PRIVACY POLICY

Information for the issue of consent to the processing of personal data
In compliance with Legislative Decree 30 June 2003 No. 196 (Privacy Code) and subsequent changes, we would
like to kindly provide you with the necessary information regarding the processing of personal data supplied by
you. The information must not be considered valid for other websites that may be consulted through links on the
domain owner’s Internet sites, which are not to be considered in any way responsible for third party websites. This
is an information document drafted pursuant to Article 13 of the legislative decree n. 196/2003 – Code regarding
the protection of personal data. The information document is also based on the Recommendation n. 2/2001 that
the European authorities for the protection of personal data, gathered in the Group and outlined by Article 29 of
Directive n. 95/46/CE, adopted on May 17th
, 2001, in order to identify certain minimum requirements for the
collection of personal data on-line, and in particular the methods, timing and nature of the information that the
data controllers must provide to users when they connect to website pages, regardless of the purposes of the
connection, as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136 /EC, on the subject
of cookies.

1. THE DATA CONTROLLER [“HOLDER” OF DATA PROCESSING], pursuant to Article 28 of the Code regarding the
protection of personal data, is Boffi spa Via Oberdan, 70 – 20823 Lentate sul Seveso (MB), in the person of the protempore
legal representative.
THE DATA PROCESSOR [PARTY RESPONSIBLE FOR DATA PROCESSING], pursuant to Article 29 of the Code
regarding the protection of personal data, is, among others, Dr. A. Loria at the aforementioned Boffi spa, De
Padova Srl, company with sole shareholder, Strada Padana Superiore 280, 20090 Vimodrone (MI), Boffi Trade srl
Via Solferino 11, 20121 Milan (MI) and MA/U Studio srl via Santa Cecilia, 7 20122 Milan and Boffi Barberini Srl Via
Margutta 21/22, 00187 Rome (RM), Italy
LOCATION OF DATA PROCESSING AND TREATMENT
The processing and actions related to the web services of this website, (physically placed “hosted” at a third
party) are carried out at the company headquarters, the data controller, and are only handled by its own
consultants and collaborators, in charge of processing, or by any external subjects for maintenance operations or
updating of website pages.

2.TYPE OF DATA PROCESSED Personal and ID data. Personal information, any information relating to an
individual, identified or identifiable, even indirectly, by reference to any other information, including a personal
identification number; Identification data, personal data that allow for the direct identification of the interested
party.
Data on web navigation The computer systems and software procedures for running this web site acquire, during
their normal operation, some personal data whose transmission is implicit in the communication protocols of the
Internet. This information is not collected to be associated with identified parties, but by their very nature could,
through processing and association with data held by third parties, be used to identify users. This category of data
includes IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource
Identifier) of the resources requested, the time of the request, the method used to submit the request to the
server, the size of the file obtained in reply, the numerical code indicating the status of the response from the
server (successful, error, etc.) and other parameters regarding the user’s operating system and computer
environment.
Legal defence The User’s Personal Data may be used for the defence by the Data Controller in court or in the
stages leading to possible legal action, against improper use of the same or related services by the User. The data
could be used to ascertain responsibility in the event of computer crimes against the site.
Maintenance The User’s Personal Data may be processed with additional means and purposes related to
maintenance.
Data voluntarily provided by the user Optional, explicit and voluntary sending of e-mail addresses listed on this site
and/or filling in forms for data collection, involves the subsequent acquisition of the sender’s address, necessary to
respond to requests, as well as any other personal data included.
Data of minors. Minors may not provide personal data. The Data Processor (Owner) shall not be in any way
responsible for any false statements that should be provided by the minor and, in any case, if it ascertains the
falsity of the declaration, it will immediately delete any personal data and any material acquired. The Owner will
facilitate, to the processor or seller, the parental authority or the legal guardian, the requests concerning the
personal data of the minors, pursuant to Articles 7, 8, 9 and 10 of the Privacy Code.
Third party data. If you provide us with personal data of third parties (e.g. family members, and other interested
parties in general), you must ensure that such third parties are informed and have consented, if necessary, to the
use of data as described in the information document herein.
Specific information documents
Specific information documents may be found in the pages of the Website in connection with particular services
or processing of Data provided by the User or by the interested Party.
Cookies
Please see the cookies policy at the following link.

3.PURPOSES OF DATA PROCESSING AND TREATMENT
The data will be processed for the following purposes:
– Navigation on this website;
– Possible filling out of the form for contact request, with the sending of requested information;
– Possible filling out of the form for the receipt of communication material, for direct marketing activities,
newsletters, market researches or other sample searches and sale via automated electronic mail, MMS or SMS
messages or other types, as well as through telephone calls and use of paper mail, of material information on
products from BOFFI, DE PADOVA, and MA/U Studio, for the survey of satisfaction, promotional, commercial and
advertising material or inherent events and initiatives by the holder of the data, even through the companies
appointed as Data Processors (De Padova Srl, single shareholder company, Boffi Trade srl MA/U Studio srl, Boffi
Barberini srl); The data will be entered in the company CRM. The data controller, in order to compare and possibly
improve the results of communication material, uses systems for sending newsletters and promotional
communications with reports.
As a result to the aforementioned reports, the Data Controller will be able to understand, for example: the
number of readers, openings, individual “clickers” and clicks; the devices and operating systems used to read the
communication material; the detail on the activity of individual users; the details of the emails sent, e-mails
delivered or not, of those forwarded; as well as all data used for the purpose of comparing, and possibly
improving, the results of communications and communication material.

4. PROCESSING METHODS – STORAGE AND RETENTION
Processing will be carried out automatically and manually, using methods and tools aimed at ensuring the
maximum security and confidentiality, by individuals specifically appointed for, in compliance with the
requirements of Article 31 et seq. Legislative Decree 196/03. The data will be kept for a period not exceeding the
purposes for which the data were collected and subsequently processed.

5. SCOPE OF COMMUNICATION AND DISSEMINATION
The data, subject to the processing described herein, will not be disseminated and may be disclosed to companies
contractually linked to Boffi spa, abroad and within the European Union, in accordance with and within the limits
of Art. 42 of Legislative Decree. No. 196/2003. Personal data may be transferred abroad in countries outside the
EU, and within the limits provided by Articles 43 and 44 letter b) of the Decree No. 196/2003, in order to comply
with contractual obligations or related purposes. The data may be disclosed to third parties in the following
categories: – suppliers of services for the management of the information system used by Boffi spa and
telecommunications networks (including e-mails and platforms); – studies or companies providing assistance and
consultancy; – Associates, subsidiaries or companies contractually linked to Boffi spa, also belonging to the Boffi
group, and/or as part of its distribution network (such as branches, importers, distributors, forwarders, etc.), even
established in countries outside the EU; – authorities competent for the carrying out the relevant laws and/or
regulations of public bodies, on request.
The subjects belonging to the above categories are considered Data processors, or they act independently as
separate Data controllers. The list of the data processors is constantly updated and available at the headquarters
of Boffi spa Via Oberdan, 70-20823 Lentate sul Seveso, Italy.

6. NATURE OF PROVISION AND REFUSAL
Apart from that specified for navigation data, the user is free to provide personal data in the data collection forms.
Failure to provide such data may make it impossible to obtain that which is requested or impede the use the
services of the data controller in dedicated areas (e.g. newsletters, informative material or other communications)

7. RIGHTS OF INTERESTED PARTIES
You have the right to make use of your rights as expressed in articles 7, 8, 9 and 10 of the Italian legislative Decree
30 June 2003 No. 196, by contacting Boffi spa or the Data Processor, sending an e-mail to privacy@boffi.com. You
have the right, at any time, to obtain confirmation of the existence of data and to know the content and origin,
verify its accuracy or request its integration or updating, or correction (Article 7 of the Code concerning the
protection of personal data). For the purposes of the aforementioned article, the user shall have the right to
request cancellation, transformation into anonymous form or blocking of data processed in violation of the law,
and to oppose in any case, for legitimate reasons, to their processing. In order to stop receiving automated direct
marketing communications (email, SMS, MMS), you can simply write at any time an e-mail to privacy@boffi.com
with the subject line: “cancellation from automated mail” [in Italian: “cancellazione da automatizzato”] or use our
systems of automatic cancellation provided only for e-mail, and you will not be disturbed any more. To stop
receiving direct traditional marketing communications (phone calls with operator, paper mail), you can simply
write at any time an e-mail to privacy@boffi.com with the subject line “cancellation from traditional marketing”
[In Italian: “cancellazione da tradizionale”], and you will not be further disturbed.

8. CHANGES TO PRIVACY POLICY STATEMENT
The data controller reserves the right to modify, update, add or remove parts of the privacy policy statement
herein at his/her own discretion and at any time. The interested party shall periodically verify these possible
changes. In order to facilitate this verification, privacy statement shall contain the date when updating took place.
The use of the site, after the publication of the aforesaid changes, shall constitute acceptance of these changes.
Updated on: April 4th
, 2018