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PRIVACY POLICY PURSUANT TO LEGISLATIVE DECREE 30 JUNE 2003 N. 196 AND EU REGULATION 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016.

1. REFERENCE LEGISLATION

Following consultation of the lovinmemory.com website (hereinafter the "Website") data relating to persons identified or identifiable pursuant to Legislative Decree 196/2003 - the so-called "Persons Identified or identifiable" pursuant to Legislative Decree 196/2003 Privacy Code - and the new European regulation 679/2016, the so-called GDPR.

LovinMemory provides each of the subjects with authorize you to process your data (hereinafter, the "User") the information on the processing of personal data, in relation to the use of the Site lovinmemory.com and the services offered by it.

2. DATA CONTROLLER AND DATA PROCESSOR

2.1 The Data Controller is Red Onion Srl, with registered office in Rende (CS, Via G. Ungaretti 1/A, C.F. e P.IVA 02767850783, e-mail: info@lovinmemory.com (in hereinafter referred to as the "Data Controller").

2.2 The Data Processor is Red Onion S.r.l., with registered office in Rende (CS), Via G. Ungaretti 1/A, C.F. e P.IVA 02767850783, e-mail: info@lovinmemory.com (in hereinafter referred to as the "Data Processor").

2.3 The User's personal data will be processed by the employees and operators of LovinMemory - who operate under the direct control of the authority of the Data Processor and have received appropriate operating instructions for the protection of such data – as well as by external parties responsible for the management of the User's data in electronic format, and by Non-Profit Organizations to which donor data is communicated, who may act, as the case may be, as joint controllers or processors of the treatment.

3. TYPES OF DATA PROCESSED

3.1 NAVIGATION DATA

The computer systems and software procedures used to operate the Site acquire, during their normal operation, some personal data whose knowledge is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified individuals, but which by its very nature could allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the Site, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the files obtained in response, the numerical code indicating the status of the response given by the server (successful, error) and other parameters related to the User's operating system and information environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning. The data may also be used where it is necessary to ascertain responsibility for illegal acts or crimes against the Site or third parties.

3.2 DATA PROVIDED VOLUNTARILY BY

THE USER In addition to those indicated above, the Data Controller will process the data provided by users at the time of registration on the Site - such as name, name if legal entity, e-mail address, address and telephone number, tax code/VAT number, date of birth or incorporation - or information regarding the payment methods used; the information contained in the correspondence sent through the Site and/or in correspondence sent to the Data Controller; further information that the Data Controller may request from users in order to verify the authenticity of the identity provided, or to carry out checks in the presence of possible illegal acts or crimes.

4. NATURE OF THE DATA AND CONSEQUENCES OF A POSSIBLE The

processing of data provided voluntarily by users is necessary in order to allow registration on the Site and/or to make donations through the Site. In case of refusal, therefore, users will not be able, depending on the case, to register on the portal or donate through the portal.

5. PURPOSE OF THE PROCESSING

The data provided voluntarily by users will be used in order to allow registration on the Site, donation through the Site and participate in the initiatives promoted and carried out through the Site itself, as well as to carry out activities directly or indirectly related to registration and such initiatives. The data provided may also be used to send the User information regarding new marketing initiatives and news on the services offered on the Site, as well as for the purpose of informing the User about new services offered by third parties in the field of the third sector, international cooperation, charity and activities of social utility in general. The processing will also concern the fulfilment of the legal obligations provided for by Legislative Decree no. 196/2003 and Regulation 679/2016.

6. PROCESSING METHODS

Personal data will be processed with computer and automated systems. The Data Controller adopts specific security measures in order to ensure the processing of data in compliance with the Personal Data Protection Code, with particular regard to the prevention of the loss of such data, illicit or incorrect use or unauthorized access to databases.

7. DATA RETENTION

The User's personal data and other information acquired will be kept for the period strictly necessary in relation to the purposes indicated above and in any case no longer than the ordinary limitation period of ten years.

8. RIGHTS OF THE DATA SUBJECT

8.1 The subjects to whom the personal data refer have the right, at any time, to obtain confirmation of the existence or otherwise of personal data concerning them, even if not yet registered, their communication in intelligible form, the correction or deletion of the data, the limitation of the processing that concerns them and to object to their processing.

8.2 To exercise the aforementioned rights, write to the Data Controller, at the registered office or at the e-mail address indicated in paragraph 2, indicating in the subject line "Privacy – exercise of rights pursuant to Article 7 of Legislative Decree 196/2003".

8.3 Pursuant to Article 13(2)(d) of Regulation 679/2016, the subjects to whom the personal data refer have the right to lodge a complaint with a supervisory authority.

9. COMMUNICATION AND DISSEMINATION OF DATA

9.1 The personal data collected on the Website are not subject to dissemination and will not be sold or transferred to third parties without the consent of the users, except in the cases provided for by law. This is without prejudice, in any case, to the communication or dissemination of data requested, in accordance with the law, by police forces, judicial authorities, intelligence and security bodies or other public entities for the purposes of defence or security of the State or the prevention, detection or repression of crimes.

9.2 If the User decides to make a donation through electronic payment services such as PayPal, Stripe or Satispay, his personal data will be communicated to the companies responsible for the execution of such payment services - whose privacy policies we invite the User to read - which will act as independent data controllers. The personal data of the donors will also be transferred to the beneficiary organization of the donation, for communications relating to this donation, to any related tax obligations and to all the purposes provided for in paragraph 5 of this document.

10. CHANGES

This document constitutes the privacy policy of the Site and will be subject to possible changes and/or updates over time.

11. UNSUBSCRIBE

In order to unsubscribe from the newsletters sent by the Site, simply click on the appropriate link in each individual newsletter or reply from the same email address to the newsletter email received, specifying the unsubscribe request. To unsubscribe from the portal, simply send an email with the subject "Unsubscribe" to your info@lovinmemory.com mailbox indicating the account you wish to cancel.