PRIVACY POLICY

AD Service s.r.l. Privacy Notice

1 WHO ARE WE?
This website www.adservice-srl.com (the “Website”) is owned and operated by AD Service s.r.l., registered in Italy under company number SP-123758 (called in this notice “we”, “our” or “us”).

2 PURPOSE OF THIS NOTICE

This privacy notice tells you about the information we collect about you when you visit our Website or otherwise provide us with information. It also tells you how you can exercise Your Rights (including the right to object to some of the data handling we carry out).

3 WHAT PERSONAL DATA DO WE COLLECT?

Site traffic data and information about your computer How do we use this data?
When you browse our Website, we use cookies to collect: 3.1 Information about your use of our Website – we collect standard internet log information and details of visitor behaviour patterns. ◦ We use this information to record visitor numbers, their use of different areas of the Website and any useful features or links. We do not use this information in any way that would identify you personally. ◦ We use a third party, Google Analytics, to collect this information but it is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

3.2 Information about your computer; this includes your IP address, operating system and browser type.
◦ We use this information to help maintain the security of our Website and to identify trends so that we can improve its performance. ◦ We also use this information to customise the Website according to your interests and to ensure the Website’s content is presented as effectively as possible for you. ◦ We do not use this information in any way that would identify you personally. Data we collect using non-essential cookies is used on the basis of your consent. Any other information that we collect about your use of our Website is used on the basis that this is necessary for the purpose of our legitimate interests in maintaining and managing our Website and ensuring its security. For more information about how we use cookies on our Website, see our Cookies Policy. How long do we keep this information for? We will only keep information about your visit to our Website for as long as is necessary for the purposes we’ve mentioned. Typically we delete user browsing information every 13 months. See our Cookies Policy for further information. Who do we share this information with? We share information about visitors to our Website with service providers who help us administer and manage the Website. Where do we transfer this information to? Information we collect about your use of our Website is held by our service provider(s) on secure servers located both inside and outside of Italy. We protect your privacy by using service providers located within the European Economic Area (EEA) whose data protection laws are deemed to provide adequate protection. We also protect your privacy by entering into approved contractual clauses with service providers operating outside Italy; such as Google (for the use of Google Analytics).

  3.3 INFORMATION YOU SEND US

How do we use this data? You do not have to supply us directly with any information when you use our Website. If you choose to use our ‘contact us’ feature or otherwise get in touch with us, we will use the information you send us for the purpose of responding to your enquiry. When we use your personal data for this purpose, we do so for our legitimate business interest in communicating with you in accordance with your wishes and expectations. We will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject. For more information about how we use information you send us for recruitment purposes see our section on recruitment. How long do we keep this information for? We will only keep your information for as long as is necessary in order to manage your query. We usually keep records of routine queries for 6 months but in some cases (for example where the query relates to a contract between us, or where we need to obtain legal advice in order to respond to a complaint) we may need to retain a record of our communications for up to 6 years. Who do we share this information with? We will share your data with our service providers and our professional advisers if this is necessary in order to resolve a query or complaint. Otherwise we will not share your information with any third party unless: • we have your permission; • we are required to do so by law; • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or • this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners). Where do we transfer this information to? Information you send us via our Website is stored within, and not transferred outside of, the United Kingdom.

  Recruitment
How do we use this data? If you use our Website to send us your CV or other information in support of an enquiry about recruitment, we will use your information to respond to your query and consider your suitability for any available position. When we use your personal data in this way, we do so for the purpose of our legitimate interests in managing our recruitment. Where necessary, we will also use this data for the purpose of our legitimate interests in accessing appropriate professional advice and in order to ensure we comply with legal obligations to which our business is subject. How long do we keep this information for? We usually retain information supplied by job applicants for no longer than 12 months following a relevant recruitment decision. If your application is unsuccessful, we may decide to retain your details for longer if we think you may be suitable for another position that may arise within the ABF group in the future. If we do this we will let you know about this so that you can opt out if you want to. Who do we share this information with? Where necessary so that we can manage our recruitment process, we will share your information with our service providers and professional advisers. Otherwise we will not share your information with any third party unless: • we have your permission (for example in order to share your details with another group company for their recruitment purposes); • we are required to do so by law; • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or • this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners). Where do we transfer this information to? Any information you send us via our Website in support of an employment application is stored within, and not transferred outside Italy. If you require further information about these safeguards, please contact us using the details below.   Information about your on-line transactions This website does not currently make use of on-line transactions.   Information you give us when you enter a competition, prize draw, or promotion This website does not currently capture data for competitions, prize draws or promotions.   Direct Marketing How do we use this data? We will use contact details you give us to deliver promotional information that you request or that we feel may interest you. We will also use this information to gain insights into the needs and interests of our customer base and to evaluate the effectiveness of our marketing activities. Unless we have obtained your contact details in the course of an online sale or negotiation for a sale and you have indicated you are happy to receive our marketing communications, we will only contact you for marketing purposes by email and/or SMS if you have consented to this. When we use your data for our direct marketing purposes we do so for our legitimate interests in promoting our business and the goods/services we offer. How long do we keep this information for? We keep information for direct marketing purposes for as long as you continue to be interested in receiving our marketing communications. We use tracking technology to help us monitor the effectiveness of our e-marketing and delete contacts from our e-marketing database after 2 years of recipient inactivity. You can tell us to stop using your details for marketing purposes by contacting us and can opt out of email marketing at any time by using our unsubscribe feature. Who do we share this information with? Where necessary we share this data with our suppliers and service providers. Otherwise we will not share your information with any third party unless: • we have your permission; • we are required to do so by law; • this is necessary so that we can enforce our terms of use, rights or property or the rights or property of any third party; or • this is necessary in connection with the sale of our business or its assets (in which case your details will be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners). Where do we transfer this information to? Information we hold for direct marketing purposes is stored within, and not transferred outside of, the United Kingdom.

4 YOUR RIGHTS

You can ask us at any time to provide you with a copy of your personal data. In relation to personal data you have supplied to us, and which is held by us for the purpose of entering into a contract between us or on the basis of your consent, you are entitled to ask us for a copy of this information in a structured, commonly used and machine readable format so that you can reuse it or share it with other organisations. If you think the personal data we hold about you is inaccurate or incomplete, you can ask us to correct it or complete it. In some circumstances you also have the right to object to our processing of your data and can ask us to restrict our use of your data and to delete it. There are some exceptions to these rights, however. For example, it will not be possible for us to delete your data if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your data may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. If you wish to exercise any of these rights you should contact us.

Contacting us and your rights of complaint

Questions, comments or requests concerning this privacy notice are welcomed and should be addressed to: Dante Passeri - info@adservice-srl.com

If you have a concern about the way we handle your personal data you have the right to complain to the Information Commissioner (ICO). You can find details of how to do this at www.garanteprivacy.it