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PRIVACY POLICY ON THE PROCESSING AND PROTECTION OF PERSONAL DATA


INTRODUCTION

In the exercise of its business activity, the owner of the business that uses
the App "MySelf" (hereinafter referred to "Operator" for the sake of brevity)
pays the utmost attention to the protection of personal data of all those who
work or interact with it (hereinafter referred to as "Interested party" and / or
"User" for brevity), implementing appropriate technical and organizational
measures to guarantee an adequate level of security in relation to the risk.

In accordance with the principles of transparency and correctness, the following
policy is created to provide all information in order to make all interested
parties aware of the methods and purposes of the processing of personal data
carried out in the provision of services and / or in the marketing of its assets
(hereinafter referred to as "Services" altogether for the sake of brevity) also
through the use of the "MySelf" App (hereinafter referred to as "App Myself" for
brevity), and this also in compliance with the provisions of San Marino law n .
171 of December 21st 2018 regarding the protection of individuals with regard to
the processing of personal data (hereinafter referred to as "RSM Privacy Law")
and, where applicable, by Regulation (EU) no. 2016/679 regarding the protection
of individuals with regard to the processing of personal data, as well as the
free circulation of such data (hereinafter referred to as "GDPR").

The processing of these data will take place in a lawful and correct manner,
with the use of manual and / or automated systems that allow to store, manage
and transmit data solely for the purposes expressly indicated below.



DATA CONTROLLER OF PERSONAL DATA

The Data Controller of the personal data is the Operator (hereinafter “Data
Controller” for brevity), whose data are known to the User who has voluntarily
connected his own mobile device to the Operator’s Server in order to benefit of
his Services also with the Myself App.



PERSONAL DATA AND PROCESSING OF PERSONAL DATA

Personal data means: "all information concerning an identified or identifiable
natural person ("data subject"); an identifiable natural person is one who can
be identified, directly or indirectly, in particular by reference to an
identifier such as the name, an identification number, location data, an online
identifier or one or more factors specific to the physical, physiological,
genetic, psychic, economic, cultural or social identity".

The processing of personal data means "any operation or set of operations,
carried out with or without the aid of automated processes and applied to
personal data (or sets of personal data), such as, by way of example but not
limited to, collection, the registration, organization, structuring, storage,
adaptation or modification, extraction, consultation, use, communication by
transmission, dissemination or any other form of provision, comparison or
interconnection, limitation, cancellation or destruction".

The personal data as described above are mainly processed when the interested
party uses the Services and / or the Myself App.

The provision of all other personal data is optional but may be necessary in
order to use the Services and / or the Myself App, such as data to make offers,
buy or sell that are necessary to conclude a contractual transaction.

Personal data are provided directly by the data subject and / or acquired
automatically through the devices when the Services and / or the Myself App are
used, when data is provided in a web form on our sites, when an account is
created and / or updated or when the interested party contacts us in any other
way or provides his personal data expressly and with his consent, all as
detailed below.



TYPE AND CATEGORIES OF DATA PROCESSED

Of the personal data as described above, and for the delivery of the Myself App,
the Data Controller only collects the following types of data:

 a. Information that can identify the person such as name, surname, date and
    place of birth, place of residence, fiscal code, vat number and venue,
    telephone number, e-mail address (even with certified email), gender or
    other data that we are supposed or allowed to collect and process, pursuant
    to current legislation, in order to authenticate or identify the User or
    verify the provided and collected information;
 b. Ip address and browsing data and every other data that concerns interaction
    between the Users and the Services and/or the Myself App, for example when
    viewing or searching content, when creating or accessing one’s own account
    and/or a reserved area. Data related to devices and/or computers used by the
    User to access to Services and/or Myself App, including the device unique
    code, the language and operating system;
 c. Data related to offers, purchases or sales related to the Services and/or
    Myself App provided during a precontractual negotiation and its following
    improvements and every other data provided in reference to these operations;
 d. Data related to payment and invoicing (and potential shipment) of the
    Services and/or Myself App;
 e. Financial data, considering that some Services and/or Myself App support
    payment and transaction with third parties. For this scope it may be
    necessary provide some data to identify and verify the identity of the Data
    subject and the payment method used, such as name, surname, credit/debit
    card number and expiry date. If collect by the Data Controller, these data
    will be saved in a cryptography mode. In some cases, to allow the User to
    speed up, future, new and similar payment operations, the Operator could
    store the last four number of the card only;

 f. f) Processing of special categories of personal data (so called “sensitive
    data”)
    
    Particular categories of personal data, for example data revealing racial or
    ethnic origin, politic opinions, religion or philosophical beliefs, trade
    union membership, and the processing of genetic data, biometric data for the
    purpose of uniquely identifying a natural person, data concerning health or
    data concerning a natural person’s sex life or sexual orientation are not
    collected and therefore not processed.



PURPOSE AND METHOD OF DATA PROCESSING

The processing of personal data collected takes place solely and exclusively for
the following purposes:

 a. Execute the contracts related to the Services and/or Myself App.
    Through the information and data communicated, we are able to carry out the
    contractual activities and services provided by the Services and / or the
    Myself App contracts requested by the interested party (also in the name and
    / or on behalf of third parties) or to execute pre-contractual measures and
    / or negotiations related to the same Services and / or the Myself App,
    including administrative and accounting activities, management of tax
    obligations, payments and invoicing.
    
    The information collected will also be used to contact the User regarding
    his account or in any case regarding his contractual position, to solve
    problems with the account and / or the reserved area, solve a dispute, carry
    out debt collection activities.

Personal data may also be processed to verify and solve any anomalies in the
functioning of the Services and / or the Myself App; to perform data analysis
and tests, to conduct research and surveys and to develop new features and
services in order to provide a better experience for the user.
 b. Provide security and protection both to personal data received and to the
    security system adopted.
    The data collected are also used to verify the identity and authenticate
    Users, allow to make and / or receive payments, protect against fraud and /
    or abuse, respond to a request or complaint, perform checks, prevent,
    detect, mitigate and / or ascertain security breaches and / or activities
    that are even potentially prohibited, illegal and / or unlawful.
    
    
 c. Communicate with the Data subject
    Data may be used to contact the User for purposes contained in this document
    and in cases laid down by the law. The contact and communication could be
    done by e-mail (even with certified email), telephone, SMS, paper mail, push
    notification on mobile devices
    
    We can use the User’s information to send service communication and/or to
    answer request, to offer discounts and special promotions, to know his
    opinion using surveys and questionnaires.
    
    
 d. Carry out marketing activities
    With the express and specific consent of the User to be provided according
    to the modality specified from time to time, we may use the User's
    information to promote new products or services to which he may be
    interested, carry out marketing activities via phone calls, and email (also
    with certified e-mail) or SMS, via paper mail, push notifications on mobile
    devices, as well as through third parties specifically appointed.
    
    The User may in any case revoke the express consent provided for marketing
    activities by following the appropriate instructions included within the
    tools used (e.g. newsletters, e-mails etc.) or by sending an e-mail to the
    Operator’s email address.
    
    

The processing of the personal data collected will take place in a lawful and
correct manner in compliance with the provisions of the Privacy RSM Law and,
where applicable, of the GDPR, with the use of manual or automated systems that
allow to store, manage and transfer (both in paper and electronic format) data
only for the purposes specified in this statement.




Only authorized personnel can access the personal data collected.





LEGAL BASIS FOR THE PROCESSING

The legal bases with which we treat the personal data of the data subject could
be different according to the circumstances, namely:

 a. contracts established or to be established (with data subjects) to make use
    of the Services; or;
    
    
 b. the consent expressed by the data subject. This consent may be revoked in
    the terms and according to the methods specified in the following paragraph
    X, lett. a); or
    
    
 c. c) our legitimate interests [with respect to which it is possible to file an
    opposition pursuant to paragraph X, lett. a)], meaning for example the
    interest to: prevent fraud; carry out direct marketing activities, improve,
    customize and develop the Services; carry out the marketing of new services
    or products that could be of interest to the User; to carry out the
    promotion of security and protection of data; to perform data processing
    within a group of companies or related entities for internal administrative
    purposes, without prejudice to the general principles and regulatory
    requirements for the transfer of personal data within an entrepreneurial
    group, including a company located in a Third Country (meaning a country
    outside the European Union).
    The processing of personal data relating to traffic is also a legitimate
    interest, to the extent which is strictly necessary and proportionate to
    guarantee network and information security, meaning the ability of a network
    or an information system to resist, to a given level of security, unforeseen
    events or unlawful or malicious acts that compromise the availability,
    authenticity, integrity and confidentiality of the personal data stored or
    transmitted and the security of the related services offered or made
    accessible through such networks.
    Without prejudice to the above, it should be noted that we may collect
    additional personal data or integrate those already in our possession with
    other data and information collected from third parties (for example our
    suppliers or business partners), also using data and information in the
    public domain, information collected through specific databases or
    additional contact information, credit verification data and information on
    solvency provided by the appointed offices, in compliance with the current
    legislation.
    We may also collect data through the social media used by the User. Where
    the User connects his account to the respective social media site, these
    social media may authorize us to automatically access certain information in
    their possession. With this possibility, the data subject expressly provides
    us access to sites with the various contents contained therein.
    
    
 d. Data collected on third part or by other sources;
    We could collect additional personal data or integrate that available to us
    with other data and information collected by third subjects (for example our
    suppliers or commercial partner), using even data and information of public
    domain, information collected by databases or additional contact
    information, credit verification data and related information to the
    solvency provided by the offices in charge, in compliance with current
    legislation.
    
    We could collect data even by social media used by the User. Where the User
    linked his/her account to his/her respective social media, these social
    media could authorize us to access automatically to specific data in their
    possession. With this possibility the Data subject provide to us direct
    access to these social media’s content.





METHOD OF INFORMATION SHARING WITH THIRD PARTIES

The personal data provided may be shared with third parties only in the
following cases:

 a. Consent of the data subject:
    
    The data subject may authorize us to share (or disclose) his data with (and
    to) other third parties, for example in case he uses our community (such as
    forums or other social media) or where he has expressed his intention to be
    contacted and / or called back for any need or clarification regarding the
    Services.
    
    
 b. Treatment by external entities:
    
    Personal data may be provided to entities connected and / or affiliated with
    our company, service providers and / or business partners that treat them
    according to instructions we provide (eg partners who provide customer
    support services, information technology, payment and / or sales management,
    marketing, data analysis, research and investigation).
    
    Personal data may also be shared with:
    * our suppliers who perform: payment processing, advertising customization,
      prevention, detection, verification of potentially illegal acts, breaches
      of the Services; collection of invoices; consulting, training and event
      organization services;
    * third party providers of shipping services (eg, DHL, UPS, GLS, Italian
      Post Office etc.) with whom we share delivery addresses, contact
      information and shipping codes;
    * providers of websites, applications, services and tools with which we work
      to provide the Services and / or the MySelf App.
    
    
 c. Justice, legal and / or general protection needs
    
    We may keep or disclose personal data where necessary to meet justice needs,
    for example because requested by an administrative authority, a control and
    / or supervisory authority or in the context of a judicial proceeding or, in
    any case, in compliance with the provisions of law, or otherwise for the
    exercise of legal rights or for the defense against complaints and / or
    legal actions or to prevent, detect or investigate illegal activities,
    fraud, abuse, violations of subjective legal positions or where there are
    even potential threats to the security of the MySelf App or to the physical
    security of any person.
    
    Except in the event that one or more recipients referred to in this article
    is in a Third and / or Foreign Country or represents an international
    organization, and without prejudice to the cases expressly permitted by law
    (RSM Privacy Law and / or GDPR) , the Data Controller will not transfer
    personal data to a country other than the Republic of San Marino and / or to
    an international organization.
    
    Any transfer of personal data to a country other than the Republic of San
    Marino and / or to an international organization will in any case take place
    in full compliance with the terms, methods and conditions provided:
    * by the Privacy RSM Law - articles 46, 47, 48 and 50, - where the transfer
      entails, respectively, one of the hypotheses governed therein; as well as;
    * by the GDPR - to articles 45, 46, 47 and 49, - where the transfer entails,
      respectively, one of the hypotheses governed therein.





DATA STORAGE PERIOD

The period of storage of personal data is determined (or determinable) according
to the purpose or the legal basis by virtue of which the processing should take
place.

Except for the case in which the personal data is processed for marketing
purposes, after the termination of the contract the data of the Data Subject
will be kept for the time necessary to correctly and fully perform the services
provided in the contract (including those strictly connected and related to its
termination). In any case the data will be stored for a period of time not
exceeding the highest between the two periods specified below, corresponding to:



 * 10 (ten) years from the termination of the Passepartout Programs and
   Services; or
 * the maturation of the statute of limitations for the commencement of the
   actions and / or initiatives that Passepartout may experience to ascertain,
   exercise or defend a right in court as a result of and / or as a result of
   the contracts established or to be established (with the Interested Parties)
   concerning the Passepartout Programs and Services.





There remains the case in which the data subject has expressly consent, also for
different reasons, for a longer period (in such case the retention period will
correspond to the permitted one) or the legitimate interests must be satisfied
as identified above (in which case the retention period will correspond to the
one required to satisfy such interest).




It also remains the case in which the greater (or less) retention of data must
be carried out to satisfy needs for justice, for example to comply with a
request from the administrative authority, supervisory authority or for the
exercise and / or for the protection (judicial and / or extrajudicial) of rights
or to exercise the defense against complaints and / or legal actions.




Personal data processed for marketing and commercial purposes will be kept until
the data subject has expressed the intention to revoke the consent expressed for
this purpose.




Once the retention period is over, personal data will be safely removed.





RIGHTS OF THE DATA SUBJECT

All interested parties, whose personal data is processed in accordance with the
terms and methods established by RSM Privacy law and GDPR where applicable, may
exercise the rights described below:

 a. Right of access, rectification and deletion of data, limitation and
    opposition to the use of data and right to withdraw consent.
    Except for what provided above in terms of conservation, the data subject
    may, at any time, access his personal data, as well as update, modify, limit
    the processing or request its cancellation.
    If you choose to delete data, please note that although most of the
    information stored will be deleted within 60 (sixty) days, it may take up to
    180 (one hundred and eighty) days to delete all data entered in our systems
    depending on the size or complexity of the systems and procedures used.
    When the processing of data is subject to the consent issued by the data
    subject, this consent may be revoked at any time. You can therefore always
    oppose yourself to receiving newsletters and to the processing of your data
    for marketing and commercial purposes.
    The data subject may also oppose himself to the processing of his data even
    if this activity is carried out for the legitimate interests.
    If asked to withdraw consent, limit the use of data or delete the personal
    data previously provided, we may no longer be able to provide the Services.
    In any case, requests for data deletion are subject to current legal
    requirements and the conservation of documents imposed by laws or
    regulations.
    
    
 b. Right to portability. The data subject has the right to receive his personal
    data in a structured, commonly used and readable format and has the right to
    transmit this data to another data controller.
    
    
 c. Right to lodge a complaint
    The data subject will always have the right to lodge a complaint with the
    competent Supervisory Authority, if he believes that the treatment of his
    data is against the applicable legislation.
    
    
 d. Right to report
    Anyone can send a report to the Guarantor Authority for the protection of
    personal data if they believe that there are violations of the Privacy RSM
    Law.
    
    
 e. Opposition rights
    Opposing the provision issued by the Guarantor Authority for the protection
    of personal data, including administrative sanctions , Passepartout or the
    data subject may file an opposition with a judicial appeal . The opposition
    does not suspend the execution of the provision.
    
    
 f. Automated decision making
    The data subject is also informed that, in the event that the processing of
    the data is based on explicit consent, the interested party has the right to
    revoke the consent at any time without prejudice to the lawfulness of the
    processing based on consent before the revocation.
    Automated technologies are used for decision-making or profiling. In any
    case, no automated decisions will be taken on the interested party that
    could have significant consequences for him, except in circumstances in
    which this decision is necessary to execute a contract or because the User
    has explicitly provided his consent.
    
    

The exercise of the rights described above may be requested by the data subject
by sending an e-mail to the email address of the Operator.





SECURITY MEASURES

We assure the implementation and maintenance of appropriate technical and
organizational measures to guarantee an adequate level of security for every
possible risk, constantly carrying out a series of technical, administrative and
physical checks to keep the personal data of the data subject confidential and
safe.



COMPLETENESS AND CHANGES

This privacy statement is issued to complement and replace any other regulation
that may exist before today regarding the protection of the User's personal data
processed for the same purposes contained herein.




Accept and confirm