Privacy Policy AGRI NETWORKING TOOLS

1. Introduction

This User Privacy Policy describes our methods for collection, use, transmission, storage and protection of your personal information.

When you register an account with AGRI NETWORKING TOOLS, you accept all the terms of the User Privacy Policy and of our User Agreement. You also consent to the collection, use, transmission, storage and protection of your personal information in accordance with what is described in the User Privacy Policy of AGRI NETWORKING TOOLS.

AGRI NETWORKING TOOLS, the company with which you enter into an agreement, is the data controller and is responsible for the collection, use, transmission, storage and protection of your personal information in accordance with current international privacy standards and national laws. The data controller may transfer data to other parties in the manner described in this User Privacy Statement. AGRI NETWORKING TOOLS may process and store your personal information on servers in our offices as well as with the CoolNetwork cloud hosting service as Data Processor.

Personal information

"Personal information" means information and/or data that can be associated with a specific person and that could be used to identify that specific person also in combination with other data that the company has or with other data that the company may attain. Information is not considered personal if it has been made anonymous or aggregated to prevent the identification of a specific person, not even in combination with other information or otherwise.

Amendments to the User Privacy Policy

We reserve the right to amend this User Privacy Policy at any time by posting the provisions on our websites. All the amended provisions become effective 30 days after they are posted.

2. Purpose of data processing and consent

This User Privacy Policy describes our methods for collection, use, transmission, storage and protection of your personal information. The provisions of this document apply to any application, service or instrument (collectively referred to as "services") of AGRI NETWORKING TOOLS where reference is made to the User Privacy Policy, regardless of the type of access and use, including use by means of mobile devices.

When you use our platforms and/or register an account with AGRI NETWORKING TOOLS, you accept all the terms of the User Privacy Policy and of our User Agreement. You also consent to the collection, use, transmission, storage and protection of your personal information in accordance with what is described in the User Privacy Policy.

If you do not provide the information requested, you may be unable to use our services.

A) primary purposes of data processing:

A.1 Pre-agreement and agreement-related purposes regarding the regulations governing the creation of an account with AGRI NETWORKING TOOLS.

Firstly, the personal information that you are required to provide when creating an account with the AGRI NETWORKING TOOLS platform is processed to enable you to participate in the negotiation initiatives offered by the platform by registering an account.

The registration process consists in filling out a participation for where you are requested to indicate your personal details - some of which are required fields - in order to activate authentication credentials (login + password) which will later be used to identify you on the AGRI NETWORKING TOOLS platform. Therefore, the primary purpose of data processing includes the need to complete the procedures required by AGRI NETWORKING TOOLS to register and create an account as well as to enable generation, technical and administrative management (including providing technical support upon request) of the account, of the passwords and similar authentication credentials created during the registration process. This procedure will be carried out regardless of whether registration is by a physical person or by a legal entity.

Moreover, before a person participates in the negotiation initiatives, in accordance with the terms set out and specifically, processing of personal information could fulfil pre-agreement purposes, such as replying to specific requests made by the user. For greater transparency, the primary purpose of data processing associated with the fulfilment of obligations deriving from negotiation initiatives can include, inter alia: performance of all the activities involved in the organization and management of the platform, administrative and technical assistance to registered users, management of requests, prevention/repression of fraudulent activities, filing of personal details of registered users, use of personal information for notifications relating to the relationship established with users who have joined a purchase/sale initiative, etc.

A.2 Purposes relating to the fulfilment of obligations provided by the law, by regulations or by EU standards.

Secondarily, personal information will be processed to fulfil the obligations provided by the law, by regulations or by European Community standards and for civil law, financial reporting and taxation purposes.

B) Disclosure and circulation of personal information for fulfilment of primary processing purposes.

We inform you that AGRI NETWORKING TOOLS may disclose your personal information to third parties when necessary for the fulfilment of obligations resulting from the negotiation activities, and required by law (inter alia: persons, companies or professional firms providing assistance, consultation or services in the area of accounting, administration, legal advice, taxation and finance in relation to trading activities).

Moreover, in the pursuit of the primary purposes, your data may be disclosed to any other third parties when such disclosure is required by the law or to duly provide services that are set forth in the regulation or in the terms of Promotional Initiatives.

Pursuant to art.13, paragraph 1 (d) of the Italian Data Protection Code and art.13, paragraph 1 (e) of EU Regulations, listed below are the persons and categories of persons who may have access to your personal information in their capacity as data processors or officers in charge:

• staff employed by the Data Controller;

• third parties involved by the Data Controller for the organization and administration of the AGRI NETWORKING TOOLS platform, from time to time considered, appointed as data processors.

You personal information will not be circulated.

B1. Optional or mandatory consent for fulfilment of the primary purposes of data processing.

In the above described events - and pursuant to the provisions of the Italian Data Protection Code and of EU regulations - the Data Controller is not required to obtain specific consent to processing of the participant's data for the trading activity considered from time to time. All the above processes pursue the primary purposes for which article 24 of the Italian Data Protection Code and article 6 of the EU regulation exclude the need to obtain a specific consent from the data subject, both because processing is necessary to fulfil an obligation required by the law, by a regulation or by EU standards, both because processing is needed to meet obligations associated with an agreement (in the case at hand: trading activities) in which the data subject participated or to meet, before closing the agreement, specific requests of the data subject or - lastly - because data processing is required for administration/accounting purposes under art. 34 i-ter of the Code.

If the data subject still refuses to supply the personal information requested and needed for the above reasons, this will result in the inability to participate in the activities offered by the AGRI NETWORKING TOOLS platform.

C. Secondary purposes of data processing - Promotional, advertising, marketing purposes, market research.

The personal information collected for the administration purposes connected with the organization of and participation in the activities of AGRI NETWORKING TOOLS from time to time considered will be processed (together with other additional and optional contact information, such as email address, mobile number, geographical address, which could be requested from the data subject) by automated means, for the following purposes, which are specified below in accordance with the General Security Measure of the Italian Data Protection Authority dated 4 July 2013, setting out Guidelines for preventing spamming: commercial promotion, advertising and marketing communication in the broadest sense, unsolicited commercial offers, market researches, surveys (including by phone, online or through forms), statistical processing (in identifiable form) regarding products and/or services associated with the Data Controller (hereinafter, collectively referred to as "Processing for Marketing Purposes"). By consenting to Processing for Marketing Purposes, the data subject specifically acknowledges such promotional, commercial and marketing purposes in the broadest sense (including the resulting administration activities) and, once consent has been given in accordance with the required procedures, expressly authorizes said processing in accordance with article 23 of the Italian Data Protection Code (as the Data Controller could use for Processing for Marketing Purposes means such as telephone with operator or other means that are non-electronic, not telematic or not supported by automated, electronic or telematic mechanisms and/or procedures, including manual contact methods and paper mail), with art. 130 of the Italian Data Protection Code (as Data Controller could use means for Data Processing for Marketing purposes such as email, fax, text messages, mms, automated systems without operator and the like, including electronic platforms and other telematic means), and with article 6, paragraph 1(a) of the Regulation.

Pursuant to the General Security Measure of the Italian Data Protection Authority dated 15 May 2013 “Consent to personal data processing for purposes of direct marketing by traditional and automated contact instruments”, attention is drawn specifically to the fact that:

1. data subject's consent to commercial and promotional communications, under art. 130, paragraphs 1 and 2, of the Code (i.e. using email, fax, text messages, mms, automated systems without operator and the like, including electronic platforms and other telematic means) will imply that said communications will be received not only through said automated contact methods, but also by traditional methods, such as paper mail or operator call;

2. the data subject's right to refuse processing of personal data for "direct marketing" purposes by the above mentioned automated contact methods, will in any case extend to traditional methods and, in that case, without prejudice to the right to exercise said right partially, in accordance with art. 7, paragraph 4, of the Code, with respect to specific types of methods or specific types of processing;

3. a data subject who does not intend to give consent in the above terms retains the right to request that communications for the above marketing purposes be sent exclusively by traditional contact means, where available: this request may be made free of charge by sending a simple email to admin@ant-program.com.

4. With the aim of ensuring that the data controller's data protection obligations are fulfilled in accordance with the principle of simplification of said obligations (art. 2 of the Code) and pursuant to General Security Measure of the Italian Data Protection Authority dated 15 May 2013“Consent to personal data processing for the purpose of direct marketing by traditional and automated contact instruments”, a unique and unified consent formula (pursuant to art. 23 and 130 of the Code) shall be available to the data subject, listing all the possible means employed for marketing data processing, without prejudice to the possibility for the data subjects to inform the Data Controller on admin@ant-program.com if they wish to receive the marketing communications they have consented to only by some means and to by other means. Moreover, also with the aim of ensuring that the data controller's data protection obligations are fulfilled in accordance with the principle of simplification of said obligations (art. 2 of the Code), the specific consent formula will be unique and unified and shall list all the different marketing purposes herein described (i.e. without multiplying the consent formulas for each different marketing purpose pursued by the data controller), without prejudice to the possibility for the data subjects to inform the Data controller, even at a later time, if they wish to express different choices with respect to their consent or non-consent to the single marketing purposes.

In order to proceed with Processing for Marketing Purposes the Data Controller is required to obtain, beforehand, a specific, separate, explicit, documented, informed and freely given consent.

Consequently, before deciding to give the specific consent, the data subject must be informed and aware that the purpose for processing is of a specific commercial, advertising, promotional and marketing nature, in the broadest sense. For absolute transparency, we are informing you that the data will be collected and then processed only after specific consent:

• to send to data subjects who have given informed consent advertising, informative material, of a promotional or other commercial nature, in accordance with article 23 and 130 of the Italian Data Protection Code;

• to carry out direct sale activities or sale of products or services of the Data Controller;

• to send commercial information; to make interactive commercial communication pursuant to article 58 of Legislative Decree 206/2005 by email;

• to produce market researches, studies, statistics and carry out surveys and inquiries by telephone or electronic communication means;

• Therefore, by giving an optional consent, the data subject specifically acknowledges and authorizes such possible, further secondary data processing.

In any event, even if the data subject has authorized the Data Controller to pursue the purposes set out in points 1 to 5 above, he/she will be entitled to revoke it at any time, by sending without any formality a clear communication to that effect to: admin@ant-program.com. Upon receipt of said opt-out request, the Data Controller shall promptly delete the data from the database used for Data Processing for Marketing Purposes and inform any third parties to which such data have been disclosed so that they may delete the data for the same purposes. The receipt of the request of data deletion shall in itself serve as confirmation of deletion.

We also inform you that, as requested by art.21 of the EU Regulation, if personal information is processed for direct marketing, you have the right to object at any time to processing of personal data for said purposes. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

We also inform you that, as requested by art.21 of the EU Regulation, if personal information is processed for direct marketing, you have the right to object at any time to processing of personal data for said purposes. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

We also inform you that, as requested by art.21 of the EU Regulation, if personal information is processed for direct marketing, you have the right to object at any time to processing of personal data for said purposes. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

3. Data collection.

AGRI NETWORKING TOOLS collects, processes and stores the personal information entered manually by the data subject and/or collected automatically through the devices (including mobile devices) when:

• the data subject uses the services offered by the AGRI NETWORKING TOOLS platform;

• the data subject registers an account with AGRI NETWORKING TOOLS, when he or she updates or adds information to the account, or contacts AGRI NETWORKING TOOLS in any other way regarding the services offered by the platform;

• supplies data to AGRI NETWORKING TOOLS in a website form.

The “personal information” collected include:

• Personal information that the data subject provides when using our platform or registering an account with AGRI NETWORKING TOOLS;

• Identifying information such as name, address, telephone number or email address, provided when registering an account with AGRI NETWORKING TOOLS, either as a physical person or legal entity;

• Information relating to purchase or sale offers, provided during a transaction or other content based on the transactions generated or connected to your account following a transaction in which you participated;

• Financial information (e.g. credit card number or bank account) in relation to a transaction;

• Information relating to shipment, invoicing and other kind of information used to collect or sell a product, as well as, where postal service is provided through one of our programmes, information required for custom clearance (e.g. tax codes or other identification numbers) and information for shipment (e.g. shipment codes and associated updates);

• Other information that AGRI NETWORKING TOOLS is required or authorized to collect and process, in accordance with current national laws, for the purpose of authenticating or identifying the user or verifying the information collected.

Personal information collected automatically when you use the services offered by the platform or you register an account with AGRI NETWORKING TOOLS:

• We also collect information on the interaction with the services offered by the AGRI NETWORKING TOOLS, advertising settings and communications with AGRI NETWORKING TOOLS. These are data collected via devices (including mobile devices) which you make use of when you access our Services, register an account with AGRI NETWORKING TOOLS, provide data to AGRI NETWORKING TOOLS in a web form, update or add information to your account, participate in community discussions, chats, resolution of disputes or contact AGRI NETWORKING TOOLS in any other way regarding our Services. This information includes: ID or unique identifier of the device, device type, ad ID and unique device token.

• Geo-location information, including position data collected through your mobile device. We remind you that most mobile devices allow you to control or disable the use of location services by the apps installed.

• Information on your computer and connection, such as statistics on pages views, traffic to and from sites, referral URL, ad data, IP address, browsing history and web log data

Personal information collected through cookies and similar technology.

We use cookies, unique identifiers and similar technology to collect information about the pages and links visited and other actions that you perform through our Services, inside advertising content or emails.

Personal information from other sources.

• We may supplement the information we collect with data from third parties and add it to your account information. For example, we may collect and use demographic data that is publicly available, additional contact information, credit check data and information relating to creditworthiness provided by credit bureaus, in conformity with current national laws.

• We can authorize you to share information with social media sites, or use such sites to create your account or to connect your account with the respective social media site. Said social media could authorize AGRI NETWORKING TOOLS to automatically access certain personal information retained by them (e.g. content viewed by you or content that you particularly like, and information about the ads you have been shown or that you have clicked on and so on). If you provide us with access to any site with video content, you authorize us to share your video viewing activity with third-party social media sites, or to obtain information about your video viewing from said sites, for at least two years or until you decide to refuse consent to data processing. You may control the personal information you allow us to access through the privacy settings available on the relevant social media and the authorization/consent you give us when you grant us access to your personal information processed by said social media. By associating an account managed by a social media with your AGRI NETWORKING TOOLS account and authorizing us to access this information, you authorize us to collect, use and store the information provided by said social media in accordance with this User Privacy Policy.

• You can give us information about another person only with their explicit and prior consent. You have to inform this person about the way we collect, use, disclose and store personal information in accordance with this User Privacy Policy.

4. Storage of data.

The data generated during a year of activity are stored on the Italian Cloud Hosting service CoolNetwork, on magnetic devices in the registered office of AGRI NETWORKING TOOLS or with the computer operator in charge of IT system management.

The personal information of data subjects who register an account with AGRI NETWORKING TOOLS and who use the services offered by the platform will be stored for the time needed to carry out the primary purposes described and therefore for the whole time you are a registered user of the platform.

5. Exercising your rights.

Pursuant to article 7 of the Italian Data Protection Code and articles 13, paragraph 2, (b) and (d), 15, 18, 19 and 21 of the Regulation, we inform you that:

1. you have the right to access your personal data, to rectify, update and erase the data, or to limit processing of data concerning you or to object to processing, in addition to the right of data portability;

2. you have the right to complain with the Italian Data Protection Authority, using the procedures and information posted on the official website of the Authority www.garanteprivacy.it.

AGRI NETWORKING TOOLS undertakes to guarantee that the personal information collected is correct and updated and that the data subject has the possibility of accessing it and rectifying it. With respect to the right of access, we guarantee that:

• - you can view, examine and change your personal information by accessing your account; you can immediately update your personal information in case of changes or errors;

• - AGRI NETWORKING TOOLS undertakes to respect your right to access, modify or erase your personal information;

• - however, AGRI NETWORKING TOOLS may deny access or decline to modify or erase your personal information but only after providing reasons for their refusal.

6. Security measures

AGRI NETWORKING TOOLS protects the information of the data subjects through the use of technological and management security measures designed to reduce the risk of loss, incorrect use, unauthorized access, disclosure and alteration.

The data collected yearly are stored on magnetic devices in the registered office of AGRI NETWORKING TOOLS or with the computer operator in charge of IT system management.

In addition, traffic will be filtered by means of CDN Cloudflare so as to prevent DDOAS attacks and ensure an effective system for caching of static content. Use of the entire platform is exclusively through HTTPS protocol with certified, verified SSL in conformity with security standards.

If you believe that your account has been violated, do not hesitate to contact us at the address indicated below.

Privacy protection procedures adopted by third parties.

This User Privacy Policy refers only to the use and transmission of the personal information we collect from data subjects. If you disclose information to other persons or if you are directed to a third-party website, the privacy policies and rules of that third party will apply.

We cannot guarantee privacy and security for information that you supply to third parties, therefore we invite you to evaluate the privacy rules and the security of the other party before participating in a transaction and choosing to share your information. This also applies in the event that the third party to whom you disclose your information are bidders, buyers or sellers on our websites.

7. Questions and complaints

For questions or complaints relating to this User Privacy Policy, to international privacy standards or information management procedures, please contact AGRI NETWORKING TOOLS Srl, via Pietro Maroncelli, 17 - 20154 Milano - Italy.