Privacy

This document deals with the data processing and protection in respect to the privacy practices for Sport Haus srl

For the purposes of this Privacy Policy and the UE 2016/679 General Protection Data Regulation and to the extent of the existing Italian rules (DLGs 2003/196), SPORT HAUS srl with seat in Alagna Valsesia (Vercelli) Company Register id 01866000027 is the Data Controller

INFORMATION COLLECTION

Sport Haus may collect personal information for the main purpose of providing an effective, enjoyable and personalized service to ensure its customers requirements are met in the best and quicker way and the services are properly tailored to their needs.

When accessing either physically or by mean of Sport Haus website, the customer may be required to provide that shall include but not be limited to : name, home/email address, phone number, hotel accommodation and personal identification document. Biometrics information is required to the sole purpose of setting all equipment handed out by Sport Haus in the appropriate way to protect the customer personal safety.

INFORMATION PROCESSING

Customer information is stored in a database being accessed by a specific software application licensed to Sport Haus. The software allows all items assigned to a customer to be identified and traced since initial delivery until final return. The system produces the corresponding price calculation being charged to the customer.

The system is accessed solely by Sport Haus personnel. It can be occasionally accessed by assistance specialists in case of software malfunctions under the control of Sport Haus. Sport Haus is not disclosing any personal information to third party. Exceptions may be limited to the following :

• Providing identity information under law enforcement request or in case of insurance indemnity in the customer interest;

• Listing customer names only for billing purposes to travel agencies, hotels, tour operators; During the process featuring either email request or physical access to Sport Haus, customers personal information is collected and stored necessary to fulfill the service as performed in way of equipment rental, equipment maintenance or depot storage.

Relevant information includes:

• Necessarily: Name and Surname plus personal weight when a binding setting is part of the required service. A photo of a Customer personal identification document (i.e. Passport, Driving License, etc. is acquired by the system. On Customer’s consent, the above document request may be restricted to one of the components of the family or group. As far as the personal weight information in concerned, the customer may require Sport Haus personnel to avoid it is entered in the system and to be used once a time or the be asked again in case a new binding setting is necessary.

SPORT HAUS s.r.l. – Loc. Miniere di Riva Valdobbia – 13021 ALAGNA VALSESIA (Vc) Cod. Fisc. e P.Iva 01866000027 – CCIAA VC – REA 167724 Unità locale : Fraz. Bonda – 13021 ALAGNA VALSESIA (Vc) Tel 0163 91308

• Optionally: phone number, home/hotel accommodation or group partnership as well as similar information may be required.

By way of example:

• Names and other personal data, when acquired though a travel/leisure agency either any hotel or a no profit organization are shared with these subjects to plan, deliver and bill the required service.

• Name and phone numbers may be shared with transport/lifts partners or ski schools and mountain guides to enable them to contact you at the desired service delivery site;

• Name and dates of birth may be required for junior customers to access specially dedicated pricing offers and shared with ski schools and mountain guides to secure appropriate assistance.

These examples are not exhaustive and should more information be necessary Sport Haus personnel and its data processor function is available for the above sake.

DISCLOSURE OF CUSTOMER INFORMATION

Sport Haus does not sell or rent any personally identifiable information about its customers to any third party.

Incidentally, due to the existing regulatory environment, Sport Haus cannot ensure that all of their customer private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy.

As an example (not limited to the foregoing) Sport Haus may be subject to a disclosure request by a government authority or by a third party under specific circumstances affecting the customer safety or its belongings security, or third parties may unlawfully intercept or access transmission of private communications.

Sport Haus could (and its customers authorize them to) disclose any information to law enforcement of other government officials as Sport Haus, at their sole discretion, believe necessary or appropriate, in connection to an investigation or fraud, Intellectual Property Right infringements, or other activity that is illegal or may expose Sport Haus to legal liability

INFORMATION MANAGEMENT AND DELETION

The Customer information is maintained until necessary to complete the full tasks of technical and administrative controls. This period encompasses at least one full season and the related fiscal period. It could be maintained for longer periods to allow Sport Haus equipment inventories reconciliation activities. Periodically, once the above operational retention needs are superseded, the customer personal information are deleted and are no longer accessible by the system users.

Backup copies of previous periods activities may be stored and could be accessed by the data processor only or in case of emergency and for the sake of preserving Sport Haus rental equipment archives integrity, by a third party technical service.

Standard procedures adopted by Sport Haus in respect of customers personal information are as follows:

• Copies of customers personal document photographic images are usually deleted every two years; SPORT HAUS s.r.l. – Loc. Miniere di Riva Valdobbia – 13021 ALAGNA VALSESIA (Vc) Cod. Fisc. e P.Iva 01866000027 – CCIAA VC – REA 167724 Unità locale : Fraz. Bonda – 13021 ALAGNA VALSESIA (Vc) Tel 0163 91308

• Customer names are deleted when a time frame of five years is expired without any service activity performed.

The Customers can ask Sport Haus, either directly or by email to manage, change, limit or delete its information, once it is no longer necessary to provide the required services.

Customer personal information is being processed by the software application managing the supply of Sport Haus services : equipment rental, equipment maintenance or depot storage.

No personal information is transferred to or processed by Sport Haus accounting software, apart from names and addresses records, as required in case of fiscal invoicing processes, for the relevant tax implications.

LEGAL REQUESTS

Sport Haus cooperates with law enforcement inquiries and other third parties to enforce laws, intellectual Property Rights and other rights. Local and international enforcement agencies can request and may receive customers personal identifiable information

SUPPLIERS AND OTHER PARTNERS

Sport Haus can receive inquiries and booking requests from travel agencies, tour operators, hotels and sport/leisure clubs. Where any third party is collecting information directly from its customers/members, it is assumed that the above subjects have duly complied with the EU regulation 2016/679. Sport Haus will not be liable for the acquisition of the information, but will apply all procedures as described in this document, anyway. Under some circumstances, either planned or incidentally, Sport Haus is using third party Suppliers and Service Providers to facilitate its operations or fix undesired system malfunctions.

EMAIL TRACKING

Customers email are stored in the mail folder within sporthaus.it domain. They are accessed by a restricted number of Sport Haus personnel. The scope of the email exchanges is for service information only, to better understand customer needs and ease delivery of the services to be performed by Sport Haus. Once completion of the service process, they may be used to ensure equipment return, personal belongings shipment, billing setting and other service related operations. Customers email addresses:

• are not used to the sake of promoting Sport Haus initiatives, unless when specifically agreed by the customer;

• are not stored/organized in a customer database;

• are not disclosed to any third party;

SPORT HAUS s.r.l. – Loc. Miniere di Riva Valdobbia – 13021 ALAGNA VALSESIA (Vc)

Cod. Fisc. e P.Iva 01866000027 – CCIAA VC – REA 167724

Unità locale : Fraz. Bonda – 13021 ALAGNA VALSESIA (Vc) Tel 0163 91308

WEBSITE REPORTS

Sport Haus may use some web analytics tools to measure www.sporthaus.it site usage, how users arrive to the site, what information category they are looking for, etc. Aniway, this analytics data once collected, is not tied to personally identifiable information.

As far as cookies being used by the website, to assist its functionalities, they can be disabled by a user request under specifications reported at http:/www.aboutcookies.org

SOCIAL BUTTONS

On each page of the website a Facebook button is present. This enable users to share or bookmark the web pages. In order to implement this button, as well as others social buttons that Sport Haus may decide to add to its website, and connect them to the relevant social networks and external sites, there are scripts and domains outside of Sport Haus snc. The customer should be aware that these sites are likely to be collecting information about what they are doing all around the internet, including on Sport Haus snc’ site.

So, when the button/s is/are clicked, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that the customer is visiting www.sporthaus.it, and the specific pages being accessed, even if the button is not clicked, while the customer is logged into their services, like Google and Facebook. Sport Haus recommends to check the respective policies of each of these sites to see how exactly they use the customer information and to find out how to opt out, or delete such information.

SECURITY

Sport Haus is committed to ensure that their customer information is secure. In order to try to prevent unauthorised access or disclosure, strict procedures and security features have been put in place. However, transmission of information via the internet is not completely secure. Sport Haus is doing the best reasonable efforts to protect their customer personal data, bur cannot guarantee the security of data being transmitted to our sites or addresses, which remains at the risk of the sender.

The data being collected will be typically managed and stored at a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA working for Sport Haus or for one of its suppliers. This include the staff engaged in the fulfillment of customers required services. Sport Haus may use the services of several companies, part of them may not be located within the EEA. Sport Haus is using the services of providers who are recognised as market leaders in their field. This includes but is not limited to the following organisations. All of these organisations have subscribed to the EU-U.S. Privacy Shield Framework. The link provided are to the relevant privacy information for each service.

• Dropbox – for file storage

• Google – Google maps

• American Express – for payment services

Sport Haus will take into proper consideration the adherence to this privacy policy whenever the following may occur:

SPORT HAUS s.r.l. – Loc. Miniere di Riva Valdobbia – 13021 ALAGNA VALSESIA (Vc)

Cod. Fisc. e P.Iva 01866000027 – CCIAA VC – REA 167724

Unità locale : Fraz. Bonda – 13021 ALAGNA VALSESIA (Vc) Tel 0163 91308

• If relevant assets or the whole business is sold to or acquired by a third party, in which case personal information may be one or part of the transferred assets, and if Sport Haus is under a duty to disclose or share its customer personal information in order to comply with any legal obligation;

• Setting of terms and conditions and other agreements, or rights/property protection, or safety or those of customers or others. This including exchanges of information with other companies and organisations for the purposes of fraud protection and credit risk reduction;

• Decision about security and where personal data are stored

CHANGES TO PRIVACY POLICY

Whereas Sport Haus should change any use of customer personal identifiable information different from that stated at the time of acquisition a proper amendment will affect this Privacy Policy and it will be posted in the website. If the customer is not accepting such changes, he/she should contact Sport Haus to have any of the relevant details removed.