PRIVACY POLICY

ACT OF INFORMATION

(November 2021)

ON DATA PROTECTION PERSONAL

PURSUANT TO REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE ADVISE

Whereas for the purposes of this regulation it is understood that:

Data Controller	The natural or legal person, public authority, agency or any other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Data Processing Officer (Internal)	This is the natural person appointed by the Data Controller as an internal contact person responsible for monitoring that the processing is carried out in the terms and manner established in Regulation (EU) 2016/679 GDPR.
Data Controllers (Outsourcing)	It is the natural or legal person, public authority, service or any other body that processes personal data. on behalf of of the Data Controller
Data Protection Officer (Data Protection Office)	This is the new figure appointed by the Data Controller, who verifies the implementation and application of the European Regulation, data security, the response to requests from interested parties to exercise the rights recognized by the Regulation, must ensure that the Data Controller or the Data Processor carry out the data protection impact assessment and request prior authorization or prior consultation in the cases provided for.
Person authorised to process data (person in charge)	They are the persons authorised to process data under the authority live of the owner or the person in charge
Personal data (Data subject)	Any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Treatment	It is any operation or set of operations, performed with or without the aid of automated processes and applied to personal data or sets of personal data, such as: the collection; recording; organization; structuring; conservation; adaptation or modification; extraction; consultation; use; communication by transmission; dissemination or any other form of making available; comparison or interconnection; the limitation; the cancellation or destruction

Having said all this, the company announces that:

THE DATA CONTROLLER IS:

Company Name	ISI BET PRO SRL
Address	VIA PADRE SEMERIA 33
City	ROME
VAT no.	13765401008
Tel	0541775417
e-mail	[email protected]

DATA PROCESSING CONTACT PERSON AND':

Surname Name	ANDREA VALUES
Tel	0572910345
e-mail	[email protected]

DATA SECURITY OFFICER (DPO) AND':

Surname Name	Sergio Petti
Tel	3928267724
e-mail	[email protected]

The list of Outsourcing Data Processors is available upon request from the Data Processing Manager ANDREA VALORI Email [email protected]

purpose of the processing

The personal data, object of the processing, and specifically, identification, administrative, accounting and fiscal, commercial, possibly computer data, directly referred to the customer or, for essentially identification and computer data, to other interested parties (such as collaborators, employees, referents, etc.), communicated by them in execution and in the development of the relationships with the owner and in compliance with and in compliance with the provisions on the processing and protection of personal data, are used for the pursuit of instrumental and/or complementary purposes to the activities statutorily expressed and functional to the performance of the contractual/pre-contractual relationship in place with the interested party and this in relation to the services/performances requested by the same.

nature of the transfer

The provision of data is mandatory for the fulfillments required and sanctioned by law, for the rest the provision is optional but necessary and any refusal by the interested party makes it impossible for the Owner to follow up on the relationship being established and its punctual execution. Consent to the processing of the aforementioned data is not necessary as they are collected to fulfill legal obligations and/or for the execution of obligations deriving from the existing contract or the so-called pre-contractual ones.

Information you can provide to us

We may collect and process the following information about you that you provide to us so that we can provide you with the best possible experience when you use our services. The personal information you provide to us may include the following:

Other personal information and documents containing personal information may be collected from time to time for business purposes, such as processing bonuses. This category of information is provided by you by performing certain activities:

• Purchasing products or placing an order from a site;
• Enter a contest, promotion or survey;
• Participate in any interactive elements of the Site by engaging in forums or posting comments or reviews about services and/or products;
• Sending a request for information from the site;
• Reporting a problem;
• Consent to receive marketing materials.

Our company adheres to the European Regulation on data protection, and will not share your personal information with external companies or suppliers, except to facilitate a business process or financial transactions on your behalf.

Other information we may collect about you

During each of your visits to our websites, we may collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit, including the full Uniform Resource Locators (URL), the clickstream to and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number, and any email address used to contact us.

Information we receive from other sources

We may work closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive personal information. We will inform you of the purposes for which we intend to use it.

Cookie

In computer science, cookies are small files containing some information that websites leave on the computers of users who visit them. In this way, the sites themselves can recognize users who return to visit them later. In fact, it is a method that servers use to recognize users, save each user's preferences and offer personalized options and performances. Detailed information is provided in our site in the "Cookies" section.

Disclosure of User Information

Information about our users and/or customers is an important part of our business and we do not intend to sell such information to others. We share personal information only as described below:

• Internal Disclosure: We necessarily require the storage and disclosure of your information within our offices on a necessary basis in order to effectively conduct our legitimate business activities.
• Commercial purposes: Limited personal information may be shared with other people who are also members or seek to become members, Your full name and current status may appear in recognition reports or be made available to a business associate. If you terminate your relationship with us, this information will be removed and no longer shared.
• Third Party Service Providers: We employ other companies and/or individuals to perform processing on our behalf. Examples may include sending postal mail and email, analyzing data, providing customer support, providing search results and links, processing credit card payments, and providing customer service. These providers have access to the personal information needed to perform their functions in accordance with contractual obligations, but may not use it for other purposes.
• Promotional offers: Our company never sells, trades or rents your personal information to unrelated third parties without your express consent. From time to time, we may send you offers and promotional materials for

(1) provide you with information about other goods and services our company produces that are similar to those you have purchased and enquired about

(2) inform you of changes to our goods and services. Individuals are free to opt out of these promotional offers at any time by notifying us via email or by calling our privacy representative.

• With yours consent: In addition to the above, you will receive notice when information about you might be sent to other third parties and you will have the opportunity to choose not to share the information.

Where we store your personal information

The information we collect from you is stored and processed by staff operating within the European Economic Area (“EEA”). However, there may be other instances where your information is necessarily provided to other entities outside the European Economic Area (“EEA”). Any information will only be shared with other foreign entities in accordance with the General Data Protection Regulation (EU) No. 2016/679. We will take all appropriate measures to ensure that:

1. your information is treated securely and in accordance with this Privacy Policy
2. that records containing your information will be retained or destroyed in accordance with our internal global records retention policy.

Retention of your personal information

We retain personal information only for as long as is necessary to provide the services you have requested and thereafter for legitimate legal or business purposes. This may include retention periods

• imposed by law,
• to preserve, resolve, defend or enforce our legal/contractual rights;

Security Measures

All information you provide to us is stored on secure servers. We maintain a variety of security programs and controls to protect your information. All payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. We follow the Payment Card Industry Data Security Standard (PCI DSS) when handling credit card information. Where we have given you (or where you have chosen) a password which enables you to log in, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and to use a unique, strong password.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Access, control

If you created an account during the registration process, you can view, update, and delete certain information about yourself and your interactions with us. If you have an order confirmation number, you may be able to modify and update your order. If you are unable to access or update your information yourself, you can always contact our company for assistance.

Your rights

We may ask you to provide a valid form of identification (such as completing a privacy verification form) for verification purposes. Your rights are as follows:

RIGHTS OF THE INTERESTED PARTY

To know:

• The identity and contact details of the data controller and of his/her possible contact person
• Contact details of the Data Protection Officer (DPO)
• The purposes of the processing for which the personal data are intended as well as the legal basis of the processing
• Where processing is based on legitimate interest, the legitimate interests pursued by the data controller or by third parties
• Recipients or categories of recipients of personal data
• The intention of the controller to transfer personal data to a third country or to an international organisation, the existence and/or absence of an adequacy decision by the EU Commission, or reference to the appropriate and suitable safeguards, the means to obtain a copy of such data and the place where they have been made available.
• The period for which the personal data will be stored, or, if this is not possible, the criteria used to determine this period
• The existence of the right of the data subject to request from the data controller access to personal data and rectification or erasure of the same or restriction of processing of personal data concerning him or her or to object to such processing, as well as the right to data portability
• Where the processing, including of special data, is based on consent, the existence of the right to withdraw consent at any time without prejudice to the lawfulness of the processing based on consent before its withdrawal.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, and whether the data subject is obliged to provide the data as well as the possible consequences of failure to provide such data
• The existence of automated decision-making, including profiling, 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
• The interested party has the right to receive in a structured, commonly used and machine-readable format the personal data concerning him/her provided to a Data Controller and has the right to transmit those data to another Data Controller without hindrance from the Data Controller to which the personal data have been provided.
• The interested party has the right to obtain from the Data Controller the erasure of personal data concerning him or her without undue delay and the Data Controller has the obligation to erase the personal data of the interested party without undue delay.

The interested party may lodge a complaint with the competent data protection supervisory authority or take legal action.

If you have any privacy questions, concerns or complaints about our Privacy Policy or how we handle your personal information, you can contact:

The Data Protection Officer is Mr. Sergio Petti:

By email [email protected]

By phone on 392 8267724