Gioielleria Picchiotti based in Corso Giuseppe Garibaldi, 137 is the Data Controller of the personal data collected on this site pursuant to and for the purposes of EU Regulation 679/2016 (hereinafter GDPR) This Privacy Notice is updated on 25/05/2018

PERSONAL DATA AND NAVIGATION DATA

Gioielleria Picchiotti undertakes to protect your personal data and asks you to take a few minutes to read how we collect, use, disclose and transfer the personal data you provide us through our website, https://www.picchiotti.it/ , or interacting with Gioielleria Picchiotti through social media platforms (jointly the "Platforms"), or transmitted to Gioielleria Picchiotti by third-party companies that provide technological and / or IT, logistical and commercial services. Furthermore, this policy explains how we collect data through the use of cookies and related technologies when you use our Platforms.

In addition to what is described above, this information lists your rights, in accordance with art. 13 of the GDPR.

1. CATEGORIES OF PERSONAL DATA PROCESSED BY THE HOLDER OF THE TREATMENT

Gioielleria Picchiotti (hereinafter Picchiotti), as Data Controller, must process some personal data necessary for the provision of the services provided by its website.

These data may be provided implicitly by the tools you use to access and use the services or they may be provided explicitly by you.

Picchiotti reserves the right to process the following categories of users' personal data in accordance with the provisions of EU Regulation 679/2016 (GDPR):

• technical navigation data relating to the IP address, the identification codes of the devices used by the user for the use of the site or services, the characteristics of the browser and access times;

• navigation data aimed at profiling provided indirectly through the use of the service itself and obtained and analyzed with the user's consent;

• common identification data provided by the user: to access certain areas of our Platform, each user must register. During the registration process, you will be asked to provide your personal data (including your name and email address). By entering your details in the required fields, you will allow Picchiotti to provide you with the indicated services; • information you provide us if you decide to interact with Picchiotti through a social media platform or other third party services;

• information about visitors to our Platform collected automatically ("Cookies"), as described in the "Cookie Policy" section

For Picchiotti it is essential to guarantee the protection of the safety and privacy of children. It is not in our interest to collect and we do not knowingly use personal data of anyone under the age of sixteen (16) or any age limit established by the legislation of their country of residence. By registering on the Site, you confirm that you have reached the age of majority in your country of residence.

2. PURPOSE AND LEGAL BASES OF THE PROCESSING

The data and cookies you receive will be processed by Picchiotti exclusively with methods and procedures necessary to provide you with the requested services and for the additional purposes for which you have given your consent.

In particular, all the information we collect will be used to:

• To understand how our Platform is used and consequently to be able to continuously improve our Platform and services and other offerings.

In the event that you have consented to a particular use of your data, we process it on the basis of your consent. You can revoke this consent at any time by contacting us (see the section below "7 - RIGHTS OF THE INTERESTED PARTY"). We also process your information to the extent that this is necessary for the performance of a contract with you or to the extent that it is necessary for our legitimate interests to operate, protect and improve our business.

Communications for market surveys or commercial information on products and promotional initiatives can be made by post mailing, e-mail, telemarketing, sms, mms. We inform you that some activities could be implemented through suppliers, specifically appointed as Data Processors, including residents outside the European Union.

3. DISSEMINATION, COMMUNICATION AND SUBJECTS ACCESSING THE DATA

Your personal data will not be disclosed, but may be disclosed where necessary for the provision of the service to third parties (such as third party technical service providers, postal couriers, hosting providers, IT companies) appointed, if necessary, as Data Processors by of Picchiotti for technical or organizational tasks instrumental to the provision of services.

Access to data is also allowed to categories of Picchiotti's employees involved in the data processing organization (administrative, commercial, marketing, customer service, system administrators).

The updated list of Managers can always be requested from the Data Controller.

The right of communication to third parties remains unaffected if you have given specific and optional consent.

In addition, we may share your personal data with third parties in connection with the potential or actual sale or restructuring of our business or any of our assets, in which case the personal data of our clients in our possession may be among the transferred assets.

We will respond to requests to disclose personal data when required by law or when we believe disclosure is necessary to protect our rights and / or comply with a judicial proceeding, court order, lawmaker request or any other legal procedure to which we are subjected. 4. TRANSFER OF DATA ABROAD

Your personal data will be processed by Picchiotti within the territory of the European Union.

If for technical and / or operational reasons it becomes necessary to make use of subjects located outside the European Union, or it is necessary to transfer some of the data collected to technical systems and services managed in the cloud and located outside the area of the European Union, the processing will be regulated in accordance with the provisions of Chapter V of the Regulation and authorized on the basis of specific decisions of the European Union. All the necessary precautions will therefore be taken in order to guarantee the most complete protection of personal data, basing this transfer: a) on adequacy decisions of the recipient third countries expressed by the European Commission; b) on adequate guarantees expressed by the third party recipient pursuant to art. 46 of the Regulation; c) on the adoption of binding corporate rules

5. DURATION OF TREATMENT AND STORAGE OF PERSONAL DATA

According to the provisions of Art. 5.1 e) of the GDPR, Picchiotti will process the data you provide for the period necessary to pursue the purposes for which they were collected. Generally, we keep your personal data for one year from the end of our relationship or from the last contact, unless otherwise prescribed by local legislation. In some cases it may be necessary for us to keep your personal data for a longer period, for example if we are requested to do so for legal, tax and financial reasons. 6. SECURITY

For Picchiotti it is very important to guarantee the maximum possible security of all personal data associated with our users. To this end, we have implemented security measures to protect personal data from accidental or unlawful destruction, accidental loss, modification, disclosure or unauthorized access. We would like to advise you, for the protection of your personal data beyond the limits of the control exercised by us, to protect the device (s) with which you access our site or our Platforms (for example, with an updated antivirus system ) and to verify that your Internet provider takes appropriate measures for the security of data transmission over the network (for example, firewalls and spam filters).

While we take reasonable protection measures, we cannot guarantee that the personal data you disclose will be 100% secure, or that no data breach will occur.

By using this Site, you accept the security implications inherent in online transactions and you will not accuse Picchiotti of any data breach that is not due to negligence.

7. RIGHTS OF THE INTERESTED PARTY

Picchiotti guarantees you to be able to exercise the rights provided by the GDPR at any time. Specifically, you can exercise the following rights:

- Right of access, rectification and cancellation: you have the right to access and receive a copy of all your personal data in our possession, to request the correction of any inaccuracy in the data concerning you and to request the cancellation of your personal data in certain circumstances. You have the opportunity to independently consult and modify your personal data on the site or you can contact us by email at [email protected]. You can delete your personal data held by Picchiotti if one of the reasons provided for by the GDPR exists.

- Right to limit the processing to only some personal data, if one of the reasons provided for by the GDPR exists. If personal data are subject to limitations in this sense, we will proceed with the processing exclusively with your consent or for the establishment, execution or defense of a legal action.

- Right to withdraw consent: where applicable, you have the right to withdraw your consent to data processing at any time. If you no longer wish to receive electronic commercial communications via you can send an email to [email protected] or by clicking on the "unsubscribe" link contained in all marketing emails sent by Picchiotti - Right to object to processing, justified on the basis of legitimate interests: where the processing of personal data is based on legitimate interests, you have the right to object to such processing. In the event of an objection, it is our duty to stop processing unless we can demonstrate the existence of overriding legitimate interests overriding your interests, rights and freedoms or we do not need to process the data for the establishment, enforcement or defense of a judicial action. In cases where we rely on legitimate interests as a justification for processing, we believe we can demonstrate those overriding legitimate interests, but we will consider each case separately.

- Right to portability: you can request and receive all your personal data processed by the Data Controller, in a structured format, commonly used and readable by an automatic device, or request transmission to another Data Controller, if technically feasible.

- Right to object in whole or in part to the processing of data in automatic or semi-automatic mode for profiling purposes.

The exercise of these rights can be exercised by communicating to the Data Protection Officer (DPO) whose contact details are indicated in the appropriate section of this statement.

Furthermore, you always have the right, if you believe that the processing of your personal data violates the legislation in force, to lodge a complaint with the Authority for the Protection of Personal Data, which can be contacted at [email protected] or via the http site. : //www.gpdp.it.

8. RESPONSIBLE FOR DATA PROTECTION

Picchiotti has appointed, pursuant to art. 37 of the GDPR a Data Protection Officer (RPD) and to contact for all requests regarding the privacy of its users and customers.

For the exercise of the rights guaranteed to you you can - write to the following address: RPD Office c / o Corso Giuseppe Garibaldi, 137

- call the following number +39 0131 953081 and ask for the Data Protection Officer

- send an email to the address: [email protected]

9. LATEST UPDATE

This Privacy Notice is updated on 25/05/2018. We may occasionally make changes to this Policy, for example in order to comply with new requirements of the applicable legislation or as a result of adjustments and / or updates of a technical nature. You will find the updated Policy on the site. In the event of substantial changes to this Policy and which require your consent, Picchiotti will contact you to request your consent, if required by current legislation. You can still stay updated by visiting this page periodically.

All data will be processed according to the GDPR UE 679/16 Regulation. Information available at the following links:

Policy: candidates to be considered for the establishment of an employment relationship

Policy: clients

Policy: consultants and freelancers, also associated ones

Policy: suppliers

Policy: Interested in video surveillance recordings

Policy: Web surfers

Policy: employees and para-subordinate staff

Policy: potential clients

Policy: members associates and members