Privacy Regulation and GDPR for “GreenHydrogenTech Accelerator”

Privacy Notice According to the Regulation (EU) 2016/679

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Officine Innovazione S.r.l., as Data Controller, would like to inform you, according to art. 13 of Regulation EU 2016/679 related to personal data protection (“Regulation”), Italian Legislative Decree no. 196/2003, as  modified by Italian Legislative Decree 101/2018, that personal data provided by you through this website (“Website”), in the context of your participation in GreenHydrogenTech Accelerator Program, organized and managed by the same Officine Innovazione S.r.l., in line with the Official Rules for the “GreenHydrogenTech Accelerator Program”, will be processed in compliance with the laws in force, as further specified.

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1. Data Controller and Data Protection Officer

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The Data Controller is Officine Innovazione S.r.l., VAT No. 10230520966, with registered office in Milano, via Tortona 25.

Officine Innovazione S.r.l. appointed a Data Protection Officer (DPO), to be contacted at the following e-mail address: dataprotectionofficer@deloitte.it

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2. Nature of Personal Data, Purposes and Legal Bases of the processing activities

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The personal data processed by Officine Innovazione S.r.l., where “personal data” means any information relating to an identified or identifiable natural person, also indirectly by reference to any other information, are those provided to Officine Innovazione S.r.l. by the person participant (hereinafter “Participant” or “Data Subject”) in GreenHydrogenTech Accelerator Program, filling in the registration form and submitting the application for this Accelerator Program, including name, surname, role assumed in the company participating to the GreenHydrogenTech Accelerator Program.

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The processing of personal data has the following purposes:​

1. for the management of any activities required for the implementation and execution of services related to the GreenHydrogenTech Accelerator Program, including the Projects evaluation and the selection of the Projects that will participate to Accelerator Program, as described in the Official Rules, as well including Participants’ registration in Officine Innovazione S.r.l. ecosystem platform;

2. for the performance of legal obligations applicable as established by national and EU legislation, also in accounting, tax, anti-money laundering and anti-corruption laws;

3. in order to comply with requests by the Authorities and public bodies, to exercise rights, also of third parties, before the Court or in administrative or arbitration or conciliation procedures;

4. with your consent, for advertising and promotional activities, in order to inform you by sending commercial communication, promotions, direct offers and newsletters about services, future initiatives, and next events organized and sponsored by Officine Innovazione S.r.l. through traditional methods, by using the telephone operator and paper mail, and/or also through automated systems (e-mail, sms, mms, fax);

5. with your consent to communicate your data to Promoters of this Accelerator Program and Officine Innovazione S.r.l. Clients in order to inform you by sending commercial communication, promotions, direct offers and newsletters about services, future initiatives, and next events.

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The legal basis for the data processing are:

• the necessity to carry out the services provided to the Participant with reference to the aforementioned purpose in point 1 (article 6, par. 1, let. b) of the Regulation);

• the fulfillment of legal obligations with reference to the aforementioned purposes in points 2 and 3 (article 6, par. 1, let. c) of the Regulation), and

• your consent with reference to the advertising and promotional purposes in points 4 and 5 (article 6, par. 1, let. a) of the Regulation).

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3. Mandatory /Optional nature of providing personal data

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The provision of personal data of the Participant for the purposes in points 1-2-3 of section 2 is mandatory as strictly necessary for the participation of the Participant in GreenHydrogenTech Accelerator Program and for the fulfillment of legal obligations. The refusal to provide personal data implies the impossibility to permit the participation of the Participant in GreenHydrogenTech Accelerator Program and to fulfill the legal obligations.

The provision of personal data of the Participant for the purpose in points 4 and 5 of section 2 is optional. The refusal to provide personal data implies to do not receive advertising and promotional communications from Officine Innovazione S.r.l, Promoters and Officine Innovazione S.r.l. Clients and it does not prevent to receive the services related to GreenHydrogenTech Accelerator Program.

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4. Methods of the processing activities

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The personal data is collected electronically and processed with electronic tools and manually, ensuring the appropriate security measures and the confidentiality of the data processed, according to the principles of art. 5 of Regulation, such as lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality.

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5. Period of the processing activities

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With reference to the purposes under section 2, points 1-3, the personal data will be processed for the entire duration of GreenHydrogenTech Accelerator Program and as long as it is needed for the performance of services related to this Accelerator Program, without prejudice for the further period required for the fulfilment of current civil, fiscal and tax obligations and for exercise or defend a right before the Court.

With reference to the purpose under section 2, points 4 (marketing) and 5 (communication to third parties), your personal data will be kept for no more than 12 months starting from the communication of your personal data to Officine Innovazione S.r.l.

6. Communication and transfer of personal data

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With reference to the above-mentioned purposes, Officine Innovazione S.r.l. may communicate the personal data to the following recipients:

• Promoters (Corporate, Supporting and Investors) GreenHydrogenTech Accelerator Program, as autonomous Data Controllers, for the aforementioned purposes;

• Officine Innovazione S.r.l. Clients, as autonomous Data Controllers;

• Third parties appointed by Officine Innovazione S.r.l. for the fulfillment of services related to the performance of the activities provided under GreenHydrogenTech Accelerator Program, as Data Processor, such as Software company which manages this Website;

• Competent authorities (including Courts), for the performance of their institutional functions within the limits established by law or regulations.

Your personal data will be processed by Officine Innovazione S.r.l. collaborators and/or employees as authorized persons, within the scope of their respective functions and in accordance with the instructions given by Officine Innovazione S.r.l. itself.

If necessary for the aforementioned purposes, the data collected will be transmitted and accessible to the aforementioned recipients, also those based in non-EU countries.

In such cases, the Data Controller guarantees the adoption of appropriate safeguards, which ensure an adequate level of data protection, such as the use of standard contractual clauses for the transfer of personal data to non-EU countries.

The personal data will not be disclosed to undetermined recipients.

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7. Data Subject’s rights

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According to the purposes of processing above, the Participant as Data Subject has the following rights (artt.15-21 of Regulation):

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• obtain confirmation that Officine Innovazione S.r.l. is processing data subject’s personal data, access it and request a copy of it (right to access);

• update, modify and/or correct personal data (right to rectification);

• request the erasure or the limitation of the processing of data processed in violation of the law, including data that do not need to be kept for the purposes for which they were collected or otherwise processed (right to restriction of processing);

• object to data processing activities and, at any time, to processing of personal data for marketing purposes (right to object);

• withdraw the consent, where given, without prejudice to the lawfulness of the processing of the consent given before the withdrawal;

• lodge a complaint with the data protection Authority or before a Court;

• receive a copy of personal data in an electronic format and request that such data will be transmitted to another Data Controller (right to data portability).

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In order to exercise these rights, the Data Subject may contact the Data Protection Officer by sending an e-mail to e-mail address mentioned above.