Privacy Policy pursuant to Articles 13 and 14 of UE Regulation 2016/679

1. Scope

This privacy policy ("Privacy Policy") is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (the "GDPR") in order to inform you about the processing of your personal data (the "Personal Data") carried out in the context of interaction with the services of the Do It Now1 group ("DIN Group"), for example in the context of browsing the website www.ithub.ventures (the "IT Hub Website") or third party websites that have installed digital tracking tools of the DIN Group (together with the Blasting News Website, the "Websites"), or provided over the phone to DIN Group employees, including those working on behalf of third parties.

2. Data Controller and Data Protection Officer

The controller of the processing of Personal Data is Blasting SA, tax code and VAT number: CHE-247.845.224, with registered office in Lugano, Via Carlo Frasca no. 3 (zip code 6900) (hereinafter referred to as "Blasting News" or the "Data Controller").

Only with your specific consent may your Personal Data also be processed by Do It Now S.p.a., tax code and VAT number 01274130119, with registered office in Milan, Via Foro Bonaparte no. 50 (zip code 20121) (hereinafter referred to as "Do It Now") and Direct Intelligence Ltd, tax code and VAT number 350502049, with registered office in London, 37-38 Long Acre, Covent Garden, WC2E 9JT (hereinafter referred to as "Direct Intelligence") as autonomous data controllers.

For any information on the processing of Personal Data as well as for the exercise of your rights you may contact the data protection officer designated by the Data Controller pursuant to Art. 37 of the GDPR (the "Data Protection Officer" or "DPO"). You may contact the Data Protection Officer, at any time, at the following e-mail address: dpo@blastingnews.com.

3. Type of Personal Data

The Personal Data covered by this Privacy Policy may be of different nature and origin.

You may in the past have authorised third parties to provide us with your Personal Data for commercial communication purposes.

You may also provide information by filling out forms on the Websites (e.g., registration forms, quotes comparison form, etc.).

In addition, the computer systems and software procedures used to operate the Websites automatically acquire certain information, such as your IP address or other parameters relating to your operating system. This information, by its nature, could allow your identification through processing and association with other data.

Finally, we may enrich and profile your Personal Data by observing your interaction with the Websites or third party services over time, through cookies and other digital tracking tools authorised by you.

The Personal Data processed in the context of one or more of the activities described above is personal data, contact details (e.g. e-mail address, mobile phone, etc.), data relating to the electronic devices that you use, your consumption and navigation preferences, your location, etc..

4. Purpose and legal basis of the processing

Personal Data is processed:

Only with your specific, free and informed consent, pursuant to Article 6(1)(a) of the GDPR, may the Data Controller:

in order to guarantee the use of the services requested by you through the Blasting News Website and to respond, in a timely and correct manner, to your requests for information and assistance pursuant to Article 6(1)(b) of the GDPR. For example, if you fill in the form for the comparison of quotes on the Blasting News Website, the Data Controller may directly process or communicate certain Personal Data to the service provider, including your telephone number, for the preparation of the quote that you have requested and the provision of a consulting service in relation to the specific quote, which is part of the service you have requested through the Website;
in order to fulfil the legal obligations to which the Data Controller and/or other companies of the DIN Group are subject, for example accounting and tax obligations, in accordance with Art. 6(1)(c) of the GDPR;
in order to satisfy the legitimate interest of the Data Controller to ensure the security and proper functioning of the Websites, or for administrative and accounting purposes of the DIN Group, in accordance with Art. 6(1)(f) of the GDPR; and
to assert or defend a right in court or at a preparatory stage of court proceedings pursuant to Article 6(1)(f) of the GDPR.
insert and/or enrich your Personal Data over time within its commercial database, using monitoring tools on electronic communication networks including cookies, tags, and other tools, in order to know your preferences, needs, consumption and professional habits and, more generally, to carry out profiling activities;
contact you, through automated means (e.g. automated calls, sms, push notifications, email, instant messaging apps, messages on social networks) and non-automated means (e.g. telephone with an operator, paper mail) to update you on the Data Controller’s and/or third parties’ product and service offers, as well as to carry out market surveys;
send you the DIN Group newsletters to promote Supermoney’ services, the editorial content of Blasting News and third party products and/or services. You may withdraw your specific consent and opt out of receiving the DIN Group newsletters at any time using the specific function in the e-mail footer;
communicate Personal Data, including profiled Personal Data, to third parties having qualified business relationships with companies of the DIN Group and belonging to different categories, including, in particular, to financial companies, agents involved in financial activities, credit brokers, banks, insurance companies, insurance brokers, fixed and mobile telephony, ADSL and fibre providers, providers of energy, electricity, gas, new downstream products and services, television services, customer care and sales services outside and inside business premises (contact centre, door to door, mall point, flagship), publishers, media centres, pharmaceutical and healthcare companies, car manufacturers, car dealers, car sellers, operators in the hospitality and catering, culture, sport, information and marketing sectors, companies active in direct marketing and list brokerage, and companies operating in event management (collectively, the "Main Recipients"). These parties will process Personal Data for their own commercial communication purposes through automated means (e.g. automated calls, sms, push notifications, email, instant messaging apps, messages on social networks) and non-automated means (e.g. telephone with an operator, paper mail). The list of third parties to whom your Personal Data may be communicated on the basis of your specific consent is available at the following link: https://www.blastingnews.com/privacy/third-party/;
communicate Personal Data, including profiled Personal Data, to third parties other than the Main Recipients and, particularly, suppliers of consumer goods and services and, in general, of goods and services related to personal care and well-being, operators in the fashion and interior design industries, political parties, trade unions and third sector parties, non-profit and charity associations, public and private research bodies and companies, commercial distributors, communication agencies, distributors of newspapers, periodicals and books, operators in the field of food and wine, alcoholic and non-alcoholic beverages, food, organic and zero-mileage agriculture, suppliers of office equipment and business services, producers and/or distributors of children’s items, roadside assistance companies, driving schools, licensing bodies, businesses dealing with the maintenance of cars and motorcycles, tire dealers, suppliers of security devices, specialised medical services, electrical systems and burglar alarms, operators in the data management, digital, technology and Internet sector, suppliers of sanitising products and solutions related to the environment, operators in the entertainment, music, and cooking industries and, in general, businesses offering products and services related to hobbies, tourism service providers, operators in the field of betting, gaming and operations with prizes, competitions and lotteries, operators linked to the organisation of rallies and competitions, to the world of navigation and water activities in general, operators in the photography, gardening, construction, decoration, design, model-making and aeromodelling sectors, real estate agencies, playgrounds, amusement parks, beauty farms, gyms and fitness clubs, and suppliers of food products linked to specific diets (collectively, the "Secondary Recipients"). These parties will process Personal Data for their own commercial communication purposes through automated means (e.g. automated calls, sms, push notifications, email, social networks, instant messaging apps, messages on social networks) and non-automated means (e.g. telephone with an operator, paper mail). The list of third parties to whom your Personal Data may be disclosed based on your specific consent is available at the following link: https://www.blastingnews.com/privacy/third-party/.

Subject to your specific consent, your Personal Data may also be processed autonomously by Do It Now and Direct Intelligence for the purposes set out in letters f) and g) above.

We may also send you emails, without your consent, to promote goods and/or services similar to those you have already purchased on the Websites, without prejudice to your right to object to these communications at any time.

5. Provision of Personal Data and consequences of any refusal to respond

The provision of Personal Data is optional. However, some Personal Data is necessary in order to allow us to provide the services you have requested and to fulfil the legal obligations to which we are subject. Failure to provide such information will prevent you from using the services offered through the Blasting News Website.

Where necessary for the performance of the processing described in this Privacy Policy, the requested consent is free. Failure to give one or more of the requested consents will not prevent you from using the services and products offered through the Blasting News Website.

6. Processing procedures

The processing of Personal Data will take place – in compliance with the principles of correctness, lawfulness and transparency - by means of computer, manual and/or telematic supports and/or tools, with logic strictly related to the purposes of the processing and, in any case, guaranteeing the confidentiality and security of the data and compliance with the specific obligations laid down by law.

The availability, management, access, storage and usability of data relating to you is guaranteed by the adoption of technical and organisational measures to ensure appropriate levels of security in accordance with Articles 25 and 32 of the GDPR, as well as, in relation to the specific processing purposes identified in the legislation on the protection of personal data, to ensure compliance with the data protection safeguards of the Data Protection Authority and relevant sector-specific provisions under EU and national law (e.g. specific provisions on commercial communications).

The processing will be carried out by persons within the organisation of the DIN Group companies specifically authorised and trained in full compliance with Art. 29 of the GDPR. In any case, the logical and physical security and confidentiality of the information processed will be guaranteed.

7. Retention of Personal Data

Personal Data will be kept only for the time strictly necessary for the purposes for which it is collected, in compliance with the principle of minimisation set forth in Article 5(1)(c) of the GDPR, as well as the legal obligations to which each data controller is bound.

If you decide to withdraw the consent given, Personal Data the processing of which is based solely on the withdrawn consent will be immediately deleted or made anonymous.

8. Scope of circulation of Personal Data

Personal Data is not/will not be disseminated (where dissemination means disclosing personal information to unspecified parties, in any form whatsoever, including by making it available or accessible for reading), except in the event that the communication or dissemination is required, in accordance with the law, by police forces, judicial authorities, information and security bodies or other public entities for purposes of defence or State security or prevention, detection or prosecution of crimes.

Subject to your specific consent, the Data Controller may communicate Personal Data to the Main Recipients and Secondary Recipients, including those located outside the European Union. The Main Recipients and Secondary Recipients, as identified above, will process the information related to you for their own commercial purposes.

When you request quotes on the Blasting News Website, your Personal Data may be communicated to electricity and telephony providers to perform the quote service and/or contractual negotiation that you have requested.

Some parties may act on behalf of the Data Controller (e.g. IT Hub S.r.l. which is in charge of the technological development of the DIN Group) as data processors.

Some advertising campaigns may be conducted in the interest of third party clients (the "Clients") with whom the Data Controller may have entered into joint data controller agreements (the "External Joint Data Controllers"). In these advertising campaigns, your Personal Data is not transferred to the Clients; the Personal Data remains at the disposal of the Data Controller who processes it for the benefit of the Clients (e.g. if Blasting News knows that you are interested in renewing an energy contract, they may contact you to inform you about an offer from a partner energy company; your Personal Data will be communicated to the Client only upon your request).

Personal Data may be transferred to countries outside the European Union. This transfer will take place to countries that guarantee an adequate level of protection according to the European Commission (e.g. Switzerland, Canada, Japan or Argentina) or, in any case, subject to the adoption of adequate guarantees, such as the signing of Standard Clauses approved by the European Commission or the selection of parties participating in international programs for the free movement of data.

9. Cookies Policy and online behavioural advertising

The Websites use cookies, tags and other tracking tools for the pursuit of the above purposes and, in particular, in order to send advertising messages in line with your browsing experience. Therefore, you may receive ads that are in line with your interests, preferences and needs. For further information, the Cookies Policy of the Blasting News Website is available at the following link, to which you may refer: https://www.blastingnews.com/cookie-policy/.

In addition to processing Personal Data in full compliance with applicable law, the Data Controller has initiated a procedure to adhere to the principles of the European Digital Advertising Alliance ("EDAA") organisation for online behavioural advertising and has requested the subscription to the Your Online Choices platform in order to allow you, at any time, to change your choices and no longer receive personalised content and advertisements.

10. Rights of the Data Subject

You may exercise your rights under Articles 15 to 22 of the GDPR at any time.

You have the right to obtain confirmation as to whether or not Personal Data is being processed and, if so, to obtain access to such Personal Data as well as information relating to the processing carried out pursuant to Art. 15 of the GDPR; to request the rectification or deletion of Personal Data or limitation of the processing; to obtain the portability of Personal Data; to withdraw, at any time, any consent given, without prejudice to the lawfulness of the processing based on consent before withdrawal; to be made aware of the existence of an automated decision-making process, including profiling; and to file a complaint with the Data Protection Authority.

Furthermore, you have the right to object to the processing of Personal Data, at any time, pursuant to Art. 21 of the GDPR. In case of opposition to the processing of Personal Data for direct marketing purposes and for the performance of profiling activities related to such direct marketing, you will obtain the immediate interruption of the processing. Please note that you may exercise your right to object to the processing for marketing purposes even if only in relation to one or more specific contact channels (for example, you may decide to continue to be contacted by the operator, but no longer receive sms or emails). In any case, if the contact channel in relation to which the right is exercised is not specified, the opposition to the processing of Personal Data will be understood to be extended to all communication methods used.

Requests to the Data Controller, Do It Now and Direct Intelligence should be submitted by contacting the Data Controller and the DPO, at the addresses specified in Section 2 of this Privacy Policy.

With reference to Personal Data processed as part of an advertising campaign carried out in the interest of a Client, you may also exercise your rights in accordance with the technical and operational procedures specified during the advertising campaign (for example, by selecting the contact channels from which you wish to unsubscribe following a phone call from an operator).

Any modification or cancellation or limitation to the processing carried out at your request or following the withdrawal of your consent - unless this is impossible or involves a disproportionate effort - will be communicated by each data controller to the other, as well as to each of the recipients to whom the Personal Data has been communicated.

21/07/2020

1 The DIN Group consists of the following companies: Do It Now S.p.A., Supermoney S.p.A., Performance Credit Mediazione Creditizia S.r.l. , IAMB S.r.l. Blasting SA, Blasting News Ltd, Blasting News Inc. , Blasting News Italia S.r.l., It Hub S.r.l., and Direct Intelligence Ltd.