Privacy

Information pursuant to and for the purposes of Article 13 et seq. of EU Regulation No. 679/2016 of 27 April 2016, (General Data Protection Regulation - G.D.P.R.) "on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)".

Pursuant to and for the purposes of Article 13 of EU Regulation No. 679/2016, we hereby inform you of the following.

By implementing the registration procedure for our services, users voluntarily communicate to the Data Controller, their personal data.

The personal data sent will be processed in compliance with the principles of personal data protection established by the EU Regulation No. 679/2016 and other applicable regulations in force.

The provision of data is optional. However, failure to provide the data deemed mandatory (marked with an *) will prevent proper registration on the site, as well as the possibility of using the services reserved for registered users.

Data Controller, Data Protection Officer and Data Processor

The data controller is Stefano Castiglione (hereinafter also the "Data Controller") and may be contacted by written communication to be sent to:

Stefano Castiglione, Viale Italia n. 120, 31015 Conegliano (Italy).

or by email to the following address: info@atlhas.com.

Purposes and methods of data processing

Personal data collected through registration or subscription to our sites are processed in order to allow access to services and contents reserved for registered users.

In the event that the user has expressed consent at the time of activation of the service, or expresses it subsequently and until the revocation of the same, his personal data may be processed by Atlhas Finance to:

1) allow access to reserved services and content;

2) to send, in the event that users have expressed their consent at the time of activation of the service, or express it subsequently, and until revocation of the same, informative and commercial communications on topics covered by the services rendered, including by automated means, for information purposes, direct sales, as well as for sending market research and verification of the degree of user satisfaction;

3) carry out, in the event that users have expressed their consent at the time of activation of the service, or express it subsequently, and until such time as the same is revoked, including by electronic means, activities of analysis of specific behaviours and surfing habits, in order to improve the services provided and to direct the commercial proposals of interest to the user, offering also to third parties the aggregate data summarising openings and clicks obtained through a tracking system using "cookies";

4) Atlhas Finance will also use personal data for administrative and accounting purposes and for the performance of contractual obligations towards users who are part of its clientele.

The personal data sent through the registration procedures for the services provided may be processed by Atlhas Finance with automated tools. This is without prejudice to the possibility for Atlhas Finance to process the aforementioned data in aggregate form, in compliance with the measures prescribed by the Guarantor Authority and by virtue of the specific exemption from consent provided by the same, for analysis and electronic processing (eg, classification of the entire customer base in homogeneous categories for levels of services, consumption, spending, etc..) aimed at periodically monitoring the development and economic performance of Atlhas Finance activities, to guide the related industrial and commercial processes, to improve services, as well as to design and implement commercial communication campaigns.

Specific security measures are observed by Atlhas Finance to prevent loss of data, unlawful or incorrect use and unauthorised access. Personal data are recorded and stored on electronic databases located in Italy, in countries belonging to the European Economic Area (EEA) and in third countries that guarantee an adequate level of data protection.

The processing of personal data provided by users may also be carried out by companies, entities or consortia, appointed as data processors under Article 28 of the EU Regulation mentioned above, which, on behalf of Atlhas Finance, provide specific processing services, or related activities, instrumental or support, including automated. Specifically, Atlhas Finance uses in some cases an external marketing automation platform called Mailchimp to which the data provided by users are sent for processing and storage in accordance with the Privacy Policy of Mailchimp available at the following link:

https://mailchimp.com/legal/privacy/

The personal data provided by users may also be communicated

• to affiliated or associated companies;
• to subjects whose right to access personal data is recognized by provisions of law, regulations or Community legislation;
• to subjects to whom communication is provided for by law or regulations, or by public subjects for the performance of their institutional functions.

The period of retention of personal data referred to above shall be in line with the provisions of the law.

Rights of the data subject

The data subject shall have the right to request from Atlhas Finance access to his/her personal data, as well as rectification, erasure, restriction or opposition to their processing, if carried out automatically on the basis of consent or for the performance of the contract.

The data subject shall have the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.

The data subject shall have the right to lodge a complaint with the Supervisory Authority for the processing of personal data, pursuant to Article 77 of EU Regulation 679/2016.

COOKIES POLICY

Our policy on cookies

On Atlhas Finance's websites, information is collected that may relate to the user, their preferences, or their Internet access device (computer, tablet or mobile phone) and is used mainly to adapt the operation of the site to the user's expectations, offering a better browsing experience and to send personalised promotional messages. This operation is enabled by cookies, or other similar technologies. Cookies are small text files that are downloaded to the visitor's computer - or other device - by the server that hosts the Atlhas Finance website. Your web browser sends cookies back to this Website on each subsequent visit so that it can recognise you and remember information such as your preferences. You can find out more about cookies and how they work by visiting http://www.aboutcookies.org/.

If the user proceeds to browse, he or she automatically consents to the use of cookies - and similar technologies - in accordance with this "Cookie policy".

You can find out more about the various types of cookies used below.

Notwithstanding the above, we use the following categories of cookies on our website:

1. Essential cookies

These cookies are necessary for the correct operation of our websites and to use and/or improve the various functions and/or services requested. Without these cookies it would not be possible to manage and automate, purely by way of example, user authentication for access to a reserved area of the site itself.

2. Analysis cookies

These cookies allow us to improve our website by monitoring and analysing user behaviour, creating user profiles in order to make improvements and facilitate navigation.

For example, analytics cookies can help us to keep track of which pages are frequently visited and what your preferences are, whether any advertising that is displayed on the website is effective or not, and what difficulties you have using the website.

In order to analyse how the website is used, Atlhas Finance also uses the web analysis service "Google Analytics" provided by Google (https://www.google.com/intl/it_it/analytics/learn/privacy.html).

Further information about the Google Analytics service and the procedures to follow to disable cookies can be found at the following links:

http://www.google.com/intl/en/analytics/privacyoverview.html

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

This data does not allow personal identification of the user: all data collected is aggregated and, as such, anonymous.

3. Advertising and behavioural advertising cookies

These cookies may be used by Atlhas Finance to collect data on browsing habits and user preferences in order to develop a specific profile for customizing the commercial offer and for carrying out market research.

The user may decide to refuse the use of this category of cookies using the opt-out tool provided in the settings page of their browser, or as specified below.

4. Third party and social media cookies

Our website may allow the use of third party cookies that may collect information about your movements on the Internet and, in particular, within our websites.

In addition, some pages on our website feature so-called "social plug-ins", which allow you to share our content on social media networks such as Facebook, Twitter, Youtube, Linkedin.

Third-party cookies are not under our control and, therefore, for further information on how the third party uses cookies, we recommend that you visit the website of the third party, whose web address is listed below, where there are different information and methods of management of third-party cookies:

• Facebook:

Information: https://www.facebook.com/help/cookies/

Configurations: access your account, privacy section

• Twitter:

Information: https://support.twitter.com/articles/20170514

Configurations: https://twitter.com/settings/security

• LinkedIn:

Information: https://www.linkedin.com/legal/cookie-policy

Configurations: https://www.linkedin.com/settings/

• Youtube: http://www.google.com/policies/privacy/
• DoubleClick

Information: http://www.google.com/doubleclick/index.html

Configurations: http://www.google.com/policies/privacy/ads/

Waiving cookies

At any time, the user can refuse to accept all or some of the cookies used on this website in the following ways via the settings on their browser

Management of cookies used for marketing purposes

You can configure your choices about whether or not to accept our or third-party cookies for marketing purposes through the "Cookie Consent Management" module in your browser.

Should the user choose to disable the use of profiling cookies, this will prevent the subsequent storage of further cookies by us, while the cookies previously installed on the user's device will continue to be used on the user's device.

If you wish to delete all the cookies on your device, you can do so by simply selecting the settings on your browser that allow you to delete the cookies present.

Each browser has specific configuration instructions. Further information on how to disable cookies can be found on the website of the browser provider.

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=it
• Mozilla Firefox: http://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
• Internet Explorer: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
• Apple Safari: http://support.apple.com/kb/PH5049

Specifically, to disable only the use of Google Analytics cookies, the user can use the add-on made available by Google at the following link, following the opt-out procedure indicated by Google https://tools.google.com/dlpage/gaoptout?hl=it          

For more information and/or to disable other third-party targeting and advertising cookies, please visit the following website: http://www.youronlinechoices.com/it.

 Notwithstanding the above, please note that if you disable cookies you will still be able to use some parts of our websites, but some services may not be usable.

The data collected through cookies will be stored according to their nature: session cookies expire when the user closes the browser, persistent cookies have typical expiration dates that, with certain exceptions, do not exceed 20 days.

These data will be processed exclusively for the above-mentioned purposes and may be communicated to subsidiaries, parent companies, affiliates or in any case connected companies.

In compliance with the minimum security measures, your data may also be communicated to public security subjects and to other public and private subjects for the fulfilment of obligations provided for by law, also of a fiscal, administrative, financial and similar nature. In no case will the data be disseminated.

In compliance with the principles of proportionality and necessity, the data will not be kept for longer periods than those indispensable for the fulfilment of the purposes indicated above and, therefore, for the service offered or the specific legal requirements.

You may at any time exercise your rights of access vis-à-vis the Data Controller, pursuant to Article 15 of EU Regulation 2016/679, i.e. you may obtain confirmation of the existence of your personal data and request that they be communicated in an intelligible form. You will also have the right to obtain the updating, rectification, integration and deletion of your data or the limitation of their processing. Finally, you will have the right to object, in whole or in part, for legitimate reasons, to the processing of your personal data, even if pertinent to the purpose of collection, as well as to the sending of advertising or direct sales material or for carrying out market research or commercial communication, by contacting the Data Controller, where the complete and updated list of Data Processors is also available on request.

You also have the right to lodge a complaint with the Privacy Guarantor Authority.