POLICY FOR THE PROCESSING OF PERSONAL DATA - ART. 13 EU REGULATION 679/2016

Vita Health & Fitness Limited with registered office at flat 80 Durrels House, 28-46 Warwick Gardens, London W14 8QB - United Kingdom, contactable at info@vita-london.com and Vita S.R.L. based in Piazza Castello, 22 - 20122 Milan, Italy, contactable at info@vita-milano.com, as joint data controllers (hereinafter "Holder"), informs you, pursuant to art. 13 EU Regulation 679/2016 (hereinafter "GDPR"), that your data will be processed in the manner and for the purposes described below:

1. Object of the treatment

The joint Holders process personal identification data, such as e.g. images, name, email, telephone number, postal address, fiscal data, (hereinafter "Data") and particular data ("health status") provided by you, on the occasion of the purchase and in general in relation to the contractual relationship in place with the Holder.

2. Purpose of the processing and legal basis of the processing

Your personal data are processed, without your prior consent (Article 6 paragraph 1 letter b), c) GDPR), for the sole purpose of managing and executing pre-contractual and contractual relationships; the obligations related to administrative and accounting management; the obligations established by laws, regulations or EU legislation or otherwise imposed by law; for the protection of the rights of the Holder in court and management of any disputes; for the prevention and repression of illegal acts.

2.1. Additional purposes of the processing

The data collected, with your prior free and explicit consent (Article 6 letter a) GDPR), may also be used for the additional purposes indicated below under the terms and conditions specified therein: (a) to send you newsletters, through the references you have provided. (b) to manage your request for information. (c) to manage job applications.

3. Cookies and similar website tools

In compliance with the EU Directive 2009/136/EC of 25/11/2009, the Holder informs you that our website www.vitaboutiquefitness.com and the subdomains www.it.vitaboutiquefitness.com and www.en.vitaboutiquefitness.com use cookies or similar tools to allow us to improve our service and offer the user some useful features. This may include cookies from business partners that are stored by your computer or device when you visit our site (https: //www.vitaboutiquefitness/cookie-policy). Please visit the websites of our business partners for information on their cookie and privacy policy. Cookies are small text files that are transferred to your computer or device via the web browser to allow us to recognize your browser and help us to monitor visitors to our site, thus allowing us to better understand the products and services that will be more suitable for users. A cookie contains contact information and useful information allowing to identify your computer or device when you visit our sites www.vitaboutiquefitness.com www.it.vitaboutiquefitness.com www.en.vitaboutiquefitness.com with the aim of helping the user to get a better user experience. Most web browsers automatically accept cookies, but if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. If you choose to change these settings, certain features and functionality may not work as expected. The cookies used do not detect the information contained on the computer or device. For more information about cookies and how to prevent your browser from accepting them, visit the following website: http://www.allaboutcookies.org.

4. Methods of processing and storage

The processing will be carried out by means of the operations indicated in art. 4 GDPR and may take place both through IT systems (cloud, internet, intranet, computers and mobile devices) and automated processes, and in paper form (archives). For the purposes in point 2.1a) the data will be kept until the consent is revoked in accordance with the law and as specified above, except in cases where current legislation does not require the retention of your data for longer periods. For purposes 2.1b) and 2.1c) your data will be stored in the Holder’s databases only for the time strictly necessary to achieve the purposes for which they were collected and processed. If you decide to close your account, the Holder will keep personal data provided only for administrative purposes from the termination of the contractual relationship (for 7 years up to a maximum of 10 years), without prejudice to any further needs for which the Holder is allowed or required by specific provisions of the law to keep the data. The Holder will keep the personal data provided only for administrative and statistical purposes, except for any further needs for which the Holder is allowed or required by specific provisions of the law to keep the data.

5. Additional methods of processing and storage

We may use surveillance cameras at our locations that may record you and your activities. We display notices to clarify which areas are subject to video surveillance. We release footage of surveillance recordings only following a formal warrant or request from law enforcement, or as needed in connection with disputes. Recordings can be kept for a maximum period of 48 hours.

6. Nature of the provision of data and consequences of refusal

The provision of personal identification data is necessary for the execution of the contractual relationship and the obligations deriving from the fulfilment of the law, regulations or EU legislation and any refusal will make it impossible to provide total or partial services or services requested. It is understood that, if you do not want to give your consent to the processing of your data for the purposes referred to in point 2.1a) this will not prevent you from accessing our available services.

7. Data Security

We have put in place adequate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized manner, altered or disclosed.

8. Access to Data

Your Data will be processed for the aforementioned purposes by employees and / or collaborators of the Holder in their capacity as persons in charge of processing and / or internal data processors and / or system administrators; by third parties (for example, suppliers, professionals, banks, affiliates) where they carry out outsourced activities on behalf of the Holder, in their capacity as external data processors.

9. Communication of Data

Without your express consent (pursuant to Article 6 letter b), c) GDPR), the Holder may communicate your data to public bodies to comply with the obligations established by laws, regulations or EU legislation or imposed by the Authorities, which will process them in their capacity as independent data controllers. They may also be communicated to Third Parties (for example, partners and client companies), who will process the data for the performance of activities instrumental to the services requested and the aforementioned purposes. Generally, the selected service providers operate through data centres located in the European Union. If your data will be transferred to non-EU countries, also for the purpose of technical management of the data collected, this will take place exclusively in full compliance with the European GDPR legislation, to companies adhering to the Privacy Shield (USA) or to third countries for which there are adequate guarantees for the protection of the transfer or specific undersigned contractual clauses for the protection of personal data.

10. Rights of the interested party

At any time, you can exercise your rights towards the Holder, pursuant to articles 15-22 of EU Regulation 2016/679, and in particular the rights of access, rectification, integration and, in the cases permitted, the portability of the data provided, in addition to obtaining the cancellation, limitation or opposition to the processing of data for legitimate reasons and to oppose the automated decision-making process, including profiling. As well as the right to complain to the Data Protection Authority, by contacting the joint controllers by sending an email to info@vita-london.com or to info@vita-milano.com. In order to guarantee the protection of the personal information of the interested party, we may need to request further specific information, which confirms the identity of the subject requesting the data and thus guarantees the right to access information (or to exercise any of the other rights) only to persons entitled to receive such communications. This is another security measure suitable for protecting personal data. The request to access your personal information (or to exercise one of the above rights) is free. However, if the request is clearly unfounded or excessive, we may charge a reasonable fee taking into account the administrative costs incurred to provide the information or refuse to comply with the request in such circumstances.

11. Holder of the treatment

Joint data controllers are: Vita Health & Fitness Limited with registered office in flat 80 Durrels House, 28-46 Warwick Gardens, London W14 8QB - United Kingdom contactable at info@vita-london.com and Vita S.R.L. based in Piazza Castello, 22 - 20122 Milan, Italy contactable at info@vita-milano.com.

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