Samsung Electronics Italia Privacy Policy

1. Data Controller and Data Protection Officer

SEI is the Data Controller for personal data processed within the scope of the Operation. The Data Protection Officer (DPO) for all SEI affiliates established in the European Union can be contacted at:

Samsung Electronics (UK) Limited
Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 OPS

Or via email at: dataprotection.sei@samsung.com

2. Personal Data Processed

For the Operation, SEI will process information that concerns you, which may include an identifier such as your name, an identification number, an online identifier, or one or more elements characterizing your physical, physiological, psychological, economic, cultural, or social identity that can identify you (hereinafter referred to as "Personal Data").

Your Personal Data may be collected voluntarily (e.g., when you register for the Operation) or by analyzing your behavior on the Site.

The Personal Data processed include:

• Name, contact details, and other Personal Data: When participating in the Operation via the Site, you will be asked to fill out a form requesting information such as your name, surname, phone number, fiscal code, email address, full residential address, the serial number of the Promoted Product purchased, and the purchase date of the Promoted Product.
• Special categories of personal data: When filling out the forms to participate in the Operation (the "Forms"), you may have the option to send SEI image files, such as proof of purchase of the Promoted Product or the label containing the serial code. These submissions might inadvertently contain Personal Data or special categories of Personal Data (e.g., data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data relating to sexual life or sexual orientation). SEI will not process any information containing Special Categories of Personal Data and advises against communicating such data.
• Third-party data provided by the data subject: If you submit information that may contain third-party Personal Data through the submission or the Form, you are considered the independent data controller for that data and assume all legal obligations and responsibilities. You agree to indemnify SEI against any claims arising from the processing of third-party data in violation of applicable data protection laws. You must ensure that such processing is based on the consent of the third party or another valid legal basis.

3. Purposes of Processing

SEI will use your Personal Data collected during your registration and participation in the Operation for the following purposes:

• Participation in the Operation: To allow you to participate in the Operation, manage related activities, and provide necessary assistance. Providing Personal Data for this purpose is not mandatory, but failure to do so will prevent participation.
• Compliance: To comply with legal obligations that require SEI to collect and/or process certain types of Personal Data, which may include retention and communication to authorities for accounting, tax, or other purposes.
• Abuse/Fraud Prevention: To prevent and/or identify fraudulent activities or abuses related to the Operation (with criminal relevance).

4. Legal Basis and Nature of Processing

The legal bases used by SEI for processing your Personal Data are:

• Participation in the Operation: Necessary for participation and execution of the contract or pre-contractual measures. Data provision is not mandatory but is required for participation.
• Compliance: Necessary for SEI to fulfill legal obligations. Data will be processed according to applicable regulations, potentially including retention and communication to authorities for tax, fiscal, or other obligations.
• Abuse/Fraud: Information collected for this purpose is used exclusively to prevent and/or identify fraudulent activities or abuses related to the Operation (with criminal relevance).

5. Recipients of Personal Data

Your Personal Data may be shared with the following recipients (the "Recipients"):

• Data processors, such as professional firms providing assistance and consultancy to SEI in accounting, administrative, legal, tax, financial, and debt collection matters related to the Operation.
• Entities with whom interaction is necessary for managing SEI's activities (e.g., hosting providers, email service providers).
• Entities designated to perform technical maintenance, including network and electronic communication systems.
• Persons authorized by SEI to process Personal Data necessary for activities strictly related to its business, who have undertaken confidentiality obligations or have an adequate legal obligation of confidentiality (e.g., SEI employees).
• Samsung Group companies for internal administrative purposes.
• Entities, bodies, or authorities to whom Personal Data must be communicated due to Compliance, Abuse/Fraud prevention, or by order of authorities.

6. International Data Transfers

Given SEI's international presence, some of your Personal Data may be shared with Recipients located outside the European Economic Area. SEI ensures that the processing of your Personal Data by these Recipients complies with applicable regulations. Transfers are made through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other recognized guarantees. For more information, please contact SEI at dataprotection.sei@samsung.com.

7. Personal Data Retention

Personal Data processed for the purpose of Participation in the Operation will be retained by SEI for the time strictly necessary to achieve this purpose. In any case, SEI may retain this data for a longer period to protect its interests from potential liabilities related to the Operation.

Personal Data processed for Compliance purposes will be retained by SEI for the period required by specific legal obligations or applicable regulations.

Personal Data processed for the prevention of Abuse/Fraud will be retained by SEI for the time strictly necessary for this purpose and until SEI is required to retain them for legal protection or to communicate them to competent Authorities.

Upon expiry of the retention period, Personal Data will be deleted in a manner that ensures they cannot be reconstructed or read.

8. Data Subject Rights

You have the right to request from SEI, at any time:

• Access to your Personal Data (and/or a copy of such Personal Data), as well as further information on the processing activities carried out on them.
• Rectification or updating of your Personal Data processed by SEI, if they are incomplete or not up-to-date.
• Erasure of your Personal Data from SEI databases, if you believe the processing is not necessary or is unlawful.
• Limitation of the processing of your Personal Data by SEI, if you believe your Personal Data are incorrect, not necessary, unlawfully processed, or if you have objected to their processing.
• Data portability, i.e., to obtain a copy of the Personal Data provided to SEI in a structured, commonly used, and machine-readable format, or to request its transmission to another Controller.
• To object to the processing of your Personal Data, based on your particular situation, which you believe should prevent SEI from processing your Personal Data.

You can exercise your rights by writing to dataprotection.sei@samsung.com or through our GDPRS portal at www.samsung.com/request-desk.

In any case, you always have the right to lodge a complaint with the Supervisory Authority or to bring legal action before the competent Judicial Authority if you believe that the processing of your Personal Data is contrary to the applicable regulations. Contact details for all EU Supervisory Authorities are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.