing materials. Subscribing to receive newsletters and sales/marketing information is completely free and optional. Delivery information will be used for this purpose until withdrawal of consent and then erased. Product Support/Assistance: The personal delivery data given for the support request will be processed for the sole purpose of following up and managing the after-sales support request (in performance of the agreement). The above data will be kept for a maximum of 2 years. Webinar: The personal data provided to register for webinars will be processed for the organisation and management of the webinars and for related administrative activities (performance of the agreement), including satisfaction surveys and the sending of materials related to the topic addressed. In the case of webinars co-organised with other organisations, it should be noted that the partners involved do not receive the references and the delivery data of the members, but only the references to the corporate names of the companies present. The data will be kept for 1 year from the webinar. Filling out the “Work with us” form: The personal data provided is processed for the sole purpose of recruiting and selecting staff for the establishment of an employment relationship or collaboration with one of our companies (performance of the agreement). The data will be stored for 2 years after collecting the CV and then deleted from our database. Cookies The methods of processing the information collected during users' visits to the websites listed above are detailed in the Cookie Policy. To whom we disclose personal data Data collected after visits to the websites listed above are communicated to: banking institutions, parties specialising in the management of information and/or payment systems, insurance companies and credit brokers, parties responsible for keeping accounts or auditing the financial statements of Group companies and to persons carrying out transport or shipping activities third parties whose services the Company uses to carry out technical and organisational tasks and activities and related services, designated Data Processors (such as after-sales support providers, persons providing the goods and services offered by Esprinet Group Companies, persons used by the Esprinet Group to carry out promotional, advertising, marketing and communication activities, law firms and consultants, etc.) to any third party in compliance with a legal obligation or to protect the Company’s rights (institutions, law enforcement, judicial, administrative, regulatory or public security authorities, in the context of legal or administrative proceedings, or in order to comply with a legal obligation or to protect one of our rights, including in judicial proceedings). Transfers outside the European Economic Area: The possible transfer of personal data to service providers outside the European Economic Area is regulated by specific agreements that require the recipient to comply with the appropriate guarantees provided for by current legislation. Rights of data subjects The persons to whom the personal data refer, as data subjects, have the right at any time to obtain from Esprinet Group companies, pursuant to Articles 15-22 of EU Regulation 2016/679, access to their personal data, their rectification or deletion (where applicable) or the restriction of their processing. Data subjects also have the right to withdraw consent, where given, as well as the right to lodge a complaint with the Data Protection Authority in the country of the Company's data controller. All the rights summarised above can be exercised by writing to the email address contained in the table in the General Information Section under “Email address that can be contacted for further information”. We will respond promptly.