PRIVACY POLICY

Dear Customer,

In accordance with current legislation on the protection of personal data, THUN S.p.A., as Data Controller, shall use your data to execute the activities listed below:

a) Retention: issuing of a digital loyalty code and management of activities that cannot be carried out anonymously and which are required to allow subscribers to take advantage of and find promotions, offers and rewards, and participate in point collection schemes and promotional events reserved for loyal customers.

b) Marketing: with your express written consent, carrying out direct marketing activities, such as sending - by email, SMS and MMS, instant multimedia messaging applications and mobile applications created by THUN S.p.A - advertising material and communications with informational and/or promotional content regarding the products or services provided by the undersigned company, including gifts and free samples; conducting market research for the purpose of, for example, analysing consumer habits and choices and commercial communication, and assessing the level of satisfaction with the products and services offered.

c) Profiling: with your express written consent, carrying out customer profiling activities based on purchase choices and information provided optionally when registering for the Loyalty Programme, or subsequently registering via the Website.

d) with your express written consent, sending your data for specific marketing purposes to partner companies of THUN S.p.A, which belong to the following product categories: large-scale retail, clothing, publishing, electronics and IT, finance and insurance, tourism and hospitality, groceries, couponing, cosmetics and pharmaceuticals, gifting, NGOs and foundations, event organisation, training companies.

In compliance with the 'Guidelines on promotional activities and combating spam' drawn up by the Privacy Authority, the various commercial promotion aims (as set out in point b) of this policy) serve to pursue a single marketing aim, and consequently the consent required is a one-off.

If the fields marked as mandatory (with an asterisk) are not filled in, it will not be possible to issue the digital loyalty code. Optional data, if not provided, will not affect the issuing of the digital loyalty code and participation in relevant promotions. Mandatory data will be assessed by taking into account the principles of necessity and proportionality relating to data processing, as provided for by current regulations. For the purposes referred to in letter a), the provision of data is optional, but is a necessary and indispensable condition for the digital loyalty code to be issued; failure to provide the data will make it impossible for the applicant to obtain the code. For the purposes referred to in letters b), c) and d), the provision of data is optional and refusal to provide it and to give the related consent will make it impossible for the undersigned company to act on the direct marketing and profiling activities indicated therein, but does not affect the possibility of the applicant being issued the digital loyalty code and being given access to the related benefits.

In the event that no explicit consent is given, customers will be able to take advantage of purchases at all stores of the issuing company for retention purposes (points accumulation, offers reserved for digital loyalty code holders), but will not be able to receive promotional offers. Your data will be processed by staff members appointed by THUN S.p.A, who are employed in accordance with the Privacy Policy as the data manager or processor. Data may be processed by staff members of the undersigned THUN S.p.A. for the performance of customer support and assistance functions within stores. Data provided shall not, under any circumstance, be disclosed or communicated to third parties without specific authorisation, without prejudice to the parties to whom the right to access the data is granted by law, as well as the parties we use for the execution of activities which are instrumental and/or ancillary to the management of the digital loyalty code or the provision of services and benefits related to it, including providers of software, web application and storage service solutions, including those provided through Cloud Computing systems.

Regarding the data provided, you may exercise the rights specified under Article 7 of Legislative Decree 196/2003, which are confirmation of the existence of data and the communication of these; the updating, rectification, integration, deletion and transformation of managed personal data; the blocking of data processed in breach of the law. You may also object to your data being processed. This shall not involve any formalities or incur any costs as required under current legislation; simply send an email to the Data Controller at the following address: privacy@thun.it or notify the Data Controller by writing to THUN S.p.A. c/o Loyalty Office, with registered office at Via Galvani 29, Bolzano (Bz). A list of internal and external data managers is available from the Data Controller.

The pro tempore privacy manager for THUN S.p.A (appointed in accordance with the law) can be contacted by email at privacy@thun.it.

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