USER REGISTRATION POLICY

pursuant to art. 13 of the Regulation (EU) 2016/679

a) About us: OVS S.p.A., with registered and administrative office in Mestre (VE), via Terraglio n.17, VAT no. 04240010274 (hereinafter the "Company"), is the Data Controller; in fact, it is the company that collects and processes the personal data you provide by filling in this form, and, pursuant to art. 13 of Regulation (EU) 2016/679 (hereinafter "the Regulation"), provides you with the following information.

b) Why we collect data: the compulsory data you are providing us with by filling in the form, the mandatory data and, where applicable, the optional data, will be used for the following purposes:

  1. 1)  (i) allowyou to register on the OVS website www.ovs.it; (ii) enable you to proceed with the purchase of products, fulfil your obligations and exercise your rights arising from the contract concluded (iii) comply with legal, regulatory, EU, tax or accounting obligations (invoicing, record keeping and accounting entries).

  2. 2)  Profiling: If you agree and provide us with your consent, we will use the data from your purchase details for their analysis and therefore for profiling purposes, in order to improve our commercial offer thanks to a better knowledge of our customers and their consumption habits;

  3. 3)  Marketing​: to contact you - by phone, mail, e-mail, sms, mms, app, push notifications etc. - for advertising or commercial communications relating to exclusive benefits that OVS and its Business Partners reserve for their members, as well as to gauge your satisfaction with our services. - for advertising or commercial communications relating to exclusive advantages that OVS and its commercial Partners reserve for their members, as well as to gauge your level of satisfaction with our services. These communications may also be specially personalised, if you have given your consent to the profiling referred to in point b) 2, and thus to analyse your consumption habits. The sending of advertising or commercial communications may also concern the various brands that the Company is the owner of and which can be consulted on the website www.ovscorporate.it.

c)The nature of the provision of your data and the consequences of incomplete provision of data: You are absolutely free to choose whether or not to provide us with your data, but if you do provide us with data, we ask you to fill in this form, providing all the data requested as "compulsory" (*) as it is necessary for registration; if you do not fill in the form, or if it is incomplete, you will not be able to proceed with registration. Failure to fill in the data indicated as 'optional' will have no effect on your purchase.

d) Legal basis of processing: In order to contact you or send you advertising or commercial material (purpose of point b)2), to be able to know your consumption preferences and thus improve our offer (purpose of point b)3), we will only process your data with your consent.

If you do not wish to give your consent under points b) 2) and b) 3), you may still register.

We are obliged to process the data required for your purchase, whereby for the purposes of point b) (i) and (ii) the legal basis for processing is the performance of a contract, and for the purposes of point b) 1 (ii) the legal basis is a legal obligation.

e) How we process data and the profiling logic used​: The data will be processed in compliance with the regulations in force and in such a way as to guarantee their security, confidentiality and to prevent unauthorised disclosure or use, alteration or destruction. The data will be processed mainly by computer in order to grant discounts or promotions on the basis of spending

volumes and to give you access to other benefits. Furthermore, if you give us your consent to use your data for the purposes indicated in points b) 2 and b) 3, the data provided and the data relating to your purchases will always be analysed using automated tools (profiling programmes and behavioural analysis) in order to place you in specific consumption categories to send you offers that are more relevant to your consumption preferences and to allow us to adapt our commercial and promotional offer, as well as possibly send you promotions and/or discounts that may be of greater interest to you.

f) Retention period​: the data relating to purchases will in any case be retained for a maximum period of 24 (twenty-four) months from registration (or for any different period provided for by current legislation or provisions of the protection authority) for the purposes referred to in points b) 2 and b) 3, after which they will be destroyed or made anonymous, while for accounting purposes they will be kept for the period required by law.

g) To whom we disclose data: The data will not be disseminated or communicated to third parties. In order to allow us to manage your purchase and pursue the purposes to which you have consented, the data may be disclosed to: (i) companies that perform the service of storage and processing of computer files on our behalf; (ii) companies that handle the enveloping and/or sending or mailing of promotions and advertising or the performance of promotional activities (limited to name, surname and address for sending general mail; e-mail address for sending electronic mailings; telephone/cell phone number for tele-marketing activities) (iii) companies in charge of managing warehouse logistics, shipping of purchased products and related customer care activities on behalf of OVS. These subjects will act as external data processors pursuant to art. 28 of the Regulation.

The data may also be communicated to banks (for handling the payment of your purchases).

Your data may be disclosed to the persons in charge of the Marketing, Information Technology, Customer Care & e-Commerce Departments of OVS S.p.A..Only if you agree and provide us with your consent, we will share some of your data with social network channels for advertising or commercial communications that the Data Controller and its commercial partners reserve for their members.

h) The rights of the data subject and the possibility to lodge a complaint and contact details:
In accordance with the provisions of current legislation (Articles 15 to 22 of the Regulation), you have the right to obtain access to your information (art. 15), their rectification or supplementation (Art. 16), their erasure (the so-called right to be forgotten, Art. 17), restriction of processing (Art. 18) the right to the portability of your data (Art. 20), the right to object to the processing of your data on particular grounds (art. 21) and that you are not subject to an automated decision-making process (art.22); we also remind you that you always have the right to lodge a complaint with the Data Protection Authority (www.garanteprivacy.it​). To exercise these rights, you can write to us using the form ​Contact us​,or by writing to OVS S.p.A., via Terraglio n.17, 30174, Venezia Mestre (VE), to the attention of the Data Protection Officer (DPO)

You have the right to revoke your consent to carry out profiling activities in accordance with point b) 2 at any time.

You also have the right to revoke your consent to carrying out contact activities for advertising/promotional communications by e-mail (purposes of point b) 3) at any time. In this case you will no longer receive any kind of electronic or paper communication. If you wish, you may revoke your consent limited to the receipt of communications by e-mail, sms, mms, etc., and continue to receive commercial communications only by mail or telephone contact with an operator, if any.

i) Data Protection Officer​: If you wish to contact our Data Protection Officer, also known as the DPO, you can do so at the following e-mail address ​responsabileprotezionedati@ovs.it , as well aś by phone 041 239 7500.