Information regarding the Privacy Policy

The present privacy information note describes our procedures for collecting, using and disclosing information we collect from users of our services, particularly the ones offered through our website, through e-mail, or app (called with the overall term “Service”). The terms “we”, “us” and “Safari d’Arte” are referred to the Organization for Social Development Ara Macao. By using our Service the user agrees to the collection, the use and the disclosure of personal information by us in accordance with this privacy policy.

The collected personal data will be processed in compliance with the Italian Privacy Act (Legislative Decree June 30, 2003, no. 196). According to and pursuant to the Provisions of Legislative Decree no. 196/03 users are reminded that: access to and consultation of the website automatically registers the following data:

• internet dominion and IP protocol
• the type of browser and operating system used on the device

Such information cannot in any way identify the user. This automatically collected information may be used by the Organization for Social Development Ara Macao for the following motivations:

• on suspicion of violation of the current regulation

• for statistical purposes
• for the improvement of website contents and navigation

When users insert personal or business data on the forms available on www.safaridarte.it website or on the Safari d’Arte mobile device app, they consent to the processing of those data in accordance with Legislative Decree no. 196/03. The Organization for Social Development Ara Macao will protect and use the data in order to respond to the user questions, to provide the requested information and to contact the user with reference to the provided services or in case of promotional offers.

In accordance with article 13 of Lgs. Decree, 2003, June 30, no. 196 (Personal data protection code), we wish to inform the users about personal data processing procedures:

1. Purpose of data processing

The processing of the acquired data will be carried out according to the as following: a) implementation of the requested service and obligation connected to the signed contract as service provider b) accounting administrative procedures required by law and linked to the signed contract c) service/product update notification, post-purchase risk notification, upgrade notification, technical notification, software procedures notification, informative notification, and other kinds of notification related to the signed contract or to customer service. d) acquisition of business names in order to create a list for Ara Macao’s professional profile. e) commercial and advertising purposes.

2. Processing methods

Processing is carried out using manual, informative and telematic instruments. In so doing the original data collection purpose has to be secured, in order to guarantee safety and protection of data themselves, in accordance with article no. 11 paragraph 1 of Lgs. Decree, 2003, June 30, no. 196.

> 3. Optional data conferring and processing refusal consequences Data conferring is optional. If consent for letter a., b., c. (section 1 of the information note) is denied, the service implementation could be stopped or lacking. If consent for letter d., or e. is denied, the service implementation will not suffer any consequences.

4. Communication and disclosure limitations. Personal data can be disclosed to those responsible for data processing. Personal data cannot be disclosed to third parties or be provided in any form, except to the Ara Macao Organization’s network, as well as to their partners or companies, acting on the organization’s behalf for the fulfilment of financial and legal obligations. The user can ask for the data holding institutions and companies list and exercise this right (according to paragh 6 of this information note) at any time.

5. Data Controller and Data Processor Identification Data Controller details: Organization for Social Development Ara Macao,

 Via della Torre di Spizzichino 37, 00100 Rome (Italy) All notifications must be sent through registered mail or faxed to (0039) 0641229357, in accordance with article 7 of Lgs. Decree, 2003, June 30, no. 196

6. Data subject rights The data subject can exercise the right to access at any time, in accordance with article 7 of Lgs. Decree, 2003, June 30, no. 196, here quoted in its entirety:

Art. 7 – (Right to Access Personal Data and Other Rights)

• 1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
• 2. A data subject shall have the right to be informed
• a) of the source of the personal data;
• b) of the purposes and methods of the processing;
• c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
• d) of the identification data concerning data controller, data processors and the representative designated as per Section 5 (2);
• e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
• 3. A data subject shall have the right to obtain
• a) updating, rectification or, where interested therein, integration of the data;
• b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
• c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
• 4. A data subject shall have the right to object, in whole or in part,
• a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
• b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
• The information note has been translated in a different language for a better understanding of the current regulation. Despite the translated version, the Italian version will be considered the only trustworthy guideline in case of litigation.

7. Further information Information about the user may be collected and stored when the Service is used. Information may be used to fulfill user’s requests, to allow the Service operation, improve its quality, to design a more personalized user experience, to check the Service supply, to sell the Service, to provide customer care, to prearrange backup and disaster recovery procedures, to increase Service Safety, to fulfill legal obligations. In particular, we focus our attention on the following elements:

• Account information/ Tour participation: Just as the user creates his/her own account on Safari d’arte’s platform, we may store and use his/her full name, email adress and other relevant elements directly coming from the account, such as the date of birth and his/her gender. In case the user may consider that profile unapproved and very similar to his/hers, it will be signposted and removed.
• Contacts: The user may ask his/her friends to join the Service. By doing this, s/he will consent for access to the list of contacts, available on his/her computer, mobile device or other websites. This temporary sharing operations allows Safari d’Arte to elaborate invitations.
• Notifications: By signing up or by using specific website sections, you agree to receive notifications from other companies and from Safari d’Arte itself.
• Transaction Information: When the user carries out a transaction through our Service, for example in case of purchasing, we may collect and store a certain kind of information, such as name, phone number, adress, email and credit card details, in addition to other information, provided by the user in order to process the payment, send notifications, fill the forms in case of future transactions. This information may be shared with third parties for the same purposes. Safari d’Arte will not disclose any personal information with third parties for commercial purposes, unless the consent has been given. In processing credit card details, a Standard technology is used for the encryption.
• User activity: When the user make use of the Service, some information, such as access date and time, is stored. When the user make use of the Service, we may also store information coming from computers or mobile devices, such as type of browser, type of device, browser language, IP address, mobile phone service provider, telephone number, device unique identifier, advertising identifier, position (geographical position, beacon positioning, GPS positioning), required and return URL. Consent may be revoked at any time, simply changing the browser or device settings. The Safari d’Arte iOS app includes location services deactivation.

Cookie We, and third parties we authorize, may use cookies, web beacon, tag, script, local shared objects, such as HTML and Flash 5 (called flash cookies), advertising identifiers (mobile device identifiers such as Apple IDFA or Google Advertising ID) and similar technologies related to the Service, to third party website and app use. Cookies may contain unique device identifiers, which are found on their computer, mobile device, on the email we send and on our website. Cookies may transfer information related to the user and his/her Service use, such as the type of browser, search settings, IP address, advertising data related to ads seen or clicked by the user, access time and date. Cookies may be permanent or stored only during a browser session Gli scopi per cui usiamo i cookie nel Servizio comprendono:

• Processing: Cookies are used to improve the user experience. By using cookies we able, for example, to verify if the user has already signed up.
• Authorization and Security Compliance: Cookies are used to prevent fraud and to protect user data from unauthorised third parties, in accordance with the current regulation. By using cookies we are able, for example, to verify if the user is online.
• Settings: Cookies provide information about the user personal settings in relation to the Service. By using cookies we are able, for example, to verify if the user has deactivated location services.
• Notifications: Cookies allow or prevent us to receive information aimed to improve user experience. By using cookies, we able to avoid already-read notifications.
• Advertsing: Cookies make advertising more effective for the user him/herself and for the advertisers. By using cookies, we are able to filter messages according to the user personal interests, such as the website s/he visits or the ads s/he has clicked.
• Analytics: They are used to analyze customer behaviours in relation to the provided Service.

Cookie Management: Almost all cookies can be deactivated by changing the browser or device settings. This option may affect the Service functionality. Cookies deactivation may change according to browsers and devices, usually this can be easily done by accessing the security settings. iOs and Android devices are provided with ads filters.

Third parties Third parties may receive information about you for the following purposes:

• Service Providers: Third-party providers may be asked to support or provide services available through our own Service. Providers may be asked to implement services in order to allow the Service use, such as hosting and communications, network security, technical support and customer service, monitoring and reporting functions, testing quality control, payment processing, Service marketing, and other types of services. Safari d’Arte may need to share with these third-party providers the information provided by and related to the user, in order to ensure the required services and to fulfill user requests. Third-party providers may share with us the information provided by and related to the user in relation to the required service or to the fulfillment of user requests. Third-party providers may also share this information with their controlled companies, their joint venture companies and their affiliate network. Some of our website pages are displayed by framing, in order to allow third parties to provide users with content. In this case, information will be notified directly from third parties.
• Organization Ownership Transferring: the information provided by and related to the user may be shared with our controlled companies, our joint venture companies and their affiliate network. In case this may happen, we will ask these subjects to process information in accordance with this privacy information note. In case Safari d’Arte were transferred to another company and its activities totally or partially acquired, the new company will acquire the information as well as rights and obbligations, as stated in the current privacy information note.
• Control: the information provided by and related to the user may be shared with authorities in order to a) facilitate legal and executive procedures, such as a search warrant, issuance of subpoena, legal actions, legal procedures and other types of legal notifications; b) prevent, investigate, identify illicit behaviours which could undermine our Service; c) protect our rights, our reputation, user ownership, our ownership and the one of our affiliate network, as stated in our Consumer Alert Program. By doing this we will act in good faith and for cooperation purposes.
• Links: The Service may contain links referring to non-affiliated third parties. Safari d’Arte will not disclose any information with these subjects and will not be held liable for this, in accordance with the current privacy policy regulations. We suggest to carefully read the privacy policy information note provided by the forementioned third parties.
• Facebook and Twitter: If the user signs up by using Facebook or connects his/her Facebook or Twitter profiles with the Safari d’Arte profile, this will allow Safari d’Arte to receive information from this third-party provider. This information will be used to help the user in creating his/her own Safari d’Arte profile, to connect and share posts with other Safari d’Arte followers. Interaction through Facebook, Twitter, third-party providers’ icons will allow the forementioned companies to collect data about the user, such as the mobile device IP address. Interaction with third parties is regulated by the information note concerning third parties.

Data Preservation and Account closure: The user may close his/her account at any time. Public post will not be displayed anymore and/or we will detach them from the profile. We could also save the information related to the user, in accordance with the current privacy policy, unless it is forbidden by law. We could use information to prevent, investigate, identify illicit behaviours which could undermine our Service or to fulfill legal obligations.

Minors The Service is targeted for people up to 13 years old. Safari d’Arte refuses to collect any information concerning people under 13 years old. If the user gets into the know of any minor under the age of 13 providing personal information without the parental permission, we kindly ask to contact us. If Safari d’Arte gets into the know of any minor under the age of 13 providing personal information without the parental permission, measures will be taken in order to remove the profile.

Safety Safari d’Arte works according to the general standard principles on data protection. Both data acquisition and disclosure are protected. Despite our efforts, data protection on the internet cannot be 100% granted.

Dispute resolution: In case the user were of the opinion that Safari d’Arte has not applied the current privacy policy, he could contact us through this website or by sending an email.

Privacy Policy Modifications:

Safari d’Arte therefore reserves the right to modify the current privacy policy information note. Data collection, use and disclosure will be regulated by the latest updated version. The forementioned version will be available on our website and changes will be notified through email or our Service alert, before it comes into force.