PRIVACY DISCLAIME

art. 13 of EU Regulation 679/2016

Rev. June 2022

Premise

Pursuant to the European Regulation n. 679/2016 (hereinafter "Regulation") and the national legislation on the protection of personal data (hereinafter collectively "Privacy Law"), Flexbed S.r.l. We invite you to carefully read this Privacy Policy which contains important information on the protection of your Personal Data.

The processing of your Personal Data will be based on the principles of correctness, lawfulness, transparency, purpose limitation and conservation, minimization and accuracy, integrity and confidentiality, in accordance with the provisions of the Regulation.

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1. HOLDER OF THE TREATMENT

The Data Controller of Personal Data is Flexbed S.r.l. (hereinafter "Flexbed" and / or "Owner") with registered office in Rome - Via Benedetto Croce, 6, in the person of its pro tempore legal representative.

2. DATA PROTECTION MANAGER – DPO

In compliance with the provisions of the Regulations, the Data Controller has identified and appointed the Data Protection Officer (DPO), with the task of supervising compliance with the Regulations and acting as a contact point with the subjects concerned by the treatment. as well as with the Guarantor for the protection of personal data. The DPO can be contacted at the e-mail addressprivacy@flexbed.com

3. PERSONAL DATA PROCESSED

  • Personal data (such as name, surname, date of birth, age, sex, etc.)
  • Contact details (e-mail, address, telephone number)
  • Geo-localization and / or Internet browsing data (including "IP" addresses) collected through the cookies installed on your computer or mobile device (for more information see the Cookie Policy)
  • Bank data useful for managing the commercial relationship, photographic images and / or video footage, collected on the occasion of participation in promotions, contests and institutional events, events, exhibitions, exhibitions, museum contexts and installations in general.
  • Data relating to your interactions with our websites, App, by way of example but not limited to, i) data relating to your device following the download of our App and use of notifications on the publication of new content, initiatives and updates ; ii) participation in questionnaires, initiatives, contests, promotions, events (also through our social channels).

If a request is sent through the "Contact Us" section of the Website or the Flexbed App, the provision of some Personal Data is necessary for Flexbed to meet the requests, so the relevant fields in the registration form are marked as mandatory.

In addition to the aforementioned categories of Personal Data, further data directly provided by you (the so-called "Contributions") and shared on the pages of the Social Networks dedicated to Flexbed (Facebook, Twitter, Instagram, etc.) may be processed, for the management of which we refer to third parties providing such services. Among the data collected through social networks there are, for example, likes, comments, images and in general any content and information that you may have published on the pages of the Social Networks dedicated to products of the various brands of the Flexbed Group.

4. PURPOSE AND LEGAL BASIS OF THE PROCESSING

According to the needs related to access to the various sections of the Flexbed Sites (and without prejudice to individual initiatives that involve the provision of specific Personal Data, for which specific information will be published from time to time), the purposes of the processing of the Personal data and related legal bases:

· Registration via website / APP : the registration procedure, by creating an account or using an existing social network account, is aimed at allowing the use of the Flexbed portal as a "User registered "and to access a series of exclusive services offered through the same applications. The provision of data is optional. The legal basis of the processing is the execution of pre-contractual measures of which the interested party is a party .

In case of registration through the APP, authorization will be requested to receive notifications regarding the publication of new content, initiatives, events, promotions, etc. The legal basis of the processing is the consent of the interested party. You can always change your mind and change the settings regarding receiving such notifications directly from your device in the "Settings" and "Notifications" section.

In case of registration or access through your social network account, we may have access to some additional personal data with respect to those provided when registering on the portal, on the basis of the authorizations you have provided to the social network itself and to which reference should be made for the policies on the management of your privacy.

· Purchase of products : through our Website / APP you can purchase Flexbed products both as a Registered User (and in this case you will not have to re-enter all your Personal Data at each purchase) and as a Unregistered User (re-entering all the data needed to complete the purchase from time to time). Both cases will involve the processing of your Personal Data.

Your Personal Data will be processed in order to manage orders and payments and to fulfill the consequent administrative-accounting obligations as well as to contact you for any communications relating to the purchases themselves (eg information on the progress of your orders). The provision of data is necessary to complete the purchase order. The legal basis of these treatments is the execution of the Contract of which the interested party is a party.

· Management of requests : Personal Data will be collected in order to respond to requests sent to us via email, website and / or social networks such as, by way of example but not limited to, those relating to maintenance activities / repair / replacement of our products as well as requests relating to products and initiatives of the various brands of the Flexbed Group. The legal basis of these treatments is the legitimate interest of the owner.

These services may also be provided through the video chat / call activity. In this case, the support via video chat / call will be activated at the user's discretion, will take place exclusively in live mode and there will be no recording of their content.

Finalità Ulteriori:

· Marketing: subject to your express consent, we may process your Personal Data in order to send you commercial communications as well as to invite you to take part in our promotional initiatives, participate in our events, subscribe to the newsletter. The legal basis for this processing is the Consent of the interested party, which can be revoked at any time.

· Participation in competitions, prize events, loyalty programs for our brands: we may process your Personal Data in order to allow your participation in competitions and prize operations, including our brand loyalty program. The legal basis for the processing of data for the purposes of participating in competitions and prize operations is the execution of pre-contractual measures of which the interested party is a party while for loyalty programs to our brands the legal basis of the processing is the legitimate interest of the owner.

· Profiling: subject to your express consent, we may process your personal data for profiling purposes, i.e. to analyze or predict your tastes, potential habits and consumption choices in order to offer you products, services, promotions and personalized commercial communications. The legal basis for this processing is the consent of the interested party , which can be revoked at any time.

The profiling activity could also be carried out through the use of proprietary and third-party cookies. We therefore invite you to read our Cookie Policy . This treatment can be carried out on condition that you provide further specific and optional consent.

Outside of the previous hypotheses:

· Purpose of analysis: the Personal Data you provide when interacting with the Flexbed world and the information relating to the interaction will flow into our database and will be used anonymously to analyze and improve the services offered, evaluate the effectiveness of the activities and initiatives promoted by Flexbed and conducting statistical analyzes on the composition of the database itself. The legal basis of the processing is the legitimate interest of the data controller .

· Any further purpose in relation to which you have expressly given your consent, which can be revoked at any time.

5. NATURE OF THE PROVISION

The provision of your Personal Data is optional. However, their failure to communicate could affect the ability to use some services (eg. To place orders and purchases, to participate in competitions and prize operations; to send newsletters, etc.).

The mandatory or optional nature of the provision will be reported from time to time through the use of symbols (eg "*") placed alongside the information whose provision is mandatory to pursue the respective purpose.

6. METHOD OF TREATMENT

Your Personal Data will be processed in accordance with the provisions of the current Privacy Law, both with the aid of electronic and automated means and with manual methods, with logic strictly related to the purposes of the processing, through the databases, the electronic platforms managed by Flexbed or by third parties (appointed as Data Processors), the integrated IT systems of Flexbed and the aforementioned third parties, and / or websites owned or used by Flexbed.

Your data will be processed in a manner designed to guarantee maximum security and confidentiality and only by persons trained and authorized to process them. The Data Controller adopts adequate technical and organizational measures to guarantee a level of security adequate to the risk of processing.

Personal Data are mainly processed at the offices of the Data Controller and in the places where the Data Processors are located.

7. DATA ADDRESSEES

Your Personal Data may be made accessible, for the aforementioned purposes, to Flexbed employees and collaborators.

The Personal Data you provide may be transferred to companies belonging to the Flexbed Group and / or to third-party companies located in the European Union and outside it as well as the European Economic Area, in charge of carrying out the aforementioned personal data processing activities on behalf of of the Data Controller, who will act as Data Processors.

The Data Controller adopts suitable guarantees to provide an adequate level of protection equal to that used in the EU / EEA and has drawn up a list of Data Processors, constantly updated, which he makes available to you by contacting him at the addresses indicated in point 11 of this Notice.

Finally, your data may be transmitted to the judicial authority where necessary and in the cases provided for by law.

8. DATA RETENTION PERIOD

In order to ensure compliance with the principles of necessity and proportionality of the processing, different retention periods of Personal Data have been identified in relation to the individual purposes pursued:

- Registration on the website / APP: The Personal Data you provide to register on the website / APP will be kept for the entire duration of your registration on the portal itself. In case of inactivity for 24 months your account will be deleted.

- I billing information will be kept for a period of time to ensure the proper execution of the contract and in any case for a further 10 years for the purpose of fulfilling the related administrative and tax obligations.

- The data collected for the management of prize competitions and operations will be kept for the entire duration of the prize operation and for a period of time to guarantee the its correct execution. Without prejudice to the fulfillment of administrative and tax obligations in relation to which the data retention period is that required by law.

- The data collected for profiling and for marketing purposes, for which you have given your consent to the processing, will be kept for a period of time respectively not exceeding 12 (profiling) and 24 months (marketing) or any other period indicated by the authorities control. If you have not provided the aforementioned consents, your personal data will be anonymized and used forstatistical analysis activities..

- The data collected for the purpose of managing and responding to requests in relation to products and initiatives of the various brands of the Flexbed Group and the data provided in the interaction with Flexbed will be kept for the period necessary to process the requests and subsequently deleted if no further contact, except for any administrative obligations (for example, the request concerning a complaint must be kept beyond the period of management of the same for administrative purposes).

9. DATA OF MINORS

Flexbed does not normally intend to collect Personal Data from minors or deliberately establish communication with them. For this reason, we encourage parents to actively monitor the online activities of children under the age of sixteen.

However, in the event that we have to contact a child under the age of 16, the consent of the parents or those exercising parental responsibility will be required, except in the case of answering a question from the latter or resolving your request.

10. RIGHTS OF THE INTERESTED PARTY

You may at any time exercise the rights provided for in Articles 15 and following of the Regulation, including:

a) the right to obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form;

b) the right to withdraw the consent you have given in relation to the purposes of the processing at any time;

c) the right to obtain access, rectification, cancellation, limitation of the processing and portability of personal data;

d) the right to object to the processing at any time you want;

e) the right to appeal to the competent supervisory authority, if you believe that the processing of your data is contrary to the legislation in force.

11. METHOD OF EXERCISE OF RIGHTS

In the event that you wish to exercise the aforementioned rights, or wish to receive further clarifications regarding the processing of your personal data, you can write to the e-mail address: privacy@flexbed.com or to the address of the Data Controller's registered office, located in Roma – Via Benedetto Croce, 6.