WEB POLICY - SPARE PARTS WEBSITE

UNDER REGULATION (EU) 2016/679 (GDPR)

This communication is issued under Arts. 13 and 14 of the European Regulation 2016/679 on the protection of personal data (hereinafter referred to as "GDPR") as amended and supplemented, and the relevant Italian legislation, including Legislative Decree No. 101 of 10 August 2018, by the company SCOTSMAN ICE SRL - VIA LAINATE 31 - 20010 POGLIANO MILANESE - MILAN - ITALY - VAT: IT06586370964 (hereinafter also "Company"), as the Controller of your personal data, and is addressed to anyone who interacts with the Company's web services that may be accessed electronically from the address https://scotsman.aftersalestools.com This Policy is designed to inform users on how personal data concerning them are processed. Such Data may be collected because you voluntarily provide them (e.g. when you write to the Company through the "Contact Us" section) or simply by analysing the pages you visit on the website. The Personal Data processed via the website are specified in the following paragraphs.

TYPES OF DATA COLLECTED

While browsing the site https://scotsman.aftersalestools.com the Controller may, therefore, acquire information on the visitor in the ways described below.

Browsing data

The IT systems and software procedures dedicated to the operation of this website acquire, in the course of their normal operation, certain data whose transmission is implicit in the use of Internet communication protocols. This information CANNOT be associated with identified data subjects or include personal data. This category of data include only IP addresses, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are only used to obtain anonymous statistical information on website usage and to check its correct functioning and are deleted immediately after processing; at present, data on web contacts are not stored for more than 30 days

Data provided voluntarily by Users

The optional, explicit and voluntary provision of data through this site entails the subsequent acquisition (by the Company) of the sender's email address, as well as any other personal data entered spontaneously, which are necessary to use the services offered or to respond to requests for information and contact.
In the aforementioned cases, the user may be required to provide his or her name, surname, address, telephone number, e-mail address; SCOTSMAN will use this information only for processing the user's request, for sending specifically requested information as well as for the user’s subscription to the site. The information provided will not be used for marketing purposes unless consent is given and will not be sold, transferred, granted or otherwise forwarded to third parties.

OPTIONAL PROVISION OF DATA

Apart from what has been specified for (technical) browsing data, users are free to provide their personal data or not via the above-mentioned collection forms published on the site, but failure to provide such data will make it impossible to register in order to obtain the service offered or to obtain replies to any requests made to SCOTSMAN S.R.L.

BRIEF NOTE ON COOKIES

Cookies are used on our website to provide users with a better service and browsing experience: for information on this type of data and how it is processed, please see the relevant section:

https://scotsman.aftersalestools.com/htmlPages/0526_FT658S/en/cookie-policy.htm

CONDITIONS OF PROCESSING

Personal data will be processed by computer and/or telematic means for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are taken to prevent the loss, unlawful or incorrect use of and unauthorised access to data. Data are processed using organisational methods and logics that are strictly related to the indicated purposes of processing. In addition to the Controller, data may be accessed by categories of persons involved in website organisation (administrative staff, system administrators) or external parties (such as third-party technical service providers, hosting providers, IT companies) appointed as Data Processors by the Controller. The updated list of Processors may always be requested from the Controller by sending a specific communication to the addresses indicated in the "Contact Data" section of this policy.

PLACE OF PROCESSING AND RECIPIENTS

Data collected by the Company will only be shared for the above purposes; we will not share or transfer Personal Data to third parties other than those indicated in this Privacy Policy. In the course of our activities and exclusively for the same purposes as those listed in this Privacy Policy, Personal Data may be transferred to the following categories of recipients:

• persons authorised by the Company to process Personal Data where necessary to carry out activities strictly related to service supply, who have committed themselves to confidentiality or have an appropriate statutory obligation of confidentiality (e.g. employees of the Company);
• business partners of SCOTSMAN S.R.L. to whom the Controller may communicate data exclusively for the purpose of meeting online requests (external consultants);
• persons, companies or professional firms providing assistance and advice to the Company in accounting, administrative, legal, tax and financial matters;
• persons whose right to access data is recognised by law or by orders of the authorities;

The updated list of Data Processors is available at the Controller's operational headquarters and will be provided on written request to be sent to the addresses indicated in the "Contact Data" section of this policy.

PERSONAL DATA PROTECTION

The company has implemented a risk assessment study on the processing of personal data in accordance with the GDPR: therefore, it has adopted specific security measures, observed by all appointed staff, to prevent the loss, illegal or incorrect use of and unauthorised access to data.
These measures take into account:

• state-of-the-art technology;
• implementation costs;
• the nature of data;
• the risk of data processing.

The measures are designed to protect data against accidental or unlawful destruction or alteration, accidental loss, unauthorised disclosure or access, and other forms of unlawful processing. Furthermore, when handling personal data, the company SCOTSMAN:
- collects and processes personal data that are adequate, relevant and not excessive, as required to fulfil the above purposes, and - ensures that such personal data remain up-to-date, accurate and are duly erased

PURPOSES OF DATA PROCESSING

User Data are collected to enable the Controller to provide its services, as well as for the following purposes:

1. to enable navigation of the site and the provision of the service offered by the Company through it;
2. to fulfil any duties under applicable laws, regulations or EU legislation, or to fulfil requests from Authorities (tax, judicial, etc. authorities);
3. for statistical purposes, but without it being possible to trace the user’s identity.

The legal basis for the processing of Personal Data for the purposes referred to in the preceding sections is set out in Arts. 6(1)(b); 6(1)(c), 6(1)(f), 9(2)(a), 9(2)(b) of Regulation (EU) 2016/679

STORAGE PERIODS

Personal data are processed by automated means for the time strictly necessary to achieve the purposes for which they were collected; for each purpose, data will be stored for the time strictly necessary to achieve that purpose. The data of the User who has interacted through registration or the request for on-line Services to the Company will be deleted 12 months after the last relevant contact or after deletion of the account, unless there is a continuous contractual relationship over a period of time greater than 12 months. Users may always ask the Controller to interrupt the Processing or erase Data concerning them by sending a specific communication to the Contact Data indicated in the "Contact Data" section of this policy.

RIGHTS OF DATA SUBJECTS

The rights attached to the personal data processed by the Company are:

• right to rectification: users may obtain the rectification of personal data concerning them or communicated to us by them. The Company makes reasonable efforts to ensure that the personal data in its possession are accurate, complete, up-to-date and relevant, based on the latest available information;
• right to restriction of processing: users may obtain restriction of processing of their personal data if:
  1. they contest the accuracy of the personal data during the period in which the Company processes such data;
  2. processing is unlawful and they request a restriction of processing or erasure of their personal data;
  3. the Company no longer needs the personal data but they are required by users for the establishment, exercise or defence of legal claims;
  4. users object to processing pending the Company’s verification whether its legitimate grounds override theirs.
• right of access. Users may ask the Company for information about the personal data concerning them, including which categories of personal data the Company owns or controls, for what purpose they are used and to whom they may have been communicated;
• right to portability. Following the user’s written request, the Company will transfer his or her personal data to another Data Controller, if technically possible, provided that processing is based on consent or is necessary for the performance of a contract;
• right to erasure. The user may obtain from the Company the erasure of personal data where:
  1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. the user has the right to object to further processing of personal data and to exercise the right to object;
  3. the personal data have been unlawfully processed.

Unless data processing is necessary for legal or tax obligations or for the establishment, exercise or defence of legal claims:

• right to object. The user may object to the processing of personal data at any time, provided that the processing is not based on consent, but rather on the legitimate interest of the Company or third parties. In such cases, the Company will no longer process personal data unless it can prove compelling legitimate reasons or an overriding interest in the processing or the establishment, exercise or defence of legal claims. Should the user object to the processing, the user must specify whether s/he wants such personal data to be erased or to restrict their processing;
• right to lodge a complaint. In the event of an alleged infringement of the applicable privacy law, a complaint may be lodged with the competent authorities of the country or place where the alleged infringement took place.

CHANGES TO THIS PRIVACY POLICY

Any future changes or additions to the processing of personal data as described in this Privacy Policy will be published on this website:

https://scotsman.aftersalestools.com/htmlPages/0526_FT658S/en/privacy-policy.htm

DATA CONTROLLER AND CONTACT DATA

To exercise the rights laid down in Arts. 15 et seq. of Regulation (EU) 2016/679, the user may contact the Data Controller by writing to: SCOTSMAN ICE SRL - VIA LAINATE 31 - 20010 POGLIANO MILANESE - MILAN - or by sending an email to: privacy@scotsman.it