INFORMATION PURSUANT TO ART. 13 et seq. of the EU Regulation 679/2016

Framework360 owned by Marketing Studio Srl Unipersonale with its registered office at Corso Re Umberto, 8, Torino, TO, Italia, as the data controller for personal data pursuant to EU Regulation 679/2016 applicable from May 25, 2018 – General Data Protection Regulation (“GDPR”) (hereinafter conveniently referred to as GDPR or as “Applicable Legislation”), provides this information solely for the website https://www.framework360.it (“Site”) and it does not pertain to nor is it applicable to other websites that may be accessed via external links, serving as the Information provided in accordance with art. 13 et seq. of the Applicable Legislation.

PRINCIPLES

The processing of your personal data by Framework360 is carried out in accordance with the principles of accountability, lawfulness, fairness, transparency, purpose limitation and storage limitation, data minimization, accuracy, integrity and confidentiality, in compliance with the legislative provisions of the Applicable Legislation and the confidentiality obligations set forth therein.

DATA CONTROLLER OF PERSONAL DATA

Marketing Studio Srl Unipersonale with its registered office at Corso Re Umberto, 8, Torino, TO, Italia, licensee of the product Framework360 (hereinafter briefly referred to as "site"), for the purposes specified below, related to the provision of its services, and for sending information and contact requests through its website and for the operation of said website (hereafter defined as “Site”), processes your personal data acquired in the context of the execution of Services and/or during navigation on this website, as Data Controller.

The Data Controller determines the purposes and means of processing personal data.

PERSONAL DATA SUBJECT TO PROCESSING

By “Personal data” is meant any information concerning an identified or identifiable natural person (the data subject) with particular reference to an identifier such as name, an identification number, location data, an online identifier or one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

The personal data collected on this site are:

Navigation Data

The computer systems of the Site collect some of your personal data whose transmission is implicit in the use of Internet communication protocols. These are not information collected to be associated with you as an interested party, but which by their very nature could, through processing and association with data held by third parties, allow you to be identified.

Among these are the IP addresses or domain names of the devices used to connect to the Site, the URI notation addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server's response (successful, error, etc.) and other parameters related to the operating system and computing environment.

These data are used in order to obtain anonymous statistical information about the use of the Site and to check its correct functioning; to allow - given the architecture of the systems used - the correct delivery of various functionalities required, for security reasons and for determining responsibility in case of hypothetical computer crimes against the Site or third parties.

Voluntarily Provided Data

Through the Website, as a data subject, you may voluntarily provide personal data such as your name and email address to contact Marketing Studio Srl Unipersonale through the forms on the Website.

Marketing Studio Srl Unipersonale will process this data in accordance with applicable legislation, assuming that it refers to you as the data subject who has provided them or who has expressly authorized third parties to provide them on your behalf and/or for your account based on an adequate legal basis that legitimizes the processing of the data in question.

In such cases, you as the data subject, and the third party who has provided the data on your behalf/for your account, assume all legal obligations and responsibilities, indemnifying against any dispute, claim, request for compensation for damage from processing, etc., that might be received by Marketing Studio Srl Unipersonale from other subjects whose personal data have been processed through the use of the Website in violation of applicable regulations.

Cookies and Similar Technologies

Framework360 collects your personal data through cookies. Cookies are small-sized data files that may be sent by a website to the user's terminal (usually to the browser), where they are stored to be transmitted back to the site on the next visit.

A cookie cannot retrieve any other data from the hard disk of the subject's terminal, nor transmit computer viruses or acquire email addresses. Cookies can be used both by the owner of the site and by third parties and can be easily disabled by the user.

Marketing Studio Srl Unipersonale needs to use certain cookies, including those from third parties, through this Site in order to regularly provide its Services. Therefore, if you, as the data subject, decide to disable the use of cookies for purely technical reasons, Framework360 might be unable to provide you with certain Services or to provide them in the requested manner.

More information on the use of cookies and similar technologies is available in the dedicated section accessible from the footer of the website.

PURPOSE OF DATA PROCESSING AND LEGAL BASIS

Your personal data, provided by you through the Site, will be processed by Marketing Studio Srl Unipersonale for the following purposes:

a. Registration on the Framework360 website, as well as purposes aimed at carrying out everything necessary for the provision of Services offered, which takes place mainly with automated and computerized methods, intended pre-contractual actions, and contract conclusions. In such cases, for some services Framework360 will provide you with additional and specific information on the processing of personal data, in addition to this privacy notice.

The legal basis for processing your personal data for the above-described purposes (point a) is the provision of a service itself under contract or responding to a request and does not require consent according to applicable regulations.

b. Purposes for research/statistical analysis on aggregated or anonymous data, therefore not allowing your identification, solely aimed at measuring the functioning of the Site, assessing its traffic, usage and the interest it generates.

The aforementioned purpose (point b) does not involve the processing of personal data.

c. Purposes related to the fulfillment of legal obligations, regulations, community norms, orders and prescriptions from competent authorities to which Marketing Studio Srl Unipersonale is subject.

The processing related to the above-mentioned purpose (point c) does not require consent as it represents a legitimate treatment, constituting compliance with legal obligations, also connected to the provision of Services.

d. The pursuit of our legitimate interest as Data Controller, such as managing complaints and disputes, recovering debts, preventing fraud and illegal activities.

The legal basis in this case (point d) is given by the legitimate interest of Marketing Studio Srl Unipersonale also to exercise and/or defend, where necessary, its rights in appropriate forums.

e. Carry out commercial communication and promotional activities to the email address you provided us, as an interested party, related to services and activities of Framework360.

The provision of consent for the processing of your personal data for the purposes listed above (point e) is optional, but failure to provide it could make it impossible to respond to a request or fulfill an obligation to which Framework360 is subject or has been requested.

RECIPIENTS

Your personal data may be shared and communicated, for the purposes specified in point 3, within Italy or abroad, to third parties such as:

Subjects necessary for the provision of services offered by the Site, including tax and legal consultants of Marketing Studio Srl Unipersonale in relation to their obligations, companies and technical consultants responsible for the management and maintenance of information systems, software and databases, financial service companies, administrative, storage, auditing and balance sheet certification firms, always in strict connection and within the limits of performing their respective tasks and activities.

Individuals who are duly authorized by Marketing Studio Srl Unipersonale to process personal data and who have committed to confidentiality or have an appropriate legal obligation of confidentiality (e.g., employees and collaborators of Marketing Studio Srl Unipersonale).

Judicial authorities in the exercise of their functions when required by applicable Legislation.

TRANSFERS

Some of your personal data may need to be transferred to Recipients outside the European Union, in compliance with applicable legislation, including:

Amazon Web Services (AWS)

Framework360 uses Amazon Web Services (AWS) as a hosting service. The service is provided by Amazon Web Services Inc.

Privacy policy: https://aws.amazon.com/privacy/

OpenAI

Framework360 utilizes ChatGPT as an artificial intelligence service for generating texts and translations. The service is provided by OpenAI Inc.

Privacy policy: https://openai.com/policies/privacy-policy/

DATA RETENTION

Marketing Studio Srl Unipersonale will process your personal data for the time strictly necessary to achieve the purposes detailed and indicated in point 3, for a limited period of time therefore varying according to the type of activity that involves the processing of personal data.

Once this period has expired, your data will be permanently deleted or otherwise made irreversibly anonymous.

The data collected to conclude and execute contracts will be kept for ten years from the date of contract conclusion.

Data related to billing will be stored for ten years from the billing date.

Your data as a registered User, entered by yourself at the time of registration on the site, will be kept until you request deletion of your profile.

The data communicated by you to Marketing Studio Srl Unipersonale using the forms on the Site will be stored until you request their deletion.

The received curriculum vitae and the data contained therein will be stored for twelve months from receipt;

The data provided to us for commercial communications and/or sending newsletters will be kept until the user requests to stop the activity and/or requests to unsubscribe from the service or until you ask us to cease sending it.

THE DATA SUBJECT'S RIGHTS

Within the limits of applicable legislation, as a data subject of the processing of your personal data through Framework360's website, you may exercise the following rights at any time:

- The right to obtain confirmation as to whether or not personal data concerning you exists, and in such cases, to access and obtain a copy of it. Unless otherwise required by applicable law, Marketing Studio Srl Unipersonale may refuse the possibility of obtaining such a copy if this could harm the rights and freedoms of others;

- The right to obtain the indication: of the source of personal data; of the purposes and methods of processing personal data; of the logic applied in case of processing carried out with the aid of electronic tools; of the identity details of the controller and, if appointed, of the processors and the privacy representative; of the entities or categories of entities to whom personal data may be communicated;

- The right to obtain: updating, rectification, integration of data, erasure, anonymization or blocking of data processed in violation of law, including those not required to be kept for the purposes for which the data were collected or subsequently processed, in cases provided by applicable law, restriction of processing of personal data in cases provided by law;

- The right to object, in whole or in part, on legitimate grounds to the processing of personal data even though they are relevant to the purpose of collection, to the processing of personal data for purposes of sending advertising materials or direct selling or for carrying out market research or commercial communication;

- The right to withdraw consent at any time, if it constitutes the legal basis for processing, without affecting the lawfulness of the processing based on consent given before withdrawal, to lodge a complaint with the supervisory authority, in cases provided by applicable law, to receive data in a structured, commonly used and machine-readable format and to transmit such data to another data controller without hindrance;

- The right to obtain confirmation that each of the recipients to whom personal data have been transmitted has been notified of any rectifications or erasures or restrictions of processing, except where such compliance is impossible or involves a disproportionate effort compared to the protected right. In any case, upon express request as a data subject, you may also obtain details of said recipients.

The aforementioned requests should be addressed via email to the addresses:

Email: info@marketingstudio.it

CHANGES

This Privacy Policy has been effective since May 25, 2018. Marketing Studio Srl Unipersonale reserves the right to modify or simply update its content, in whole or in part, also due to changes in applicable legislation. Marketing Studio Srl Unipersonale will inform of such changes as soon as they are introduced and they will be binding as soon as published on the Site. In any case, any modifications made over time to this statement will be duly published in a specific section of this Site.