INFORMATION ON PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of Law no. 171 “PROTECTION OF NATURAL PERSONS WITH REGARD TO THE PROCESSING OF PERSONAL DATA” – Browsing the BKN301 Tech S.r.l. Website

BKN301 Tech s.r.l. located in Via Tre Settembre 99, 47891 Dogana – San Marino, as data controller (hereinafter “Company” or “BKN301” or “Controller” for brevity) respects the privacy of the users of its online services and ensures that the processing of the data collected will take place in full compliance with the applicable legislation on the protection of personal data, and in particular with Law no. 171 of 21 December 2018, entitled “Protection of natural persons with regard to the processing of personal data” (hereinafter for brevity “Law”).

This privacy statement (hereinafter “Information”) relates exclusively to the processing of personal data (hereinafter “Personal Data”) communicated by the user or otherwise obtained as a result of the use of the website www.bkn301.com (hereinafter for brevity “Website”).

1. Personal data collected, methods and purposes of the processing

The computer systems and software procedures used to operate this Website acquire, during their normal operation, some data whose transmission is automatic in the use of Internet communication protocols and are not associated with involved and identified users. In particular, these are data related to the IP addresses or domain names of the computers used by users who connect to the Website and other technical information sent automatically by the connection management programs. Such data are used for the sole purpose of obtaining the connection. Aside from what is specified for navigation data, the user is free to provide personal data contained in the appropriate electronic request forms present in the sections of the Website set up for particular services on request. Failure to provide them may make it impossible to obtain the requested service.

Through the Website, the Data Controller collects and processes the following data:

(A) Navigation data: data provided through the use of the Website and processed in order to allow the Website to function properly. In this regard, we invite you to read the Cookie Policy below, which regulates this type of data.

(B) Data provided voluntarily by the user: Personal data provided voluntarily by the user to use the Website features (such as registration, management of products/services under contract), are personal data and contact details. These data will be processed to (i) recognize the user during the login phase; (ii) provide the user with the requested services and allow the user to manage such BKN301 products/services; (iii) to provide the user with information including data on card transactions related to purchases or other transactions in which a user’s payment cards have been used, for example the partial number of the payment card, the location of the transaction, the time and date of the transaction, more in-depth information on the transaction and the amount of the transaction. During the registration process in the personal area of the Website, as well as for example the pre-activation process of the card where applicable, for temporary blocking and unblocking, etc., users will be asked for some information (personal data and card data) necessary for these purposes.

In particular, by giving us your email address and your mobile phone number, our security services (SMS Alert Service, 3D Secure Service) will be activated, which are useful for protecting your card and your online purchases.

The aforementioned personal data are necessary for the aforementioned purposes. The refusal to provide them makes it impossible to complete the registration processes in the personal area of the Website and the activation of the card and could block some features of the Website.

(C) Additional Purposes: Promotional, commercial and marketing purposes. Subject to the user’s consent, the user’s personal data may be used by the Data Controller, both electronically (such as SMS, instant messaging, email, etc.) and with traditional methods (such as mail, telephone, fax and/or attachment in the invoice), also for the following purposes: 1) sending/communicating advertising materials, information, promotional material on new BKN301 products/services; 2) verification of the degree of satisfaction with the quality of the product/service provided, studies and statistical and market research.

Except for the reference to navigation data, governed by the Cookie Policy below, the personal data collected are provided voluntarily and directly by the user through the use of the Website. Any data acquired is processed with automated tools for purposes related to the navigation on this Website and is retained only for the time strictly necessary to fulfill the purposes for which it was collected. The systems are equipped with the appropriate and necessary security measures to prevent data loss, illicit or incorrect use and unauthorized access. However, these measures, due to the nature of the online means of transmission, cannot absolutely limit or exclude any risk of unauthorized access or loss of data. To this end, it is advisable to periodically check that the computer is equipped with software devices suitable for the protection of data network transmission, both incoming and outgoing (such as updated antivirus systems) and that the Internet service provider has adopted suitable measures to the security of data transmission over the network (such as firewalls and spam filters).

2. Legal basis of data processing and retention period

With the exception of navigation data, with reference to the processing carried out for the purposes of:

(i) use of the Website – point 2 (B), the legal basis lies in the contract between the user and BKN301 for the use of the Website itself;

(ii) the treatments carried out for marketing purposes and for the communication of data to third parties – point 2 letter (C) – are based on any consent given by the user.

All Personal Data collected are retained only for the time strictly necessary to fulfill the purposes for which they were collected.

3. Categories of data recipients

For the aforementioned purposes, personal data of the user and collected by BKN301 may be known by (i) employees and consultants of BKN301, within the scope of their work duties, who act as subjects authorized to process data and in this sense instructed by the Controller; (iv) external consultants and third parties (suppliers of technical and technological services, credit and banking institutions, suppliers of services instrumental in the management/maintenance of the Website, as well as third-party call center companies.

The categories of subjects referred to in points (iii) and (iv) above act as persons in charge appointed by BKN301.

The list of those designated as responsible for particular processing will be kept updated at the offices of BKN301 and will be sent upon specific request to the addresses indicated in point 1.

4. Data transfer abroad

Any acquired data collected while browsing the Website is not transferred abroad; should this need arise, it will be the responsibility of BKN301 to take all the necessary measures to ensure that such processing complies with the privacy legislation in force.

BKN301, limited to the achievement of the purposes indicated in point 4, relating to the execution of your contract or any legal obligations, or for technical/operational needs, reserves the right to communicate personal data in foreign countries belonging to the European Union, or in foreign countries who follow an adequacy decision of the European Commission, or based in foreign countries with which the Republic of San Marino has signed bilateral agreements or treaties that provide for the exchange of personal data and regulate the guarantees for their treatment in compliance to the Law, all pursuant to art. 46 of the Law. Any transfer of data to international organizations and/or countries not belonging to the aforementioned categories will take place in one of the ways permitted by the current legislation. Upon request, it is possible to obtain more information from the Company at the addresses indicated in point 1.

5. Rights of interested parties

Users to whom the personal data refers, if collected, have the right at any time to obtain confirmation of the existence or non-existence of such data and to know its content and origin, verify its accuracy, request its integration or updating, or rectification, erasure, portability, and restriction of processing under Articles 15 and onwards of the Law and under Articles 15 and onwards of the GDPR. The aforementioned rights can be exercised by sending a written communication to BKN301 Tech s.r.l., Via Tre Settembre, 99 – 47891 Dogana (Republic of San Marino), by calling the BKN301 Customer Service.

COOKIE POLICY

1. What are cookies?

Cookies are small text files saved on your computer or device while browsing, which collect information about your online activity. They have a time limit after which they are eliminated; some are deleted directly at the end of the session.

1. Why do we use them?

Cookies allow BKN301 to customize your navigation and design it on the basis of your preferences. They also allow us to understand how to improve our Website in order to make it more pleasant and easier to visit.

3. What type of cookies do we use?

The cookies used by BKN301 are:       

Technical cookies: which allow the site to function properly, allowing the user to better navigate the Website.

• Analytical cookies: intended to provide the Website manager with purely statistical data such as the total number of visits to each page with reference to specific time slots.

Name	Provider	What it does	Expiration
_ga_C62969DCC4	Google	Statistical cookies: they are used for the purpose of optimizing the site, directly by the owner of the site, who can collect information in aggregate form on the number of users and how they visit the website.	2 years
_ga	Google	Statistical cookies: they are used for the purpose of optimizing the site, directly by the owner of the site, who can collect information in aggregate form on the number of users and how they visit the website.	2 years

4. How to manage cookies

Here’s a list of links that explain how to manage, check, and delete cookies from your device, based on the browser used:

Internet Explorer: http://support.microsoft.com/gp/cookies/en

Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies

Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

Safari: http://support.apple.com/kb/PH5042

Opera: http://www.opera.com/browser/tutorials/security/privacy/