PRIVACY POLICY ART. 13 GDPR

Whereas:

1. Following your visits to this website, completion of forms, receipt of your requests/inquiries, preliminary contacts, market surveys, and research, or the possible establishment of commercial relationships, our company may collect and process your personal data.

2. For clarity, we hereby specify the following definitions provided by Regulation (EU) 2016/679:

• Personal Data: any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• Processing: any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Therefore, according to Article 13 of Regulation (EU) 2016/679, we inform you that:

a) General Purposes: your data will be processed to respond to your requests/inquiries, to properly fulfill bureaucratic, accounting, fiscal, commercial, and technical obligations, and for company activities required by law and strictly related to existing relationships;

b) Promotional Purposes – Sending of Newsletters and Commercial Communications: your data may also be used, only with your free, optional, specific, and explicit consent, which can be revoked at any time, for the sending via email of our periodic newsletter and other commercial communications containing information about our company, products, and services. After giving consent, you retain the right to object at any time and free of charge to the processing of your data for this purpose;

c) Legal Basis: the legal basis for processing may be your consent for specific purposes, or, depending on the case, the necessity to perform a contract or pre-contractual measures requested by you;

d) Methods: data will be processed using both paper and electronic/IT/telecommunication tools, in full compliance with legal provisions, according to principles of lawfulness and fairness, and in a manner that ensures confidentiality;

e) Optional Provision: the provision of your data is optional and not mandatory;

f) Consequences of Refusal: refusal to provide data or total opposition to processing for the purposes under point a) may result in our inability to fulfill certain requests; refusal to use data for the purposes under point b) will have no consequence on promotional benefits or existing relationships;

g) Recipients: data may be disclosed to third parties only to fulfill legal or contractual obligations. Data will not be disseminated under any circumstances.

h) Authorized Personnel: data will be processed exclusively by a limited number of company employees in the administrative, marketing, IT, and commercial departments, specifically authorized.

i) Automated Decision-Making (e.g., Profiling): no automated decision-making processes are used;

j) Data Subject Rights: you have all the rights provided by Regulation (EU) 2016/679, including the right to access, rectify, erase, restrict processing, object to processing, and data portability. You also have the right to complain to the Supervisory Authority;

k) Transfers to Third Countries: any transfer of personal data to a third country outside the EU or an international organization will be based on an adequacy decision by the Commission or, in the case of transfers under Articles 46, 47, or 49(1) of the Regulation, on appropriate safeguards;

l) Data Retention Period: data will be retained for the period strictly necessary to fulfill the data subject’s requests or as required by applicable laws or contractual clauses;

m) Data Controller: the Data Controller is Zapi S.p.A. – Società per Azioni con Unico Socio, headquartered in Poviglio (RE), Via Parma no. 59, represented by the legal representative pro tempore;

n) Data Protection Officer (DPO): the DPO is Dr. Juri Torreggiani, with an office in Reggio Emilia, Via Piccard no. 16/G, tel. +39 0522/30.11.69, fax +39 0522/38.79.96. Any request for clarification or information may be addressed to this officer.

This notice may be supplemented, orally or in writing, with additional elements and indications to better meet your privacy-related information needs and to comply with regulatory developments.

Date: 28/07/2025
Data Controller
Zapi S.p.A. – Società per Azioni con Unico Socio