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Privacy and Cookies Policy — May 2018 Directive

Introduction

EVOFORCE SRL (hereinafter “EVOFORCE”) is committed to protecting the user’s privacy.

This privacy notice describes the procedure adopted to protect personal data when the user visits EVOFORCE’s websites or uses an online application that contains a link to this notice (collectively, the “Sites”). This notice also covers the information that EVOFORCE receives when the user contacts it (for example, when the user submits a comment or a support request for an EVOFORCE product or service).

This document describes the personal data collected, the purposes for which it is used and the user’s options regarding its use by EVOFORCE. This document also illustrates the procedure adopted by EVOFORCE to protect the user’s personal data and how the user can review and modify their personal data. By accessing the Sites or providing personal data when contacting EVOFORCE, the user consents to the collection of information and to the operating practices described in this privacy notice. For the purposes of this notice, “personal data” means information that identifies a person, such as name, postal address, email address or telephone number. When personal data is associated with other information — for example, choices regarding newsletters sent by email or customer preferences regarding products — such additional information also becomes personal data.

Information collected by EVOFORCE

EVOFORCE receives data directly from the user. As a general principle, the user can visit EVOFORCE’s Sites without entering any personal data.

On certain pages, however, EVOFORCE may request some personal data from the user, in order to provide access to information protected by login, or to send technical and/or commercial updates (newsletters). The user may also provide some personal data when contacting EVOFORCE (for example, when sending a comment, a query or a support request).

The personal data collected by EVOFORCE may include the following information:

• contact information, such as the user’s name, title, company/organization name, email address, telephone and fax numbers, and physical address;

• information about the user’s company and job role;

• user preferences relating to email marketing;

• information useful for personalizing and facilitating the user’s use of the Sites, including technical and access data;

• requests regarding EVOFORCE products and services;

• information that helps EVOFORCE identify the products and services most suited to the user’s needs;

• data relating to event registration.

The user is not required to provide such data, but if it is not provided, EVOFORCE will not be able to offer the requested service.

EVOFORCE collects data relating to the user’s visits to its Sites, including the type of pages viewed, the number of bytes transferred, the links selected, the materials accessed by the user and other operations carried out on EVOFORCE’s Sites.

EVOFORCE may associate this information with the user’s personal data and use the combined information in accordance with this privacy notice. EVOFORCE also collects certain standard data sent by the user’s browser to all visited websites, such as the user’s Internet Protocol (IP) address, the type, features and language of the browser, the operating system, the date and time of access to the Site and the website from which the user connected to one of the Sites. EVOFORCE does not associate this standard data with any other personal data.

Use of information by EVOFORCE

EVOFORCE uses the user’s personal data to provide services or perform transactions requested by the user, including, without limitation, providing information about products or services, responding to support requests and simplifying the use of EVOFORCE’s Sites. The data collected from EVOFORCE’s Sites may be associated with information that EVOFORCE collects or acquires by other means, in order to offer the user a more consistent experience during their interactions with EVOFORCE. Such interactions include, without limitation, those aimed at understanding the user and how they use and interact with EVOFORCE’s products and services; interactions useful for the development and management of products and services, including support; and those aimed at providing the user with information about EVOFORCE products and services that may be of interest.

EVOFORCE may use the user’s personal data to perform business analysis or for other purposes aimed at improving the quality of EVOFORCE’s activities, its Sites and its products or services (including new products or services), or to simplify the use of the Sites by ensuring that the user does not have to enter the same data multiple times, or by personalizing the Sites based on the user’s specific preferences or interests.

EVOFORCE may use the user’s personal data to update them on available products or services in which the user may be interested and to send surveys regarding the user’s use of EVOFORCE products and services. The user can refuse promotional communications from EVOFORCE by contacting EVOFORCE through the email address shown on the website. In addition, all promotional email communications sent by EVOFORCE contain an unsubscribe link, which allows the user to block the future sending of such communications. If the user decides to unsubscribe, EVOFORCE will remove their name from the relevant list within 10 working days.

The user may provide EVOFORCE with personal information — for example through a curriculum vitae — in connection with a job application or recruitment request. EVOFORCE may use such information internally for the purpose of evaluating the recruitment request. If the request is accepted, EVOFORCE will retain the information for future use, for a limited period of time, unless the user asks EVOFORCE not to retain it.

In addition to the uses listed above, EVOFORCE may use the data collected to identify and prevent fraud, infringements of intellectual property rights, of EVOFORCE’s Terms and Conditions and of laws, or other improper uses of the Sites, and to react to them.

Use of cookies and Web beacons

Cookies are text files containing a small amount of information that are downloaded onto the user’s hard disk or browser memory when the user visits a website. Cookies are useful for organizing content and designing the layout of EVOFORCE’s Sites, allowing EVOFORCE to recognize computers or other devices that have connected to its Sites in the past. Cookies perform many different functions; for example, they allow EVOFORCE’s websites to remember the user’s preferences and help EVOFORCE improve the performance of its Sites and the user’s experience while using them.

EVOFORCE’s Sites may also contain virtual images, known as beacons or sometimes single-pixel gifs, which allow EVOFORCE to keep track of users who have visited specific pages. EVOFORCE may include Web beacons in newsletters or promotional email messages to determine whether the user has opened the messages and interacted with them.

Categories of cookies

The types of cookies used by EVOFORCE’s Sites can fall into one of the following four categories: strictly necessary, performance, functionality and profile, and advertising.

1. 1. Strictly necessary cookies

These cookies are essential because they allow the user to browse EVOFORCE’s Sites and use their functionality, especially in relation to searching for information about the products marketed by EVOFORCE. Without these cookies, the services requested by the user cannot be provided. These cookies do not collect user information that could be used for marketing purposes or to remember the websites visited by the user. An example of strictly necessary cookies are “shopping basket cookies”, which are used to remember the products that the user wishes to purchase when adding items to the cart or proceeding to checkout.

2. 2. Performance cookies

These cookies collect information about how the user uses EVOFORCE’s Sites, for example which pages are visited most often and any error messages received on certain pages. These cookies only collect anonymous data that is used to improve the operation of EVOFORCE’s Sites. They are not used to send the user online advertising. Without these cookies, EVOFORCE cannot understand the performance of its Sites and make significant improvements that could enrich the user’s browsing experience. Some examples of performance cookies used by the Sites are the Google Analytics and Adobe Analytics tools (illustrated below).

3. 3. Functionality and profile cookies

These cookies allow EVOFORCE’s Sites to store information provided by the user, such as language preferences, and to save technical data useful for the user’s interaction with such Sites. For example, they store the user’s ID and certain elements of their profile. They also ensure that the user’s experience while using the Sites and EVOFORCE’s marketing operations are interesting for the user. These cookies may also be used to provide services requested by the user, such as displaying a video or posting a comment on a blog. The information collected by these cookies is anonymous and cannot track the user’s browsing activity on other websites. Without these cookies, a website would not be able to remember the user’s previous choices, nor personalize their browsing experience. For example, to store the user’s language preferences, a cookie is used that allows EVOFORCE to display product search results in the correct language; in addition, EVOFORCE uses a cookie that stores the user’s choices regarding the appearance of the cookie information banner displayed on EVOFORCE’s Sites. This cookie helps EVOFORCE remember the user’s choice during subsequent visits to the Site on which it was made and to any other EVOFORCE Site belonging to the same domain or group of domains.

4. 4. Advertising cookies

These cookies may be used to deliver advertisements of greater interest to the user. They may also be used to limit the number of times an advertisement is displayed and to help determine the effectiveness of an advertising campaign. Although these cookies can keep track of the user’s visits to other websites, they are usually not able to identify the user. Without these cookies, the online advertisements displayed may be of little interest to the user.

The user has the option to accept or refuse cookies. The Internet browser automatically accepts cookies, but the user can generally modify their browser settings to refuse cookies or to receive a warning when a cookie is registered on their computer. By choosing to refuse cookies, the user may not be able to fully experience the functionality of EVOFORCE’s Sites or other visited websites.

Use of Web Analytics services by EVOFORCE

EVOFORCE uses industry-standard Web Analytics services to keep track of visits to its Sites. These services are provided by Google Analytics and Adobe Analytics. The information generated by the cookie regarding the user’s use of EVOFORCE’s Sites (including the user’s IP address) will be transmitted to Google and Adobe, who will store it on servers located in the United States. Google and Adobe will use this data to examine the user’s use of EVOFORCE’s Sites, compile reports on website activity for the operators of such Sites, and provide other services related to such activities and to internet use. Google and Adobe may also transfer such information to third parties where there is a legal obligation to do so or where these third parties process the information on their behalf. Google and Adobe will not associate the user’s IP address with any other data they hold.

The user may opt out of Web Analytics services by visiting the following links and following the relevant procedures:

https://tools.google.com/dlpage/gaoptout (Google Analytics opt-out)

https://www.adobe.com/it/privacy/marketing-cloud.html (Adobe Analytics opt-out)

Some Web browsers can transmit “do-not-track” signals to the sites with which the user communicates.

Due to the different ways in which Web browsers integrate and activate this functionality, it is not always clear whether users want such signals to be transmitted, or whether they are even aware of their being sent. There is currently disagreement, even among members of the main organizations defining Internet standards, about the behaviors that websites should adopt when receiving these signals.

At present, EVOFORCE takes no action in response to these signals. If and when a definitive standard is established and accepted, EVOFORCE will reassess how to respond to these signals.

Disclosure of the user’s personal data

Without prejudice to what is illustrated above, the user’s personal data, collected by EVOFORCE through its Sites or provided by the user when contacting EVOFORCE, will not be shared outside EVOFORCE without the user’s authorization.

EVOFORCE enters into contracts with other companies to provide services on its behalf, such as website hosting, transmission of information, conducting surveys, processing transactions, analyzing EVOFORCE’s Sites and carrying out activities and other analyses aimed at improving the quality of EVOFORCE’s activities, its Sites and its products or services. EVOFORCE provides these companies only with the user’s personal data that they need to provide such services effectively. These companies and their employees are not authorized to use the personal data they receive from EVOFORCE for different purposes.

In order to respond to the user’s requests, EVOFORCE may share the user’s personal data with companies that distribute EVOFORCE’s products or with EVOFORCE’s suppliers. In these cases, EVOFORCE provides these companies only with the user’s personal data that they need to respond to such requests; these companies and their employees are not authorized to use such personal data for different purposes. In some cases, EVOFORCE may ask for the user’s authorization to share their data with certain distributors for marketing activities that do not consist of responding to a user’s request. EVOFORCE will not, however, share the user’s information for such purposes unless it has received the user’s explicit consent.

In connection with certain transactions, EVOFORCE may disclose some or all of the user’s personal data to financial institutions, government authorities and shipping or postal companies involved in the execution of the transaction.

EVOFORCE may disclose personal data when there is a legal obligation or authorization to do so, or where it believes in good faith that such action is necessary to comply with legal requirements or with the needs of a legal proceeding to which EVOFORCE is a party, to protect and defend its rights or property or, in urgent cases, to protect the personal safety of any person.

Security

EVOFORCE is committed to safeguarding the security of the user’s personal data. To this end, it uses various technologies and security procedures that help protect the user’s personal data from disclosure or unauthorized access and use. For example, EVOFORCE stores the personal data provided by the user on computer networks with limited access, located in facilities whose access is also restricted. With regard to the Sites that the user accesses, it is the user’s responsibility to ensure the security of their password and not to share it with others. When the user navigates within a Site to which they have logged in, or moves away from a Site and connects to another Site that uses the same access mechanism, EVOFORCE verifies the user’s identity by means of an encrypted cookie, registered on the user’s machine.

Reviewing the user’s personal data

In some cases, the user can review and modify the personal data provided through EVOFORCE’s Sites by visiting the page on which the information was provided. In any case, the user can always request to review and modify their personal data, collected through EVOFORCE’s Sites or provided when contacting EVOFORCE, or may ask EVOFORCE to stop using such data. EVOFORCE may take steps to verify the user’s identity before making the user’s personal data accessible. The user can help EVOFORCE preserve the accuracy of their information by communicating any changes to their postal address, telephone number or email address.

Information relating to children

EVOFORCE does not knowingly collect information from children and does not direct its Sites at children.

Links to other sites

EVOFORCE’s Sites may contain links to other websites, for example to sites operated by distributors and parties affiliated with EVOFORCE’s sales network, by suppliers of products or services, by professional associations, by government bodies, or to magazine and newspaper sites. EVOFORCE also offers links to third-party providers that host and manage online training courses. Although it strives to offer links only to websites that share its high standards and respect for privacy, EVOFORCE is not responsible for the content, security or privacy practices adopted by other websites.

Application of this privacy notice / Contacts

In case of questions about this notice or the management of the user’s personal data, please send your communication to the following email address:

info-privacy@evoforce.it

EVOFORCE undertakes to address the matter promptly and to seek a satisfactory solution.

Changes to this privacy notice

EVOFORCE may update this privacy notice. In such case the “last updated” date at the beginning and at the end of the privacy notice will be modified. If EVOFORCE makes substantial changes to the methods of collection, use and/or sharing of personal data collected by EVOFORCE through its Sites, the user will be notified by means of an email message sent to the last address provided by the user and/or by publication of a notice regarding such changes in a clearly visible location on the Sites.