COMPANY INFORMATION

Company: Dazme S.r.l.

Headquarters: via Lorenzo Mascheroni 14, 20145, Milano,

PEC: dazme@legalmail.it

General contact E-mail : info@dazme.com

Compliance contact report E-mail: compliance@dazme.com

REA: MI – 2676524,

Company VAT : 12664610966

(precedes, “Dazme”).

Website: www.dazme.com (“Site”)

App: Dazme® App published on the main mobile device platforms  (“App”).

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SITE TERMS OF USE

( Compliance with Terms of Use ) The use of the Site by each visitor (the “User”) is subject to the following terms and conditions of use (the “Terms”). The User undertakes to comply with the Terms during their access and use of the Site. If the User does not intend to comply with the Terms they are invited to immediately cease using the Site.

( Purpose of the Site ) DAZME® publishes the Site to provide information and promote the identity, services and products of DAZME® . The use of the App is subject to specific terms and conditions, which the user of the App is required to approve during installation, including a detailed privacy policy pursuant to art. 13 GDPR. The other DAZME® services and products are subject to specific terms and conditions, agreed with customers during the contract phase.

( Ownership ) The User is informed, acknowledges and accepts that DAZME® is the exclusive owner of the Site and all material and data contained therein (including texts, information, data, icons, photographs, illustrations, multimedia contents, videos, codes HTML and other source code) (the “ Material ”), as well as any Industrial Property Rights (as defined below) that may be present on the Site, whether or not incorporated into the Material.
“ Industrial Property Rights ”, or “ IPR ”, means all industrial property rights, including all trademarks, whether registered or not and , de facto and trade names, logos, patents, designs and models, model patents utilities, rights in domain names, copyrights and information fixed in any tangible medium of expression (whether or not protected by copyright law), moral rights, distinctive features of trade, trade secrets and know-how, related similarities, ideas (whether or not protected by trade secret laws), rights in software, apps, databases and code , including front-end and back-end code , right to sue for trademark infringement or unfair competition and any other subject matter protected by industrial property law, whether now or hereafter existing, whether under statutory or common law, in any jurisdiction in the world, for all media now known or hereafter developed, including all fields of art, combinations, discoveries, formulas, programming codes, algorithms, specifications, production techniques, technical developments, systems, computer architecture, works of art, software, programming, applets, scripts, designs, processes and business methods. This also includes all applications and rights to request and obtain renewals or extensions and rights to assert priority of such rights and all similar or equivalent rights or protections that now or hereafter exist or will exist anywhere in the world. Use of the Site does not imply assignment or other right or title to the User with respect to the Site, the Material and the IPR.

( Compliance ) 2.1 The User agrees to use the Site in accordance with these Terms and all laws applicable to it. You must not use the Site in any manner that could cause harm to any third party, including damaging, disabling, overburdening, or impairing the Site or interfering with any other party’s use and enjoyment of the Site. You must not attempt to gain unauthorized access to any portion of the Site, accounts, computer systems or networks connected to the Site through hacking, password mining or any other means. You agree not to transmit or upload viruses, malware or other harmful content that could interrupt or damage the Site or other users’ devices.

( Non-commercial use of the Material ) The User can use the Site by browsing its pages; the User undertakes not to download, upload, copy, photograph, take screenshots, store, translate, modify, reformat, manipulate, print, reproduce, display in public, create derivative copies, assign, license, access through automatic processes or through bots or artificial intelligence, sell or resell, distribute, reverse engineer, reverse look up, mirroring, framing, linking, hacking and password mining, carry out activities that place unreasonable load on the network and structure, use devices or software suitable for interfere with the functionality, transmit or otherwise use the Material for commercial and/or advertising purposes, unless otherwise agreed with DAZME® .

( Disclaimer, Limitation of liability ) The Site, including the Material and IPR, is published and promoted by DAZME® (or subsidiaries, connected or affiliated with DAZME® authorized by it) in the state in which it is located from time to time (“ as-is and as-available”). To the maximum extent permitted by applicable law, DAZME® and its subsidiaries, affiliates or subsidiaries will in no event be liable for any damage or loss arising directly or indirectly from the use of the Site, and this is made available without any implied or express warranty towards the User, including guarantees of suitability for the User’s purposes, accuracy, completeness, truthfulness and safety (including the express exclusion of any guarantee or liability connected to unauthorized access by third parties to communications, loss of data, loss or corruption of software and hardware, storage defects, viruses, Trojan horses, and worms).
Browsing and using the Site does not give the User any right, legitimate expectation, or other title towards DAZME® or companies controlled, connected, or affiliated with DAZME® .
Browsing the internet is by its nature subject to risks. Third parties may intercept and fraudulently use your data transmissions and browsing experience. The User surfs the internet at their own risk and is invited to take all appropriate organizational and protection measures for their systems, including the use of antivirus, anti-malware and other IT security tools. Use of the Site is under the sole responsibility of the User and, to the maximum extent permitted by applicable law, DAZME® and its subsidiaries, affiliates or affiliates are expressly exonerated by the User from any liability and indemnified by the User for any claim of third parties towards DAZME® and its subsidiaries, connected or affiliated companies linked to actions of the User.

( Submissions by the User ) Unless a confidentiality and/or retention of title clause is added during sending, any material sent by the User to DAZME® , including information, data, content, documents, photographs, graphics, videos, file, code, comment, suggestion, idea, information and data (the ” User Material “) will be considered non-confidential and non-proprietary, will be acquired, will become the property of and may be used by DAZME® , including for commercial purposes, free of charge, without liability and without obligation of confidentiality. DAZME® and its controlled, connected or affiliated companies reserve the right to use the User Material, directly or indirectly, also for commercial, promotional, advertising and product development purposes, without this giving rise to rights for the User, legitimate expectations or other title, which are expressly renounced at the time of sending without confidentiality clause and/or retention of title of the User Material. The User is invited not to send material for which they do not agree to these terms, or to expressly specify their title and expectation of use of the such material.

( Links to third party sites ) The Site may include links to third party sites, or textual or graphic references to third party names and brands. The links are intended to be provided for the sole purpose of facilitating navigation and understanding. The contents and industrial property rights of such third parties remain reserved to the third parties, as specified from time to time in the terms and conditions published by the third parties on the respective platforms, which the User is invited to verify and respect. Unless expressly stated, DAZME® and its subsidiaries, connected or affiliated companies are independent entities with respect to third parties and will not be considered controlled, connected, or affiliated with third parties. DAZME® and its subsidiaries, connected or affiliated companies do not exercise any control or monitoring over such sites and their contents and, therefore, links to third party sites must be considered covered by the Disclaimer indicated above.

( Suspension ) DAZME® does not guarantee the continuous publication of the Site and reserves the right to suspend, temporarily or permanently, with or without notice, the publication of the Site.

( Applicable law ) Access to and use of the Site as well as these Terms are governed by Italian law. The Court of Milan, Italy, will be the only competent body for any dispute directly or indirectly arising from access to and use of the Site and these Terms.

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PRIVACY – SITE, SOCIAL NETWORKS AND OTHER ONLINE PLATFORMS

1. PARTIES INVOLVED IN THE TREATMENT

This information, published pursuant to art. 13 GDPR, applies to every interested party whose Personal Data is processed by the Data Controller during the latter’s online activity, in relation to the use of activities on the Site (as defined above), on social networks and on other online platforms.

“ Interested Party ” is considered to be the identified or identifiable natural person whose Personal Data is provided to the Owner. A natural person is considered identified or identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more elements characteristic of their or her identity. physical, physiological, genetic, psychological, economic, cultural, or social.

The “ Owner ” is DAZME® , as detailed above.

DAZME® has designated a “ Data Protection Officer ”, or “ DPO ” pursuant to §37 GDPR, Dr. Cosimo Calabrese, whose contact address is: dpo@dazme.it .

Within its own structure, the Data Controller may appoint subjects who can assume the role of internal data controllers, or other data processors who may, acting under the authority of the Data Controller, have access to Personal Data and who will be instructed by the Data Controller on the methods of processing.

Any reference to the ” Recipients ” is intended to include the categories of recipients to whom the personal data of the interested party may be communicated, also in consideration of the outsourcing to third parties of some processes, functions, or activities by the Data Controller. In general, even where not specified, IT service providers, consultants and professionals are included in the recipients. The Recipients may operate as independent owners, joint controllers (§26 GDPR) or managers (§28 GDPR) of the processing in relation to the type of processing to be carried out. If the Recipients qualify as independent owners or joint owners, they will be required to provide their own privacy information. Furthermore, in relation to joint controllers, the interested party will be able to exercise their rights under the GDPR towards and against each data controller.

2. DATA PROCESSED
“ Personal Data ” means any information relating to an interested party.

Personal Data is collected by the Data Controller through the Site, social networks or other online promotion and advertising platforms, by means of (a) spontaneous provision by the Interested Parties (for example contact emails or interactions on social networks with the Owner), (b) through third parties (e.g. social media, administrative and judicial authorities), (c) combination of non-personal data carried out through automatic tools which could make the non-personal data personal.

The processing involves exclusively common data: personal identification data, contact data, activity on social media and on third-party online promotion and advertising platforms, data relating to work activity (for example in the case of spontaneous application).
We may also process non-personal data, not directly related to an identified or identifiable individual, such as (a) demographic information, statistics or aggregate information (for example, aggregation of data to calculate the percentage of users accessing a specific functionality of the website); (b) technical information, such as the full/partial Internet Protocol (IP) address you use, browser type and version, time zone settings, browser plug-in types and versions, or operating system and platform ; (c) non-personal details related to users’ interactions with the Site, such as full Uniform Resource Locators (URLs), page interaction information, length of visits to certain pages, page response times, download errors , or methods used to leave the page. If the combination of such non-personal data allows us to trace an identified or identifiable natural person, this will be considered an interested party, and the provisions of this information will apply to this person.

The Data Controller does not process particular categories of personal data (§9 GDPR, and therefore personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as processing genetic data, biometric data intended to uniquely identify a natural person, data relating to the person’s health or sexual life or sexual orientation) or personal data relating to criminal convictions and offenses (§10 GDPR).

The Site may include links to third-party websites, plug-ins, social networks, or applications. By clicking on such links or enabling such connections, you may allow the third party to collect or share data about you. The Owner cannot control such third-party sites, applications and services and invites the interested party to read the specific privacy policies of such third parties.

3. PRINCIPLES APPLICABLE TO PROCESSING (§5 GDPR)
Personal Data is:
a) ( principle of lawfulness, correctness and transparency ) processed in a lawful, correct and transparent manner towards the interested party;
b) ( principle of purpose limitation ) collected for specified, explicit and legitimate purposes, and subsequently processed in a way that is not incompatible with those purposes;
c) ( principle of data minimization ) adequate, relevant and limited to what is necessary with respect to the purposes for which they are processed (“data minimization”);
d) ( accuracy principle ) exact and, if necessary, updated; all reasonable measures will be taken to promptly erase or rectify data that is inaccurate in relation to the purposes for which they are processed;
e) ( principle of limitation of conservation ) stored in a form that allows the identification of the interested parties for a period of time not exceeding the achievement of the purposes for which they are processed;
f) ( principle of integrity and confidentiality ) processed in a manner that guarantees adequate security of personal data, including protection, through appropriate technical and organizational measures, from unauthorized or unlawful processing and from accidental loss, destruction or damage.

4. GENERAL INFORMATION AND DEFINITIONS
When we refer to the ” Privacy Legislation ” we mean Regulation (EU) 2016/679 (” GDPR “) and the primary and secondary Italian legislation applicable to the processing of personal data
When we refer to the ” Legal Bases ” we mean the legal bases on which the processing is based, as provided for by §6 GDPR, and therefore: (a) consent ( the interested party has expressed consent to the processing of their data personal for one or more specific purposes); (b) contractual obligation (processing is necessary for the execution of a contract of which the interested party is a party or for the execution of pre-contractual measures adopted at the request of the interested party); (c) legal obligation (processing is necessary to fulfill a legal obligation to which the data controller is subject) (f) legitimate interest (processing is necessary for the pursuit of the legitimate interest of the data controller or third parties , provided that the interests or fundamental rights and freedoms of the interested party which require protection of personal data do not prevail, in particular if the interested party is a minor; without limitation, the exercise of the right of defense in court is considered to be included or in the event of a dispute with the interested party, the legal basis of which is found in Article 6(1)(f) of the GDPR, and direct marketing activities pursuant to Recital 47 of the GDPR).
Other capitalized terms not defined here will be deemed to have the same meaning as set out in the GDPR.

5. PURPOSE OF THE PROCESSING AND LEGAL BASIS
The Site and the social channels and other promotional and advertising channels used by DAZME® collect exclusively Personal Data transmitted voluntarily by the interested party.
The collection and processing of such data are carried out in order to:
(a) verify the requests made by the interested party (for example the Personal Data transmitted by email from the “Contacts” area); in compliance with the art. 6 of the GDPR, the legal basis of the processing is the fulfillment of the services requested by the user (par. 1, letter b)).
(b) comply with any legal obligations to which the Data Controller is subject; fulfill obligations deriving from law, regulations, national and community legislation or an order from the Authority. In compliance with art. 6 of the GDPR, the legal basis of the processing is the fulfillment of a legal obligation (par. 1, letter c)).

In addition to these data, freely transmitted by the user on the site, navigation data may also be processed, collected following the use of our services by the user and, in particular:
– information about the device with which the user connects;
– device-specific information (e.g. device type, mobile network information);
– log information. During your use of our services or viewing content provided by the Owner, we may automatically collect and store some information in server logs . This information may include: data about how you use our service, such as search queries; information on internet connection data such as IP address and all data connected to it; information about device events such as system activity, hardware settings, browser type and language, date and time of requests and referring URLs; cookies that may uniquely identify your browser or account.
We and our partners may use various technologies to collect and store information when the Site is visited and/or a Company service is used which may involve sending one or more technical cookies or anonymous identifiers to the user’s device.
We invite you to consult the following “COOKIES” section.

6. PROCESSING METHODS
The processing of Personal Data is carried out through IT procedures or in any case telematic means by internal and/or external subjects specially trained, instructed and authorized. The data is stored in computer and telematic archives. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
In case of processing based on consent or contract and carried out using automated tools, the User has the right to receive the Personal Data in a structured, commonly used, and machine-readable format, and, if technically feasible, to transmit them to another owner. without impediments.
Without prejudice to the fact that no processing can be completely safe, the Data Controller has equipped itself with procedural and organizational safeguards to ensure compliance of the processing with the Privacy Law. The interested party is invited to pay maximum attention before providing consent and in managing their Personal Data in interaction with the Owner (for example, careful use of passwords, devices, firewalls, and anti-virus).

7. NATURE OF THE CONFERMENT AND CONSEQUENCES
The provision of Personal Data is necessary to be able to provide the services requested through the Site or to proceed with promotional and advertising activities (for example, comments, likes or responses by interested parties to marketing posts on social networks, which involve the disclosure of the identity of the interested party). The absence or refusal to provide Personal Data will make it impossible to provide the requested service.

8. PLACE OF DATA PROCESSING
The Data Controller operates from Italy, but also on a global scale, and could process the Personal Data even in a State other than the one in which they were originally provided, and, therefore, the Data Controller, as well as the Recipients, could, for them organizational structure, process Personal Data in other states of the European Union, as well as outside the European Union, provided that (a) in countries that guarantee an adequate level of protection, as established by the European Commission pursuant to art. 45 of the Regulation, without prejudice to the rights of the interested party, or (b) towards a third country only in the presence of adequate guarantees and on the condition that the interested parties have enforceable rights and effective means of appeal pursuant to the articles. 46 and 47 of the Regulation, or (c) in the presence of the specific conditions provided for in art. 49 of the Regulation.
The processing relating to the Site is conducted using IT tools installed at the AWS Amazon Server Farm in Germany (EU).
The processing connected to activities on social networks or other online promotion and advertising platforms will be carried out by DAZME® in Italy; such Personal Data may also be collected and processed by social network providers and other online platforms, independently by DAZME®, in accordance with their architecture, pursuant to their respective privacy policies, which the interested party is invited to read.

9. DATA RETENTION TIME
The browsing data is anonymized at the end of the session, unless legal obligations or other legitimate reasons induce the Data Controller to behave differently (for example following a request from the judicial authority or in the case of activities conducted to the detriment of Dazme®).
The other data processed are kept for the time necessary to provide the service requested by the user, after which they are aggregated and made anonymous.

10. RIGHTS OF THE INTERESTED PARTY (§§ 15-22 GDPR)
The interested party can exercise the rights provided for by articles 15 to 22 of the GDPR at any time by contacting the Data Controller at the following references:

Dazme Srl
via Lorenzo Mascheroni 14, 20145, Milan,
PEC : dazme@legalmail.it
Email : compliance@dazme.com

or by contacting the Data Protection Officer at dpo@dazme.it ,

in particular, to exercise the right to receive information concerning them from the Data Controller (§13 and 14 GDPR), the right of access (§15 GDPR), the right of rectification and cancellation, also known as the right to be forgotten (§16 GDPR), the right to limit processing (§18 GDPR), the right to data portability (§20 GDPR), the right to object (§21 GDPR), the right not to be subjected to a decision based solely on processing automated, including profiling (§22 GDPR).

Without prejudice to the interested party’s right to appeal to any appropriate forum for the protection of their or her rights, the interested party may also complain at any time to the Guarantor Authority for the Protection of Personal Data at the following contacts: website: www.garanteprivacy.it; Piazza di Montecitorio n. 121 00186 ROME Fax: (+39) 06.69677.3785 Telephone switchboard: (+39) 06.696771 E-mail: garante@gpdp.it.

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PRIVACY – APP AND CUSTOMERS

The use of the App (as defined above) is reserved for specifically authorized users (the ” App Users “) and involves the processing of Personal Data. In relation to this processing, DAZME® publishes and keeps updated a specific information notice pursuant to art. 13 GDPR (“ App Policy ”), specifically accepted initially and confirmed from time to time by the App Users. For further details and information, please refer to the App Policy.

The commercial relationships between DAZME® and its customers involve the processing of Personal Data transmitted during the commercial relationship, including the relevant directors, attorneys, and employees. In relation to this processing, DAZME® and the customer sign specific agreements and information regarding the confidentiality of personal data, including the roles of the subjects involved and the rights of the interested parties. For further details and information, customers are invited to consult the privacy agreements in question in existence from time to time.

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PRIVACY – EMPLOYEES, COLLABORATORS, CANDIDATES

The social activity of DAZME® involves the establishment of working and collaboration relationships, which involve the processing of one’s own and third parties’ Personal Data. In relation to this processing, DAZME® and its employees and collaborators sign specific agreements and information regarding the confidentiality of personal data, including the roles of the subjects involved and the rights of the interested parties. For further details and information, employees and collaborators are invited to consult the privacy agreements in place from time to time.

If natural persons spontaneously send their application to DAZME®, they assume the status of Interested Parties and the provisions of the “PRIVACY – SITE, SOCIAL NETWORKS AND ONLINE PROMOTIONAL AND ADVERTISING ACTIVITIES” section above apply. In this case, the retention time of the relevant Personal Data will be limited to the time necessary to provide the service requested by the user, in any case within a maximum of 6 months, at the end of which the email and CVs will be deleted. In light of the fact that social networks and other online platforms may have internal rules for archiving and deleting messages and means of communication between users, interested parties are invited not to submit their application through these methods, which could prevent or limit DAZME® ‘s power to stop storing Personal Data.

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COOKIES

( General information ) The Site uses cookies to function correctly, improve the User’s browsing experience, and perform performance analyzes of the Site. Cookies are small text files that are stored on the User’s computer or mobile device when visits the Site. Cookies allow the Site, among other things, to remember the User’s actions and preferences (for example, language or font size) so that we can offer a more personalized browsing experience.

( Types of Cookies ) Cookies can be installed by this Site (first-party cookies) but also through third-party sites that install them through the first site (third-party cookies, for example images, videos and links to content developed by third parties) Cookies can be classified based on their characteristics and purposes of use.
Based on their characteristics, cookies can be: (a) Technical : Technical cookies are necessary for the correct functioning of the website and allow you to navigate effectively. Without them, some features may not be accessible. (b) Profiling : Profiling cookies are used to collect information on user behavior and personalize their browsing experience. These cookies help us improve our services and offer more relevant content.
Depending on the purpose, cookies can be: (c) Necessary : Necessary cookies are essential for the correct functioning of the website and allow you to navigate effectively. Without them, some features may not be accessible. (d) Analysis : Analysis cookies help us understand how users interact with the site, providing us with information on the pages visited, the time spent on the site and any problems encountered. (e) Profiling : Profiling cookies are used to collect information on user behavior and personalize their browsing experience. These cookies help us improve our services and offer more relevant content.

( Purpose of the Processing ) DAZME® uses cookies to: (a) allow navigation and use of the Site’s features; (b) collect information about your use of the Site to improve the experience. (c) evaluate the performance of the Site and conduct analyzes on its functioning and aimed at its implementation.

( Legal basis ) For strictly necessary cookies, the legal basis of the processing is the execution of a contract with which the User asks DAZME® to access and use the Site; for other cookies the legal basis is the User’s consent.

( Consent ) In addition to cookies strictly necessary for the functioning of the Site, DAZME® uses cookies to remember the User’s preferences and evaluate the performance of the Site, as clarified here. During the first access to the Site the User is asked to express their/her consent and preferences regarding cookies. Cookies can be rejected, or accepted, completely or in a customized manner. The choice is recorded in a special technical cookie which allows the User’s choice to be remembered for their next accesses. Failure to accept cookies does not prevent browsing, but blocking some cookies may impact the browsing experience and the services that the site is able to offer. By continuing to browse without expressing any express preferences, the User explicitly consents to the use of all cookies. Consent can always be changed in the User’s browser settings.

( Management of Cookies ) The User can configure the browser to accept/reject cookies or receive warnings. Disabling it may affect your browsing experience. Each browser has its own cookie management rules; To manage cookies, the User is invited to follow the instructions provided by their browser.

( Recipients ) The data collected through cookies will be accessible and processed by Recipients identified by the Data Controller, including internal and external resources dedicated to the management of the IT infrastructure. The Recipients conduct their processing activity according to precise instructions given by the Owner.

( Rights of the interested party ) Please refer to the previous section “PRIVACY – SITE, SOCIAL NETWORKS AND ONLINE PROMOTIONAL AND ADVERTISING ACTIVITIES” above, with particular regard to art. 10.
Specifically with respect to cookies, the interested party also has the right to withdraw consent for non-necessary cookies without compromising the operation and functionality of the Site.

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SITE CHANGES
DAZME® reserves the right to update and modify from time to time any element or information on the Site, including the information on this page. These changes will be made by updating the Site. The User is invited to periodically view the Site and this page.