POLICY STATEMENT PURSUANT TO ART. 13 OF REG. (EU) 679/2016 ON THE USE OF PERSONAL DATA WITHIN THE FRAMEWORK OF THE “OUR BEST ENDORSER IS YOU” SELFIE CAMPAIGN

Dear Employee, we herewith inform you that within the framework of the “Our Best Endorser Is You” selfie campaign, UMBRAGROUP S.p.A., in its capacity as “Controller”, will process your personal data. Therefore, in compliance with “European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data”, UMBRAGROUP, pursuant to Article 13 of the aforesaid Regulation, is hereby providing you with the following information.

1) Purposes of the processing and legal basis:

UMBRAGROUP S.p.A. may process the photographic images you have freely taken via the website which is accessible through the link: https://evolution.umbragroup.com/ for the pursuit of the following purposes:

a) conducting of the “Our Best Endorser Is You” selfie campaign through the acquisition and storage in its database of the images obtained following the use of the application;

b) use and publication of the images for future promotional and company information campaigns.

The legal bases underlying the processing of the data carried out by UMBRAGROUP S.p.A. are the following;

- for pursuit of the purpose under letter a) the processing (in accordance with letter b) of Art. 6 of Reg. (EU) 679/2916) is necessary for the performance of the activity covered by the selfie campaign promoted by UMBRAGROUP S.p.A., “Our Best Endorser Is You”, in which you have freely decided to participate;
- for pursuit of the purpose under letter b) the processing (in accordance with letter a) of Art. 6 of Reg. (EU) 679/2916) may take place only with your explicit consent, given by signing the form consenting to the use of the images.

2) Processing procedures:

The photographic images will be subjected to processing in full compliance with the above-mentioned regulation and the confidentiality obligations inspiring the activity of UMBRAGROUP S.p.A. Such personal data will be processed with both digital instruments and paper media (hard copy), in compliance with the security measures envisaged by the GDPR.

3) Mandatory or optional nature of the provision of data and consent

Participation in the “Our Best Endorser Is You” selfie campaign is completely optional. You may decide to provide or not provide your data (by taking or not taking the selfie). Obviously, if you decide not to provide your image, it will be impossible for you to participate in the aforesaid selfie campaign.
On the other hand, if you decide to participate in the selfie campaign and provide your data, but do not grant your consent to the pursuit of the purpose as specified in letter b) of paragraph 1), this will only entail the impossibility for UMBRAGROUP S.p.A. to use your image in its future company campaigns.

4) Transmission and dissemination of data:

The personal data covered by this policy statement may be transmitted to third parties known to us solely and exclusively for the pursuit of the abovesaid purposes after appointment of an outside Processor pursuant to Art. 28 of Reg. (EU) 679/2016. UMBRAGROUP S.p.A. will not disseminate personal data acquired within the framework of the selfie campaign to third parties, except for the pursuit of the purposes stated in letter b) of paragraph 1), and solely with your explicit consent granted via the form consenting to the use of your image.

5) Data Controller and Processors:

The data controller is UMBRAGROUP S.p.a., headquartered in Foligno, at 1 Via Valter Baldaccini, in its capacity as data controller, in the person of its legal representative pro tempore. The Controller may be contacted at the email address: Privacy.ugi@umbragroup.com

6) Rights of the Data Subject:

You may exercise the following rights with the Data Controller, as per Articles 15 through 21 of the GDPR, at any time:

- Right to access (Art. 15);
- Right to rectification (Art. 16);
- Right to erasure (Art. 17);
- Right to restriction of processing (Art. 18);
- Right to data portability (Art. 20);
- Right to object to the processing (Art. 21);
- Right to withdraw the consent given;
- Right to lodge a complaint with a supervisory authority.

7) Storage period:

The data collected for the purposes of the “Our Best Endorser Is You” selfie campaign will be kept for a period of no more than two years. After this period, the images will be considered obsolescent and will be erased. In the case of images used for pursuit of the purposes stated in letter b) of paragraph 1), the data will be kept on file as a historical record for the entire life of the company.