INFORMATION ON THE PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of Regulation (EU) 2016/679 (the “GDPR“)

 

Polynt S.p.A., with registered office in via E. Fermi, 51, 24020 Scanzorosciate (BG), fiscal code and VAT no. 04902660960 (hereinafter “Polynt”, the “Data Controller” or the “Company“), as data controller, will process your personal data, collected in a dedicated section of the website www.polynt.com (the “Website“), in compliance with the applicable legislation on the protection of personal data and the confidentiality obligations that inspire the activity of our Company.

Please read this privacy policy carefully.

In case of doubts on the characteristics of the Data processing, you can contact us at privacy@polynt.com, or by contacting the Polynt Legal Department by writing to the address at via E. Fermi, 51, 24020 Scanzorosciate (BG).

*****

1. Data controller

The Data controller is Polynt S.p.A. with registered office in via E. Fermi, 51, 24020 Scanzorosciate (BG), fiscal code and VAT number 04902660960.

2. Data collected and processed

Polynt collects and processes, through the form present in the “Investors” section of the Website, the relevant and not exceeding data in order to establish and manage the contractual relationship with the Company (the “Relationship“) and, specifically:

• Identification data, such as first and last name;
• Contact data, such as e-mail address;
• Information relating to the position held and, in the case of legal persons, the name and position held by the person filling in the form (hereinafter referred to as the “Disclosed Data” or, simply, the “Data“)

Please do not disclose any personal data of third parties to Polynt, unless it is strictly necessary to achieve the purposes of the processing: in this case, we remind you to comply with the legal requirements on the protection of personal data and, in particular, to inform third parties of the disclosure of their data and to obtain their consent, if necessary.

With reference to any personal data of your employees, collaborators and subjects involved by you in the performance of the Relationship, we remind you to provide them with a copy of this information notice at the latest at the time of communication to Polynt of the data in question.

 

 

 

3. Purpose of processing and legal basis

Execution of the Relationship

The Data will be processed to manage the Relationship with Polynt, including the sending of informative communications relating to the activities of Polynt and the Polynt Group, and the performance of administrative-accounting activities, the fulfilment of fiscal obligations and the management of any litigation.

The legal basis for such processing is the performance of a contract to which the data subject is party or the implementation of pre-contractual measures taken at the request of the data subject, as well as the fulfilment of related legal obligations.

For the same purpose, the Data may be communicated to public authorities (e.g. Consob) and to third party providers of ancillary services necessary to the execution of the relationship (e.g. banks and credit institutions involved in the management of investments; consultants and professionals in charge of administrative, fiscal and corporate fulfilments; providers of trading services). Such subjects shall process the Data, depending on the case, as data controllers, or as data processors, by virtue of a specific written appointment given to them by Polynt.

The Data will also be disclosed in order to comply with legal obligations, first and foremost transparency and publicity obligations relating to communications to the Register of Companies and deriving from the legislation dedicated to listed companies, including Consob circulars and regulations.

The processing of the Data described above is necessary as it is connected and instrumental to the establishment, continuation and proper management of the Relationship: therefore, any refusal to provide the Data may make it impossible to establish or perform the Relationship.

Investor newsletter

The Data will also be processed in order to send you, via e-mail, the investors’ newsletter, i.e. informative communications specifically addressed to Polynt’s investors containing news and updates on new material uploaded in the specific “Investors” section of the Website.

The legal basis for such processing is Polynt’s legitimate interest in keeping its investors informed and in promoting its and Polynt Group’s business, and it is compatible with your position since it is reasonable to assume that you also have a corresponding interest in being informed about investment opportunities, business developments and any further activities of Polynt and Polynt Group. You may, at any time, object to the receipt of such communications or to the use of one or more of the contact details provided by following the procedure at the end of such communications, by contacting us at privacy@polynt.com, or by contacting the Legal Department at Polynt by writing to the address at via E. Fermi, 51, 24020 Scanzorosciate (BG).

The processing of Data as described above is not necessary for the management of the relationship, and any objection to the receipt of such communications shall in no way affect the relationship with the Company.

Legal protection

The Data may be processed, on the basis of a legitimate interest of the Company, to ascertain, exercise or defend the rights of the Data Controller in judicial and/or extrajudicial proceedings. This legitimate interest, given the constitutionally guaranteed interest of the Data Controller in defending its rights in court and the negligible impact on the sphere of confidentiality of the data subjects, is to be considered prevailing.

4. Recipients of the Data and transfers outside the European Union

The Data may be known and processed by the employees of the Company’s corporate functions, assigned to the pursuit of the above-mentioned purposes, who have been expressly authorised to process them and have received adequate operating instructions.

Furthermore, the Data may be communicated to third parties. In this case, the third party recipients of the Data – data controllers or duly appointed as data processors – belong to the following categories:

1. external subjects operating as autonomous holders such as, by way of example, supervisory and control bodies and in general to subjects, including private ones, legitimately entitled to request the data (such as, for example, accounting consultants, legal consultants), Public Authorities who make an express request for administrative or institutional purposes, in accordance with the provisions of current national and European legislation;
2. subjects extraneous to the Controller who provide services to the Company and who are useful for its activities (for example: suppliers of IT services for the management of databases, including contacts and e-mails, providers of digital services and IT consultants who provide technical assistance to the Controller, companies that offer support in carrying out market studies); these subjects have been specifically appointed as data processors and their names are available on request to the Controller, using the contact details indicated in Section 7 below.

The Data will be processed at the Data Controller’s premises and the Data will be stored on servers and/or archives within the European Union.

Transfers may take place to the extent necessary for the performance of the Relationship and subject to the adoption of the appropriate safeguards as set out in Article 46 of the GDPR, and, specifically, the Standard Contractual Clauses prepared by the European Commission, supplemented where necessary with additional security measures to ensure the effective security of the transfers made.

5. Processing methods

In relation to the aforementioned purposes, the Data will be processed by means of manual and automated tools, which ensure the protection of the Data from the design and by default, adequate to guarantee their security and confidentiality, and with logics strictly related to the purposes themselves, by personnel to whom Polynt has given adequate operating instructions with particular reference to the purposes and methods of processing, as well as the security measures adopted.

6. Data retention

The Data will be stored in a form that allows identification of the user, for a period of time not exceeding that necessary to achieve the purposes of the processing and, in particular:

• for the preliminary phase of evaluation and acquisition of information prior to the establishment of the Relationship, for a maximum of 2 years from the provision of the Data in the “Investors” form and, subsequently, in the case of establishment and execution of the Relationship, for the entire duration of the Relationship and for the subsequent period necessary to fulfil the related tax, accounting and labour law obligations, as well as to ensure the judicial protection of Polynt’s rights;
• with regard to the purpose of sending the investors’ newsletter, up to 18 months from the provision of the Data in the “Investors” form on the Website, which can be extended by subsequent periods of 18 months if the data subjects accepts it by responding positively to the request that we will send with one month’s notice before this deadline.

 

7. Your rights

Investors, both actual and potential, as data subjects (i.e., subjects to whom the Data refer), are entitled to rights conferred by the GDPR. In particular, pursuant to Articles 15-22 of the GDPR, data subjects have the right to request and obtain, at any time, access to their Personal Data, information on the processing carried out, rectification and/or updating of Personal Data, erasure and restriction of processing. They also have the right to object to the processing and to request data portability (i.e. to receive Personal Data in a structured, commonly used, machine-readable format). Finally, data subjects always have the right to withdraw their consent at any time (this, in any case, will not affect the lawfulness of the processing carried out on the basis of the consent given before the revocation) and to lodge a complaint with a supervisory authority (in Italy: the Garante per la Protezione dei Dati Personali).

These rights may be exercised by writing to privacy@polynt.com, or by contacting the Polynt Legal Department, writing to the address at via E. Fermi, 51, 24020 Scanzorosciate (BG).

For information or clarification of these rights, please contact us at the same address.

8. Integrations

In the event of material changes to this policy, Polynt will notify you by e-mail to inform you of the changes and to collect any request to exercise the rights described above.

*****

I declare that I have read the Information on the processing of personal data, provided pursuant to Article 13 of European Regulation 2016/679 (GDPR) (mandatory)