PRIVACY POLICY

1. DATA CONTROLLER

Identity: INGROSSOITALY (1) ("Ingrosso Italy")

Telephone: (+39) 329 755 1382
E-mail address: contact@ingrossoitaly.com
(1) For purpose 1.iii) of the following point, the Data controller will be the subsidiary entity of the Ingrosso Italy group, franchisee or collaborator whose data is indicated in the general conditions of sale that the customer accepts at the time of purchase.

2. PURPOSE

For what purpose do we process your personal data?

In compliance with European General Data Protection Regulation 2016/679, we inform vou that Ingrosso Italy will process the data vou provide us for the following purposes:

1.To correctly execute the management of our services, consisting of:

(i) Management of vour user account on the Ingrosso Italy website.

(ii) Management of Ingrosso Italy loyalty programme in force from time to time (the "Loyalty Program").

(iii) Purchase and shipment of the Ingrosso Italy product you have purchased from Ingrosso Italy or our trusted partner, as well as sending your purchase receipt to the e-mail address you provide us with.

(iv) Management or our servIces, including reminders, technical notices, updates, securIti alerts, support messages, among others.

(v) Registering and managing the resolution of shop and online incidents.
(Vi) Registering and managing the communication channels between the customer and Ingrosso Italy, through our chat, using the "Contact us" application, or by letter, e-mail, or telephone, onculding the the recording of your calls with our customer services.

2. To send commercial notifications to inform vou of our products and notifications related tc Ingrosso Italy competitions, and to conduct satisfaction auestionnaires, as Iona as we have vour consent to do so. Satisfaction auestionnaires are conducted to offer vou personalised service
in order to improve your shopping experience at Ingrosso Italy.

3. Analysis of your behaviour as a user as well as commercial profiling to show personalise‹ davertising adapted to your preferences and, where applicable, to your browsing history. Ingrosso Italy will elaborate your commercial profile based on data collected through third-part sources including, for example, third-party cookies. No automated decision-making which may have legal or similar significant effects on vou will be made based on said profiling. Commercial profiling through cookies may be used by third-party websites to show you personalised advertising. You can manage vour cookies by following the instructions stated in our Cookies Policy.
4. In addition, Ingrosso Italy will elaborate vour commercial profile based on internal sources such as
(i) the information you provide; (ii) Ingrosso Italy own cookies; (iii) your purchasing history; (iv) how often you open your e-mails; and (v) your replies to any satisfaction questionnaires we may send you. No automated decision-making which may have legal or similarly significant effect on you will be made based on said profiling. Furthermore, in regard to such profiling, Ingrosso Italy may aiso send you commercial notifications concerning simmar products as wel as, witnin the framework of the Loyalty Program, new benefits, new partnerships, and exclusive events. Bear in mind that the analvsis of vour behaviour as a user allows us to improve vour experience as a customer of the Ingrosso Italy brand.

5. Prevention of abuse and fraud in the use of our services (e.g. fraudulent activities, denial-of-service attacks, spam, among others).

6. Transter of data to public bodies and authorities. whenever required in accordance with legal
and statutory provisions.

3. PERIOD OF DATA RETENTION

How long do we store vour data?

Your data will be kept as long as the contractual and commercial relationship remains in force in accordance with the recommended or regulatory time limits established and, in any case, until tne statute of the limitations for any actions that may arise.

What is the lawful basis for processing of your data?

The lawful basis for treating your data lies in:

The execution of a contract with Ingrosso Italy, in relation to section 1 above.
The consent provided by you, in relation to the purposes indicated in sections 2, 3 and 5above.
The legitimate interest of Ingrosso Italy, for the purposes indicated in sections 4 and 6 above.

- In relation to section 4 above, the legitimate interest lies in making a profiling of our customers to the extent that it is related to such direct marketing, which consists in showing you products which we belleve may be of interest to you due to then "similarity" to other products of the brand you have purchased and based on your commercial profiling. To this effect, Ingrosso Italy will monitor your behaviour in order to determine whether you would benefit from other Ingrosso Italy brand offers or products. Your commercial profile is produced with information belonging to Ingrosso Italy.
- In relation to section 6 above, the legitimate interest lies in protecting Ingrosso Italy users through the prevention of abuse and fraud in the use of our services.

Compliance with legal obligations applicable to Ingrosso Italy, for the purpose indicated in section 7 above.

4. LAWFUL BASIS

To which recipients will your data be communicated?

Your data may be disclosed to third parties in the following cases:

Your personal data may be processed by suppliers who provide services to Ingrosso Italy in relation to the purposes described, such as services for content storage, instant messaging, sending notifications, advertising services, etc. Ingrosso Italy has signed the corresponding data processor agreements with each of the suppliers who provide services to Ingrosso Italy in order to ensure that your personal data is treated in accordance with the provisions established in the applicable legislation.
Ingrosso Italy forms part of a group of companies in the business of manufacturing distributing, and selling, on an international level, a range of products under the Ingrosso Italy commercial brand, including, amongst others, adults' and children's clothing, accessories, footwear, and decoration articles (the "Ingrosso Italy Group"). Your personal data may be disclosed and processed by Ingrosso Italy Group
Your personal data may be processed by franchisees of Ingrosso Italy Group.
Your personal data may also be transferred in cases where there is a legal obligation.
Furthermore, your personal data may also be disclosed to third parties who act as partners for the provision of some Loyalty Program benefits, in order to verify that the benefit has been used. In these cases, their specific Terms & Conditions and Privacy Policies will be also applicable, as indicated in each case.
Your personal data will be processed within the territory of the European Union. However, if necessary, for technical or operational reasons, Ingrosso Italy reserves the right to transfer your personal data to countries outside the European Economic Area, subject to the existence of adequacy decisions by the European Commission, or on the basis of suitable safeguards, or the specific exceptions governed by the GDPR. In this sense, where applicable, you will be informed about these data transfers and their characteristics.

5. RECIPIENTS

What are your rights when you provide us your data and how can you exercise them?

You have the right to obtain confirmation as to whether or not Ingrosso Italy is processing persona data that concerns you.

You also have the right to access your personal data and to request the rectification of inaccurate data or, where applicable, request its erasure when, among other reasons, the data is no longer necessary for the purposes it was collected for.

In certain circumstances, you may request the restriction of the processing of your personal data, in which case we will only keep them for the exercise or defence of legal claims In addition, under certain circumstances and for reasons related to your personal situation, you may object to the processing of your data. Ingrosso Italy will stop processing your data, except for compelling legal grounds or the exercise or defence of possible legal claims.

You can also exercise the right to data portability as well as withdraw the given consent at any time, by visiting your user area; nonetheless, this will not affect the legality of any processing based on the consent prior to its withdrawal.

If you wish to exercise any of your rights, you can contact us through the enabled links, which you will find in Ingrosso Italy e-mails and notifications or in your user account. Remember to provide as much information as possible regarding your request, including name and surname(s) and the e-mail address you use for the account or website related to your request.

Finally, we inform you that also have the right to lodge a complaint with the competent data protection supervisory authority, and other competent public bodies for any claim deriving from the processing of your personal data.

6. RIGHTS

What are the consequences of not providing the data and/or not authorising the communication of the data?

The provision and communication of data is a prerequisite for the creation of your user account.
If you do not accept or authorise the processing and communication of data, the user account cannot be created.

7. OBLIGATION TO PROVIDE AND COMMUNICATE DATA

What cookies do we use?

To find out what cookies we use, remember you can acess our Cookies Policy via the following link.