Informativa Privacy

A

GENERAL PROVISIONS

This privacy statement is intended to describe the methods of processing personal data (hereinafter the "Data") relating to users of the site www.epico.com (the "Website") owned by the company eFanswer LTD, with Headquarters: 55 London Road, St. Johns Wood, London, N127JJ, VAT No. GB 205 5973 05 (hereinafter the "Company"). The information applies only to the Website and not to other websites that may be consulted by the user through specific links.

B

HOLDER OF THE TREATMENT

Data processing carried out by the Company, ie eFanswer LTD, based in 55 London Road, St. Johns Wood, London, N127JJ, VAT No. GB 205 5973 05, as data controller, and is based on principles of correctness, lawfulness, transparency and protection of the rights of users of the Website.

C

PERSONAL DATA ACQUIRED, PURPOSE OF THE TREATMENT AND LEGAL BASIS

The Company collects and processes personal data specifically and voluntarily provided by users of the Website, namely: name, surname, email, nationality and city of residence / domicile (the "Data"). The Company processes the Data correctly and adopts adequate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of the Data. Data provided by users will be processed, also by automated means, for following purposes:

C.1

USE OF THE WEBSITE (AND ITS FUNCTIONS)

The Data collected by completing the registration form on the Website will be processed to allow the user to interact with the Website and therefore with the various features present on the same, including the possibility for users to ask questions and interact with the VIP (from the sports world, television, music, etc.). The provision of data is necessary to allow the user to interact with the functions of the website: therefore, in the event of refusal or failure to communicate the requested data, it will not be possible to exploit the functions of the website. present processing is the need to perform pre-contractual measures taken at the request of the interested party (ie, the user).

C.2

Marketing (receiving commercial communications)

Subject to the user's express consent, which represents the legal basis for processing the Data for this specific purpose, the Data collected will be used for the purpose of sending information and / or commercial communications, including any offers regarding products and / or services of society. The user may in any case cancel his subscription to the newsletter service (for marketing purposes) at any time, following the procedure indicated in each communication or by sending a specific request to the Company, at the addresses indicated in the following point G. (Contact details )

C.3

Communication and / or transfer of personal data to third parties for commercial purposes

Subject to the user's express consent, which represents the legal basis for processing the Data for this specific purpose, the Data collected will be communicated and / or transferred to third-party companies that have signed commercial agreements with the Company and used by them for the purpose of sending of communications of an informative and / or commercial nature, including any offers concerning products and / or services by the aforementioned third party companies. The third-party companies to which the Data will be transferred (subject to the consent of the interested party), which act as autonomous data controllers, will be expressly identified, from time to time, on the Site. The user may in any case revoke the consent to this specific treatment in any time, following the procedure indicated in each communication, you should receive from third-party companies.

D

PROCEDURES AND RESPONSIBLE FOR THE TREATMENT

The Data will be processed using manual and IT tools by Company personnel and collaborators and / or external parties duly designated contractually as data controllers and processors. In particular, the Data will be accessible - for the same purposes for which the data is collected - to data controllers, including, primarily, parties that provide services for the management of the Company's IT system and telecommunications networks. The complete list of data processing managers is available upon request, which can be sent to the addresses indicated below in the next item G. (Contact data).

E.

DATA ADDRESSEES

The data communicated will in no case be disclosed. Subject to the express consent of the user, to be displayed within the Website and / or in the forms that the Company deems appropriate, the Data may be transferred to third party companies with which the Company collaborates in the supply of products and / or services. These third party companies will process the User data as autonomous data controllers, providing the user - in the first useful moment - with his / her own information on the processing of personal data.

E.

STORAGE PERIOD

The Data collected and processed by the Company, for the purposes identified in the preceding point C, may be kept for a period: a) not exceeding 12 (twelve) months, for the hypothesis defined in point C.1, ie for registration and for interaction with the functions of the Website; b) not exceeding 24 (twenty-four) months, for the hypothesis defined in point C.2, ie for the receipt of communications, by the Company, for commercial purposes.

G.

RIGHTS OF THE INTERESTED PARTY AND CONTACT DATA

The user may: (I) obtain confirmation of the existence or not of personal data concerning him; (II) know the purposes of the processing and the methods, the recipients of such data, the storage period; (III) to obtain the correction or cancellation, and where applicable, the limitation of the processing; (IV) oppose the processing; (V) where applicable, receive in a structured format, commonly used and readable by an automatic device, the personal data concerning him provided to the Company and transmit such data to another data controller without hindrance by the Company; (VI) lodge a complaint with the Guarantor Authority for the protection of personal data. Requests to exercise the aforementioned rights must be sent to one of the following addresses: - via email, to the address [privacy@epico.com]; - registered mail to / r, to [55 Loudoun Road, St. John's Wood, London NW8].

F. VIDEO QUESTIONS

RELEASE TO USE IMAGE AND CONTENT

The information provided herein are addressed to those who upload their video-questions on the website https://epico.com (the “Website”) to create the digital book-interview (the “Social Biography”) edited and published by the company eFanswer LTD, with registered office in 55 London Road, St. Johns Wood, Londra N127JJ, P. IVA GB 205597305 (“eFanswer”). The creation, the editing and the advertising of the Social Biography might involve the publication of the video-questions, uploaded by the Website’s users, in the digital version of the Social Biography and on the social networks pages of eFanswer and; therefore, the uploading of the video-questions involves the collection of information that constitutes personal data according to the D.Lgs 196/2003 (the “Privacy Code”) and the Reg. 2016/679 (the “GDPR”). 1. Data controller: eFanswer LTD For the purposes hereof, the data controller is the company, eFanswer LTD, with registered office in London Road, St. Johns Wood, London N127JJ, P. IVA GB 205597305 (the “Company”, “eFanswer” or the “Data Controller”). For any clarification on how personal data is processed by the Company, you may contact the Company at any time at the following e-mail address [ complete]. 2. Data collected Users images (videos-questions) In order to create and publish a Social Biography, the users of the Website are asked to provide the Company with a video of their self in which they ask a question to the famous person subject of the interview (the "Images"). The Images are associated with the personal data already provided within the registration on the Website and, in any case, make it possible to identify the users by its nature. Therefore, the Images are considered personal data according to the GDPR. Indeed, considering the peculiar aspects of this specific type of personal data, they are considered included within the “special categories of personal data” according to article 9 of the GDPR. 3. Legal basis and purposes of data processing The Images shall be processed to: (i) create and publish the digital version of the Social Biography; and (ii) to promote the Social Biography through the publishing of the Images on the Company’s social network pages, according to the provision of the release to use image and content, to which the present privacy policy is attached. The legal basis for the processing of personal data is, for both of the abovementioned purposes, the consent released by filling the form at the end of this privacy policy. 4. Data notification and Data recipients Data will be communicated and may be known (i) by employees and collaborators of the Company, duly instructed to process the Data; (ii) by third parties who provide, on behalf and in favour of the Data Controller, tasks of technical nature (for example, IT service providers), of organisational kind or professional assistance/advice and service supply (in particular, with regard to administrative-accounting and legal services) and other instrumental services necessary to the creation and publication of the Fab-Book, appointed as external data processors; (iii) the companies that manage web platforms and related social networks (i.a. Facebook®, Instagram®, Twitter® and YouTube®), who will treat them as independent data controllers. In no other case will the Data be disclosed to third parties, unless this is necessary to fulfill requests from the Judicial Authority, Public Security or another Public Authority. 5. Place of Data processing: no extra-EU The data processing shall be made at the Company’s offices. The personal data shall be stored in servers and/or archives located within the European Union. The Company will not process or transfer data outside the European Union or in Countries that do not provide personal data protection as guaranteed by the EU law or that are subject to the adoption of the measures required to ensure a standard of Data protection similar to the one guaranteed within the European Union. As for the publication on social networks: the companies that manage such platforms (i.a. Facebook®, Instagram®, Twitter®, YouTube®) are part of the so-called Privacy Shield, a system that protects European citizens when their data transit to the United States of America, so the transfer of personal data is considered lawful. 6. Data retention period and security measures Data will be processed by electronic, digital or automated media, through systems ensuring their protection, security, and confidentiality. In addition, the Data Controller has adopted specific and adequate, logic, legal, organizational and technical security measures to prevent data loss, illegal use or non-permitted use and unauthorized access. Personal data are processed only for the time strictly required to achieve the purposes for which it has been collected as specified in Paragraph 3. In particular, Data will be retained for the entire duration necessary to (i) collect, organize, store and process personal data in order to set up, create, edit and publish the Social Biography; and (ii) for the Images published on the Company’s social networks pages, until the consent is revoked by the user, considering the interest of the Company in promoting and keep informed its follower of the activities carried out. The data contained in the release to use image and content, to which the present privacy policy is attached, will be kept for a period equal to the statutory period prescribed by law. 7. Nature of the provision of Data The provision of personal data by the users is necessary only to allow the Company to publish the Images within the digital edition of the Social Biography and on the Company’s social networks pages. In case of a denial of the consent, the Images of the users will not be used for the purposes explained within the paragraph 3 of the present privacy policy, but they will be used only to extrapolate the questions to be asked to the subject of the interview in order to create and publish the Social Biography. 8. Rights of the data subject. Contact data. The data subjects hold the rights granted by the GDPR. In particular, pursuant to articles 12-23 of the GPDR, the data subjects are entitled to request and obtain, at any time, access to their personal data, information about data processing, personal data rectification and/or update, erasure and restriction of processing. They are also entitled to object to processing and to request data portability (i.e. to receive personal data in a structured, commonly used, machine-readable format). Finally, the data subjects are entitled to file any complaint to the supervisory authority. The aforementioned rights may be exercised at any time upon request to be sent to the Data Controller: • by e-mail to: info@epico.com; • at the following address: [London Road, St. Johns Wood, London N127JJ].

H.

COOKIE POLICY

Cookies are small text strings that the sites visited by the user send to the browser of its own terminal, where they are stored before being re-transmitted to the same sites at the next visit by the same user. During navigation on a site, the user can also receive on his terminal cookies that are sent from different websites or web servers (so-called "third parties"), on which certain elements may reside (such as, for example, images, maps, sounds, specific links to pages of other domains) present on the site that he is visiting. The Website uses cookies for the following purposes: technical cookies: these are used for the sole purpose of transmitting a communication over an electronic communications network, or as strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide this service. They are not used for other purposes and are normally installed directly by the website owner or manager. They can be divided into browsing or session cookies, which guarantee the normal navigation and use of the website (allowing, for example, to make a purchase or authenticate to access restricted areas); functionality cookies, which allow the user to browse based on a series of selected criteria (for example, the language, the products selected for purchase) in order to improve the service rendered to the same. The prior consent of the users is not required for the installation of these cookies. profiling cookies: they are designed to create user profiles and are used in order to send advertising messages in line with the preferences shown by the user in the context of surfing the net. The Website does not directly collect this type of cookie to create your own navigation profile. third-party cookies: these cookies allow users to create an anonymous profile based on their browsing experience on this and all other sites. In this way, you can provide targeted advertising on your interests instead of generic advertising. These cookies are not managed by our company and are referred to as third-party cookies. The third-party cookies collected through the Website are: ü Cookies for Remarketing and Behavioral Targeting purposes: AdWords Remarketing and Behavioral Targeting are services provided by Google Inc. ("Google") that connects the activity of this Website with the Adwords advertising network and the Doubleclick Cookie, which tracks the use of this Website and user behavior in relation to advertisements, products and services offered. The user can decide at any time not to use the Doubleclick Cookie by deactivating it by connecting to the following link https://adssettings.google.com/authenticated?hl=it; . Cookies for statistical purposes, in particular through Google Analytics, which is a web analysis service provided by Google. Google uses the Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google. Google may use Personal Data to contextualize and personalize the ads of its own advertising network. Social network plug-in cookie links: the Website uses social network plug-in cookies of different third parties. This allows you to link to the Website with an automatic registration and to share the contents of the Website on specific social networks. These plug-ins also optimize the ease of use of the Website. The use of data collected by third parties through social network plug-ins is determined exclusively by the third parties in question. Company is unable to access these cookies, just as third parties cannot access Company cookies. To obtain information on third-party cookies, consult the policies of the parties in question. Among the third-party social network plug-in cookies collected through the Website are those of the Facebook social network, in particular "Facebook Authentication" which is a registration and authentication service provided by Facebook Inc. Options regarding use of cookies. You can make your PC warn you whenever a cookie is sent, or you can choose to have all cookies turned off. You can do this through your browser settings. Since each browser has slightly different functions, check the "help" menu of your browser to understand how to correctly change the cookie settings. You can then change your browser settings so that cookies are deleted or not saved on your computer or mobile device without the