1. Personal Data

Any information concerning an identified or identifiable natural person ('concerned'); an identifiable natural person can be identified, either directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online ID or one or more characteristic elements of his physical identity, physiological, genetic, psychological, economic, cultural or social.

2. Sensitive Data

Personal information related to ethnic origin, political opinions, religious or philosophical beliefs, union membership, health status, life or sexual orientation of the interested party, as well as genetic, biometric and geo-location information. Judicial data includes personal information relating to criminal convictions, crimes or related security measures.

3. Data Controller

The natural or legal person, public authority, service or other body that, individually or together with others, determines the purposes and means of processing personal data.

4. Data Processor

The natural or legal person, public authority, service or other body that processes personal data on behalf of the data controller.

5. Holder of the Treatment

D3E Studio

Address: 392 E Winchester St., Suite 201, Salt Lake City, UT 84107

Phone: +1(510)-378-8077

6. Data Protection Manager

D3E Studio has appointed a Personal Data Protection Manager (RPD-DPO) available at [email protected] for any inquiries related to data protection.

7. Purpose of the Processing of Personal Data

The processing of information concerning the CLIENT will be constantly based on the principles of correctness, lawfulness, transparency and protection of confidentiality. D3E Studio collects and stores personal, commercial and fiscal data relating to each CUSTOMER in order to:

• Fulfill the contractual obligations and for the protection of the company in court
• Allow the activation, provision, management and/or maintenance of services
• Provide assistance, including by telephone, following an explicit request

Legitimate Interests (Article 6.1(f)):

• Verification and improvement of market analysis processes
• Direct customer contact and communication for customer loyalty and service improvement
• Advertising, market research and surveys
• New contractual proposals
• Information exchange with affiliated companies for compliance, audits and accounting
• Protection of information security
• Protection of the company in judicial and extrajudicial proceedings

8. Obligatory Nature of Data Conference

Failure, partial or incorrect conferment of the requested data, as well as the lack of consent to the processing of data necessary for the pursuit of specified purposes, does not allow the completion of the contract.

Any subsequent revocation of the consent granted excludes the continuation of the existing contractual relationship and the provision of related professional services.

In accordance with current legislation, each CLIENT is required to declare that he has read this information by ticking the box in the appropriate registration form.

9. Method of Treatment of Personal Data

D3E Studio processes personal data through manual and/or computerized tools with logic strictly related to the specified purposes. Personal data will be kept for the entire duration of the contractual relationship and for a further 10 years from the termination, in compliance with accounting record obligations.

Personal data are collected in a minimized manner linked to identification only for administrative and fiscal aspects. Data concerning online work sessions are kept for highlighting client activities. Data can be managed through cloud systems to guarantee flexibility, physical security, data resilience, availability and resource redundancy.

Data Location: The physical location of the data will always be in Europe or in countries authorized by the GDPR in compliance with adequacy clauses or standard contractual clauses.

Client Responsibility: It is the Client's responsibility to keep his access credentials to safeguard the integrity of personal data and profile information.

Security systems and infrastructure are subject to periodic audits by both internal and external bodies with independence and third-party requisites.

10. Communication and Diffusion of Data

The CUSTOMER is informed that data provided may be transferred, within the terms provided for by law, to companies that may be connected, controlling, subsidiaries, or distribution companies, with the principle of minimization applied to data indispensable for providing the service.

External Processors may include:

• Database managers for services provided by them
• Companies managing hardware and software maintenance
• Correspondence distribution companies
• Distribution and resale companies
• Companies managing expiry notice services

For online payment services, D3E Studio transfers to bank management portals with their own personal data protection policies. Customers may request a list of Data Processors by emailing [email protected] with a valid identity document.

11. Rights of the Interested Party

For all treatments carried out directly by D3E Studio, the CLIENT may at any time exercise the following rights:

• Access to personal data
• Updating, rectification or integration of data
• Treatment limitation
• Cancellation or transformation into an anonymous form
• Opposition including blocking of data processed in violation of the law
• Appeal to the Supervisory Authority to propose a complaint

Most operations mentioned above can be carried out directly by the Customer on their profile page.

Right to Object:

The Customer also has the right to object, in whole or in part:

• For legitimate reasons, to the processing of personal data that concern him
• To the processing for sending advertising material, direct selling, market research or commercial communication

Requests for exercising the above-mentioned rights must be sent to the Data Protection Manager by email to [email protected]