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      Triboo Digitale S.r.l. with registered office in Viale Sarca 336, Building 16, 20126 Milan, VAT number/Fiscal code and registration number with the Register of Companies of Milan IT02387250307 (hereinafter also "Triboo") and VR/46 Racing Apparel S.r.l., with registered office in Via F.lli Rosselli, n. 46, VAT number/Fiscal code and registration number with the Register of Companies of Pesaro 02495180412 (hereinafter, the "Partner" and, together with Triboo, the "Owners"), as joint holders of the processing of personal data of users (hereinafter, the "Users") who surf and use the services available on the website www.vr46.com (hereinafter, the "Site" and the "Services") provide below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter referred to as the "Regulation" or the "Applicable Regulations").

      This Site and the Services are reserved for people over eighteen years old. The Owners therefore do not collect personal data relating to people under 18 years old. Upon request of the Users, the Owners will promptly delete all personal data involuntarily collected and related to people under 18 years old.

      Owners take into the utmost account the right to privacy and the protection of their Users’ personal data. For any information in connection with this privacy policy, Users can contact The Owners at any time, using the following methods:

      For Triboo:

      -        by sending a registered letter to the owner's legal office: Viale Sarca 336, Edificio 16, 20126 Milan;

      -        by sending an e-mail message to: triboospa@legalmail.it

      -        by sending a fax to 02 64741401

      For the Partner:

      -        by sending a registered letter to the owner's legal office in Via F.lli Rosselli, No. 46 – 61121 Pesaro (PU);

      -        by sending an e-mail message to privacy@vr46racing.com;

      Users can also contact:

      -        Triboo's Data Protection Manager (RPD or DPO), whose contact details are: lapo.curinigalletti@triboo.it.

      -        - The Partner's Data Protection Manager (RPD or DPO), whose contact details are as: privacy@vr46racing.it.

       

      1. Purpose of treatment

      Users’ personal data will be treated lawfully by Triboo under art. 6 of the Regulation for the following treatment purposes:

      (a) contractual obligations and the provision of the Services to allow the navigation of the Site, that is to comply with the Terms of Use of the Site, which are accepted by the User during the registration phase on the Site and/or during the use of the Services, and comply with specific requests of the User. Users’ data collected by Triboo for the above listed purposes include: first name, last name, tax code, age, home address, gender, e-mail address, as well as any personal information the User may have voluntarily published. Unless the User gives to Triboo a specific and optional consent to process his data for further purposes, User’s personal data will be used by Triboo for the sole purpose of verifying the identity of the User (also by validating the e-mail address), thus avoiding possible scams or abuses, and contacting the User for service purposes only (e.g. sending notifications about the Services). Without prejudice to what stated elsewhere in this privacy policy, in no case Triboo will make the personal data of the Users accessible to other Users and/or third parties.

      (b) administrative-accounting purposes, i.e. to carry out organizational, administrative, financial and accounting activities, such as internal organizational activities and functional activities to the fulfillment of contractual and pre-contractual obligations;

      (c) legal obligations, that is to fulfill obligations required by the law, by an authority, by a regulation or by European legislation. The provision of the personal data for the above processing purposes is optional but necessary, since the failure to provide them will result in the inability for the User to browse the site, sign up to the Site and take advantage of the Services. The personal data which are necessary for the pursuit of the processing purposes described in this paragraph 1 are indicated with an asterisk within the registration form on the Site.

      2. Additional processing purposes: marketing (sending advertising material, direct sales and commercial communication)

      With the free and optional consent of the User, some of the User’s personal data (i.e., first name, last nameemail address, home address) may also be processed by the Partner for marketing purposes (sending advertising material, direct sales and commercial communication), i.e. so that the Partner can contact the User by mail, e-mail, telephone (fixed and/or mobile) and/or SMS and/or MMS to propose to the User the purchase of products and/or services offered by the same Partner and/or third-party companies, submit offers, promotions and business opportunities.

      In case of non-consensus, the possibility of registering on the Site will not be affected in any way. In the case of consent, the User may at any time revoke it, making a request to the Partner in the manner indicated in the next paragraph 7.

      The User can also easily object to further sending of promotional communications by e-mail by clicking on the appropriate link for the withdrawal of consent, which is present in each promotional email. After the consent is revoked, the Partner will send an e-mail to the User to confirm that his consent has been revoked. If the User wish to withdraw the consent to send promotional communications by telephone, but to continue to receive promotional communications via email, or vice versa, he has to send a request to the Holder in the manner indicated in the next paragraph 7. The Partner informs that, as a result of exercising the right of opposition to sending promotional communications by email, it is possible that, for technical and operational reasons (e.g. contact list training already completed shortly before the Opposition Request Is received) the User continues to receive some additional promotional messages. If the User continues to receive promotional messages after 24 hours have passed since the exercise of the right of opposition, he has to report the issue to the Partner, using the contacts indicated in the next paragraph 7.

      3. Additional processing purposes: newsletter

      With the free and optional consent of the User, some personal data of the User (i.e. first name, last name, address, e-mail address) may also be processed by the Partner for the purpose of sending the newsletter. Therefore, the User will receive from the Partner a periodic newsletter that will contain information in relation to news and promotions within the Site and/or Partner initiatives. In the event of non-consensus, the possibility of registering in the Site will not be affected in any way. In the event of a consent, the User may at any time revoke it making a request to the Owner in the manner indicated in the next paragraph 7. The User can also easily object to further submissions of promotional communications by clicking on the appropriate link for the withdrawal of consent, which is present in each email containing the newsletter. After the consent is revoked, the Partner will send an e-mail to the User to confirm that his consent has been revoked.

       

      4. Additional processing purposes: profiling

      With the free and optional consent of the User, the User's personal data (i.e. personal and contact data, as well as information relating to services which the User has expressed his interest in) may be processed by the Partner also for profiling purposes, i.e. to reconstruct the User's tastes and consumption habits by identifying the consumer profile in order to be able to send to the User commercial offers which are consistent with the identified profile. In case of non-consent, the User possibility to subscribe to the Site will not be affected in any way. In case of consent, the User can revoke the same at any time, by making a request to the Partner in the manner indicated in paragraph 7 below.

      5. Processing methods and data storage times

      The Owners will process the User’s personal data through manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data. Users' personal data will be kept for the time strictly necessary to carry out the primary purposes illustrated in paragraph 1 above, or in any case as necessary to protect the interests of both Users and Triboo in civil law. In the cases referred to in paragraphs 2, 3 and 4 above, Users' personal data shall be kept for the time strictly necessary to fulfil the purposes illustrated in the same and, in any case, for no longer than twenty-four (24) and twelve (12) months respectively.

      6. Scope for data communication and dissemination

      Employees and/or employees of the Owners responsible for managing the Site and all services related to the provision of the Services may become aware of the personal data of the Users. These individuals, who have been instructed in this way by the Holders under the Article 29 of the Regulation, will treat the Users' data solely for the purposes set out in this statement and in accordance with the applicable rules' forecasts.

      As provided for by the General Measure of the Data Protection Authority called 'Fidelity card' and guarantees for consumers. The rules of the supervisor for loyalty program" of 24 February 2005. Third-party parties who will be able to process personal data on behalf of the Holders as "External Treatment Managers", such as, but not limited to, providers of IT and logistics services that are functional to the operation of the Site and/or Services, outsourcing or cloud computing service providers, professionals and consultants, may also become aware of the personal data of the Users. Users have the right to obtain a list of any treatment managers appointed by each Owner respectively, requesting them from the Holder concerned in the manner indicated in the next paragraph 7. In addition, the Users’ personal data may be disclosed by Triboo, to the extent that this is necessary and essential to implement contractual obligations, to autonomous third parties that hold the treatment, such as the operators of the payment services and logistics services necessary for the delivery of goods sold through the Site. These autonomous holders will only process the User data for the purpose of the correct fulfillment of the orders relating to the Services.

       

      7. Social buttons and widgets

      There are also social buttons/widgets on the Site. These are in particular the icons of social networks, such as, Facebook, Twitter, Pinterest, Google, Youtube and Instagram, which allow the Users to reach - by means of a "click" on the icon - the related social networks. With the support of these tools, the User can share, for example, some contents or recommend some products of the Site in the social networks. Some contents shared on the social networks may also be shared on the website's dedicated page. After a click on social buttons/widgets, the social network may collect data related to the User's visit on the Site. As mentioned in the premise, this privacy policy does not affect the treatment of the User’s data by the social network which the User must refer to exclusively by the privacy policy provided by the social network. Outside the cases where the User spontaneously share his data with the chosen social networks by clicking on social buttons/widgets, the Owner does not disseminate or share any personal data of the User with the social network.

      8. Rights of Interested Parties

      Users will be able to exercise the rights guaranteed to them by the Applicable Policy, by contacting The Holders in the following ways:

      -        By sending a registered letter to the owners' legal office

      for Triboo: Milan (MI) Viale Sarca, 336, 20126

      for Partner: Strada Pirano Ang. Via Pio la Torre, 1/8 – 61010 - Tavullia (PU)



      -        By sending an e-mail message to the following address:

      Triboo: triboospa@legalmail.it

      Partner: privacy@vr46racing.com

      Triboo will comply with the User's requests for the treatment in paragraph 1, while the Partner will comply with the Users' requests for treatment in paragraph 2, 3 and 4.

      Under the Applicable Policy, Holders inform that Users have the right to obtain the indication (i) of the origin of personal data; (ii) of the purpose and manner of treatment; (iii) of the logic applied when being treated with electronic instruments; (iv) of the identification details of the Holders and those responsible; (v) of individuals or categories of people to whom personal data may be disclosed or who may become aware of it as managers or appointees.

      In addition, Users have the right to obtain:

      (a) access, update, adjustment and, when they are interested in, data integration;

      b) the deletion, the anonymous transformation or blocking of data processed in violation of the law, including those which do not need to be retained in relation to the purposes for which the data was collected or subsequently processed;

      (c) the evidence that the transactions referred to in the letters a) and b) have been brought to the attention, including with regard to their content, of those to whom the data have been disclosed or disseminated, except where such fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected law.

      In addition, Users have the right to obtain:

      (a) access, update, adjustment or, when you are interested in, data integration;

      b) the deletion, anonymous transformation or blocking of data processed in violation of the law, including those which do not need to be retained in relation to the purposes for which the data was collected or subsequently processed;

      (c) the evidence that the operations referred to in the letters a) and b) have been brought to the attention, also as regard to their content, of those to whom the data have been disclosed or disseminated, except where such fulfilment proves impossible or involves the use of means manifestly disproportionate to the protected right.

      In addition, Users have:

      (a) the right to withdraw the consent at any time, if the treatment is based on their consent;

      b) (where applicable) the right to data portability (right to receive all personal data relating to it in a structured format, commonly used and readable by an automatic device), the right to restrict the processing of personal data and the right to delete ("right to be forgotten"); c) the right to object:

      (i) in all or part, for legitimate reasons for the processing of personal data about it, although relevant to the purpose of collection;

      (ii) in all or part, the processing of personal data relating to it for the purpose of sending advertising material or direct sales or for carrying out market or commercial research;

      (iii) if personal data is processed for direct marketing purposes at any time to the processing of their data for that purpose, including profiling to the extent that it is related to direct marketing.

      (d) if they felt that their treatment violates the Rules, the right to complain to a supervisory authority (in the Member State where they usually live, where they work or in the one where the alleged infringement occurred). The Italian Control Authority is the Guarantor for the Protection of Personal Data, based in Piazza Venezia No. 11, 00187 – Rome (http://www.garanteprivacy.it/).

      Holders are not responsible for updating all the links that can be viewed in this Notice, so whenever a link is not working and/or up-to-date, the Users recognize and accept that they will always refer to the document and/or section of the websites recalled from that link.

      Having read the privacy policy, I expressly agree to the processing of my personal data by VR/46 Racing Apparel S.r.l.  for marketing purposes (newsletters, news, promotions, market research and/or statistics, satisfaction surveys).

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