Francesco Palma makes this website available to its users to provide free, simple and direct information about its activities. Our aim is to give up-to-date, accurate and as complete information as possible. In any case, our Company can in no way be held responsible for the accuracy, completeness or quality of the information provided within the site itself. Therefore, we exclude any liability for material or immaterial damage resulting from the use or non-use of the information provided or from the use of incorrect or incomplete information.

This information on the processing of personal data describes the processing of personal data entered or collected at www.palmafineart.it ("Site"). The information also explains the processing of personal data held by it, even though it is entered or collected through forms or other channels (e.g., social pages).

Information on the processing of personal data

Francesco Palma informs that this page describes the methods of management of the company website ("Site") with reference to the processing of personal data of visitors and users who consult it. The information is given, in compliance with Italian and European legislation on the protection of personal data (EU Regulation 2016/679), to those who interact with the web services of the Site and, therefore, does not apply to information collected through channels other than this website. It does not, therefore, refer to processing carried out through other partner sites of Francesco Palma, which the user may access through links from this website. For such processing will have to be provided, by the respective Owners, autonomous information.

Data controller

The data controller is Francesco Palma:

• Registered address MELPIGNANO (LE) VIA CAMPA, 47 - ZIP code 73020
• PEO address info@palmafineart.it
• Tax code and VAT number 04360600755.

What personal data we collect and why

Personal information means any information about you that allows us to identify you, such as: your first name, last name, contact information, phone number, email address, IP address, and information about your access to our website.

We may collect your personal information when you email us or make requests of various kinds.

Therefore, as a result of consulting this Site or using the services made available through it, the following types of personal data of users may be processed:

• Navigation data
• The computer systems and software procedures used to operate the site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes: the IP addresses or domain names of the computers used by users who connect to the site; the addresses in URI (Uniform Resource Identifier) notation of the resources requested; the time of the request; the method used in submitting the request to the server; the size of the file obtained in response; the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system as well as the user's computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Site or third parties: except for this possibility, at present the data on web contacts do not persist for more than seven days.Personal data voluntarily provided by Users.

The personal data freely and voluntarily provided by users of this site concern respectively:

• (i) those sent via e-mail messages to the e-mail addresses indicated on the Site, for the purpose of providing feedback to user requests.

With the use or consultation of this Site, therefore, Francesco Palma will process the data of visitors and users for:

• Provide the information services on the activities of the company (including the organization of events or events) or partners;
• Responding to inquiries and contact requests;
• Verify the necessary and automatic collection of data inherent in interaction with the website;
• Analyze aggregate data of visitor and user behavior or analysis, on aggregate data, of behavior on the website;
• To acknowledge requests for subscription to the service of any newsletter and to provide an information and promotional communication service of the Company's activities;
• Provide services or initiatives (e.g., promotions, activities, events) that the Company reserves for users;
• Prevent or detect fraudulent activity or abuse detrimental to the Site.

We will only process your personal data if we have a legal basis for doing so. The legal basis will depend on the reasons for which we have collected and need to use your personal data. These reasons consist, in some cases, in the need to provide feedback to your requests (contractual or pre-contractual purposes, legitimate interest), to comply with certain legal and/or regulatory requirements or to pursue the legitimate interest of the Data Controller; in other cases, however, we may need your consent (e.g. for marketing activities and sending newsletters containing commercial communications, opinion polls or market research).

Where we obtain the data and the nature of the provision of the data
(including the consequences of withholding it)

Your data may be collected online when you browse the site, when you send e-mails, faxes, or when you make phone calls to the numbers listed. In particular, your personal data, e-mail address and, where required, telephone number are necessary for the pursuit of the purposes indicated above - such as, for example, the provision of response to your requests received. Failure to provide data necessary to acknowledge your requests may result in the inability to provide you with a comprehensive response or the other services available. As appropriate and, if necessary, from time to time you will be informed of the mandatory or optional nature of providing personal data (e.g. to make a specific request). The compulsory or optional nature of the provision of data will be highlighted by means of a notice or a special character to the information of a compulsory nature. Finally, please note that failure to provide optional personal data will not result in any obligation or disadvantage.

To whom we disclose and/or disseminate your data

For the purpose of using online services, as well as to fulfill certain legal and/or regulatory requirements or for the legitimate interest of Francesco Palma, your data may be disclosed:

• to our employees and internal collaborators (e.g., contractors and employees specially authorized for processing);
• to third party companies, contractually linked with the Company or other entities that perform outsourced activities and services on behalf of the Data Controller (third party technical service providers such as, for example, hosting providers, communication agencies, provider of web platform development and maintenance services, provider of development, delivery and operational management services of the technology platforms employed, etc.), appointed where necessary as External Data Processors;
• to third parties for whom this is necessary and indispensable (or otherwise functional) for the performance of Francesco Palma's activities.

Personal data in any case will not be disseminated. This is without prejudice, in any case, to the communication or dissemination of data required, in accordance with the law, by Police Forces, Judicial Authority, information and security bodies or other public entities, for purposes of defense or state security or the prevention, detection or repression of crimes.

To whom we transfer your data

The management and storage of personal data will take place in Italy and, in any case, within the European Union. Currently, the servers used are located within the European territory. The data will not be transferred outside the European Union.

It is in any case understood that, should we deem it necessary, we will be entitled to change the location of the servers in Italy and/or in the European Union and/or in countries outside the EU. In this case, we will ensure as of now that the transfer of data outside the EU will take place in accordance with the applicable legal provisions, entering, if necessary, into agreements that guarantee an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission or only in the presence of other requirement in accordance with the applicable Italian and European regulations.

For marketing activities we use tools from Google and/or other providers located in non-EU terriories, which ensure that the processing is done in a manner that complies with applicable regulations.

How long we keep your data

The data collected by the Site during its operation are used only for some of the above purposes and kept for the time strictly necessary to carry out our activities.

We will not retain data for longer than is necessary, to fulfill the purpose for which it was processed. In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process it, and whether we can achieve those purposes by other means.

The data collected by the Site will, therefore, be retained for as long as necessary to respond to your requests and, even after termination, to manage all contractual, pre-contractual, administrative or legal obligations related to or arising from them. This is except in cases where you have not given explicit consent in relation to some of the services offered, since, in the latter cases, the processing may last until the consent is revoked.

Finally, users' personal data may also be kept as long as permitted by Italian law to protect the Company's legitimate interests (Art. 2947, par. 1 and 3 of the Civil Code).

How we process your data and how we comply with data protection regulations

Personal data are processed by electronic and automated means for the time strictly necessary to achieve the purposes stated above. Specific technical and organizational security measures are observed to prevent data loss, illegal or incorrect use and unauthorized access.

We adopt a set of technical and organizational security measures to ensure the confidentiality, integrity and availability of your data. Data are processed lawfully and correctly, carried out in accordance with the principle of "minimization."

How we guarantee your rights

Francesco Palma informs you that, according to the new European legislation on data processing, under certain circumstances you have the right to:

• Ask us to confirm whether or not we are processing personal data about you and, if so, to obtain access to that data and to all information relating to that processing.
• To obtain rectification and correction of inaccurate personal data and to supplement incomplete personal data, including by providing a supplementary statement.
• Obtain cancellation if:
  • data are no longer necessary in relation to the purposes for which they were collected or processed;
  • The data were processed unlawfully;
  • data must be deleted to fulfill a legal obligation;
  • consent was revoked;
  • one opposes the treatment.
• Obtain the restriction of processing-and thus to suspend it-when one of the following occurs:
  • If you dispute the accuracy of personal data, for the period necessary for us to verify said accuracy;
  • if the processing is unlawful and you object to the deletion of your personal data and request, instead, that their use be restricted; if the personal data are necessary for the establishment or exercise of a legal right of the data subject;
  • whether the data subject has objected to the processing, pending verification as to whether our legitimate reasons outweigh yours.
• Request the transfer of your personal information in electronic and structured form to another party ("data portability").
• Oppose, in whole or in part, the treatment.
• Revoke, at any time, the consent given. In such cases, revocation of consent does not affect the lawfulness of processing based on consent before revocation.

Interested parties may contact Francesco Palma for all matters relating to the processing of their personal data and the exercise of their rights under these regulations by sending an email to the following address: info@palmafineart.it.

Users who believe that the processing of their personal data, carried out through this site, takes place in violation of the provisions of the current legislation on the protection of personal data have the right to lodge a complaint with the Supervisory Authority under Article 77 of the Regulations or to take appropriate legal action. For more information we advise you to visit the website of the Guarantor for the Protection of Personal Data.

DATA RELATED TO YOUR SOCIAL MEDIA ACCOUNTS

Foreword

The information provided below is made only and exclusively for the data processed by Francesco Palma that are available on Facebook or other social platforms. For the sake of clarity, the Data Subject (user or site visitor) is reminded that the personal data he or she enters is on a Social Network page or Fan Page in the specific case Facebook and that, therefore, there are other Data Controllers. In this regard, Francesco Palma assumes no responsibility regarding the use of personal data by other Data Controllers.

As far as Facebook is concerned, the Interested Party is referred:

• to the terms of use of the Facebook platform;
• to the warnings included in this section of Francesco Palma's privacy policy.

In particular, we inform the Data Subject that his or her data available on Facebook, which he or she has entered on our fanpage, will be processed exclusively to send him or her information as a fan of our page and for any marketing purposes specified from time to time on our fanpage.

In addition, data will be processed only by duly appointed and authorized personnel, and will not be disclosed to unauthorized third parties.

Specifically, when you follow our Fan Pages (e.g., Facebook) within social networks, to find information regarding our company as well as to receive our updates, we learn about the data you have shared with us through the social network. This data may include your first and last name, email address, photos, interests expressed within the social network, as well as posts and messages that are sent to our Fan Pages.

Should you collect, process, and disclose to us information referring to third parties, you must do so in accordance with the provisions of the GDPR and, therefore, you will be required to give them prior notice of the processing and, if necessary, you must collect their free and express consent before processing.

Purpose of processing and nature of conferral

We process your personal data only with respect to the management of our Fan Pages, in order to respond to any requests and to ascertain that the messages and/or posts on the Fan Page(s) are in line with the directions expressed in this privacy policy. Providing your personal information is optional, but without it, you will not be able to view the content of our Fan Pages or interact with them. The moment you decide to follow our Fan Pages - and thus to interact with them and receive our updates directly on your homepage - you provide your personal data associated with your social network account (this is equivalent to the provision of explicit consent, in accordance with the guidance of the Italian Data Protection Authority). If you do not wish to provide us with personal data, you should stop or refrain from following our Fan Pages.

Methods of data processing and data storage

We process the user's personal data through electronic means and through the tools provided by the social networks that host our Fan Pages, in compliance with the security requirements of the applicable regulations.

Our security measures include contractual means with third-party processors to ensure the protection of the security and confidentiality of personal data, in accordance with the provisions dictated by applicable data protection regulations.

We retain personal data for as long as you follow our Fan Pages. Even after you choose to stop following our Fan Pages, we will process data with respect to your activity and interactions with those pages that occurred prior to that date, in accordance with the policies of the social networks that host our Fan Pages (to this end, we encourage users to view their respective privacy policies).

In addition, we will retain the Data Subject's data to the extent necessary to comply with obligations imposed by laws or regulations, to protect our rights, to prevent fraud, or to enforce this policy.

Changes and updates to this Privacy Policy

Francesco Palma will take care of modifying or simply updating, in whole or in part, the Privacy Policy of the Site, also in consideration of the modification of the laws or regulations that govern this matter and protect the rights of the users.

Changes and updates to the Privacy Policy of the Site, to users of our services, whose data are in our possession, will be notified by e-mail and, in any case, will be made available on the Home Page, as soon as adopted.

Therefore, please access this section regularly to review the most recent and up-to-date Privacy Policy.

Last update: April 14, 2025