PRIVACY POLICY

PRIVACY NOTICE (SIMPLIFIED)

The purpose of this privacy notice is to provide maximum transparency regarding the information this website collects and how it uses it.

In compliance with obligations arising from national legislation (Legislative Decree No. 196 of June 30, 2003, Personal Data Protection Code, and subsequent amendments) and European legislation (European Regulation for the protection of personal data No. 679/2016, GDPR), this website respects and protects the privacy of visitors and users, making every possible and proportionate effort not to infringe on users' rights.

This website does not publish advertisements or use data for advertising purposes, but it does use third-party services to improve site usage. These third parties may collect user data and then use it to send personalized advertisements on other sites. However, this site makes every possible effort to protect user privacy and minimize the collection of personal data.

For example, the site uses web software in some cases that are configured not to send cookies (and therefore not collect data).

The site also uses social web plugins to simplify content sharing on social networks. These plugins are configured to send cookies (and therefore potentially collect data) only after the user has activated the service.

For information purposes, it should be noted that cookie management is an extremely complex area that involves activity both by the site manager (who may not be able to properly manage third-party cookies) and by the user (who may block cookies essential for site operation). To avoid any form of liability, the use of appropriate tools is recommended. Therefore, for better and simpler protection and to protect privacy absolutely, the use of anti-tracking tools is recommended, which block tracking by sites.

Users' failure to use these tools is attributable to their free choice, so continued navigation and use of the site and service without the use of appropriate anti-tracking tools releases the site manager and data controller from any liability, both civil and criminal.

For more information, please read the complete policy below.

PRIVACY NOTICE (COMPLETE)

Data Processing Parties

The data controller under current laws is the site administrator, Old Money, who can be contacted through the CONTACT section (link at the bottom of the page).

Legal Basis for Processing

This website processes data primarily based on user consent. Consent is given through the banner at the bottom of the page, or through the use or consultation of the site as conclusive behavior, or through registration on the site or subscription to the service. By using or consulting the site, visitors and users approve this privacy notice and consent to the processing of their personal data in relation to the methods and purposes described below, including any disclosure to third parties if necessary for service provision. Through communication forms or service request forms, additional consents are collected relating to the specific purpose of the service.

The provision of data and therefore consent to data collection and processing is optional; users can deny consent and can revoke previously given consent at any time (through the banner at the bottom of the page or browser settings for cookies, or the Contact link). However, denying consent may make it impossible to provide some services and the browsing experience on the site would be compromised.

Data for site security and prevention of abuse and SPAM, as well as data for site traffic analysis (statistics) in aggregate form, are processed based on the legitimate interest of the Data Controller to protect the site and users themselves. In such cases, users always have the right to object to data processing (see User Rights section).

Purpose of Processing

The processing of data collected by the site, in addition to related, instrumental and necessary purposes for service provision, is aimed at the following purposes:

Main Activities Collection of data and information for the purpose of performing the service as indicated in more detail in the terms and conditions (link at the bottom of the page) and which, for illustrative but not exhaustive purposes, consists of main and ancillary activities related to social media management operations.

Statistics (Analytics) Collection of data and information in exclusively aggregated and anonymous form to verify the correct functioning of the site. None of this information is correlated to the individual user of the site, and does not allow their identification in any way. Consent is not required.

Security Collection of data and information to protect site security (spam filters, firewall, virus detection) and users and to prevent or unmask fraud or abuse against the website. Data is recorded automatically and may include personal data (IP address) that could be used, in accordance with current laws, to block attempts to damage the site itself or harm other users, or otherwise harmful activities or crimes. Such data is never used for user identification or profiling and is periodically deleted. Consent is not required.

Ancillary Activities Communicating data to third parties who perform functions necessary or instrumental to service operation (e.g., comment boxes), and to allow third parties to perform technical, logistical and other activities on our behalf. Providers have access only to personal data necessary to perform their tasks, and undertake not to use the data for other purposes, and are required to process personal data in accordance with current regulations.

Data Collected

This website collects user data in two ways:

Data Collected Automatically During user navigation, the following information may be collected and stored in the site's server (hosting) log files:

• Internet Protocol (IP) address
• Browser type
• Device parameters used to connect to the site
• Internet Service Provider (ISP) name
• Date and time of visit
• Visitor's referring web page and exit page
• Number of clicks (if applicable)

This data is used for statistical and analytical purposes, exclusively in aggregated form. The IP address is used exclusively for security purposes and is not cross-referenced with any other data.

Data Provided Voluntarily The site may collect other data when users voluntarily use services, such as comment services, communication services (contact forms, comment boxes) and any other data provided during registration and subscription. Such data will be used exclusively for the provision of the requested service.

Data Retention Period

Data collected by the site during its operation is retained for the time strictly necessary to carry out the specified activities. Upon expiration, data will be deleted or anonymized, unless there are additional purposes for their retention.

Data (IP address) used for site security purposes (blocking attempts to damage the site) is retained for 30 days.

Data for analytics purposes (statistics) is retained in aggregated form for 24 months.

Transfer of Collected Data to Third Parties

Data collected by the site is generally not provided to third parties, except in specific cases: legitimate request by judicial authorities and only in cases provided by law; when necessary for the provision of a specific service requested by the user; for security checks or site optimization.

Transfer of Data Outside the EU

This website may share some of the collected data with services located outside the European Union area. In particular with Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized based on specific decisions of the European Union and the Data Protection Authority, in particular decision 1250/2016 (Privacy Shield which can be found on the information page of the Italian Privacy Authority), therefore no further consent is required. The above-mentioned companies guarantee their adherence to the Privacy Shield.

Security Measures

We process visitor/user data lawfully and correctly, adopting appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. We are committed to protecting the security of your personal data during transmission, using appropriate security software that encrypts information in transit. Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the controller, in some cases, categories of persons involved in site organization or external parties (such as third-party technical service providers, hosting providers) may have access to the data.

Cookies

This site uses cookies, text files that are recorded on the user's terminal or that allow access to information on the user's terminal. Cookies allow storing information about visitor preferences, are used to verify the correct functioning of the site and improve its functionality by customizing page content based on the browser type used, or to simplify navigation by automating procedures (e.g., Login, site language), and finally for analyzing site usage by visitors.

This website uses the following categories of cookies:

Technical cookies - used solely to transmit electronic communication, ensure correct site display and navigation within it. Additionally, they distinguish between various connected users to provide requested service to the right user (Login), and for site security reasons. Some of these cookies are deleted when the browser is closed (session cookies), others have a longer duration (such as the cookie necessary to store user consent regarding cookie use, which lasts 1 year). Consent is not required for these cookies.

Analytics cookies - used directly by the site manager to collect information, in aggregated form, about the number of users and how they visit the site. They are treated as technical cookies if the service is anonymized.

Profiling and marketing cookies - used exclusively by third parties other than the owner of this site to collect information about user behavior during navigation, and about interests and consumption habits, also to provide personalized advertising.

By clicking "ok" on the banner present at first access to the site, browsing the site, registering on the site or subscribing to the service, the visitor expressly consents to the use of cookies and similar technologies, and in particular to the recording of such cookies on their terminal for the purposes indicated above, or to access through cookies to information on their terminal.

Disabling Cookies

Users can refuse the use of cookies and can revoke previously given consent at any time. Since cookies are linked to the browser used, they can be disabled directly from the browser, thus refusing/revoking consent to cookie use, or through the banner at the bottom of the page.

Disabling cookies could prevent the proper use of some site functions, in particular services provided by third parties may not be accessible, and therefore may not be viewable (for illustrative but not exhaustive purposes):

• YouTube videos or other video sharing services
• Social network social buttons
• Google maps

Instructions for disabling cookies can be found at the following web pages: Mozilla Firefox, Microsoft Internet Explorer, Microsoft Edge, Google Chrome, Opera and Apple Safari.

Third-Party Cookies

This site also acts as an intermediary for third-party cookies (such as social network buttons), used to provide additional services and features to visitors and simplify site use, or to provide personalized advertising. This site has no control over their cookies entirely managed by third parties and has no access to information collected through said cookies. Information on the use of said cookies and their purposes, as well as methods for possible disabling, are provided directly by third parties at the pages indicated below.

It should be noted that generally user tracking does not involve identification, unless the user is already registered with the service and is also already logged in, in which case it is understood that the user has already expressed consent directly to the third party when registering for the relevant service (e.g., Facebook).

This website uses cookies from the following third parties:

Google Inc. - for information on data use and processing by Google, we recommend viewing Google's privacy policy and How Google uses data when you use our partners' sites or apps.

Google Analytics - used to analyze site use by users, compile reports on site activities and user behavior, verify how often users visit the site, how the site is found and which pages are visited most frequently. Information is combined with information collected from other sites to create a comparative picture of site use relative to other sites in the same category.

Data collected: browser identifier, date and time of site interaction, referring page, IP address. Data processing location: European Union with service anonymization active.

The collected data does not allow personal identification of users and is not cross-referenced with other information relating to the same persons. It is processed in aggregated and anonymized form (truncated to the last octet). Under a specific agreement (DPA), Google Inc. (data processor) is prohibited from cross-referencing such data with data obtained from other services.

Further information on Google Analytics cookies can be found at the Google Analytics Cookie Usage on Websites page. Users can selectively disable (opt-out) data collection by Google Analytics by installing the appropriate component provided by Google (opt-out) on their browser.

YouTube - platform owned by Google for video sharing. Cookies are set when accessing pages containing the embed and when starting the video, and do not allow user identification unless already logged into the Google profile. For videos on the site, the "enhanced privacy (no cookies)" option has been activated, which means YouTube does not store visitor information unless they voluntarily play the video. Data collected: number and behavior of service users, IP address, information linking site visits to Google account for already logged-in users, video viewing preferences.

Social Network Plugins

This website also incorporates plugins and/or buttons to allow easy content sharing on your favorite social networks. When you visit a page of our website that contains a plugin, your browser connects directly to the servers of the social network from which the plugin is loaded, which server can track your visit to our website and, if applicable, associate it with your social account, particularly if you are connected at the time of the visit or if you have recently browsed one of the websites containing social plugins. If you do not want the social network to record data relating to your visit to our website, you must log out of your social account and probably delete the cookies that the social network has installed in your browser.

Plugins with advanced user privacy protection features are installed on this site, which do not send cookies or access cookies present in the user's browser when opening the page but only after clicking on the plugin.

The collection and use of information by such third parties are governed by their respective privacy policies to which please refer:

• Facebook (cookie policy)
• Instagram (cookie policy)
• Twitter (cookie policy)
• LinkedIn (cookie policy)
• Google (cookie policy)

User Rights

Under European Regulation 679/2016 (GDPR), users may, according to the methods and within the limits provided by current legislation, exercise the following rights:

• Object in whole or in part, for legitimate reasons, to the processing of personal data concerning them for the purposes of sending advertising or direct sales material or for carrying out market research or commercial communication
• Request confirmation of the existence of personal data concerning them (right of access)
• Know their origin
• Receive intelligible communication
• Have information about the logic, methods and purposes of processing
• Request updating, rectification, integration, cancellation, transformation into anonymous form, blocking of data processed in violation of law, including those no longer necessary for pursuing the purposes for which they were collected
• In cases of consent-based processing, receive at the sole cost of any support, their data provided to the controller, in structured form readable by a data processor and in a format commonly used by an electronic device
• The right to file a complaint with the Supervisory Authority (Privacy Authority)
• As well as, more generally, exercise all rights recognized by current legal provisions

Requests should be addressed to the data controller.

Updates

This privacy policy is updated as of February 12, 2021.

CONTACTS

Email: info@oldmoneybrand.com