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WALLIANCE PRIVACY POLICY

Dear User,

Walliance S.r.l., as Data Controller of personal data (hereinafter: "Data Controller") recognizes the importance of the protection of personal data and considers the privacy and protection of personal data one of the main objectives of its business.

Before communicating any personal data to the Data Controller, we therefore invite you to read this Privacy Policy carefully, as it contains important information about your privacy, protection of personal data and security measures taken to ensure confidentiality in full compliance with applicable legislation . This Privacy Policy also:

is intended for the website https://www.walliance.eu of Walliance (hereinafter "Site") which are managed by the Data Controller; this Policy does not apply to websites that may be consulted via external links;

it is also intended as a Disclosure pursuant to Art. 13 of Italian Legislative decree no. 196/2003 (below: "Privacy Code") and pursuant to Art. 13 of the EU General Data Protection Regulation ("GDPR") to those who interact with the site;

conforms to Recommendation n. 2/2001 on the minimum requirements for online data collection in the European Union, adopted on May 17, 2001 by Working Group "Article 29".

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The Data Controller informs you that the processing of your personal data will be based on principles of fairness, lawfulness, transparency and protection of your privacy and your rights. Your personal data will therefore be processed in accordance with the provisions of the GDPR and the confidentiality obligations set out therein.

TABLE OF CONTENTS Below we provide the Table of Contents of this Privacy Policy so that you can easily find the information related to the processing of your personal data that may concern you.

1. DATA CONTROLLER AND PROCESSORS FOR THE PROCESSING OF PERSONAL DATA

2. PERSONAL DATA SUBJECT TO PROCESSING

2.1 Navigation data

2.2 Data provided voluntarily by the user

2.3 Information concerning the use of Cookies

3. PURPOSE OF THE PROCESSING AND MANDATORY OR OPTIONAL NATURE OF DATA

4. METHOD OF PROCESSING, SECURITY AND PLACE OF DATA PROCESSING

5. COMMUNICATION AND DISSEMINATION

6. YOUR RIGHTS

7. CHANGES

8. CONTACTS

1. DATA CONTROLLER AND PROCESSORS FOR THE PROCESSING OF PERSONAL DATA

Following consultation of this Website, data relating to identified or identifiable persons may be processed. The identifying details of the Data Controller and operator of the Site are the following: Walliance Srl, with registered office at Viale della Costituzione 16, 38122 Trento, Tax Code and VAT number 02432640221, Economic Administrative Index TN-224237.

The list of data processors may be requested by sending an E-mail to: privacy@walliance.eu.

Your personal data may be brought to the attention of employees or collaborators of the Data Controller, belonging to the categories of administrative, commercial, legal, accounting or IT system administrators, depending on the processing, which, operating under the direct authority of the latter, are appointed as persons responsible or in charge of the processing pursuant to Articles 29 and 30 of the Privacy Code and pursuant to Articles 28 and 29 of the GDPR, and receive appropriate operational instructions in this regard.

2. PERSONAL DATA SUBJECT TO PROCESSING

2.1 Navigation data

During their normal operation, the computer systems and software procedures used to operate this Website acquire some personal data whose transmission is implicit in the use of Internet communication protocols. This entails information which is not collected for association with identified persons, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category includes IP addresses, or domain names, of the computers used to connect to the Website, URI (Uniform Resource Identifier) addresses of the requested resources, timestamp of the request, method used to submit the request to the server, size of the file obtained in response, numerical code indicating the server response status (successful, error etc.), and other parameters pertaining to the user's operating system and IT environment.

This data is used to obtain anonymous statistical information on the use of the Site and to check its correct functioning, to allow, given the architecture of the systems used, the correct provision of the various functionalities requested by the user, for security reasons and to ascertain responsibility in case of hypothetical computer crimes against the Site or third parties, and are deleted immediately after processing.

Under no circumstances does Walliance cross any such information with any other data it may have in order to track the activities of specific users.

2.2 Data provided voluntarily by the user

To access the features offered through the Site and reserved for registered users, registration is required through the following personal data: first name, last name, E-mail and phone number for account verification.

Once you have registered in your personal area, you can enter other data related to your profile, such as, for example, date of birth, social security number, citizenship, sex, residence address, copy of an identification document in addition to the expiry and number of the document, the bank account or bank current accounts from which the amounts invested are sent.

This data is voluntarily provided and will be processed in full compliance with data protection legislation. The failure to provide such data will have the sole consequence of the inability to create an account and access certain features.

The user is responsible for the accuracy of the data entered in the profile and guarantees the accuracy of the same.

Said data may also be processed in relation to the subsequent possible authorization of users as "Investors" and "Offeror" for the purpose of joining equity crowdfunding campaigns (under the conditions available in the specific area of the Website), or for the purposes of Walliance, and any subsequent publication on the Website, of offers to the public for the collection of risk capital through online portals.

Access to the site and services can be done using the credentials provided by a third party, such as Google, Facebook, or similar service ("social log-in"). In this case, the user is required to check the settings of such service and carefully read the policies of the third party provider, as these may authorize the third party to share his personal information and authorize Walliance to collect information such as contacts, friends and other user data. We will keep the identification code associated with the user's account at the service of the third party when you use it to log in to Walliance or to share content hosted by the site; the code will be kept as long as necessary to provide the required services. If you create a Walliance account or use site services by logging in through the social login, we may use the information contained in the originating account to complete your profile on the Site. The user can update or modify the profile information and contact information at any time through the social login.

Such data is kept for the time necessary to provide the requested services and, even for further periods, if the archiving is required by law or for other legitimate purposes such as defense in Walliance legal proceedings, or in case there is a legitimate interest of the data controlled or third parties.

2.3 Information collected through cookies

- Definitions, characteristics and application of the legislation

Cookies are small text files that the sites visited by the user send and record on his personal computer or any other device, even mobile, to then be re-transmitted to the same sites at the next visit. Thanks to cookies, a site remembers the user's actions and preferences (such as login data, the chosen language, font size, other display settings, etc.) so that they do not have to be re-indicated when the user returns to visit said site or browse from one page to another. Cookies, therefore, are used to perform computer authentication, monitoring sessions and storing information regarding the activities of users accessing a site, and may also contain a unique identification code that allows for tracking the user's navigation within the site itself for statistical or advertising purposes. During navigation on a site, the user can also receive, on his/her computer or mobile device, cookies from websites or web servers other than the one he/she is visiting (so-called "third-party" cookies). Some operations may not be able to be performed without the use of cookies, which in some cases are therefore technically necessary for the functioning of said site.

There are various types of cookies, depending on their characteristics and functions, and these can remain in the user's computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user's equipment until a predetermined deadline.

According to the legislation in force in Italy, the user's express consent is not always required for the use of cookies. In particular, "technical cookies", namely those used for the sole purpose of transmitting a communication over an electronic communications network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words, these are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

Among the technical cookies, which do not require express consent for their use, the Italian Data Protection Authority (See Measure Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies of May 8, 2014, hereinafter referred to as "Measure") also includes:

  • Similar to technical cookies where used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site,
  • browsing or session cookies (to authenticate the user),
  • functional cookies, that allow the user to browse based on a set of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided to the latter.

On the other hand, or "profiling cookies", namely those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the same in the context of surfing the net, a prior consent of the user is required.

Types of cookies used by this Site

The Website uses the following types of cookies, and offers the possibility to de-select the same, except for third-party cookies for which the user must refer directly to the relative methods of selection and de-selection of the respective cookies , indicated via the links:

  • Technical cookies, navigation or session, strictly necessary for the operation of the site, or to allow the user to take advantage of the contents and services requested by them.
  • Cookie analytics, which allow the Website manager to understand how the site is used by users. With these cookies we do not collect information about the user's identity or any personal data. Such information is treated in an aggregate and anonymous manner;
  • Functionality cookies, used to activate specific functions of the Site and a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service provided.

Ā ATTENTION: by disabling technical and / or functional cookies, the Site may not be available or certain services or certain functions of the Website may be unavailable or may not work properly, and the user may be forced to change or manually enter certain information or preferences every time they visit the Website.

  • Third-party cookies, namely cookies of sites or web servers other than that of the Owner, used for the purposes of said third parties, including profiling cookies. Please note that said third parties, listed below with the relative hypertext links to privacy policies, act as independent data controllers of data collected through the cookies they send; therefore, the user must refer to their policies regarding the processing of personal data, information and any forms of consent collection (selection and de-selection of the respective cookies).

Links to the respective information on the use of cookies (as required by the Measure Identification of the simplified procedures for the information and the acquisition of consent for the use of cookies - May 8, 2014, are shown below:

Google https://www.google.it/intl/it/policies/technologies/types/

Google Connect https://www.google.it/intl/it/policies/technologies/types/

Facebook Connect https://www.facebook.com/policies/cookies/

Intercom https://www.intercom.com/terms-and-policies#cookie-policy

Mailchimp https://mailchimp.com/legal/cookies/

Slack https://slack.com/cookie-policy

Facebook Pixel https://www.facebook.com/policies/cookies/

Mobyt https://www.mobyt.it/pdf/MOBYT_Informativa_cookies.pdf

Databox https://databox.com/privacy-policy

Prosperworks https://www.prosperworks.com/privacy

Realisti.co https://www.iubenda.com/privacy-policy/7795654/legal

The cookies forwarded directly by Walliance through the Website, are specified in more detail at the following link:

http://help.walliance.eu/tutorials-in-english/legal/cookies-policy

3. PURPOSE OF THE PROCESSING AND MANDATORY OR OPTIONAL NATURE OF DATA

The data you provide through the Website will be processed by the Data Controller for the following purposes:

a) Purposes related to the provision of the services requested (e.g.: contact request, newsletter subscription, registration, submission of offers by investors and bidders, resolution of issues related to the use of the Website, complaints, etc.).

The provision of your data for the purposes referred to in letter a) is optional, but failure to provide it could make it impossible to operate the required functionality. We do not require consent to the processing of personal data for these purposes because this treatment "is necessary to fulfill obligations arising from a contract of which the party concerned is part or to fulfill, before the conclusion of the contract, specific requests of the party concerned" (See Article 24, paragraph 1, letter b of the Privacy Code), and because "the processing is necessary for the execution of a contract of which the party concerned is a party, or for the execution of pre-contractual measures taken at the request of the latter"(see Article 6, paragraph 1, letter b GDPR).

b) purposes of statistical research/analysis on aggregated or anonymous data, without the possibility of identifying the user, aimed at measuring the functioning of the Website, measuring traffic and evaluating usability and interest

The processing of aggregated or anonymous data, as per letter d), does not provide for the application of the Privacy Code and the GDPR.

c) purposes related to the fulfillment of obligations under the law, a regulation, or Community legislation

The provision of your data for the purposes listed above (c) is mandatory. If not provided, this would not allow the data controller to meet the obligations established by law, by regulations or community legislation.

d) marketing purposes

The data provided may be processed, subject to explicit and specific consent, for sending promotional and marketing communications, including the sending of newsletters and market research, through automated tools (SMS, MMS, E-mail, push notifications, Fax) and non-automated tools (paper mail, telephone with operator). The legal basis for the processing of your data for these purposes is Art. 6, paragraph 1, letter a) of the Regulations. Commercial profiling and direct marketing treatments are optional and depend on your free choice; therefore, failure to provide your consent for these purposes will not affect the use of the services.

For processing carried out for the direct sending of own advertising material or direct sales, or for carrying out market research or commercial communications in relation to products or services of Walliance similar to those purchased by you, Walliance may use, without your consent, E-mail and paper mail addresses pursuant to, and within the limits permitted by Art. 130, paragraph 4 of the Code and the provision of the Italian Personal Data Protection Authority of June 19, 2008. The legal basis for the processing of your data for these purposes is Art. 6, paragraph 1, letter f) of the Regulations.

4. METHOD OF PROCESSING, SECURITY AND PLACE OF DATA PROCESSING

Your personal data is processed by the Data Controller, or by third parties selected with care for their reliability and competence as well as duly appointed data processors, limited to the achievement by the same of the purposes specified above, mainly with automated tools, but also in the paper form, for the time strictly necessary to achieve the purposes for which they were collected.

Specific security measures are observed to prevent the loss of data, illicit or incorrect use, and unauthorized access in full compliance with the provisions of Articles 31 et seq. of the Privacy Code and the Technical Disciplinary Rules - Annex B to the Privacy Code - regarding minimum security measures, and Art. 32 GDPR.

5. COMMUNICATION AND DISSEMINATION

Your personal data may be communicated to subjects external to the Data Controller, whose activity is necessary and functional to the provision of the Website's features.

Your personal data may be disclosed to third parties such as:

  • Persons, companies or professional firms that provide assistance and consulting to the Data Controller, duly appointed as data processors;
  • persons, entities or authorities who require the communication of your personal information as mandated by law or by order of the authorities;
  • persons delegated and/or appointed by the Data Controller to carry out activities strictly related to the pursuit of the aforementioned purposes (including technical maintenance interventions on the systems), duly appointed as data processors;Ā 
  • to business partners, service providers functional to software development, for the provision of services related to the Site. Where necessary, the Data Controller reserves the right to collect your specific consent.

Your personal data will not be disclosed by the Data Controller, unless your specific consent is given. Your data could be transferred abroad, in countries of the European Union or in countries outside the European Union that have received an adequacy decision by the Commission, or in countries that have not received this adequacy decision, in compliance and within the limits set forth in Articles 43 and 44 of the Code, as well as Articles 44 - 49 of the Regulations.

6. YOUR RIGHTS

You can exercise the rights referred to in Art. 7 of the Code, as well as, starting from May 25 2018, those referred to in Articles 15 - 22 of the Regulations - by sending a written request to the Data Controller. You can therefore obtain from the Data Controller confirmation of the existence or non-existence of your personal data and its availability in an intelligible form, of the identifying details of the Data Controller, the Data Processors and the persons to whom the data may be communicated, as well as obtaining the updating, rectification and integration of data, cancellation, transformation into anonymous form or blocking of data processed in violation of the law, and object, for legitimate reasons, to the processing of data, as well as submit a complaint to the Guarantor for the protection of personal data. For example, you can object to the sending of direct marketing with automated tools (SMS, MMS, E-mail, push notifications, Fax) and non-automated tools (paper mail, telephone with operator), at any time; furthermore, this right may also be exercised partially, that is, by opposing, for example, to the sending of promotional communications only via automated tools. Such rights (including, without limitation, the right to object) can also be exercised in relation to the data collected for profiling purposes. You can revoke the consent already given, at any time without affecting the lawfulness of the processing carried out before the withdrawal of consent.

Requests can be addressed by sending an E-mail to: privacy@walliance.eu

By leaving this page, the user declares to have read the information on the cookies above and to give their consent to their use as specified from the above-stated list.

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