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PRIVACY POLICY

The way in which your personal data is used and shared is a matter of the utmost importance to us.

Our privacy policy sets out how we process the personal data we collect via our websites and services.

Who is the data controller?

The controller of any personal data provided via the www.externalytics.com and www.openeconomics.euwebsites (hereinafter the “Website”) is OpenEconomics S.r.l., with registered office in via Giovanni Paisiello 9, 00198 Roma, Italy VAT no. 12504821005, tax no. 12504821005 (hereinafter “OpenEconomics”). OpenEconomics shall process such data in accordance with the provisions laid down by current personal data privacy and protection legislation and by this policy. When subscribing to or accessing the various services, the names of any additional data controllers or processors shall be provided.

OpenEconomics has appointed a Data Protection Officer (DPO) who can be contacted at the following e-mail address dpo@OpenEconomics.eu.

WHAT DATA DO WE COLLECT?

OpenEconomics shall process any personal data that you have provided to us or that we have legitimately collected. This may include contact details or browsing data:

Contact details: name, surname, e-mail address, telephone number, the content of the message you sent and any other personal data you may have provided during your communications with us. We shall process such personal data, should you submit any enquiries, request information or send us communications of any type. This personal data needs to be processed in order to enable us to provide a response to your enquiries or requests. The provision of any further personal data should be considered optional.

Browsing data: during the course of their normal functioning the IT and telecommunications systems, as well as the software processes that exist to ensure the proper functioning of the Website, collect certain data: for example, the access date and time, pages visited, name of the Internet Service Provider and IP address used to access the Internet, the internet address from which you connect to our Website, etc. The transmission of such data is implicit in the use of web communication protocols or is useful for the improved management and optimisation of the data and e-mail sending system.

WHAT IS PERSONAL DATA PROCESSING?

Personal data processing refers to any operation or set of operations performed on personal data using automated means, such as collection, recording, organisation, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

HOW IS YOUR PERSONAL DATA PROCESSED?

Your personal data is processed by OpenEconomics manually and/or using IT and telecommunications tools. OpenEconomics shall process such data for specific purposes and only where there is a specific legal basis for doing so as laid down by current personal data privacy and protection legislation. Specifically, we shall process your personal data only when one or more of the following legal bases have been satisfied:

§you have freely given your specific, informed, clear and unambiguous consent to the processing of such data; §the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract; §OpenEconomics has a legitimate interest in processing such data; §OpenEconomics is legally obliged to process the personal data.

The following table sets out the purposes for which OpenEconomics processes your personal data and the legal bases for doing so.

PURPOSE OF PROCESSING

LEGAL BASIS

To enable users to utilise all the Website’s functions

Performance of a contract

To check the correct functioning of the Website

Performance of a contract

To ascertain responsibility in the event of computer crimes detrimental to the Website; detection, prevention, mitigation or verification of fraudulent or illegal activities in
connection with the services provided by the Website; implementation of security controls required by law

Legitimateinterest

To respond to a query or request submitted by the data subject

Take steps at the request of the data subject prior to entering into a contract

The provision of your personal data is necessary in all cases where the data processing is a legal requirement or when it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. Any refusal may make it impossible for us to fulfil the purpose for which your personal data is collected.

However, the provision of your personal data is voluntary when required for any other purposes: in such cases, the absence of your consent shall have no impact on the completion of the contract. The obligatory or discretionary nature of the data provision shall be indicated at the time of its collection.

WHO ARE THE RECIPIENTS OF THE PERSONAL DATA?

Your personal data may be made available to:

§OpenEconomics employees and consultants who are responsible for data processing, or to our Group's companies within the European Union for the purposes of performing organisational, administrative, financial and accounting activities; §third party companies or other entities, in their role as external data processors, which provide outsourced services to OpenEconomics to enable the Website to function.

WHERE AND FOR HOW LONG IS THE PERSONAL DATA STORED?

Your Personal Data will be processed within the European Union and stored on servers located within the European Union. The same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, recognized by a specific adequacy decision of the European Commission.

Any transfers of Personal Data to non-EU countries, in the absence of a European Commission adequacy decision, will only be possible if Data Controllers and Data Processors involved provide adequate guarantees of contractual nature, including Binding Corporate Rules and Standard Contractual Clauses.

The transfer of your Personal Data to third countries outside the European Union, in the absence of an adequacy decision or other appropriate measures as described above, will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest. In these cases, we inform you that, although the OpenEconomics Group adopts operating instructions common to all the countries in which it operates, the transfer of your Personal Data may be exposed to risks related to the peculiarities of local legislation regarding the processing of Personal Data. Any personal data processed shall be stored in accordance with the principles of proportionality and necessity and, in any case, until the purposes of the data processing have been completed.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

With respect to the personal data provided, in accordance with articles 15 – 21 of EU Regulation 2016/679 (GDPR), you have the following rights:

§to request access the data and request a copy; §to request rectification; §to request erasure; §to obtain restriction of processing; §to object to the processing; §to receive the personal data in a structured, commonly used and machine-readable format and to transmit such data to another controller without hindrance, where technically feasible.

In any case, you have the right, at any time, to object to the processing of your personal data that is performed for the purpose of pursuing Openeconomics’ legitimate interests. You can exercise your rights and withdraw your consent by writing an e-mail to privacy@openeconomics.eu.

Please be aware that it is your right to submit a complaint to the competent data protection authority. If you wish to do so, you can in one of the following ways:

a) registered letter with return receipt to: Garante per la ProtezionedeiDatiPersonali (The Italian Data Protection Authority), Piazza Venezia 11, 00186 Roma, Italy;

b) e-mail to: garante@gpdp.it, or protocollo@pec.gpdp.it;

c) fax to: +39 06 696773785

Should you object to the processing of your personal data, OpenEconomics shall suspend processing such data, except where legitimate reasons for continuing with the processing are demonstrated or where it is necessary for the establishment, exercising or defence of a right in a court of law.

For further information regarding your personal data, please contact OpenEconomics’ DPO at dpo@openeconomics.eu, writing the word “Privacy” in the subject line of the e-mail.