PRIVACY

PRIVACY POLICY

VERS.4/2018- DRAFTED PURSUANT TO ART. 13 AND 14 GDPR 2016/679 EXTRACT. THE FULL TEXT CAN BE OBTAINED FROM THE REFERENCES IN THIS DOCUMENT

The purpose of the Legal Notes and Privacy Policy is to ensure that users can transparently verify the processing activities of their data on the web, in addition to the importance of addressing entities dedicated to protecting user rights and adhering to legal provisions. It is emphasized that the text complies with the recent regulations dictated by GDPR 2016/679 and privacy legislation in the countries where Bros Manifatture srl, Bros Usa Corporation and Bros Asia Limited (“Bros Group”) offer their web services. The policy declares that Bros Manifatture S.r.l. is the data controller and owner of the domains and websites. Bros Group recognizes the importance of protecting personal data of its customers and users of its websites and adopts specific policies and security measures to comply with current laws on data protection. The Customer’s data refers to the information freely provided by users on the website www.brosway.com which includes personal information needed for acquisition interests, postal addresses, phone numbers, and electronic mail. Only information contained in the corresponding session of the site is acquired and stored.

TRADEMARK PROTECTION AND INTELLECTUAL PROPERTY RIGHTS

BROS MANIFATTURE S.r.l. is not only the name of the owner but also its trademark. Legal protection is extended to the domain based on recognition received by the legislator under the new Industrial Property Code (Legislative Decree 30/2005). This new legal provision allows the defense of the domain name against infringement and seizure by third parties, providing both ordinary and precautionary measures for protection. In particular, Art. 133 of the CPI allows the judicial authority to order the injunction of the use of the illegitimately registered domain, or its temporary transfer, where appropriate subject to the provision of adequate security by the beneficiary of the measure. The website and its contents are exclusively owned by the company, which reserves the right to grant third parties the right to use them. Any copying, downloading, or reproduction of content on this website is strictly prohibited unless explicitly permitted. The user is authorized only to view the site and perform all those acts of temporary reproduction that are considered transient or accessory, integral and essential to the same browsing www.brosway.com and its contents and all other navigational operations performed only for legitimate use. The copyright protections are exclusively for this website. As for the regulation of links, it should be noted that there are currently no links to other websites within www.brosway.com. If there were, the BROS MANIFATTURE S.r.l. does not monitor such websites and their contents and cannot be held responsible for their content or privacy and handling of personal data during browsing. “Surface linking,” or the classic link that transfers a visitor to the home page of another site, is considered legitimate. However, “deep linking” and “framing” are not authorized and could result in liability for copyright infringement and unfair competition, respectively.

PRIVACY POLICY

This page describes how the site is managed with regard to the processing of personal data of users consulting it. The information is provided only for the website www.rosato.it and not for other websites that may be consulted by the user via links.

DATA CONTROLLER

In order to uphold the principles of transparency and fairness stated by the Privacy Code, Bros Manifatture Srl is responsible for the processing of personal data. The complete details of the company can be found on the homepage, and the domain is owned by the same company. The email address for communication regarding privacy matters is privacy@brosmanifatture.it.

Bros Manifatture srl
Via Guido Rossa, 1 63025 Montegiorgio (FM)

Bros Usa Corporation
169 East Flager Street, Suite 1022Miami, FL 33131

Bros Manifatture Asia Limited
Suite 2301, 23rd Floor, Chinachem Hollywood Centre, 1-13 Hollywood Road Central, Hong Kong S.A.R.

DATA CONTROLLER

According to Article 28 of GDPR 2016/679, the reference for any information requests to be sent to the Data Controller is: resp.trattamento@brosmanifatture.it. Additionally, the complete and up-to-date list of Data Controllers can be requested by writing to the address provided on this website.

INTERNATIONAL TRANSFERS OF PERSONAL DATA

If a customer decides to register with the Bros Group customer database, their personal information will be gathered in their home country and then moved to another country where the group’s companies’ servers are situated to provide worldwide personalized services. The privacy and personal data protection rules in the storage countries might not be as strict as those of the customer’s residence country. Nevertheless, Bros Group companies will ensure that the information is handled safely and according to the principles of fairness, need, and proportionality. By utilizing the websites mentioned in this policy, a customer agrees to transfer their personal data outside their home country, including the United States and Asia, as a regular Bros Group commercial operation. This policy authorizes and governs the transfer of data among Bros Group companies situated in various geographic regions, while still complying with privacy rules.

PLACE AND METHOD OF DATA PROCESSING

In this context, the term “processing mode” refers to the technical and organizational methods implemented by Bros Manifatture srl to ensure adequate and secure management and storage of data. Data is processed electronically and on paper, is accessible only to authorized personnel and is not disclosed. Their electronic storage takes place on the server located at the registered office located in Via Guido Rossa no. 1 – 63833 Montegiorgio (FM) and on the provider’s server units where the domain is located. Meanwhile, in the case of paper management, storage takes place in the archive or at our headquarters. For the sake of transparency, it is noted that the domain is supported by an external provider responsible for its operation and security. In the event of violations, it is subject to the responsibilities dictated by specific sector regulations. The service-related processing for the website www.brosway.com is carried out by the data controller and any third-party companies acting as data processors under art. 28 of GDPR 2016/679.

DATA TYPES

The present section specifies which data Bros Manifatture S.r.l. may collect during simple navigation on the Websites, without logging in as a registered user, and their methods of processing. WEB BROWSING DATA During the normal operation of this website, computer systems and software procedures acquire certain personal data, which is transmitted implicitly through internet communication protocols. This category includes IP addresses or domain names of the computers used by the users connecting to the site, the Uniform Resource Identifier (URI) addresses of the resources requested, the numerical code indicating the status of the response given by the server (e.g. successful, error), and other parameters relating to the user’s operating system and computer environment. This data could potentially be used to verify responsibility in the event of hypothetical computer crimes committed against the site. DATA PROVIDED VOLUNTARILY BY THE USER The optional and voluntary sending of email to the addresses provided on this website results in the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data provided. The processing of this data is exclusively related to the purpose of answering inquiries made by users. The data is kept only for the time necessary to fulfill the same purpose and then deleted. The information provided is acquired and managed exclusively by this studio in accordance with the principles of data integrity and confidentiality. It should be noted that among the Personal Data collected by these websites, either independently or through third parties, are: Name and surname, phone number, email address, address, city, province, country, business name, profession, website, cookies, usage data, IP address, and location. Unless otherwise specified, all data requested by these websites is mandatory to allow the Holder to respond to your requests; if the user refuses to communicate them, it may be impossible to provide the service.

PERIOD OF CONSERVATION

The data is processed and stored for the time required for the purposes for which it was collected. Therefore: • Personal Data collected for purposes related to our activities and for which the User has freely expressed an interest will be retained until the completion of the requested presentations; •Personal Data collected for purposes related to the legitimate interests pursued by the Owner will be retained until such interests are met. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner. When the processing is based on the User’s consent, the Owner may retain Personal Data longer until such consent is revoked. In addition, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority. At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this period, the right of access, erasure, rectification and the right to data portability cannot be exercised. The only data that, at the end of the relationship or in case of a request for deletion, must be kept for 10 years are the data contained in the sales invoices for purposes deriving from tax regulations.

OPTIONALITY OF DATA CONFERRAL

In short, the message states that except for navigation data, users are free to provide personal information by filling out the appropriate form in the “CONTACT” section. It also states that in some cases, authorities may request information for the purpose of monitoring the processing of personal data, and failure to respond may result in administrative penalties.

RIGHT TO BE FORGOTTEN

The message states that besides the required navigation data, the user can also provide personal data which the company will handle in accordance to the user’s right to be forgotten. This guarantees the right to request the deletion of their personal data without delay.

RIGHTS OF INTERESTED PARTIES

Each subject has the right at any time to obtain confirmation of the existence or non-existence of data and to know its content and origin, verify its accuracy or request its supplementation or updating, or rectification (Art. 7 GDPR 2016/679); it is likewise the right of each user to revoke any consent previously granted for information or marketing purposes. Pursuant to the same article, users have the right to request the deletion, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose their processing in any case, for legitimate reasons. The subjects to whom the personal data refer have the right, at any time, to obtain - The confirmation or non-confirmation of the existence of the same data; - To know the content of the same data, as well as their origin - To verify their accuracy; - To request their integration or updating or rectification (art. 7 GDPR 2016/679); - The cancellation of the data or making them anonymous; - To block the data as well as to oppose, for legitimate reasons, their processing. Requests should be addressed by email to: privacy@brosmanifatture.it The Data Controller protects the digital identity of the User through the implementation of precise policies. The User is required, in fact, to provide, in the appropriate form on the site, only the information strictly necessary for the implementation of the purposes for which it is provided. The Data Controller and each designated person implement the security measures deemed most appropriate to guarantee security in data processing and storage activities.

PRIVACY POLICY SOCIAL NETWORK

VER.1/2021 - WRITTEN IN ACCORDANCE WITH GDPR 2016/679. THE DETAILED TEXT CAN BE REQUESTED FROM THE REFERENCES CONTAINED IN THIS DOCUMENT.

The purpose of this Privacy Policy is to ensure that the user can verify with full transparency the processing activities related to their data on the social profiles of our company, Bros Manifatture Srl. In particular, Bros Manifatture Srl, as the Data Controller, respects and protects the privacy of its users and is committed to transparency in processing personal data. This Privacy Policy aims to explain how Bros Manifatture Srl, as the Data Controller, processes personal data using different social platforms such as Facebook, Instagram, and YouTube. This information may be subject to changes, so we invite users to consult it to see the most updated version.

CUSTOMER'S INFORMATION

In this context, the term “User data” refers to all the information freely provided by the user in the appropriate forms present on the social pages of our company, Bros Manifatture Srl. The personal data subject to processing may include, for example, information such as name, surname, email, age, gender, country, job title, current or previous employer, educational background, profile picture, interests, friends and/or followers list, and other publicly available information, provided that the user has published all this information on their social profile. Additionally, further information that the user will provide by posting comments and/or “Likes” on our company’s social page or by sending us direct messages may also be collected. If the user decides to subscribe to a newsletter or request to be contacted for information, they may provide personal data such as name, surname, email address, and phone number. We also inform users that social media platforms collect personal data through the use of cookies and similar technologies, including cookies collected through social networks such as Facebook, Instagram, and YouTube. In some cases, such as our Facebook page, we act as “Co-controllers” together with Facebook for the processing of personal data. Therefore, we advise users to read Facebook’s privacy policy to understand how they process and handle personal data. Informative on the processing of personal data by different social platforms such as Facebook, Instagram, and YouTube are available for users to read.

POLICY FOR USERS

Users who connect to the social pages of our company BROS MANIFATTURE S.R.L. are required to comply with the following policies: ➢Users must pay particular attention to the possibility of inserting information that could indirectly reveal the identity of third parties in their interventions. In such cases, they declare to have personally requested the consent of such third parties for disclosure; ➢ Users must be aware that the content of their messages and/or posts can be seen by the entire community. Therefore, BROS MANIFATTURE S.R.L. reserves the right to remove, even without notice, all posts that are deemed inappropriate and non-compliant with this policy or with current legislation; ➢Users must be polite and respectful in their interventions. The use of inappropriate language, harmful to the image of our company, discriminatory against sexual orientation, personal and social conditions, race, language, nationality is prohibited ➢Users must refrain from violating copyright, privacy rights of individuals or unauthorized use of registered trademarks. It is forbidden for users to advertise other brands or logos on our pages, and it is forbidden to publish SPAM content that could harm other fans (viruses, harmful software, etc.) or legitimate owners.

WEBSITE

The social media pages of BROS MANIFATTURE S.R.L. [Facebook, Instagram, and YouTube] may contain links to sites owned by the Data Controller or third-party owned sites. This Privacy Policy does not apply to third-party sites, so if the user wishes to obtain information on their data collection methods and distribution policies, we suggest contacting them directly.

TRANSFER OF DATA ABROAD

Your personal data will not be transferred by us outside the European Union or to countries that do not guarantee an adequate level of data protection.

RIGHTS OF THE INTERESTED PARTIES

Each individual has the right at any time to obtain confirmation of the existence or not of their data, and to know their content and origin, verify their accuracy or request their integration or updating, or rectification (art. 7 GDPR 2016/679). It is also the right of each user to revoke any previously given consent for informational or marketing purposes. Under the same article, one has the right to request the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, as well as to oppose their processing in any case, for legitimate reasons. Requests should be sent via email to privacy@brosmanifatture.it. The user has the right to lodge a complaint with the Guarantor Authority for the Protection of Data.

DATA RETENTION

The owner is required to follow the policies established by the service provider regarding the preservation of data on social media pages.

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BROS MANIFATTURE S.R.L. Via Guido Rossa, 1 63833 Montegiorgio (FM) P.I e C. Fiscale 01943400448 - Camera di Commercio delle Marche, N. Rea FM-186119 - Capitale Sociale 100.000,00 i.v.