Information on the processing of personal data in accordance with EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). Effective as of 18 October 2022.

INTRODUCTION

This privacy policy takes into account the provisions of the GDPR and the Privacy Code (Legislative Decree 30 June 2003 no. 196). The document has also been prepared in accordance with the Guidelines of the Privacy Authority (especially the Guidelines on spam prevention issued by the Privacy Authority on 4 July 2013).

Data Controller: Desa S.R.L. - Viale G. De Gennaro, 1 | c/o Interporto Puglia - 70123 Bari (BA) - VAT number IT06276470728 - tel. +39 0492020056 - commerciale@desasolar.com

Website to which this privacy policy refers: https://www.desasolar.com/

GENERAL INFORMATION

Below are the main processing activities of your personal data provided on the website. It explains the legal basis for the processing, whether the provision is mandatory, and the consequences of not providing personal data.

Website Registration

The information and data requested during registration will be used to allow you to access the restricted area of the website and to use the online services offered by the Data Controller to registered users. The legal basis for the processing is the necessity for the Data Controller to perform pre-contractual measures requested by the data subject. Providing the data is optional. However, if you refuse to provide the data, you will not be able to register on the website.

Purchases on the Website

Your personal data will be processed to allow you to make purchases on the Website. In the case of online purchases, in order to conclude the purchase contract and correctly carry out related operations (and, if necessary, to comply with tax obligations based on industry regulations). The legal basis for processing is the obligation of the Data Controller to perform the contract with the data subject or to fulfill legal obligations. Regardless of the above (and therefore without your consent), the Data Controller may process your data for the purpose of so-called "soft-spam", regulated by Article 130 of the Privacy Code. This means that, limited to the email provided by you in the context of a purchase through the Website, the Data Controller will process the email to enable direct offers of similar products/services, provided that you do not object to such processing in the manner provided in this information. The legal basis for processing is the legitimate interest of the Data Controller in sending this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving "soft-spam" communications. The Data Controller may send emails to remind the user to complete a purchase. The legal basis for this processing is the legitimate interest of the Data Controller in sending this type of communication.

Responding to your requests

Your data will be processed to respond to your information requests. Providing this data is optional, but your refusal will result in the impossibility for the Data Controller to respond to your inquiries. The legal basis for processing is the legitimate interest of the Data Controller in following up on user requests. This legitimate interest is equivalent to the user's interest in receiving a response to communications sent to the Data Controller.

Generic Marketing

With your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters related to its own or third-party products. The legal basis for this processing is your consent. Providing personal data for this purpose is purely optional. Failure to give consent to the processing of data for marketing purposes will result in the impossibility for you to receive advertising material related to products/services of the Data Controller and/or third parties, as well as the impossibility for the Data Controller to carry out market research, including assessing the level of user satisfaction, and to send you newsletters. These communications will be sent to the email address provided by you on the Website.

Profiling

With your consent, the Data Controller may process your personal data for profiling purposes, i.e., for analyzing your consumption choices by revealing the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters related to its own or third-party products that are of specific interest to you. The legal basis for this processing is your consent. Providing data for this purpose is purely optional. Failure to give consent to the processing of your personal data for profiling purposes will result in the impossibility for the Data Controller to create your commercial profile by detecting your purchasing choices and habits, as well as to send you advertising material related to products of the Data Controller and/or third parties that are of specific interest to you. These communications will be sent to the email address provided by you on the Website.

Transfer of Data

The Data Controller does not transfer your personal data to third parties.

Disclosure of Personal Data

In the scope of its ordinary activities, the Data Controller may disclose your personal data to certain categories of entities. In Article 2, you can find the list of entities to which the Data Controller discloses your personal data. To facilitate the protection of your rights, Article 2 may specify in some cases when your data is not disclosed to third parties. The "communication" of personal data to third parties is different from "transfer" (governed by the preceding point). In fact, in communication, the third party to whom the data is transmitted can only use it for the specific purposes described in the relationship with the Data Controller. In transfer, on the other hand, the third party becomes an independent Data Controller of the personal data. In addition, your consent is always required to transfer your personal data to third parties. Notwithstanding the above, the Data Controller may still use your personal data to fulfill legal obligations as required by applicable laws.

SPECIFIC PRIVACY INFORMATION

Art. 1 Processing Methods

1.1 The processing of your personal data will mainly be carried out using electronic or automated means, in accordance with the GDPR. If the automatic chatbot service is operational, your personal data will also be processed to enable the activation of this service, through which the user can contact and be contacted by the Data Controller, subject to your consent. The legal basis is the legitimate interest of the Data Controller in responding to user requests through the chatbot service. This legitimate interest can be considered equivalent to the user's interest in using the automatic chatbot service.

1.2 The information obtained and the methods of processing will be relevant and not excessive

1.3 Through the Website, "special data" is not processed. Special data refers to data that may reveal racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership in parties, unions, associations or religious, philosophical, political or trade organizations, as well as health and sexual life.

1.4 Judicial data is not processed through the Website.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The following are the subjects to whom the Data Controller reserves the right to communicate your data:

The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data under regulatory or administrative provisions.

Your personal data may also be communicated to all those public and/or private subjects, individuals and/or legal entities (legal, administrative and tax consulting firms, Judicial Offices, Chambers of Commerce, Labor Chambers and Offices, etc.), if the communication is necessary or functional to the proper fulfillment of legal obligations.

The Data Controller employs employees and/or collaborators in any capacity. For the proper functioning of the Website, the Data Controller may communicate your personal data to these employees and/or collaborators.

In its ordinary management of the Website, the Data Controller uses companies, consultants or professionals responsible for the installation, maintenance, updating, and, in general, the management of the hardware and software of the Data Controller or used by the latter for the provision of its services. Therefore, only with regard to these purposes, your data may also be processed by these subjects.

For sending its communications, the Data Controller uses external companies entrusted with the sending of this type of communication (CRM platforms). Your personal data (in particular, your email) may therefore be communicated to these companies.

The Data Controller does not rely on external companies to provide customer care service.

The Data Controller reserves the right to modify the above list based on its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Storage of personal data

3.1 This article describes how long the Data Controller reserves the right to keep your personal data.

Your personal data will be kept for as long as necessary to guarantee the proper provision of the services offered through the Website.

For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defense and to demonstrate that it has correctly executed the contract.

As provided for in article 2220 of the civil code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in case of inspection.

For marketing purposes, personal data will be kept until the consent is revoked. For inactive users, personal data will be deleted after one year from the last email that may have been viewed.

3.2 Notwithstanding the provisions of article 3.1, the Data Controller may keep your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is based within the European Union. Therefore, the processing of your data is safe from a regulatory perspective as it is governed by the GDPR. If the transfer of your personal data takes place to a country outside the EU for which the European Commission has expressed an adequacy decision, the transfer is considered safe from a regulatory perspective in any case.

Art. 5 Rights of the data subject

Pursuant to Article 13 of the Privacy Regulation, the Data Controller informs you that you have the right to:

• request the Data Controller access to your personal data and their rectification or erasure, or the restriction of processing concerning you, or to object to their processing, as well as the right to data portability

• withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal

• lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The above rights can be exercised by making a request, without formality, to the contacts indicated in the introduction.