VIR Valvoindustria Ing. Rizzio SpA, in the person of the Data Controller, the Chairman, Mr Savino Rizzio,   pursuant to and with the effects of European Regulation 2016/679 (General Data Protection Regulation, hereinafter also only “GDPR”), would like to inform you, subsequent to the establishment of the current contractual relationships with you, that it is or will be in possession of specific individual and tax data described as personal by law, acquired directly or through third parties.With reference to the aforesaid data, we would inform you that:

1. the data is processed in accordance with contractual requirements and for the fulfilment of legal and contractual obligations resulting from it and to achieve effective management of business relations.
   The provision of data is compulsory for all that is required by legal and contractual obligations. Therefore, any refusal to provide it or as regards its subsequent processing may make it impossible for our company to proceed with the contractual relationship;
2. the data may be used to extract statistical information, in order to improve the delivery of our services, as well as for commercial and marketing purposes so as to be able to keep you up-to-date on new items provided by our services.
   Solely limited to the aforesaid purposes, the provision of data is optional; therefore, any refusal would not lead to any consequences for the data subject or in the execution of the current contractual relationships with you;
3. the data will be processed lawfully and thoroughly, and, in any case, in compliance with the aforementioned legislation through the use of technical and organisational tools, suitable for ensuring their security and confidentiality;
4. the processing is carried out by specialist personnel assigned with this task, using paper-based, IT or electronic tools, and any other type of support deemed technologically fit to ensure the rights and freedoms of the data subject;
5. the data will be stored in the archives and the relevant offices of VIR Valvoindustria Ing. Rizzio SpA;
6. without prejudice to the disclosures and diffusion carried out in compliance with legal obligations, the data may be disclosed in Italy to: banks, post offices or other mail delivery companies, credit institutions and debt collection companies, insurance companies, consultants, freelance professionals, IT maintenance companies, training providers, and in any case to all those third parties identified for the above-listed purposes, and for the execution of the current contractual relationship with you.
7. the data will be processed and stored for the entire duration of the contractual relationship, and also subsequently, in those cases in order to ensure fulfilment of all required legal obligations;
8. the data will be processed inside and, if necessary, outside the European Union. The Data Controller ensures, as of now, that any transfer of data outside the EU will be performed in accordance with the applicable legal provisions and with the requirements of the GDPR.

With regard to the data, you can exercise the rights provided for in Articles from 15 to 22 of EU Regulation 2016/679 (a copy of which is attached). In detail, the rights of the data subject concerning the processing of their personal data are as follows:

• Right of access to personal data;
• Right of rectification of personal data;
• Right to restriction of processing and erasure of personal data;
• Right of portability of personal data.
• Right to refer to a supervisory authority;

These rights may be exercised by sending a written communication to the Data Controller, VIR Valvoindustria Ing. Rizzio SpA, with registered office in Via Circonvallazione, no. 10-13018 Valduggia (VC) Italy – Tel. +39.0163.47891 – Fax +39.0163.47895 – email info@vironline.com.

Rights of the Data Subject (Articles 15 to 22 EU Regulation 2016/679)

Article 15 – Right of access by the data subject

1. The Data Subject has the right to obtain, from the Data Controller, confirmation as to whether or not personal data concerning him/her is being processed, and if so, to obtain access to this personal data and the following information:
   1. the purposes of the processing;
   2. the categories of personal data concerned;
   3. the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations;
   4. where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;
   5. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
   6. the right to lodge a complaint with a supervisory authority;
   7. where the personal data is not collected from the data subject, any available information as to their source;
   8. the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data is transferred to a third country or to an international organisation, the Data Subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The Data Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the Data Subject, the Data Controller may charge a reasonable fee based on administrative costs. Where the Data subject makes the request by electronic means, and unless otherwise requested by the Data Subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

Article 16 – Right to rectification

The Data Subject shall have the right to obtain from the Data Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17 – Right to erasure (‘right to be forgotten’)

1. The Data Subject has the right to obtain, from the Data Controller, the cancellation of personal data concerning him/her without undue delay and the Data Controller has the obligation to erase personal data without undue delay, where one of the following grounds applies:
   1. the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
   2. the Data Subject withdraws consent on which the processing is based according to point (a) of Article 6 (1) or point (a) of Article 9 (2), and where there is no other legal ground for the processing;
   3. the Data Subject objects to the processing pursuant to Article 21 (1) and there are no overriding legitimate grounds for the processing, or the Data Subject objects to the processing pursuant to Article 21 (2);
   4. the personal data has been unlawfully processed;
   5. the personal data has to be erased in compliance with a legal obligation in the Union or Member State law to which the Data Controller is subject;
   6. the personal data has been collected in relation to the offer of information society services referred to in Article 8 (1).
2. Where the Data Controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Data Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Data Controllers which are processing the personal data that the Data Subject has requested the erasure by such Data Controllers of any links to, or copy or replication of, that personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
   1. for exercising the right of freedom of expression and information;
   2. for compliance with a legal obligation which requires processing by Union or Member State law to which the Data Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
   3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3);
   4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
   5. for the establishment, exercise or defence of legal claims.

Article 18 – Right to restriction of processing

1. The Data Subject has the right to obtain, from the Data Controller restriction of processing where one of the following applies:
   1. the accuracy of the personal data is contested by the data subject, for a period enabling the Data Controller to verify the accuracy of the personal data;
   2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
   3. the Data Controller no longer needs the personal data for the purposes of the processing, but it is required by the Data Subject for the establishment, exercise or defence of legal claims;
   4. the data subject objected to processing pursuant to Article 21 (1), pending the verification whether the legitimate grounds of the Data Controller override those of the Data Subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the Data Subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A Data Subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the Data Controller before the restriction of processing is lifted.

Article 19 – Notification obligation regarding rectification or erasure of personal data or restriction of processing

The Data Controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort. The Data Controller shall inform the data subject about those recipients if the Data Subject requests it.

Article 20 – Right to data portability

1. The Data Subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a Data Controller, in a structured, commonly used and machine-readable format and have the right to transmit that data to another Data Controller without hindrance from the Data Controller to which the personal data has been provided, where:
   1. the processing is based on consent pursuant to point (a) of Article 6 (1) or point(a) of Article 9 (2) or on a contract pursuant to point (b) of Article 6 (1); and
   2. the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the Data Subject shall have the right to have the personal data transmitted directly from one Data Controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21 – Right to object

1. The Data Subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 (1), including profiling based on those provisions. The Data Controller shall no longer process the personal data unless the Data Controller demonstrates compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.
2. Where personal data is processed for direct marketing purposes, the Data Subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the Data Subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the Data Subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the Data Subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the Data Subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data is processed for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1), the Data Subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22 – Automated individual decision-making, including profiling

1. The Data Subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2. Paragraph 1 does not apply if the decision:
   1. is necessary for entering into, or performance of, a contract between the Data Subject and a Data Controller;
   2. is authorised by Union or Member State law to which the Data Controller is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests; or
   3. is based on the Data Subject’s explicit consent.
3. In the cases referred to in points (a) and (c) of paragraph 2, the Data Controller shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Data Controller, to express his or her point of view and to contest the decision.
4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9 (1), unless point (a) or (g) of Article 9 (2) applies and suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests are in place.