GDPR / PRIVACY RULES

INFORMATIVE EX ART.13D.LGS. 196/2003 AND INFORMATION EX ART 13 AND 14 OF THE NEW EUROPEAN REGULATION 2016/679 (GDPR) FOR THE PROCESSING OF PERSONAL DATA

T.M.I. Srl Special Services, with registered office in Viale Ercole Marelli, 352 - 20099 Sesto San Giovanni (MI) Italy, CF and VAT number IT 02553550969 (hereinafter "Holder"), as data controller, informs you pursuant to art. . 13 D.Lgs. 30.6.2003 n. 196 (hereinafter, "Privacy Code") and art. 13 and 14 EU Regulation n. 2016/679 (hereinafter, "GDPR") that your data will be processed in the manner and for the following purposes:

1. Object of the Treatment

T.M.I. Srl Special Services , processes personal data, identifiers (for example, name, surname, company name, address, telephone, e-mail, bank and payment details) - hereinafter, "personal data" or even "data") that you have communicated on the conclusion of contracts for the services of the Owner.

2. Purpose of the processing

Your personal data are processed:

A) without your express consent (Article 24 letter a), b), c) Privacy Code and art. 6 lett. b), e) GDPR), for the following Service Purposes:

- conclude the contracts for the services of the Owner;

- fulfill the pre-contractual, contractual and tax obligations deriving from relations with you in existence;

- fulfill the obligations established by law, by a regulation, by community legislation or by an order of the Authority (such as for anti-money laundering);

- exercise the rights of the owner, for example the right to defense in court; B) Only subject to your specific and distinct consent (articles 23 and 130 of the Privacy Code and article 7 of the GDPR), for the following Marketing Purposes:

- send via mail and / or electronic messaging services, newsletters, commercial communications and / or advertising material on products or services offered by the Owner and recognition of the degree of satisfaction on the quality of services;

- send via mail and / or electronic messaging services, newsletters commercial and / or promotional communications of third parties (for example, business partners, insurance companies, other companies of the Card Protection Plan Group). Please note that if you are already our customers / suppliers, we may send you commercial communications relating to services and products of the Owner similar to those you have already used, subject to your disagreement (Article 130 paragraph 4 of the Privacy Code).

3. Processing methods

The processing of your personal data is carried out by means of the operations indicated in art. 4 of the Privacy Code and art. 4 n. 2) GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing.

The Data Controller will process the personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality relationship and no later than 2 years from the collection of data for the Marketing Purposes.

4. Access to data

Your data may be made accessible for the purposes referred to in art. 2.A) and 2.B):

to employees and collaborators of the Data Controller or companies in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators; to third party companies or other subjects (as an indication, credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, etc.) who carry out outsourced activities on behalf of the Owner, in their capacity as external managers of the treatment.

5. Communication of data

Without the need for express consent (pursuant to Article 24 letter a), b), d) Privacy Code and art. 6 lett. b) and c) GDPR), the Data Controller may communicate your data for the purposes referred to in art. 2.A) to Supervisory Bodies (such as IVASS), Judicial Authorities, to insurance companies for the provision of insurance services, as well as to those subjects to whom the communication is mandatory by law for the accomplishment of said purposes. These subjects will process the data in their capacity as independent data controllers.

Your information will not be disseminated.

6. Data transfer

Personal data are stored on servers located in Monza (MB), within the European Union. In any case it is understood that the Data Controller, if necessary, will have the right to move the servers to another location, subject to communication. In this case, the Data Controller hereby ensures that the transfer of data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

7. Nature of the provision of data and consequences of refusal to reply

The provision of data for the purposes referred to in art. 2.A) is mandatory. In their absence, we can not guarantee the services of the art. 2.A).

The provision of data for the purposes referred to in art. 2.B) is optional. You can therefore decide not to give any data or to subsequently deny the possibility of processing data already provided: in this case, you will not be able to receive newsletters, commercial communications and advertising material concerning the Services offered by the Data Controller. However, you will continue to be entitled to the Services referred to in art. 2.A).

8. Rights of the interested party

In your capacity as an interested party, you have the rights set forth in art. 7 of the Privacy Code and art. 15 GDPR and precisely the rights of:

1) obtain confirmation of the existence or not of personal data concerning you,

even if not yet registered, and their communication in intelligible form;

2) obtain the indication: a) of the origin of personal data; b) of the purposes and methods of the processing; c) of the logic

applied in case of treatment carried out with the aid of electronic instruments; d) of the identification details of the owner, the managers and the designated representative pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, managers or agents;

3) obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where such fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right;

4) object, in whole or in part: a) for legitimate reasons to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail. It should be noted that the right of opposition of the interested party, set out in point b) above, for direct marketing purposes through automated methods extends to traditional ones and that in any case the possibility remains for the data subject to exercise the right to object even only partially. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.

Where applicable, it also has the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

9. ​Use of cookies

During a visit to our website, ‘cookies’ can be placed on the hard disk of your computer. A cookie is a tiny text file stored in the browser of your computer or mobile device when you visit a website. Cookies cannot be used to identify people, a cookie can only identify a machine. These cookies facilitate visiting the website and speed up your future visits. They are used, among other things, to personalize the website according to your preferences and ensure that when you visit our website you do not always receive the same information or need to re-enter your details. Our site contain cookies from third parties. You can adapt your browser’s settings in such a way that cookies are not accepted, that you receive a warning when a cookie is installed or that the cookies are subsequently removed from your hard drive. Keep in mind that certain graphic elements may not appear correctly, or that you will not be able to use certain applications without cookies. By using our website, you agree to our use of cookies.

10. How we secure your data

T.M.I. Srl Special Services takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure and unauthorized modification. The website of T.M.I. Srl Special Services uses a reliable SSL Certificate to ensure that your personal information does not fall into the wrong hands. If you have the impression that your data is not secure or that there are indications of misuse, or if you would like more information about the security of personal data collected by T.M.I. Srl Special Services , please contact us via fanelli@tmisrl.net.

​11. How to exercise rights

You can exercise your rights at any time by sending:

• a registered letter a.r. at T.M.I. Srl Special Services

• Operating office at Viale Ugo Foscolo, 82

• 20900 Monza (MB) – ITALY

• an e-mail to the address fanelli@tmisrl.net

12. Owner, manager and agents

The data controller is T.M.I. Srl Special Services with registered office in :

• Viale Ercole Marelli, 352

• 20099 Sesto San Giovani (MI)

and operational headquarters at

• Viale Ugo Foscolo, 82

• 20900 Monza (MB).

The updated list of data processors and data processors is kept at the registered office of the Data Controller.

25 May 2018 T.M.I. Srl Special Services