Personal Data Processing Policy Articles 13 and 14 EUROPEAN REGULATION NO. 679/2016  Legislative Decree 196/2003 amended by Legislative Decree 101/2018 Dear Interested Party, the Undersigned INTERMEETING srl, located in Via Fornaci 239/A – 35129 Padua (PD), Fiscal Code and VAT no.: 02227260284 in the capacity of “Processing Holder” informs you that, in accordance with articles 13 and 14 of European Regulation no. 679/2016 (hereinafter "EU Regulation"), your data with be processed according to the following:

1. Data Processor

The Data Processor informs you that personal data (e.g. first name, last name, business name, address, phone number, e-mail, bank details and/or payment details, etc.) − hereinafter referred to as "personal data" or even simply "data" − which refers to you or was provided by you verbally, directly or via third parties, in relation to the establishment of a contractual agreement, can be subject to processing in accordance with EU Regulation. Data Processing refers to any operation or series of operations pertaining to the collection, registration, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, notification, sharing, and destruction of said data.

2. Nature of the Processed Data, Legal Framework and Processing Purposes

Nature of the processed data: in relation to the contractual agreement or in relation to all the preliminary phases which precede the conclusion of the contract, only the following "personal data" will be processed:

• personal data (first name, last name, etc.), residence and/or domicile and contact details (telephone number, cell phone, e-mail);
• data pertaining to one’s professional qualification and role in the company
• bank data and/or data required for payment

Legal basis and aims: EU Regulation no.679/2016, Legislative Decree no.196/2003, amended by Legislative Decree no.101/2018. The processing of your personal data – given in writing and/or even provided by you verbally – complies with what is set forth in art.6 of EU Regulation 2016/679, and takes place following your consent to protect the rights of the Undersigned Data Processing Holder in the event of a dispute, to execute a contract you are engaged in and/or execute pre-contractual measures you have requested (e.g. the preparation of an offer, etc.). There are two types of personal data which are to be provided, one without your expressed consent and one with your expressed consent:

1. A) without your expressed consent (art.6 of the EU Regulation) - Primary Purposes:

• to execute a contract which the interested party is engaged in or to execute pre-contractual, contractual, and tax measures adopted upon request of the interested party (art. 6, paragraph 1, letter b);
• to comply with the obligations set forth by the Law, a regulation, community legislation or an order issued on behalf of the Authority (such as, for example, orders pertaining to money laundering) which the Processing Holder is subjected to (art. 6, paragraph 1, letter c.);
• to comply with civil accounting, tax and public safety regulations, and the administrative management of the relationship (invoicing, any document management, etc.) and comply with the requirements connected to the execution of the contract with professional contractors;
• to provide the Interested Party with the information they request regarding events, gatherings, courses and/or equipment;
• to transfer information regarding events, gatherings, courses, etc. that the interested party is enrolled in;
• to exercise the rights of the Processing Holder, for example the right to legal defence;
• to pursue the legitimate interest of the Processing Holder;
• for credit management;
• for statistical analysis, market research and quality control;
• for insurance management;
• for the organisation and development of events and meetings of a promotional nature;
• for technical assistance.

1. B) Only upon specific and explicit consent (art.7 of the EU Regulation) - Secondary Purposes - Purposes of a promotional, advertising and marketing nature.

The personal data gathered for primary purposes could also be processed (alongside other additional contact information and optional information such as email addresses, cellphone numbers, geographical addresses, which could also be requested to the interested party in the registration forms) via automated IT methods for the following purposes which are specified below, as requested by the Italian Data Protection Authority on 4th July 2013, which indicates the anti-spam Guidelines. These purposes are specifically commercial promotions, advertising communications and marketing in a general sense. By consenting to Data Processing for Marketing Purposes, the interested party specifically acknowledges the promotional, commercial and marketing purposes of said data processing (including subsequent management and administrative activities) and expressly authorises, once consenting, to said processing, and acknowledges that the Processing Holder may use means for marketing purposes such as phone calls made on behalf of operators or other non-electronic, non-telematic means or means which are not supported by automatic mechanisms and/or procedures, whether electronic or telematic, including manual or paper-based contact modalities; the interested party also acknowledges that the Processing Holder may use means for marketing purposes such as e-mails, faxes, SMS, MMS, WhatsApp messages, social media (Facebook, etc.), automatic systems without the intervention of operators or the likes, including electronic platforms and other telematic means. To execute Processing for Marketing purposes, a special, separate, express, documented, prearranged, informed, free, and fully optional consent needs to be obtained. As a consequence, if the interested party decides to give said consent, they must be notified in advance and must be aware that the purposes of the data processing pursued are commercial, advertising, and promotional in nature, and constitute marketing in broad terms. Within a framework of absolute transparency, we would like to inform the interested party that the data will be gathered and subsequently processed only once specific consent has been granted:

1. to send advertising and information material (e.g. newsletters), of a promotional nature;
2. to send commercial information; to carry out interactive commercial communications on paper, automatic or electronic formats, and, specifically, via standard post or e-mail, telephone (e.g. calls, WhatsApp messages, SMS and MMS), fax and any other IT channel (e.g. websites, mobile Apps);
3. to send invitations to events, gatherings and meetings of an informative or promotional nature;
4. to send updates on promotional initiatives or technical updates pertaining to equipment, services, training or assistance and/or indication of the level of quality satisfaction;
5. to send commercial and/or promotional information on behalf of third parties (for example, associates, business partners, companies and/or legal or natural persons who collaborate with the Company) via paper, automated or electronic formats and, specifically, via standard post or e-mail, telephone (e.g. calls, WhatsApp messages, SMS and MMS), fax and any other IT channel (e.g. websites, mobile Apps);

By opting in and giving consent, the data provider acknowledges and authorises the potential secondary processing of their data.

3. Processing Method - The automated decision-making process, which includes Profiling

Your personal data is processed through operations indicated under art.4 no.2 of the EU Regulation and, more specifically, it entails the collection, registration, organisation, structuring, storage, adaptation or amendment, extraction, consultation, use and notification by sending, sharing or any other way of disclosing, comparing or interconnecting, limiting, cancelling destroying, or restricting. The data processing will be based on principles of correctness, lawfulness and transparency, and can be carried out using manual, IT and telematic means, on paper and/or digital supports. The processing will be carried out so as to guarantee the safety and confidentiality of the data. In the event of your expressed consent, your personal data (gathered for the purposes indicated under the previous points) will be processed for the purposes of profiling; in particular, for the creation of your profile and/or the analyses of your preferences, also by cross-referencing said data with other information gathered through profiling cookies you have accepted. The processed data can be used to forward targeted commercial information and personalised promotional initiatives. Data processing for profiling purposes will be conducted using the tools and methods indicated above.

4. Data Processing Times and other Information

The processing will be automated and/or manual, in compliance with what is set forth in article 32 of the EU Regulation on the subject of safety measures, and will be carried out by appointed subjects in compliance with what is set forth in art.29 of the EU Regulation and what is indicated by art.130 of Legislative Decree no.196/2003, amended by Legislative Decree no.101/2018. We would like to inform you that, in accordance with the principles of lawfulness, limitation of  purposes and minimisation of  data, and in compliance with art.5 of the EU Regulation, once you freely give your explicit consent, your data will be preserved for the time required to achieve the purposes for which said data was collected and processed, or at the very least until the specific consent is revoked by the interested party. Specifically: - with regard to the primary purposes, the data will be preserved for no longer than the time strictly required to carry out the legal and contractual obligations; - with regard to the secondary purposes, the data processed for Marketing and Profiling will be preserved by the Undersigned from the moment the interested party provides their consent until said consent is revoked. In the event that the consent is revoked, said Data can no longer be processed for the above-mentioned Marketing and Profiling purposes, but it could still be preserved in order to address potential disputes and/or claims. The amount of time that the Data is stored for the Undersigned's Marketing and Profiling purposes complies with local regulations and the provisions of the Italian Data Protection Authority. The length of time that the data is stored specifically in each data category can be accessed by the interested party upon request at the company premises. The personal data is collected and subsequently processed in order to execute the purposes for which it has been collected and in order to comply with the legal and contractual obligations deriving from its collection. The data processing is performed exclusively by the Holder or subjects entrusted with performing data processing in accordance with articles 28 and 29 of the EU Regulation, who operate using IT and telematic tools in ways which are strictly correlated to the purposes expressed and, in any case, in order to guarantee the safety and confidentiality of the data itself. In agreement with what is set forth in article 5 of the EU Regulation, the data subject to data processing is: * processed legally, correctly and transparently to respect the interested party ("lawfulness, correctness and transparency"); * gathered for specific, explicit and legitimate purposes, and subsequently processed so as to not be incompatible with said purposes; additional personal data processing for the purpose of scientific or historic research of for statistical purposes is not deemed incompatible with the initial purposes and is in compliance with article 89, paragraph 1 ("limitation of the purposes"); * suitable, pertinent and limited to what is necessary for the data processing purposes ("data minimisation"); * correct and, if necessary, updated; all reasonable measures necessary to delete or immediately rectify incorrect data for the data processing purposes are to be adopted ("correctness") * preserve the data in a way that allows for the interested parties to identify said data for a time period which does not exceed the time period required to achieve the purposes for which the data is being processed; personal data can be stored for longer periods, provided the data is processed exclusively for archiving purposes in the interest of the public, and in the interest of scientific, statistical or historic research, in agreement with article 89, paragraph 1, with the exception of the technical and organisational measures required by the current regulation aimed at protecting the rights and freedom of the interested party ("storage limitation"); * processed in order to guarantee adequate safety of the personal data, including the protection, through appropriate technical and organisational measures, of non-authorised or illegal processing and loss, destruction, or accidental damage ("integrity and confidentiality"). The data you provide will be processed “legally, correctly and transparently”, protecting your confidentiality and rights. It is worth highlighting that, in the absence of significant contacts for a period of ten years, or in the event the rights set forth in the EU Regulation are exercised on behalf of the interested party (e.g. the right to eliminate/forget/limit), the personal data will be transferred to a designated digitally encrypted and/or paper-based archive (protected archive), making said data accessible exclusively to the Processing Holder or they will be destroyed and no copy will be saved, unless the Law in force requires otherwise. A periodic assessment of the processed data is foreseen on an annual basis and the data can be deleted if no longer required for the foreseen purposes.  

5. Access to Data (categories of recipients to whom the data could be disclosed)

In addition, we would like to inform you that the data gathered will never be disclosed or shared without your explicit consent, with the exception of necessary communication required to provide public bodies, consultants or other parties with the information needed to comply with tax and legal obligations or to comply with primary and secondary purposes (where authorised); prior to disclosing said data, we will issue a letter of appointment, which enforces their duty to comply with the confidentiality and safety requirements of personal data processing. In compliance with art.13, paragraph 1, letter (3) of the EU Regulation, we hereby list the subjects or categories of subjects (adequately identified and appropriately instructed) who can gain access to the user's personal data as managers or operators:

• List any known main business partners or eliminate this point if there are none
• Partners, employees and collaborators of the Processing Holder in Italy and abroad, as internal processing operators and/or managers (e.g. offices: commercial, technical, administrative, legal, press) and/or systems' administrators;

Your personal data can be disclosed to external subjects responsible for procedures which concern you, in order to perform the above-mentioned tasks, and external subjects who interact with the Undersigned, always and exclusively for functional activities related to the above-described purposes. These categories are:

1. Consultants (such as, for example, accountants and/or financial advisors and/or careers' advisors) for aspects which may concern you, in full compliance with the Law;
2. Companies operating in the IT sector (Data Centers, Cloud Providers, companies which provide IT services and back up and/or maintenance of the systems and software, including applications, etc.), even residents abroad, but in any case always established in and/or which use systems located in the European Union, for the safe and confidential processing of your data;
3. Professionals and/or Companies operating in the field of safety at work;
4. Consultants and legal firms for any litigations;
5. Public administrations for institutional functions, within the limits established by the Law and regulations;
6. Social security and welfare organisations and certifying agencies,
7. Insurance companies, liquidators, consultants, and experts;
8. Company consultants;
9. Partner companies and/or service providers or instrumental service providers for the purposes outlined under point 2;
10. Public authorities and administrations for the purposes connected to compliance with legal obligations and subjects legally allowed to access in accordance with the law, regulations, and community norms;
11. Banks, financial institutions, or other subjects to whom the transfer of said data is necessary in order for us to perform our activity in relation to the contractual obligations we have undertaken towards you.

For the sake of brevity, the detailed list contained these subjects is available at our premises and is at your complete disposal.

6. E 7. Data Transfer and Communication

Without the need to expressly consent (art. 6 letter b) and c) of the EU Regulation), the Processing Holder can indicate their data for the purposes indicated under point 2A) to supervisory bodies, legal authorities, and subjects for whom communication is compulsory by Law in order to execute the purposes indicated above. Said processing data holders will process the data as independent contractors. During and after browsing, your data can be shared with third parties and specifically: - see the cookie policy. Your data will not be shared. Your personal data is stored on devices located at the headquarters of the Processing Holder or with providers located in the EU. The data you have provided can be transferred to Countries which are not located in the EU, as we rely upon external processing managers who, in order to carry out their services (such as supplying email addresses, or other types of clouds or services), are authorised to transfer the data, even via their own subordinate managers, outside the EU. The data can also be transferred to subjects who independently or on behalf of the Undersigned provide:

• the management and/or management of websites and electronic tools and/or telematic tools used by the Company;
• the processing of statistical research and market research;
• the organisation and development of events and meetings even of a promotional nature;
• legal, tax, welfare, accounting, organisation, and commercial assistance;
• reviewing activities.

To guarantee the safety of such transfers, we rely solely upon subjects who offer the guarantees necessary to ensure suitable technical and organisational measures, in order for the processing to comply with what is carried out by EU Regulation 679/2017 (for example, assessing the presence of adequacy decisions or governing the relationship through standard contractual clauses). However, it is understood that the Processing Holder, where necessary, will be allowed to transfer the data even to countries outside the EU.  In this case, the Holder immediately ensures that the transfer of the data outside the EU will take place in conformity with the applicable legal provisions, after standard contract clauses (standard contract clauses are available at this link http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm) and standard assessments set forth by the European Commission have been stipulated (specifically, the conditions indicated in CAPO V of the EU Regulation will be adhered to). The transfer to countries outside the EU will in any case comply with appropriate and opportune guarantees in accordance with art. 46, 47 or 49 of EU Reg EU 679/2016/. With regard to both the data available on your devices and any data stored by providers, the Processing Holder has set out technical and organisation measures aimed at guaranteeing a suitable level of safety, in full compliance with what is set forth in the EU Regulation. Browsing: your browsing data can also be transferred, within the limits indicated above, to the following states: - see the cookie policy. Cookie management: if you have any doubts or concerns pertaining to the use of Cookies, you can always block the setting and reading of your data, for example by changing the privacy settings on your browsers to block certain types of Cookies. Because every browser, and often different versions of the same browser, can be noticeably different from one another, if you would rather set your own browser preferences, you can find detailed information about the necessary procedures to do this in your browser guide.

8. Nature of Data Sharing and Consequences of your Denial of Consent

Conferring data for the purposes indicated under  "Point 2.A) - primary purposes" of this Policy is a necessary step to establish a contract and allow for the execution of said contract. We would like to inform you that, should you refuse to share said data or if an authorisation is not granted to process the data for said purposes, it will be impossible for our Company to comply with the legal and contractual obligations we have undertaken with you. In this case, failure to share data will lead to the impossibility to establish or maintain the contractual relationship, as said data is required to correctly meet the legal requirements to manage the contract. Providing data for the purposes under the "Point 2.B) - Secondary Purposes" of this policy is optional.  So, you can decide to not share your data or deny processing of said data even after providing your consent, at any moment in time. Providing personal data to the Processing Holder and providing consent to Processing for Marketing Purposes and consent to sharing your data with third parties for processing for Marketing purposes, according to the methods and procedures mentioned above is completely optional (and you can revoke your consent informally even after the consenting to the service by sending an e-mail to the Undersigned (see point 10). Failure to provide said data will yield no consequences,  other than the impossibility for the Processing Holder and any third party to carry out the marketing processing mentioned and, therefore, to inform you directly about news pertaining to the product and technical services. If you deny marketing consent, this will neither interfere with nor limit the chance to apply for Promotional Initiatives on a case-by-case basis; however, you will not receive direct notifications. Some fields on the website may feature an asterisk*. This means that you are required to fill in these fields when inserting your data. If you do not provide said information, you cannot benefit from the service. Following the receipt of an opt-out request, the Processing Holder will immediately remove and delete the data from the database used for Marketing purposes and will notify any third parties to whom the data has been communicated.  The cancellation request automatically confirms that the cancellation has taken place.

9. Rights of the Person concerned:

As the interested party, you possess the rights under articles 15 to 22 of the EU Regulation indicated below, and you have the right to: - request confirmation of the existence and processing of personal data that concerns you, and obtain a written (electronic) copy indicating this in clear and understandable language (so-called "right to access"); - obtain information regarding the purposes of the processing, the personal data categories, the recipients and the categories of recipients to whom said personal data has been or will be communicated to and, where possible, find out how long said data will be stored for; - request the correction of the data concerning the interested party (so-called "right to adjustment"); - request the correction of the data concerning the interested party (so-called "right to adjustment"); - request  processing limitations (so-called "right to limit the processing"); if the data is not gathered directly from the interested party, to request all the information available pertaining to its source of origin; - object to the portability of the data, that is to receiving the data from a processing holder in a structured format, of common and readable use, from an automatic device and send it to another processing holder without obstructions (so-called "right to data portability"); - object to the processing at any time and even in the case of processing for direct marketing purposes (so-called "right to opposition").  We'd like to inform you specifically and separately, as requested by art.21 of the EU Regulation, that, if the personal data is processed for direct marketing purposes, the interested party has the right to oppose the processing of their personal data at any time and that if the interested party opposes  processing for direct marketing purposes, the personal data can no longer be processed for said purposes; - object to an automated decision-making process relating to physical people, including profiling; - revoke consent at any point, without compromising the lawfulness of the processing based on the consent given prior to the revocation; - make a complaint to a supervisory authority (Guarantor for the Protection of Personal Data). Conditions or limitations to the rights of the interested party may apply. For example, it is not certain that the right to data portability is applicable in all cases; this depends on specific processing circumstances.

10. Ways in which you can exercise your rights

You can, at any moment in time, exercise your rights by sending a clear notification, without any special formalities: - a registered letter with return receipt to the undersigned (see the address indicated on the headed paper) - an e-mail to amministrazione@intermeeting.net.

11. Minors

What the data processing Holder offers and the subject of the relationship established with you is not aimed at minors and, therefore, the data processing Holder does not intend to acquire personal information relation to minors. If information relating to minors is involuntarily processed, the Data Processing Holder will immediately delete said data, upon the request of the interested party.

12. Personal data not gathered from the interested party

There may be circumstances in which the Undersigned is not the Processing Holder to whom you have given your personal data; instead, it may be a co-holder of the processing or may be responsible for externally processing data and that, consequently, your data may have reached the hands of the Undersigned indirectly due to a contract between the parties. In this case, we would like to inform you that the Undersigned will take the steps necessary to verify that you have been informed and have consented to the data processing. You can ask the Undersigned for the source of procurement of your Data at any moment.

13. Holder, D.P.O. and Operators

Below, we would like to provide you with some information you need to be aware about, not only to comply with legal provisions, but also because transparency and correctness towards our staff/collaborators is an essential part of our business. Data Processor. The Data Processor responsible for processing your personal data is INTERMEETING srl represented by Mr Mario Carlo Baccaglini, who is responsible towards you for the legitimate and correct use of your personal data and whom you can contact for any information or request by calling +39 049 7386856 or e-mailing amministrazione@intermeeting.net D.P.O. (Data Protection Officer) . You can also contact the Data Protection Officer for information and forward requests pertaining to your data or to report poor services or any problem you may encounter. The Data Processor has appointed Mr Nicola Ghinello Data Protection Officer; you can contact him here: +39 348 3165267 and e-mail: nicola.ghinello@dpo-rpd.com. Employees. The updated list of employees who handle the processing is stored at the Data Processor's premises.

Data Processor INTERMEETING srl

To get in touch Intermeeting srl is happy to receive your comments pertaining to this Privacy Policy. We invite you to contact us at this address: amministrazione@intermeeting.net.