Effective date: 27 July 2021

This Privacy Policy explains which personal data is collected by THM srl (hereinafter "THM") and how such data is used when the User uses the THM website (www.thmitalia.it) and/or any online product of THM (including THM mobile applications), THM hardware or software or other services (hereinafter the “Services”). The person in charge of the treatment according to the art. 4 (7) of the General Data Protection Regulation (hereinafter "RGPD") is THM srl with registered office in via Sanpietro 112 21047 Saronno (VA), e-mail: privacy@thmitalia.it ).

THM will post any modifications or changes to the Privacy Policy on the THM website. THM reserves the right to modify this Privacy Policy at any time, therefore we recommend that you review it frequently. In the event of material changes to this Privacy Policy, the User will be notified by email or via a notice on the THM website before the changes take effect. THM regularly updates software applications (including those for mobile and desktop devices) to make improvements, including those that best meet your right to privacy.

THM may process, transfer and store User information in other locations outside the European Economic Area. Any transfer of your data to another location outside the European Economic Area will comply with applicable European data protection laws. THM makes use of the standard data protection clauses adopted by the European Commission pursuant to art. 46 (2)(c) of the GDPR. For further information, contact the THM privacy team with registered office in via Sanpietro 112 21047 Saronno (VA), e-mail: privacy@thmitalia.it ).

Information You Provide

THM collects a series of information provided directly by the User, including Personal Data that may be contained in any video, comment or other material that the User uploads or publishes on the Services. “Personal data” is information that allows the User to be identified and which is collected in the following situations:

account registration and THM account administration (in which case the following categories of Personal Data are collected: name and email address); uploads or postings to the Services (in which case the following categories of Personal Data are collected: all Personal Data included in content uploaded or posted by the User); customer support and technical assistance services (in which case the following categories of Personal Data are collected: name, postal address, geolocation, IP address, serial number, telephone number and e-mail address); processing of orders for products or services offered by THM (in which case the following categories of Personal Data are collected: name, postal address, billing address, payment details, telephone number and address email); product registration (in which case the following categories of Personal Data are collected: name, mailing address, telephone number, device ID, serial number and email address); obtaining firmware updates and/or or application software (e.g. antivirus software..) (in which case the following categories of Personal Data are collected: name and serial number); newsletter subscriptions (in which case the following categories of Personal Data are collected: name, postal address and e-mail address); access to products or services on social networks or third party services (in which case the following categories of Personal Data are collected: categories of data that the User provides based on their settings on social networks or on third party services); or services provided online (in which case the following categories of Personal Data are collected: name, postal address, billing address, payment details, telephone number and email address).

Information Collected Automatically

When using THM's Services that connect to the Internet, including, but not limited to, when accessing the Services through devices, applications (web, mobile, desktop software, cloud services, connected TV and game consoles) , the THM websites and the THM online shop, the User's personal data is collected as described below. This information includes aggregated (non-personally identifiable) user data, as described in more detail below. Third party analytics providers and technologies are also used to collect this information, as further explained in the Cookie Policy.

Web sites

When THM websites are used (including the online store), the following information about the User's computer or mobile device is collected and analysed: browser type, IP address, mobile device identifier (for example, IDFA on Apple products such as iPhone and iPad or similar identifiers), browser language, operating system, error log and other similar information.

Information from other sources

If the User connects to a third party network, platform or service (for example a social network) through the Services, he is asked to authorize THM to collect, store and use, in accordance with this Privacy Policy, all information (such as name, email address and position) that the User has agreed to provide to THM based on their settings on the network or third-party platform. When the User connects to the network, platform or third party service through the THM Services and/or when he connects to one of the THM applications through one of these services, he will be asked for his consent.

The User can revoke the consent at any time by contacting privacy@thmitalia.it The revocation will have immediate and non-retroactive effect and will not affect the processing of Personal Data prior to the moment of withdrawal.

Consult the Cookie Policy.

THM uses the Personal Data collected as described in Section 2 above for the purposes and based on the legal bases described below:

Customer Service : Depending on the type of Personal Data provided when registering for a THM account or making a purchase, the User will receive a confirmation email to verify their username and password. THM will also communicate with the User in response to his questions, to provide the requested services and to manage the THM account. THM will communicate with the User by email or telephone, depending on the preference expressed by the User.

This processing of Personal Data is necessary for the performance of the THM Services; therefore, the legal basis of this processing of Personal Data is the art. 6 (1) (b) of the GDPR. Please note that the User is contractually required to provide such Personal Data and that without them, THM will not be able to send communications relating to the User's orders.

Newsletters, social media campaigns, special offers and updates: only with the prior consent of the User, THM will occasionally send information on products, services, special promotions, contests, events, customer satisfaction surveys and opportunities to interact with THM and its community . The User can sign up to receive such emails and social media campaigns from THM on the newsletter signup page and/or during checkout when purchasing a product. The User has the right to opt out of receiving this type of communication at any time.

The legal basis for this processing of Personal Data is therefore the User's consent (Article 6(1)(a) of the GDPR). Please note that the User is not legally required to provide Personal Data. However, without such data, THM will not be able to send the User newsletters and other information as described above.

Service related communications: In some rare cases, if necessary, THM will send service related communications. For example, if the service is temporarily suspended for maintenance, you may receive an email. Generally, the User does not have the option to opt out of receiving these non-promotional communications. If the User does not wish to receive them, he can deactivate his THM account.

This processing of Personal Data is necessary for the performance of the THM Services; therefore, the legal basis of this processing of Personal Data is the art. 6 (1) (b) of the GDPR. Please note that the User is contractually required to provide such Personal Data and that without them, THM will not be able to send communications relating to the User's orders.

THM Customization Services : Only with your prior consent, information collected while you access the Services across devices, applications (web, mobile, desktop software, cloud services, connected TVs and game consoles), THM account, websites and online store are used to create profiles and to further customize and improve the Services, for example by providing personalized customer assistance (for example to access THM device logs and resolve technical issues), sending messages and in-app promotions, by recommending features and personalizing content and advertising.

The legal basis for this processing of Personal Data is therefore the User's consent (Article 6(1)(a) of the GDPR). Please note that the User is not legally required to provide his consent. However, without the Personal Data, THM will not be able to offer the personalization services described above.

Order-related communications: if you place an order, THM will use your name and email address to send an order confirmation email and a shipping confirmation email.

This processing of Personal Data is necessary for the performance of the THM Services; therefore, the legal basis of this processing of Personal Data is the art. 6 (1) (b) of the GDPR. Please note that the User is contractually required to provide such Personal Data and that without them THM will not be able to send communications relating to the User's orders.

THM does not share, sell, transfer or otherwise disclose the User's Personal Data to third parties, except as required by law pursuant to Article 6 (1)(c) of the GDPR, except as required for the purposes of the contract pursuant to the 'Art. 6 (1)(b) of the GDPR or unless the User has expressly consented pursuant to art. 6(1)(a) of the GDPR.

THM makes use of other third party service providers to offer or facilitate services on its behalf and shares the User's Personal Data with these providers to the extent necessary to allow them to perform their services on its behalf. In particular, use a shipping company to fulfill orders, an e-commerce platform to provide the online store, a credit card processing company to charge for goods and services, cloud-based enterprise resource planning software providers to record and manage subscriptions and online store sales, cloud-based customer relationship management software to be able to record and schedule customer interactions, a cloud-based subscription software provider to automate subscription billing, a data center for administer all online aspects of the Services, a cloud-based storage provider to store content uploaded from THM accounts, a payment service provider to process payments to Users, a social media agency to manage social campaigns, a company that collects data to implement social campaigns. When the User orders a THM product, the company shares the User's Personal Data to the extent necessary to allow such third party service providers to provide the applicable service to or on behalf of THM. Any sharing of Personal Data with such third party service providers will be done in accordance with applicable data protection laws and will be limited to the extent necessary. Such third parties are prohibited from using the User's Personal Data for purposes other than those described in this document.

THM may be required to disclose User information to government officials or law enforcement agencies in response to a lawful request from a public authority or, if necessary, to comply with a legal obligation, including to satisfy the requirements of national security or law enforcement agencies pursuant to Article 6 (1)(c) of the GDPR. THM may also disclose the User's information in order to pursue its legitimate interest in applying or enforcing its terms and conditions or in responding to any request for compensation, protect its rights or those of third parties, protect the security of any person or prevent any illegal activity (including for the purposes of fraud protection and credit risk reduction) pursuant to Article 6 (1)(f) of the GDPR. For further questions regarding the comparative test in relation to art. 6 (1)(f) of the GDPR, please contact THM at the contact details set out in Section 16 below.

THM provides the User with a number of options with respect to the information it collects and uses, as explained in this Notice. Some of the available options include:

Marketing communications. If you purchase a product but do not wish to receive additional marketing material, you can indicate your preference on the order form by leaving the appropriate checkbox empty. If you have opted-in to receive newsletters, social media campaigns and promotional emails and no longer wish to receive them, please follow the instructions included in each newsletter or email or contact customer service at http://www.thmitalia.com .it/contatti/ . Customization services from THM. As detailed in Section 4, THM may use the information collected from and about the User to personalize the THM experience. If you do not want THM to provide such personalized services, you can deactivate your THM account settings by disabling the personalization data submission tab. Opt out of receiving personalized online ads. THM is committed to providing the public with relevant and value-added content in the form of online advertisements. However, THM respects the wishes of those who do not want to be tracked by third party online advertising agencies. For information on how you can choose not to participate in online advertising and analysis programs based on cookies, please refer to the Cookie Policy.

Occasionally, THM posts customer testimonials on its website. You are advised not to include Personal Data in such testimonials and in particular to use a nickname instead of your real name.

You may be able to disclose personal information while contributing self-generated content in publicly available areas of the Services. This includes, but is not limited to: uploaded photos or videos, full name, email address, phone number, address, interests and favorite content. Your content will also be shared with users of other social media services with which you have chosen to share your content, consistent with the privacy settings of those services. Such information is unencrypted and is public and accessible or recordable by THM and cannot be considered private or confidential. Any information, including Personal Data submitted by the User in the course of such activities, may be read, collected or used by other users. In particular, THM cannot prevent the User from receiving unwanted messages from other users. If the user wishes specific content generated by him to be removed from publicly accessible areas of the THM services, he can contact us at privacy@thmitalia.it.

All Personal Data published on public areas of the THM services are processed in order to provide the User with the respective Service pursuant to the article. 6 (1)(b) of the GDPR.

If the User sends his video or other content to THM, it may be published on the THM website or applications together with certain Personal Data that identifies him, for example name and surname or username, provided that the User has given its consent.

The legal basis for this processing of Personal Data is therefore the User's consent (Article 6(1)(a) of the GDPR). Please note that the User is not legally required to provide Personal Data. However, without Personal Data, THM will not be able to attribute the content sent by the User to the User.

The User has the following rights:

Right of access (Article 15 of the GDPR): the User has the right to request confirmation of whether or not his Personal Data is being processed and, if so, to access them and information such as the purposes of the treatment or the categories of Personal Data concerned.Right of rectification (art. 16 of the RGPD): the User has the right to request the correction of inaccurate Personal Data.Right of cancellation (art. 17 of the RGPD): The You have the right to request the erasure of your Personal Data without undue delay in certain circumstances, for example if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw your consent on which the processing is based. pursuant to article 6 (1)(a) of the GDPR and if there is no other legal basis for its processing. Right to limitation of processing (art. 18 of the GDPR): the User has the right to request a THM to limit the processing of its Personal Data in certain circumstances, for example if it believes that its Personal Data processed is incorrect or unlawful. Right to data portability (art. 20 of the RGPD): in some cases, the User has the right to receive the Personal Data he has provided, in a structured format, commonly used and capable of automated reading and has the right to transmit this information to another holder of the processing without impediments and to request THM to do so. Right to object (Article 21 of the GDPR):

the User has the right to object to the processing of Personal Data in certain circumstances, in particular if the data processing is based on legitimate interest (art. 6 (1)(b) of the GDPR) or if such data is used for marketing purposes.

It is possible to assert these rights at any time, by duly requesting THM by sending an email to privacy@thmitalia.it. You can also send an email to correct or change any information or request what Personal Data (e.g. name and address) has been stored or to assert any other of the above rights.

The User has the right to lodge a complaint with a supervisory authority, in particular that of the EU Member State in which he has his habitual residence, place of work or place of the alleged infringement, if he considers that the processing of your Personal Data violates applicable data protection laws. Contact privacy@thmitalia.it for detailed information on the contact details of the competent supervisory authorities.

THM Services may contain links to third party websites or features. This Privacy Policy describes the privacy practices practiced by THM and does not contemplate the privacy practices practiced by third party websites or features. THM is not responsible for the privacy policies and/or practices of third parties. When you connect to another site or use a third-party service, you should read the privacy policy of that site or service. To the extent certain features of third-party websites are available on the THM Services, the following conditions will apply:

Facebook

Facebook Like button: THM uses a Facebook Like button plug-in (provided by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA) to allow users of the THM website to place easily "Like" content found on THM.com and then share it with your friends on Facebook. Whenever a page of the THM website containing this plug-in is consulted, the browser establishes a direct connection to the servers managed by Facebook. As a result, the content of the social plug-in is transferred via Facebook directly to the User's browser and then incorporated into the displayed website. If the user visits the THM website when he is logged into his Facebook account, the information relating to the visit is transferred to Facebook, which can associate the visit to the THM website with the User's account. Please note that a data transfer is already triggered when you visit the THM website, regardless of whether you interact with the plug-in. Information resulting from interaction with Facebook plug-ins (e.g. clicking the Facebook "Like" button or leaving a comment) is transferred directly to Facebook and stored by it. To prevent this from happening, you must log out of your Facebook account before visiting the THM website. Please refer to Facebook's privacy policy at http://.facebook.com/privacy/explanation.php for further information on the purpose and scope of the data collection and data analysis by Facebook, as well as for information on options to change the settings and how to protect your privacy.

Facebook Connect: The THM website also uses Facebook Connect, offered by Facebook, Inc. This feature allows you to use your Facebook account to access your THM account on the THM website and other websites without further registration.

By using Facebook Connect, Facebook will have access to certain Personal Data, in particular the encrypted email address and other information relating to the User's account. Facebook may also store this data in the United States. In turn, THM may gain access to publicly available Facebook profile data. If you do not accept this practice, it is advisable not to use Facebook Connect. In this case, you can continue to access your THM account via the THM website. For more details, see Facebook's Privacy Policy at https://www.facebook.com/policy.php .

Facebook Messenger: The Quik mobile application also uses Facebook Messenger, offered by Facebook, Inc. This feature allows you to share content through the Facebook Messenger application.

By using Facebook Connect, Facebook will have access to certain Personal Data, in particular the User's email address. Facebook may store this data in the United States. If you do not agree with this practice, please do not use Facebook Messenger. For more details, see Facebook's Privacy Policy at https://www.facebook.com/policy.php .

Google

Google +1 button: THM uses the social plug-in for the Google +1 button (provided by Google Inc., 1600 Amphiteatre Parkway, Mountain View, CA 94043, USA) to allow website users to easily access content "+" present on THMweb.it and share them within the Google platform. Whenever a page of the THM website containing this plug-in is consulted, the browser establishes a direct connection to the servers managed by Google +. As a result, the content of the social plug-in is transferred via Google + directly to the User's browser and then incorporated into the displayed website. If you visit the THM website when you are logged into your Google + user account, the information relating to your visit is transferred to Google + and Google + can assign the visit to the THM website to this account. Please note that a data transfer is already triggered when you visit the THM website, regardless of whether you interact with the plug-in. Information resulting from interaction with the Google + plug-ins (e.g. clicking on the Google + button or leaving a comment) is transferred directly to Google + and stored by it. To prevent this from happening, you must log out of your Google + account before visiting the THM website. Please see the Google + privacy policy at https://policies.google.com/privacy for more information about the purpose and scope of data collection and data analysis by Google +, as well as information about your options to change the settings and how to protect your privacy.

Sign in with Google: The THM website also uses Sign in with Google, offered by Google, Inc. This feature allows you to use your Google + account to sign in to your THM account on the THM website and other websites without additional registration .

By using Sign in with Google, Google will have access to certain Personal Data, in particular the encrypted email address and other information relating to the User's account. Google may store this data in the USA. In turn, THM may gain access to publicly available Google+ profile data. If you do not agree with this practice, we recommend that you do not use Sign in with Google. In this case, you can continue to access your THM account via the THM website. For more details, see Google's Privacy Policy at https://policies.google.com/privacy/ .

Instagram

The THM and Quik mobile applications also use Instagram (provided by Instagram LLC, located at 1601 Willow Road Menlo Park, California 94025. United States of America). This feature allows you to share content via the Instagram application.

By using Instagram, the app will have access to certain Personal Data, in particular the User's email address. Instagram may store this data in the United States. If you do not accept this practice, it is advisable not to use Instagram. For more details, see Instagram's Privacy Policy at https://instagram.com/about/legal/privacy/before-january-19-2013/.

Whatsapp

The Quik mobile application also uses WhatsApp (provided by WhatsApp, Inc., located at 1601 Willow Road Menlo Park, California 94025. United States of America). This feature allows you to share content via the WhatsApp application.

If you use this application, WhatsApp will have access to certain Personal Data, in particular your email address. WhatsApp may store this data in the United States. If you do not accept this practice, it is advisable not to use WhatsApp. For more details, see WhatsApp's Privacy Policy at https://www.whatsapp.com/legal/#privacy-policy.

YouTube (videos)

THM uses YouTube plug-ins (provided by YouTube (Google, Inc.), 901 Cherry Ave., Second Floor, San Bruno, CA 94066, USA) to allow the User to share content from the THM website. Whenever a page of the THM website containing this plug-in is consulted, the browser establishes a direct connection to the servers managed by YouTube and the plug-in is displayed on the THM website. As a result, YouTube will receive information about the THM websites visited by the User. If you visit the THM website when you are logged into your YouTube user account, YouTube can assign information about your visit to the THM website to your account. Information resulting from interaction with YouTube plug-ins (e.g. clicking or starting video playback or posting a comment) is also assigned by YouTube to your YouTube user account. To prevent this from happening, you must log out of your YouTube account before visiting the THM website. Please see YouTube's privacy policy at https://policies.google.com/privacy for more information about the purpose and scope of data collection and data analysis by Vimeo, as well as information about your options for changing settings and how to protect your privacy.

The protection of users' personal information is a very important aspect for THM. To this end, it has implemented adequate administrative, technical and physical protection measures to protect the User from unauthorized access, destruction or alteration of his information. This includes encrypting the services using Secure Sockets Layer (SSL) and limiting access to Personal Data to THM employees, contractors and agents who need to know such information in order to process it on behalf of THM and who are subject to strict restrictions confidentiality agreements. However, despite all the efforts made, there are no absolutely impenetrable protective measures.

THM deletes or anonymizes the User's Personal Data as soon as it is no longer necessary for the purposes for which it was collected, as indicated in this Privacy Policy, unless further processing or storage of the User's Personal Data is necessary. User to comply with a legal obligation. For more information on the various categories of Personal Data and their respective retention periods, contact privacy@thmitalia.it

THM does not use the User's Personal Data to make decisions with legal or similar consequences based solely on the automated processing of the User's Personal Data.

If you wish to contact THM or if you have any questions or complaints in relation to this Privacy Policy, please use the following contact details:

THM srl – via Sanpietro 112 – 21047 Saronno (VA)

Email: privacy@thmitalia.it

We have summarized here the main changes and the resulting benefits.

Greater transparency: as technology evolves, so does the information we are able to collect. Therefore, we have updated our Privacy Policy to reflect the information we currently collect automatically through our website, software applications (including mobile and desktop apps). General Data Protection Regulation (GDPR): l 'GDPR gives users in the European Union a set of established rights regarding the collection, use and onward transfer of their personal information. These include the right, under certain circumstances, to: Access your personal information; Correct any inaccurate personal information; Request the erasure of your personal information without undue delay; Request restricted processing of your personal information; Receive the personal information which have provided in a structured, commonly used and machine-readable format, as well as to transmit the information in question to another supervisory body without restrictions or to ask us to do so; Object to the processing of your personal information.