Privacy for Customers and Suppliers

Subject: Information notice for customers and suppliers issued by Modula S.P.A. pursuant to Art. 13 of Leg. Decree 196/2003

This new information notice, drawn up pursuant to Art. 13 of Leg. Decree 196/2003, is issued following the amendments of Law Decree No. 201 dated 6 December, which introduced major changes affecting some regulatory definitions.
Accordingly, this new information notice updates any previous versions issued so far.
Based on the above, we would like to underline that:
1) by virtue of the commercial relationship established with our Company and during its performance, our Company shall collect and process your personal data;
2) by way of clarity, below please find the definitions provided by Legislative Decree 196/2003:

Processing: any operations carried out using or without using electronic means and aimed at gathering, recording, organising, storing, processing, editing, selecting, extracting, comparing, using, interconnecting, blocking, transferring, disseminating, deleting and destructing data;

Personal data: any information concerning a private individual identified or identifiable - also indirectly - by means of references to any other information, there including a personal ID number.

Pursuant to Article 13 of Leg. Decree 196/2003 (Privacy Code) therefore,

We inform you:
that your personal data shall be collected and processed by the underwritten Company in compliance with the following:

a) purposes: your personal data shall be processed for proper compliance with accounting, fiscal, commercial and technical requirements and to perform all corporate operations connected with the existing relationship;
b) advertising purposes: your personal data may be used, subject to your prior and express consent, also to send advertising materials/communications by regular mail, e-mail, fax, short text messages and the like; after giving your consent, you shall be however entitled to object, at any time and without incurring expenses, to the processing of your personal data for this purpose;
c) processing methods: your data shall be processed using hard copy/paper as well as electronic/information/telematics means in full compliance with applicable legislation and according to principles of lawfulness and correctness, so as to protect your confidentiality;
d) optional provision: providing your data is optional and not obligatory;
e) consequences of your refusal: should you refuse to provide your personal data or fully object to their processing, it may be impossible for you to pursue any commercial relationship - or any other type of relationship - with our Company; should you refuse to consent to the use of your data for sending advertising materials/communications, your refusal shall have no consequences on our current or future relationships;
f) subjects or categories of subjects whom your personal data may be disclosed or communicated: your personal data may be communicated to third parties only for the purpose of meeting legislative or contractual obligations. Personal data shall not be disseminated, under any circumstance.
g) company managers and persons in charge of data processing: personal data shall be processed exclusively by the corporate managers and persons in charge of accounting and commercial departments;
h) rights of the data subject: the data subject is entitled to all the rights provided by Art. 7, which is fully attached to this information notice and constitutes an essential and integral part thereof;
i) data controller: the data controller is Modula S.p.A., with registered office in Fiorano Modenese (MO), Via Ghiarola Vecchia No. 73, represented by its pro tempore legal representative;
j) manager/s: the manager in charge of responding to the data subject is Mr. Juri Torreggiani, with office in Reggio Emilia, Via Piccard No. 16/G, tel. 0522/38.28.11, fax 0522/38.79.96. You may address any requests for clarifications or information to the aforementioned manager. The complete and updated list of the data managers is available on the company website and/or on the hard copy document filed at the company headquarters.

This information notice may be subject to additions, in oral or written form, to provide further information and indications aimed at responding to your queries concerning the Privacy legislation and to follow the evolution of related and applicable regulations.

FIORANO MODENESE (MO), 23/02/2016 The Data Controller
Modula S.p.A.

Article 7 of the Leg. Decree 196/2003 (Right to access personal data and other rights).
1. The data subject has the right to obtain confirmation on the existence or non-existence of his/her personal data, even if not yet recorded, and to receive communication thereof in an intelligible form.
2. The data subject has the right to obtain information about: a) the origin of personal data processed; b) the purpose and methods of data processing; c) the methods and criteria applied in the event of processing using electronic means; d) identification details of the Data Controller, Data Managers and of the Representative appointed as per article 5, paragraph 2; e) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of such information as appointed representative in the territory of the State, as persons in charge or persons appointed for this purpose.
3. The data subject has the right to obtain: a) the updating, the correction or, when of interest, the integration of data; b) the deletion, conversion to an anonymous form or blocking of the information processed in violation of the law, there including any data that do not need to be stored in relation to the purposes for which they were collected or processed at a later date; c) a statement certifying that the operations provided for under letters a) and b) have been made known, including their content, to the persons whom the data were communicated or divulged, except in the event that such certification is impossible or involves the use of means that are clearly non-proportional with respect to the protected right.
4. The data subject has the right to object, fully or partially: a) for legitimate reasons, to the processing of his/her personal data, even if such processing pertains to the scope of data collection; b) to the processing of his/her personal data for the purpose of sending advertising or direct sales materials or for conducting market research or sales communication surveys.

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