Privacy Policy

in accordance with EU Regulation 2016/679 (hereinafter "GDPR")

BENUE INVESTMENTS LTD, a BVI company.

We take seriously the protection of your personal data and for this reason we process your personal data scrupulously, exclusively according to the applicable data protection law, in particular to the GDPR. In the following privacy notice we would like to inform you about how we process your personal data and what your rights are.

Who process personal data

1.1. The Data Controller

The Data Controller is BENUE INVESTMENTS LTD, represented by its pro-tempore legal representative, with registered office in Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands

For the purpose of pursuing the purposes indicated in the premises, the Data Controller uses some data processors.

The updated list of data processors is kept at the registered office of the Data Controller.

1.2. People and countries who personal data may be provided to BENUE INVESTMENTS LTD may transfer your personal data to the recipients and / or categories of recipients listed below:

o Suppliers of products purchased at BENUE INVESTMENTS LTD, in order to ship them to the customers; o suppliers of external IT services that provide IT maintenance, server infrastructure or extensive IT solutions (eg cloud services) and software solutions on behalf of BENUE INVESTMENTS LTD;

o external service providers for the purpose of filing invoices;

o Governmental authorities, courts, external consultants and similar third parties that are public entities or other authorized third parties, provided that there are necessary circumstances (eg in the event of an improper conduct on your part in relation to BENUE INVESTMENTS LTD or for information obligations established by law);

o credit agencies in order to carry out credit checks, prevent fraud and verify your identity;

o service providers for organizing marketing and promotional activities;

o logistics company if the processing is necessary for communications and mailings;

o external service providers to provide customer service (customer care).

In any case, BENUE INVESTMENTS LTD will process your data in countries where the European Commission has established that there is an adequate level of personal data protection.

Your personal data may also be transferred outside the European Union to be processed by some of our service providers.

In this case, we make sure that this transfer takes place in compliance with the current legislation and that an adequate level of personal data protection is guaranteed based on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules.

Under no circumstances do we sell personal data to third parties.

Your data may also be made accessible for the purposes referred to in point 2, also:

o to employees and collaborators of the Data Controller in Italy and abroad, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;

o to third-party companies or other subjects (such as, for example: law firms, consultants, credit institutes, etc.) who carry out outsourced activities on behalf of the Data Controller.

How we use personal data collected BENUE INVESTMENTS LTD processes your personal data if this is necessary for the execution of the service and a contract of which you are a part or to carry out pre-contractual measures with BENUE INVESTMENTS LTD adopted on your request (Article 6 paragraph 1 b, GDPR).

We use the data collected mainly to offer you our service; as well as to inform you about our activities and business proposals or to propose a "tailored" service based on your interests.

2.1. To ensure you access to our services and improve their provision

In particular, we use your data to ensure the use of our services and their provision, including:

o registration and creation of the reserved area;

o communications related to the services of BENUE INVESTMENTS LTD;

o communications on the availability specific products at your request;

o use of "favorite" and "saved search" features;

o contact with Customer Care;

o activities of an administrative, financial or accounting nature, such as those relating to the purchase of services and any credit recovery and reimbursements.

If you contact our customer care service by e-mail or telephone, BENUE INVESTMENTS LTD collects the information and data (including personal data) provided by you in order to process your request.

Further collection and processing of your personal data, such as recording calls to improve our customer service, will only take place if you have given your prior consent.

If you use third-party services (eg, the services of the partners of BENUE INVESTMENTS LTD) within the contractual relationship with BENUE INVESTMENTS LTD, the latter transfers personal data to these third parties in order to fulfill the contractual relationship with you.

In any case, the processing of your personal data is carried out by means of the operations indicated in art. 4 nr. 2 GDPR and more precisely: collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. Your personal data are subjected to both paper and electronic and / or automated processing. These processing are necessary to correctly deliver the services of BENUE INVESTMENTS LTD towards the users who subscribe to it. We also use your data to improve and implement the Service, through the following processing:

o detection of your current position (approximate) to facilitate the use of some functions of the service, such as the sending of advertising material and commercial promotions;

o communications relating to services similar to those used by you;

o market research, optional surveys and user satisfaction surveys. These processing are based on the c.d. "Legitimate interest" of the Data Controller (see Article 6 GDPR) you can oppose at any time.

2.2. To provide you a tailored service (“profiling”)

We may process the data collected, if you have expressly provided your consent, to analyze your habits or consumption choices in order to propose an increasingly personalized service and in line with your interests and to improve our commercial offer. These analysis are not the result of automated decision-making.

2.3. Survey and market research

We may ask you, while browsing our website, to participate in targeted surveys in order to know your opinion and degree of satisfaction with regard to the services provided by BENUE INVESTMENTS LTD. These surveys can be carried out directly on BENUE INVESTMENTS LTD or through the use of external platforms. Within the surveys it may be requested, optionally, to provide an e-mail address in order to receive news and information on the services of BENUE INVESTMENTS LTD. We remind you that participation in surveys is completely optional and that you can always oppose and revoke this processing.

2.4. Marketing

The Data Controller with your express consent, free and unequivocal pursuant to Article 6, paragraph 1, point a) of GDPR, may request, in addition to the above data, additional Personal Data such as, purely by way of example and not exhaustive, data related to tastes, preferences, habits, needs and consumption choices, for the purposes of marketing. This term means the will of the Data Controller to carry out promotional and / or marketing activities for you also on behalf of third parties.

This data can be used to perform analysis and reporting activities related to promotional communication systems, such as the detection of the number of open e-mails, clicks made on links within the communication, the type of device used to read the communication and its operating system or the list of newsletter subscribers.

The processing of your Personal Data for the purposes referred to in paragraph 2.4 will require the obtaining of your consent that will necessarily comply with the conditions set out in Article 7 of GDPR, thus determining the lawfulness of the processing of your data.

The contact methods aimed at marketing activities may be either automated (e-mail, sms, mms, fax, telephone calls without operator) or traditional (telephone calls with operator, postal items). In any case, you can revoke your consent, even partially, for example by consenting only to traditional contact methods.

With regard to the methods of contact that provide for the use of your telephone contacts, we remind you that the marketing activities by the Data Controller will be carried out after verification of your possible registration in the Register of Oppositions as established pursuant to and for the effects of the Presidential Decree September 7, 2010, n. 178 and subsequent modifications.

The Data Controller will process personal data for the time necessary to fulfill the aforementioned purposes and in any case for no more than 10 years from the termination of the Service Finality report and for no more than 2 years from the collection of data for Marketing Purposes.

The protection of your data

The data are collected by the subjects listed in point 1 (The Subjects of the Processing) implementing appropriate technical and organizational measures to guarantee a level of safety appropriate to the risk, according to the indications of the relevant legislation and, in particular, of art. nr. 32 of GDPR.

Data we collect

When you use our services, you accept that our company collects some of your personal data. This information is intended to tell you what your data we collect, why and how we use it. We process two types of data:

- data provided by the user, and - data we collect automatically.

Your data will be the subject of processing always inspired by the principles of correctness, lawfulness, transparency, protection of privacy and your rights, in full compliance with current legislation on the protection of personal data.

4.1. Data provided by the User

If you are a private individual. If you are a private individual, when you register on the site www.Baucorp.com (hereinafter the "Site") and use one of our services, we ask you to provide us with some data that you need to use our service. These are examples of data that you are asked for: shipping address, e-mail, name and surname.

If you are a Professional. If you are a professional, when you create a professional account you are asked to provide us with some data. These are examples of data that are required: company name, shipping address, VAT number, contact name, e-mail address, telephone number.

Data of children under 16 years. If you are under the age of 16, you cannot provide us with any personal data and you cannot register on our website and in any case we do not assume any responsibility for any false statements that you provide. Should we notice the existence of untruthful declarations, we will proceed with the immediate cancellation of any personal data acquired.

Third parties Data. If you provide personal data of third parties, such as those of your family or friends, you must be sure that these individuals have been adequately informed and have consented to the related processing in the manner described in this Privacy Notice.

4.2. Data collected automatically

Through the services you use, we also collect the following data:

o data collected using the c.d. cookies or similar technologies. For more information on these techniques, please read the contents of this link: https://www.Baucorp.com/it/cookie-policy/.

o technical data: such as: IP address, geolocation, i.e. data relative to the current (approximate) position of the instrument you are using, type of browser, information on your device.

The provision of personal data

The provision of personal data is required exclusively for the processing necessary for the provision of the Services provided by BENUE INVESTMENTS LTD. In this regard, we inform you that any refusal to provide the service makes it impossible to use the service.

The provision of data is optional for marketing, promotional and profiling purposes and any refusal to provide such consent does not have negative consequences on the provision of the service offered on the website www.Baucorp.com and related, any applications.

Failure, partial or incorrect provision of personal data could result, as a consequence, the failure or partial execution of the service.

Your personal data are processed:

Without your express consent (Article 6 letter b), e) GDPR), for the following Service Purposes:

to conclude the contracts for the services offered by BENUE INVESTMENTS LTD;

to fulfill the pre-contractual, contractual and tax obligations deriving from relations with you in existence;

iii. to fulfill the obligations established by national or community law or by an order of the Authority;

to exercise certain rights of the Data Controller, eg the right to defense in a trial.

Only with your specific and distinct consent (Article 7 GDPR), for the Marketing Purposes (see point 2.4).

Please note that if you are already our customer, we can send you commercial communications relating to services and products of the Data Controller similar to those you have already used, except your disagreement (Article 130, paragraph 4 of Legislative Decree 196/2003).

Data retention

The Controller stores your personal data as long as these are necessary for the achievement of the purposes for which they were collected.

Furthermore, the Data Controller retains personal data if this is required by regulatory obligations. In addition, the Data Controller retains your personal data until the expiry of the limitation period in order to be able to enforce any existing legal claims.

o The retention of personal data will be in paper and / or electronic / informatic and for the time strictly necessary to fulfill the purposes referred to in paragraph 2, in compliance with your privacy and current regulations;

o For direct marketing and profiling purposes we keep your data for a maximum period equal to that foreseen by the applicable legislation (respectively equal to 24 and 12 months);

o Invoices, accounting documents and transaction data are stored for 10 years in accordance with the law (including tax obligations);

o For purposes of analysis directed to the development and improvement of the service, the user's personal data may be subject to the 36-month retention period;

o In the case of exercise of the right to be forgotten through the request for explicit cancellation of personal data processed by the Data Controller, we remind you that such data will be stored, in a protected form and with restricted access, only for purposes of ascertainment and repression of crimes, period not exceeding 12 months from the date of the request and will subsequently be securely deleted or anonymised irreversibly.

We also inform you that for these purposes, data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which implemented the EU Directive 2017/541 on anti-terrorism.

If you do not exercise any active action (for example navigation, searches and / or any other way of using the service) on BENUE INVESTMENTS LTD for a period of 27 months, you will be classified as an inactive user and your personal data will be deleted automatically.

Personal data is stored on servers located within the European Union. In any case, it is understood that the Data Controller, if necessary, will have the right to move the servers even outside the EU.

In this case, the Data Controller hereby ensures that the transfer of non-EU data will take place in accordance with the applicable legal provisions, subject to the stipulation of the standard contractual clauses provided by the European Commission.

Can you have information about your data, change it, delete it or have a copy? Yes! That's how

7.1. Access to your personal data from the private area. We inform you that you can withdraw, at any time, the consents you have provided through your reserved area. Moreover, at any time you can view your personal data in your private area, accessing it by clicking on the "Login" section of "My account".

7.2. Cancellation and export of personal data. You can request the cancellation of your data or export them by sending the request to the following e-mail address: sales@thebrickarmory.com.

The cancellation will be made within the expected technical times and in accordance with the retention period specified in art. 6 of the present (Retention of your data). Your personal data will be exported within 30 days or, in case the export becomes particularly complex, within three months.

7.3. Your rights (Article 15 and subsequent GDPR)

At any time you can:

obtain by the Data Controller information about the confirmation that it is or is not undergoing processing of data concerning him and, in this case, obtaining access to them and the existence of your personal data, the origin of the same, the purposes and methods of processing and the information referred to in Article 15 of the GDPR;

request the rectification, integration, updating, deletion, limitation of the processing of data in the event one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected and / or subsequently processed;

oppose, in whole or in part, for legitimate reasons, to the processing of data, even if pertinent to the purpose of the collection and processing of personal data provided for the purposes of commercial information or sending advertising material or direct selling or for the fulfillment of market research or commercial communication (marketing);

withdraw the consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the revocation;

receive personal data, provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device and transmit them to another data controller without impediments;

to lodge a complaint with the Italian Data Protection Authority.

MAY THIS PRIVACY NOTICE BE AMENDED?

YES! This privacy notice may be subject to change. In case of substantial changes to the use of your data by

in accordance with EU Regulation 2016/679 (hereinafter "GDPR")

At BENUE INVESTMENTS LTD. (hereinafter "BENUE INVESTMENTS LTD" or "Data Controller") we take seriously the protection of your personal data and for this reason we process your personal data scrupulously, exclusively according to the applicable data protection law, in particular to the GDPR. In the following privacy notice we would like to inform you about how we process your personal data and what your rights are.

Who process personal data

1.1. The Data Controller

The Data Controller is BENUE INVESTMENTS LTD. , represented by its pro-tempore legal representative, with registered office in Tortola Pier Park, Building 1, Second Floor, Wickhams Cay I, Road Town, Tortola, British Virgin Islands

For the purpose of pursuing the purposes indicated in the premises, the Data Controller uses some data processors.

The updated list of data processors is kept at the registered office of the Data Controller.

1.2. People and countries who personal data may be provided to

BENUE INVESTMENTS LTD may transfer your personal data to the recipients and / or categories of recipients listed below: