PRIVACY STATEMENT

AS PER ARTICLE 13 OF ITALIAN LEGISLATIVE DECREE NO. 196/2003
(PROTECTION OF INDIVIDUALS AND OTHER PARTIES WITH REGARD TO THE PROCESSING OF PERSONAL DATA)

Dear Client, as required under Italian Legislative Decree No. 196/2003, repealing Italian Law No. 675/1996, and the associated legislation on the “Protection of individuals and other parties with regard to the processing of personal data”, we, in our capacity as the Controller, hereby wish to bring to your attention the following information regarding the use of your personal data.

CATEGORIES AND SOURCES OF PERSONAL DATA
Personal data may be acquired by BTicino S.p.A. (the Controller) in one of the following manners:

• provided by your or learnt by us, including incidentally, during the performance of contractual activities;
• acquired from a third party;
• acquired from a publicly-accessible database.

Personal data acquired by us belong to the following categories: identification data, administrative data, accounting data, IT data. Individual categories are automatically determined from the specific data collection forms prepared in relation to the various services offered by us.

PURPOSES OF THE PROCESSING FOR WHICH THE DATA ARE INTENDED
Personal data are processed as part of BTicino S.p.A.’s regular activities for the following purposes:

• as required in conformity with legal, contractual or pre-contractual obligations relating to the activities connected with the fulfilment of our company objects or to ensure compliance with legal and contractual obligations;
• for purposes connected with obligations arising from the applicable law, regulations and EU legislation or with guidelines issued by entitled public authorities or by supervisory bodies;
• for purposes that are strictly connected with and instrumental to the management of relations with Clients, within the context of the activities conducted by BTicino S.p.A. under its Articles of Association or the applicable law;
• for purposes that are functional to BTicino S.p.A.’s business activity. This includes:
• measuring the level of client satisfaction on the quality of the services supplied to Clients and the activities conducted by BTicino S.p.A., either directly or through specialist companies, by means of direct or telephone surveys, questionnaires, etc.;
• sending commercial, advertising or promotional communications regarding the activities or services offered by the Controller or by a third party via automated (e.g.: e-mail, text message, etc.) or traditional means (e.g.: operator telephone call);
• identifying errors generated by the Power On app; information collected may include, without limitation: version of operating system installed on the smartphone; make and model of the smartphone; technical details that can help identifying the error.

OBLIGATORY/VOLUNTARY NATURE OF DATA PROVISION AND CONSENT
Provision of the data is obligatory to the extent required to ensure compliance with the applicable law; it is voluntary but necessary to the extent required to enable the Client to use the activities/services offered by the Controller, as well as for the conclusion of the specific contractual relationship and the fulfilment of the obligations deriving from it; it is also voluntary but necessary to the extent required for the attainment of the additional purposes pursued by the Controller under sub-paragraph (4). A refusal to provide the data may make it impossible:

• to complete certain activities that may be in the direct interest of the data subject, including:
• entering into a contractual relationship with the Controller
• commencing or continuing the supply of the services:
• currently under way
• currently being arranged;
• that may be arranged in the future
• pursuing the purposes listed in this privacy statement.

Please be informed and keep in mind that the purposes under sub-paragraphs (1), (2) and (3) fall in the categories exempt from prior consent under article 24 of Italian Legislative Decree No. 196/2003, exclusively as regards those data that are intrinsic in and strictly necessary for the existence of the contractual relationship. For the purposes under sub-paragraph (4), items a) and b), consent is required and failure to provide consent shall make it impossible to process the data for said purposes; consent is not required for the purposes under sub-paragraph (4), item c), as this activity involves the collection of aggregated data that are processed anonymously (i.e.: they may not be traced back to the data subject);

METHODS OF PROCESSING
The data will be processed using manual, IT or electronic means, through a logic that is in strict connection with the above purposes and in such a manner as to protect the security and confidentiality of the data.

MAXIMUM LENGTH OF TIME FOR WHICH THE DATA MAY BE STORED
As regards the purposes under sub-paragraphs (1), (2) and (3), the data may be kept for the length of time indicated in the applicable legislation (to which express reference is made), including, in particular, tax-related legislation; as regards the purpose under sub-paragraph (4) a), the data may be processed for up to twice as long as the duration of the contractual relationship in place between the Parties, starting from the date of termination of said contractual relationship.

CATEGORIES OF RECIPIENTS TO WHOM THE DATA MAY BE DISCLOSED
For the performance of its activities, BTicino S.p.A. may disclose the data to:

• Legrand SA (parent company) and its subsidiaries;
• entities involved in the prevention and control of insolvency risks;
• entities involved in fraud control and debt collection;
• entities providing certification of the activities offered by BTicino S.p.A.;
• entities providing verification and/or audit of the activities offered by BTicino S.p.A.;
• IT supplies and IT support companies;
• developers and estate agencies involved in the project using BTicino systems.

Disclosure of the data to the above third parties, other than the Controller, the Processors (internal or external) and the persons authorised to process the data, as identified and appointed in accordance with articles 29 and 30 of Italian Legislative Decree No. 196/2003, as amended and supplemented, is possible subject to express consent, except where disclosure is required by law or is necessary in order to perform the obligations arising from the agreement that you have entered into or to fulfil your specific requests before the conclusion of said agreement.

BTicino S.p.A. makes use of various external parties for the processing of the data. The recipients included in the categories of recipients to whom the data may be disclosed will, in their capacity as “processors”, process the data in accordance with the applicable law, within the context of the existing contractual relationship. A comprehensive list of these companies is available from our offices.
The geographic area of disclosure includes the Italian territory and may extend outside the same, although within the European Union, except as otherwise notified within the Group, and always with the safeguards and guarantees as set out under articles 42 and 43 of Italian legislative Decree No. 196/2003. The data may not be disclosed to unidentified recipients.

RIGHTS OF THE DATA SUBJECT UNDER ARTICLE 7 OF ITALIAN LEGISLATIVE DECREE NO. 196/2003

Please be also informed that, in accordance with article 7 of the above-mentioned Italian legislative decree, the data subject shall have specific rights regarding the processing of his/her personal data.
In particular, in accordance with the above article 7, the data subject shall have the right to obtain confirmation as to whether or not personal data relating to him/her exist, even if they have not been recorded yet, and to obtain communication of said data in an intelligible form. The data subject shall have a right to obtain information on: a) the source of the personal data; b) the purposes and methods of processing; c) the logic involved in any electronic processing; d) the identification details of the controller, the processors and the representative designated under article 5, paragraph 2; e) the recipients or categories of recipients to whom the data may be disclosed or who may access the data in their capacity as designated country representative, processors or persons authorised to process the data. The data subject shall have a right to obtain: the updating, rectification or, should it be in his/her interest, supplementation of the data; b) the erasure, transformation in anonymous form or blocking of data which do not comply with the provisions of the applicable law, including any data that no longer need to be stored in relation to the purposes for which they were originally collected or processed; c) certification that notification has been given to any and all third parties to whom the data have been disclosed of any and all operations carried out in compliance with items a) and b) above, including with regard to their content, unless this proves impossible or involves a disproportioned effort in relation to the right protected. The data subject shall have a right to object, in whole or in part: a) on legitimate grounds, to the processing of personal data relating to him/her, even when they are relevant to the purposes for which they were originally collected; b) to the processing of personal data relating to him/her for purposes of direct marketing, direct selling, market research or advertising.

CONTROLLER, PROCESSORS AND PERSONAL DATA-RELATED COMMUNICATIONS

The Controller is:
BTicino S.p.A.
Viale Borri, 231
21100 Varese – Italy

The person responsible for responding to personal data-related requests, for the purposes of article 8 of Italian Legislative Decree No. 196/2003, is BTicino S.p.A.’s current Head of Sales, whose address for the purposes of his/her office shall be at BTicino S.p.A.’s registered office.

Communications may be sent in writing to:

• BTicino S.p.A., Viale Borri 231, 21100 Varese - Italy;
• by ordinary mail to the above address;
• by fax to +39 0332 423675

An up-to-date and complete list of processors is available at BTicino S.p.A.’s registered office.