PRIVACY POLICY

Privacy Notice to Users

Axio Parts S.r.l., with registered office at Via Asti 19/B - 10098 Rivoli (TO), VAT/Tax Code 13413810014 and registration number with the Turin Companies Register 13413810014, as independent controllers of the personal data of users (hereinafter, the "Users") who browse and use the services available on the website axio-parts-srl.myshopify.com (hereinafter, the "Website" and the "Services") hereby provide the privacy notice pursuant to art. 13 of EU Regulation 2016/679 of April 27, 2016 (hereinafter, the "Regulation", or also the "Applicable Law").

This Website and the Services are reserved for individuals who have reached the age of eighteen. The Data Controllers therefore do not collect personal data relating to individuals under 18 years of age. Upon Users' request, the Data Controllers will promptly delete all personal data inadvertently collected relating to individuals under 18 years of age.

The Data Controllers highly value the right to privacy and the protection of their Users' personal data. For any information regarding this privacy notice, Users can contact the Data Controllers at any time using the following methods:

• By sending a registered letter with return receipt to the legal headquarters of the Data Controller Axio Parts S.r.l. (Via Asti 19/B, 10098, Rivoli, Turin);
• By sending an email to the address ecommerce@axioparts.com;
• By sending a certified email (PEC) to the address axioparts@pec.it.

Axio Parts S.r.l. has not appointed a Data Protection Officer (DPO), as it is not subject to the designation obligation under art. 37 of the Regulation.

Purpose of processing

Users' personal data will be lawfully processed by Axio Parts S.r.l. pursuant to art. 6 of the Regulation for the following processing purposes:

a) Contractual obligations and provision of Services:

• To enable the use of the Services, including but not limited to purchasing products, shipping purchased products, managing any returns of purchased products: the data processed includes first name, last name, shipping address, email address, phone number, as well as all personal information voluntarily provided by the User, for example in the case of a return note;
• For managing any requests received through customer service and/or the Website: the data processed includes first name, last name, email address, phone number, and other data that may be necessary depending on the circumstance (for example, order number, shipping address, information about purchased products).

The User's personal data will be used by Axio Parts S.r.l. exclusively to verify the User's identity (also through validation of the email address), thus preventing possible fraud or abuse, and to contact the User for service reasons only (e.g., sending notifications related to orders, shipping confirmations, order status updates) and/or manage orders and requests as indicated above. Without prejudice to what is provided elsewhere in this privacy policy, under no circumstances will Axio Parts S.r.l. make Users' personal data accessible to other Users and/or third parties.

The legal basis for the processing is the necessity to execute pre-contractual and contractual obligations of which the User is a party. Providing personal data for the processing purposes indicated above is optional but necessary, as failure to provide them will make it impossible for the User to use the Services and purchase Products on the Site or receive after-sales assistance.

b) Administrative-accounting purposes:

Personal data are processed to carry out organizational, administrative, financial, and accounting activities, such as internal organizational activities and activities functional to fulfilling contractual and pre-contractual obligations, for example issuing purchase receipts and/or invoices, managing company accounting and administrative archives.

The legal basis for the processing is the necessity to execute pre-contractual and contractual obligations of which the User is a party, as well as the need to comply with legal obligations. Providing personal data for the processing purposes indicated above is mandatory to finalize orders and comply with legal obligations.

c) Legal purposes:

Personal data are processed to comply with obligations provided by Italian and European law, regulations, community legislation, or orders from competent Authorities. This includes, by way of example but not limited to, tax, fiscal, document retention obligations, as well as obligations arising from requests by judicial or public security Authorities.

The legal basis for the processing is the fulfillment of a legal obligation to which the Data Controller is subject pursuant to art. 6, par. 1, lett. c) of the Regulation. Providing data for these purposes is mandatory, and failure to provide them may result in the inability to complete the order or provide the requested Services.

Processing methods

The Data Controllers will process Users' personal data using manual and electronic tools, with logic strictly related to the purposes themselves and, in any case, in a way that guarantees the security and confidentiality of the data.

Data retention periods

Users' personal data will be retained for the time strictly necessary to fulfill the primary purposes described in the previous paragraph, or in any case as provided by law and/or necessary for the civil protection of the interests of both Users and Data Controllers.

In particular, Axio Parts S.r.l. undertakes to delete the data provided from its systems:

• For the execution of sales and management of Services, including after-sales services, after 10 years from the date of the last purchase or last interaction with Axio Parts S.r.l.;
• Data provided in relation to requests submitted through customer service or the Site, after 10 years from the date of provision;
• Data provided for registration on the Site, after 10 years from the date of cancellation of the related registration on the Site;
• Data processed for the purpose of sending commercial information as well as for participation in customer satisfaction surveys and market research, after 5 years from data collection, or until any opposition.

In any case, the Data Controller undertakes to base data processing on the principles of adequacy and minimization, annually verifying the necessity of retention for a period not exceeding what is necessary to achieve the purposes for which the data were collected and processed.

The Data Controller may retain the data to comply with legal obligations or to ascertain, exercise, or defend its rights in court.

Once the purposes for which the data were collected and processed have been achieved, the Data Controller will take appropriate measures to anonymize them, thereby preventing the identification of the User, while still retaining the possibility to continue using the data in anonymous form.

Scope of communication and dissemination of data

Employees and/or collaborators of the Data Controllers responsible for managing the Site and all services related to the provision of the Services, including marketing activities, may become aware of Users' personal data. These individuals, who have been instructed accordingly by the Data Controllers pursuant to Article 29 of the Regulation, will process Users' data exclusively for the purposes indicated in this privacy notice and in compliance with the provisions of the Applicable Law.

Third parties who may process personal data on behalf of the Data Controllers as "Data Processors," such as, by way of example, providers of IT and logistics services essential to the operation of the Site and/or Services, outsourcing providers, hosting or cloud computing providers, couriers and shippers, credit institutions and payment services, professionals and consultants of the Data Controller, may also become aware of Users' personal data.

Users have the right to obtain a list of any processors appointed by the Data Controller by making a request using the methods indicated in this privacy notice.

Furthermore, Users' personal data may be communicated by Axio Parts S.r.l., to the extent necessary and essential to fulfill contractual obligations, to independent third-party data controllers, such as payment service providers and logistics service providers necessary for the delivery of goods sold through the Site. These independent controllers will process the User's data exclusively for the correct fulfillment of orders related to the Services.

The Data Controllers will not disclose Users' personal data.

Transfer of personal data to third countries

All data processing takes place in Italy, in countries within the European Union, in Canada, and, in some cases, in the United States.

If there is a need to transfer data to additional Third Countries, the Data Controller undertakes to:

• Ensure that the country to which the data will be sent guarantees an adequate level of protection, as provided for by Article 45 GDPR; or
• Use the standard contractual clauses for data protection approved by the European Commission for the transfer of personal information outside the EEA pursuant to Article 46.2 GDPR.

Rights of the Data Subjects

Users may exercise the rights guaranteed to them by the Applicable Regulations by contacting the Data Controllers using the following methods:

• By sending a registered letter with return receipt to the registered office of Axio Parts S.r.l. (Via Asti 19/B, 10098, Rivoli, Torino);
• By sending an email to the address ecommerce@axioparts.com;
• By sending a certified email (PEC) to the address axioparts@pec.it.

Axio Parts S.r.l. will comply with Users' requests related to the processing for which it is the Data Controller.

Pursuant to the Applicable Regulations, the Data Controllers inform that Users have the right to obtain the indication of (i) the origin of personal data; (ii) the purposes and methods of processing; (iii) the logic applied in case of processing carried out with the aid of electronic tools; (iv) the identifying details of the Controllers and processors; (v) the subjects or categories of subjects to whom personal data may be communicated or who may become aware of it as processors or appointees.

Furthermore, Users have the right to obtain:

a) access, updating, correction, or, when relevant, integration of data;
b) the deletion, anonymization, or blocking of data processed unlawfully, including data that do not need to be kept in relation to the purposes for which they were collected or subsequently processed;
c) the confirmation that the operations referred to in letters a) and b) have been brought to the attention, including regarding their content, of those to whom the data have been communicated or disclosed, except where this proves impossible or involves a manifestly disproportionate effort compared to the protected right.

Furthermore, Users have:

a) the right to withdraw consent at any time, if the processing is based on their consent;
b) (where applicable) the right to data portability (the right to receive all personal data concerning them in a structured, commonly used, and machine-readable format), the right to restrict the processing of personal data, and the right to erasure ("right to be forgotten");
c) the right to object:
   i) in whole or in part, for legitimate reasons to the processing of personal data concerning them, even if relevant to the purpose of collection;
   ii) in whole or in part, to the processing of personal data concerning them for sending advertising material or direct sales or for carrying out market research or commercial communication;
   iii) if personal data are processed for direct marketing purposes, at any time, to the processing of their data carried out for such purposes, including profiling to the extent that it is related to such direct marketing.
d) if they believe that the processing concerning them violates the Regulation, the right to lodge a complaint with a Supervisory Authority (in the Member State where they usually reside, where they work, or where the alleged violation occurred). The Italian Supervisory Authority is the Data Protection Authority, located at Piazza Venezia no. 11 - 00187 – Rome (http://www.garanteprivacy.it/).

Liability for links

The Owners are not responsible for updating all the links visible in this Notice; therefore, whenever a link is not working and/or updated, Users acknowledge and accept that they must always refer to the document and/or section of the websites referenced by that link.

Axio Parts S.r.l.
Registered office: Via Asti 19/B, 10098 Rivoli (TO)
Tel. +39 340 673 7574
Email: ecommerce@axioparts.com
PEC: axioparts@pec.it
VAT number, Tax Code, and registration number in the Turin Business Register: 13413810014