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Privacy Policy,ARUBA,v.2.3_ASOn_27.01.2022,1,Aruba S.p.A.,Via San Clemente No.53, Ponte San Pietro 24036 (BG) ,VAT Reg. No. 01573850516 | Tax ID No. 04552920482,REA [Administrative and Economic Index] BG 434483 | Share Capital€ 4,000,000 fully paid up | Certified ,email:aruba@aruba.pec.it | Websitearuba.it,Privacy Policy pursuant to Articles 13 and 14 of Regulation (EU) 2016/679,Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the “Regulation”), Aruba S.p.a. (“Aruba”or “Data Controller”), hereby provides ,below to its customers, including potential customers, as well as third parties in general (e.g. delegates, legal representatives, etc.) who come ,in contact with Aruba on behalf of or as mandated by customers, including potential customers (the “Data Subjects”), the information required ,by law relating to the processing of their personal data (“Data”).,ABOUT,US,DataControllerThrough its pro tempore legal representative, Aruba S.p.A., with registered office in Ponte San Pietro ,(BG) at Via San Clemente No. 53,privacy@staff.aruba.it,DataProtectionOfficer(DPO)dpo@staff.aruba.it,HOW WE COLLECT,PERSONAL DATA,The data processed by the Data Controller are acquired as follows:,•from the Data Subject, also through remote communications techniques used by the Data Controller (e.g. websites, smartphone and tablet ,apps, call centres, etc.);,•from third parties (e.g. those arranging transactions for the Data Subject, business information and financial risk companies, external ,companies for market research purposes, etc.).,Data from public sources, such as public registers, lists, public domain documents (e.g. financial statements, information contained in the ,register of companies at the Chambers of Commerce, real estate deeds and other so-called detrimental acts, such as the registration of ,mortgages or the transcription of attachments), as well as data extracted from sources that can be publicly and generally accessed by anyone, ,suchas print or digital newspapers, information from telephone directories, websites of public bodies or other supervisory and control ,authorities, will also be used.,WHAT DATA,DO WE PROCESS? ,CATEGORYOFDATAEXAMPLES OF TYPES OF DATA,PersonalinformationName, surname, street address, nationality, province and municipality of residence, landline and/or ,mobile phone number, fax, taxpayer ID number, email address, copy of identification document ,BankinginformationIBAN and banking/postal account information (except for Credit Card number),LogSourceIPaddress,Log(systemandnetwork),InternettrafficDataDataprocessedforthepurposeoftheconveyanceofacommunicationonanelectronic,communicationsnetworkorforthebillingthereof,WHY ARE THE DATA SUBJECT'S,DATA NEEDED?,PURPOSESOFTHEPROCESSINGLEGAL BASIS,Registration and management of contact requests and/or The legal basis for this processing is to provide the services relating ,information materialsto a request for registration, information and contact and/or to send ,Yourpersonaldataisprocessedtoimplementpreliminaryactionsandinformation materials and to comply with legal requirements. ,thosefollowingaregistrationrequest,tomanageinformationandThe provision of the data is optional. However if the Data Subject ,contactrequests,and/ortosendinformationalmaterials,aswellastorefuses to provide the data, it will not be possible for the Data ,satisfyanyandallotherobligationsarisingherewith.Controller to provide the requested service.,ManagementofthecontractualrelationshipThe legal basis for this processing is to provide the services relating ,The Data Subject's personal data are processed to implement actions to the contractual relationship and to comply with the legal ,in preparation of and following the purchase of a Service and/or a requirements. ,Product, such as management of the relevant order, provision of the ,Service itself and/or production and/or shipping of the purchased ,Privacy Policy,ARUBA,v.2.3_ASOn_27.01.2022,2,Aruba S.p.A.,Via San Clemente No.53, Ponte San Pietro 24036 (BG) ,VAT Reg. No. 01573850516 | Tax ID No. 04552920482,REA [Administrative and Economic Index] BG 434483 | Share Capital€ 4,000,000 fully paid up | Certified ,email:aruba@aruba.pec.it | Websitearuba.it,Product, related invoicing and payment management, handling of any The provision of the data is optional. However if the Data Subject ,claims and/or notifications to the support service and provision of the refusesto provide the data, it will not be possible for the Data ,support itself, sending communications for information as well as Controller to provide the requested service.,fulfilment of any and all other obligations arising from the contract. ,DefendingarightincourtoroutofcourtThe legal basis of the processing is the pursuit of the legitimate interest ,The Data Subject's personal data are processed to ascertain, exercise of the Data Controller, given the balance of the rights of the latter and ,or defend a right of the Data Controller and/or to defend itself against the Data Subject.,third party claims, in court or out of court.,PhysicalandInformationSecurityThe legal basis for this processing is compliance with the law and the ,The Data Subject's personal data are processed to ensure network pursuit of the legitimate interest of the Data Controller, given the ,and information security, the protection of corporate assets and the balance of rights of the latter and the Data Subject.,security of the Aruba Group's offices and corporate systems.TheDataSubjecthastherighttoobjectatanytimetotheprocessing,oftheirpersonaldataforthepurposeinquestion,ongroundsrelating,totheirpersonalsituation.,FraudpreventionThe legal basis of the processing is the pursuit of the legitimate interest ,The Data Subject's personal data are processed to allow controls that of the Data Controller, given the balance of the rights ofthe latter and ,monitor and prevent fraudulent payments by software systems running the Data Subject.,automated checks, prior to the negotiation of Services/Products. If TheDataSubjecthastherighttoobjectatanytimetotheprocessing,these checks return a negative result it will be impossible to complete oftheirpersonaldataforthepurposeinquestion,ongroundsrelating,the transaction. the Data Subject can, of course, express their opinion, totheirpersonalsituation.,request an explanation, or challenge the decision by sending their ,reasons to Customer Support ortoprivacy@staff.aruba.it. ,PromotionalactivitiesforServices/ProductssimilartothoseThelegalbasisfortheprocessingistheDataController'slegitimate,purchasedinterestinpromotingproductsorserviceswhichmayreasonablybeof,TheDataSubject'spersonaldataareprocessedinordertosendinteresttotheDataSubject,giventhebalanceoftherightsofthelatter,emailsrelatingtopromotionsandoffersrelatingtotheDataandtheDataController.,Controller'sServices/Productsidenticaland/orsimilartothoseTheDataSubjecthastherighttoobjectatanytimetotheprocessing,coveredbythecurrentcontractwiththeDataSubject,unlesstheDataoftheirpersonaldataforthepurposeinquestion,ongroundsrelating,Subjectobjectedtotheprocessing,initiallyorduringsubsequenttotheirpersonalsituation.,communications.,Promotional activities for Services/Products offered by ArubaThe legal basis of this processing is the consent initially granted by the ,The Data Subject's personal data are processed in order to send, with Data Subject for the processing itself, which may freely be withdrawn ,specific consent, promotional communications and offers relating to at any time, without prejudice to the lawfulness of any previous ,the Data Controller's Services/Products through traditional methods processing.,(e.g. ordinary mail, landline calls) and/or automated methods (e.g. If the Data Subject refuses to give their consent, it will not be possible ,email, SMS, MMS, fax, pre-recorded calls).to use the relevant services, without this entailing detrimental ,consequences for the contractual relationship with the Data Controller.,Promotional activities for Services/Products of theAruba Group The legal basis of this processing is the consent initially granted by the ,companiesData Subject for the processing itself, which may freely be withdrawn ,The Data Subject's personal data are processed in order to send, with at any time, without prejudice to the lawfulness of any previous ,specific consent, communications of promotions and offers of processing.,Services/Products of Aruba Group companies through traditional If the Data Subject refuses to give their consent, it will not be possible ,methods (e.g. ordinary mail, landline calls) and/or automated methods to use the relevant services, without this entailing detrimental ,(e.g. email, SMS, MMS, fax, pre-recorded phone calls).consequences for the contractual relationship with the Data Controller.,ProfilingThe legal basis of this processing is the consent initially granted by the ,The Data Subject's personal data are processed, with specific Data Subject for the processing itself, which may freely be withdrawn ,consent, for profiling purposes such as the analysis of the transmitted at any time, without prejudice to the lawfulness of any previous ,data and the purchased Services/Products in order to offer advertising processing.,messages and/or business deals that are aligned with user selections. If the Data Subject refuses to give their consent, it will not be possible ,to use the relevant services, without this entailing detrimental ,consequences for the contractual relationship with the Data Controller. ,TO WHOM DO WE COMMUNICATE,THE DATA SUBJECT'S DATA? ,CATEGORIESOFRECIPIENTPURPOSE,Companies belonging to the Aruba Fulfilment of administrative and accounting requirements, as well as those connected with the ,S.p.A. Group (“Aruba Group”)services requested ,Privacy Policy,ARUBA,v.2.3_ASOn_27.01.2022,3,Aruba S.p.A.,Via San Clemente No.53, Ponte San Pietro 24036 (BG) ,VAT Reg. No. 01573850516 | Tax ID No. 04552920482,REA [Administrative and Economic Index] BG 434483 | Share Capital€ 4,000,000 fully paid up | Certified ,email:aruba@aruba.pec.it | Websitearuba.it,Third party providers and companies Performance of services (assistance, maintenance, delivery/shipping of products, performance of ,belonging to the Aruba Groupadditional services, providers of networks and electronic communication services) associated with ,the requested service,Credit andelectronic payment Managing deposits, payments, reimbursements associated with the contractual service,institutions, banks/post offices,External professionals/consultants and Fulfilment of legal requirements, exercising rights, protecting contractual rights, credit recovery,consulting firms ,Financial Administration, Public Fulfilment of legal requirements, defence of rights. lists and registers held by Public Authorities or ,Agencies, Legal Authorities, similar agencies based on specific regulations relating to the requested service,Supervisory and Oversight Authorities ,Formally mandated subjects or those Legal representatives, administrators, guardians, etc.,with recognized legal rights,Persons belonging to these categories operate independently as separate data controllers or as data processors appointed by the Data ,Controller.The Data Controller's personnel that are specially authorised for processing, including interns, temporary workers, consultants, may ,also have knowledge of the data, inrelation to the performance of their assigned tasks. In no case shall personal data be disclosed and they ,shall not, therefore, be accessible by undefined parties, in any form, for example by them being made available or subject toconsultation.,HOW WE PROCESS THE DATA,SUBJECT'S DATA,The data shall be processed using manual, electronic and remote means and in accordance with the requirements set by the relevant ,legislation, which seeks to ensure the confidentiality, integrity and availability of theData, and to avoid material or moral damages.,WHERE WE PROCESS THE DATA,SUBJECT'S DATA,The Data Subject's data is stored in archives located in European Union countries. Where necessary for the pursuit of the stated purposes, ,the Data Subject's Data may be transferred abroad, to countries/organizations outside the European Union guaranteeinga level of personal ,data protection deemed adequate by the European Commission by its own decision or, otherwise, on the basis of other appropriate safeguards, ,such as the Standard Contractual Clauses adopted by the European Commission or the Data Subject's consent. The Data Subject is entitled ,to obtain acopy of any appropriate safeguards, as well as the list of countries/organizations to which the data has been transferred by writing ,to privacy@staff.aruba.it.,HOW LONG WE RETAIN THE DATA,SUBJECT'S DATA,The Data will be held in a form which enables the Data Subject to be identified for no longer than is necessary for the collection purposes, ,given the laws covering the activities and sectors in which the Data Controller operates. Once the periods thus established have transpired, ,the Data will be deleted or processed anonymously, unless further retention is necessary to comply with obligations (e.g. taxand accounting) ,that may persist even after termination of the contract (Art. 2220 of the Civil Code) or to comply with orders issued by Public Authorities and/or ,Supervisory Bodies.,WHAT ARE THE DATA,SUBJECT'S RIGHTS?,The Data Subject shall contact privacy@staff.aruba.itto exercise their the right to obtain, in the cases provided for in the Regulation, access ,to the data concerning him/her, deletion of the data,correction of incorrect data, completion of incomplete data, limitation on processing the ,data, portability of the data and opposition to the processing.,The Data Subject also has the right to lodge a claim with the competent Italian supervisory authority (Italian Personal Data Protection Authority) ,or with the agency performing its duties and exercises its rights in the member State where the breach occurred, as provided for in Art. 77 of ,the Regulation, as well as to file appropriate legal proceedings pursuant to Arts. 78 and 79 of the Regulation.,Privacy Policy,ARUBA,v.2.3_ASOn_27.01.2022,4,Aruba S.p.A.,Via San Clemente No.53, Ponte San Pietro 24036 (BG) ,VAT Reg. No. 01573850516 | Tax ID No. 04552920482,REA [Administrative and Economic Index] BG 434483 | Share Capital€ 4,000,000 fully paid up | Certified ,email:aruba@aruba.pec.it | Websitearuba.it,Privacy Policy for E-Security services / products,In addition to the above, in the event of“E-Security" Services/ Products, such as Certified Email Service (PEC), Digital Signature, DocFly ,Substitute Storage and E-billing, Temporary Stamp, and Sim Card or Smart Card readers of the types presented at www.pec.it, the information ,required by law relating to the processing of personal data is provided below.,ABOUT,US,Joint Data ControllersThrough its pro tempore legal representative, Aruba S.p.A., with registered office in Ponte San ,Pietro (BG) at Via San Clemente No. 53,Through its pro tempore legal representative, Aruba PEC S.p.A., with registered office in Ponte San ,Pietro (BG) at Via SanClemente No. 53,privacy@staff.aruba.it,Data Protection Officer (DPO)dpo@staff.aruba.it,WHAT DATA,DO WE PROCESS?,CATEGORYOFDATAEXAMPLES OF TYPES OF DATA,PersonalinformationCopy of identification document ,Applicant data and registration documents, qualification certificate data and data found in the ,qualification certificate,Log C ertified email messages log, Control Journal (Audit Log),ImagesandsoundsAudio-video footage for remote visual identification,InternettrafficDataData processed for the purpose of the conveyance of a communication on an electronic ,communications network or for the billing thereof,Privacy Policy for SSL Server and Code Signing Certificates,In addition to the above, in the event of Services relating to the supply of SSL Server and Code Signing Certificates, the information required by ,law relating to the processing of personal data is provided below.,ABOUT,US,Joint Data ControllersThrough its pro tempore legal representative, Aruba S.p.A., with registered office in Ponte San Pietro ,(BG) at Via San Clemente No. 53,Through its pro tempore legal representative, Actalis S.p.A., with registered office in Ponte San Pietro ,(BG) at Via San Clemente No. 53 ,privacy@staff.aruba.it,Data Protection Officer (DPO)dpo@staff.aruba.it,WHAT DATA,DO WE PROCESS?,CATEGORYOFDATAEXAMPLES OF TYPES OF DATA,Personal informationRequests to issue certificates and documents provided by the applicants, data contained in the ,qualified certificate, public keys provided by the applicants and personal information of the applicants ,and DataControllers (in the event of being different parties). results of checks performed by the CA. ,Certificate suspension or revocation requests,LogOriginating IP addresses associated with compilation of the remote form and the logs on the ,associated transactions





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