Vendor policy

Privacy Policy (in accordance with Article XIII of Italian Legislative Decree no. 196,

June 30, 2003, “Privacy Act”)

Dear Vendor,

The undersigned “Achilli, S.R.L.,” as Data Controller, advises that personal information acquired during business transactions will be processed in accordance with the regulations named above.

Achilli, S.R.L. will gather, and properly manage, the following types of data:

• Identifying information (business or trade name, address, telephone, fax, email, tax i.d. number, etc.);
• Financial and business information (orders, credit-worthiness, bank information, tax and accounting information, etc.);

This data is either directly provided by you, or obtained via third parties who are independently responsible for privacy compliance (for example, entities within our network of agents and representatives for data related to contracts and orders, of agencies who handle business data, business-data registers, lists or public databases containing information related to credit-worthiness, etc.).

Please note, furthermore, that you authorize our processing your personal data for the following purposes:

• To execute agreements once finalized, and to carry out any assignments related thereto;
• To fulfill any legal duties arising out of those contracts;
• To manage the logistical and sales components of the contract (for example, relationships with agents and representatives, contractors used to organize operations at customer locations);
• To safeguard our rights under the contract.

Both the submission and the processing of these items of personal information are necessary to comply with legal and contractual requirements. Furthermore, the data submission is imperative so that Achilli, S.R.L. can carry out all reasonable and necessary steps to fulfill its duties under the contract. Refusal to submit required personal information, for these uses, will make it impossible for Achilli, S.R.L. to fulfill its legal and contractual duties.

Personal information will be kept in print and electronic format, and will be placed into pertinent databases to which the following subjects have access:

• Shareholders;
• Administrative and Accounting Departments;
• Human Resources Department;
• Sales Office;

Information Technology personnel or contractors.

Data collected and processed by Achilli, S.R.L. to finalize contract orders and activities related thereto, for legal and regulatory compliance related to contract management, as well as for managing contract rights, may all be disclosed to the following entities, or categories of entities:

• Transportation and courier companies, for shipping and customs;
• Bank institutions, for managing accounts receivable and payable;
• Finance agencies, and other business or public entities, for issues of legal compliance;
• Legal firms or business, for management of contract rights;
• Independent contractors, for accounting services, to whom proper handling of personal data will be delegated.

Those entities processing personal information, who fall into neither the “Controller” category nor into the “Data Processor” category, will have access to information as a “independent handlers of personal information,” in accordance with Italian privacy regulations, as third parties to the original data submission from vendor to Achilli, S.R.L.

Your personal information will not be disclosed.

Please also note that you have rights under Article VII of Legislative Decree, June 30, 2003, no. 196; specifically, you have the right to access your personal information, to request corrections, updating, and deletion, if incomplete, incorrect, or obtained illegally, as well as to object (for legitimate reasons) to their processing. Such requests must be addressed to: Achilli, S.R.L., Via Montescudo 148 – 47924 Rimini (Rn), Italy. The company’s legal counsel, who may be reached at the same address, is responsible for privacy compliance.

Please contact us at the address above to request further information on data submission, including how to request an updated list of those designated “compliance officers” for data processing.

For more information on our company’s privacy policies, please visit www.achilli.com.